Klayman V Judicial Watch FLSD 1:13-cv-20610 #89 - 3

1
IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

LARRY KLAYMAN,

Plaintiff,
v.

JUDICIAL WATCH, et. al.

Defendants.

Case No: 1:13-cv-20610-CMA

AFFIDAVIT OF LARRY KLAYMAN

I, Larry Klayman, being over eighteen years of age and duly competent to testify, hereby
swear and affirm as follows:

1. I have personal knowledge of the following facts and, when called upon as a witness, will
testify competently thereto.
2. I am a resident of Florida and have, at all material times, resided in and done business in
this judicial district.
3. I began my legal career in this district as an associate for Blackwell and Walker, which
was the largest litigation firm in Florida at the time. I was admitted into The Florida Bar
and became a member of the bar of this Court on December 7, 1977. I have practiced law
in this district continuously and extensively throughout my career, and have active cases
pending in this district and elsewhere in Florida.
4. I founded Judicial Watch in 1994, a public interest group that purports to fight against
government corruption. I left Judicial Watch in 2003 to run as a candidate for the U.S.
Senate in Florida in the Republican primary election.
5. I am now the founder, chairman and general counsel of Freedom Watch, which also has
the similar goal of fighting government corruption through legal advocacy.
Case 1:13-cv-20610-CMA Document 89-3 Entered on FLSD Docket 03/17/2014 Page 1 of 631
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6. Over the last thirty-seven years of my legal practice, I have enjoyed a successful legal
career including having had a court declare that President William Clinton committed a
crime. I also helped expose the Chinagate scandal involving President Clinton.
7. I also brought a case for Jose Basulto of Brothers to the Rescue in this Court, which
resulted in a $1.8 million judgment against the Republic of Cuba, represented the Miami
family of Elian Gonzales and other victims of Fidel Castro, such as journalists who were
jailed by Castro for their political beliefs. In this latter regard, I not only filed a criminal
complaint for these victims against Fidel Castro in Belgian courts, but also lobbied and
testified before various European parliaments, including those of Italy and France, as well
as lobbied the European Union for increased sanctions on Cuba. Over the years, I have
been extremely active representing and advocating for Cuban-American interests in the
Miami community in particular, and continue to do so.
8. I also represented, at all material times, the families of Navy SEALs and other Special
Operators, one of which resides in Florida, over a helicopter shoot-down in Afghanistan
on a mission code named Extortion 17. These SEALs were responsible for the capture
and killing of terrorist Osama Bin Laden. The shoot-down recently resulted in a
congressional hearing regarding the circumstances surrounding the deaths of these
servicemen.
9. On December 16, 2013 I was granted a preliminary injunction in my case against the
National Security Agency (NSA) (Case No. 13-cv-851) and the Obama Administration,
and the Honorable Richard J. Leon found for the first time in the history of the country
that the collection of metadata telephony records by the NSA was likely unconstitutional
under the Fourth Amendment to the U.S. Constitution.
10. As a result of my success against the NSA and the Obama Administration, ABC News
did a profile on me, entitled Meet Larry Klayman: Man Behind the NSA Lawsuit
3
which is exemplary of my reputation. A true and correct copy of the profile has been
attached as Attachment A.
11. As an attorney, I rely on my virtues and honesty, as my reputation will determine the
amount of clients that come to me for their legal problems and in the public interest.
12. Any damage done to my reputation would harm my ability to practice law as a lawyer
convicted of a felony is likely to be disbarred.
13. Constance Ruffley is employed by Judicial Watch in a managerial position as head of its
west coast office. She speaks for Judicial Watch and is a representative of Judicial Watch.
At the time the defamatory remarks were made, Ruffley admitted that she attended the
event where she offered up the defamatory remarks on behalf of Judicial Watch. Ruffley
Deposition at 21; Ruffley Aff. at 7. Attached as Attachment 1 to this Opposition to
Defendant's Motion for Summary Judgment is a true and correct copy of the publication
which defamed me, which was circulated widely on the internet in this district,
throughout Florida, the United States, and internationally.
14. As a public interest attorney and one who has brought lawsuits challenging the eligibility
of Barack Obama, I am fully aware of the website titled Worlds Leading Obama
Eligibility Challenge Web Site, of Orly Taitz and the publications which comprise
Exhibits 1, 2, and others to the depositions of Judicial Watch directors. I became aware
of, and viewed myself, these publications and ordered my web-master, Ethan Stone, to
save them for possible litigation if Judicial Watch did not correct the defamatory
statements. See Transcript of Klayman at 8. These saved postings comprise the exhibits I
used at the depositions of Judicial Watchs directors and a true and correct copy of these
postings are attached as Exhibits 1 and 2 to Plaintiff's Opposition to Defendant's Motion
for Summary Judgment. The Taitz website postings are therefore authenticated under the
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case precedent in In Re Homestore.com, Inc. Sec.Litig., 347 F.Supp.2d. 769, 782 (C.D.
Cal. 2004) and Rule 902(6) of the Federal Rules of Evidence.
15. Ruffley falsely stated to Dr. Orly Taitz of the Defend Our Freedom Foundation that
donors should know about litigation in Ohio, where he was convicted just recentlty [sic]
of not paying large amount in child support. See Exhibit 1 to Opp. Motion Summary
Judgment. When I spoke to Orly Taitz on the phone regarding her subpoena, Taitz
confirmed that Ruffley indeed said the defamatory remarks to her. And she confirmed to
me that in fact Ruffley had said those things. See Transcript of Klayman at 13.
16. Judicial Watchs Constance Ruffley, who admittedly was a legal secretary before joining
Judicial Watch, in particular since she works in a management position for a legal
organization, knows the meaning of the word convicted and intended to convey that to
my donors and the general public. Ruffley admits that she knows the difference between
being indicted for an alleged crime, where there is a presumption of innocence until
proven guilty, and being convicted. In the context of the O.J. Simpson trial, in which a
Judicial Watch employee, Ernie Norris, had participated while previously Deputy District
Attorney for Los Angeles County, Ruffley testified:
Question: You have spent a good deal of time working with Ernie Norris, who is former
Deputy District Attorney of Los Angeles - -
Answer: Yes.
Question: -- at Judicial Watch. Correct?
Answer: Yes.
Question: Correct?
Answer: Yes.
Question: Ernie is a -- Ernie was a criminal prosecutor for a number of years with the
District Attorneys Office in Los Angeles. Correct?
Answer: 32 years. Yes.
Question: In fact, he played a role in the prosecution of O.J. Simpson underneath Deputy
D.A. Gil Garcetti. Correct? . . .
Answer: No, he did not have anything to do with the O.J. Simpson trial. The O.J.
Simpson trial was given to his underling, Marcia Clark, and to Chris Darden. But Ernie
did not have --
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Question: You are aware that -- you have talked about the O.J. Simpson case with Mr.
Norris. Correct?
Answer: Oh, off and on.
Question: And Mr. Norris was quite -- was quite despondent or upset that O.J. Simpson
was not convicted of the crime of murder. Correct?
Answer: I cant speak to his feelings on that or emotions.
Question: You are aware that O.J. Simpson was indicted but never convicted for murder.
Correct?
Answer: Did you say Ernie Simpson or O.J. Simpson? . . .
Question: O.J.
Answer: Yes.
Question: Okay.
Answer: Im aware that he was not convicted.
Question: Therefore, you know the meaning of the word convicted as opposed to
indicted. Correct?
Answer: More now. But at the time -- but at the time, I was not aware of a difference
between indicted and convicted.
Question: So during the time of the O.J. Simpson trial, you thought that O.J. Simpson
was convicted because he was indicted?
Answer: No.
Question: You are a highly intelligent person; are you not, Ms. Ruffley?
Answer: Thank you. Yes. See Deposition of Constance Ruffley at 76-79.

17. The false and defamatory statements were, in fact, published on The Worlds Leading
Obama Eligibility Website. Orly Taitz writes and reports to the readers, Ms. Ruffley
actually advised me that Larry Klayman is not licensed in California, she told me that he
no longer works with the Judicial Watch and that donors should know about litigation in
Ohio, where he was convicted just recentlty [sic] of not paying large amount in child
support. She provided me a lot of other information. Exhibit 2. This publication has
been widely published on other websites and is still on the Internet.
18. I have never been convicted of any crime in any circumstance. Additionally, I had a valid
defense for not paying the child support as my obligation to pay the child support was
nullified under Virginia law, since I had been completely and unlawfully denied access to
my children. Hartman v. Hartman, 33 Vir. Cir. 373, 1994 WL 1031136 (Apr. 13, 1994).
19. Attached as Attachment B is a true and correct copy of the Agreed Judgment Entry
Regarding Child Support Arreage and Withdrawal of Capias. This Judgment Entry
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shows that any such contempt had been vacated and dismissed against me, as I had paid
the amount due while reserving all of my rights to appeal and fight the payment of the
child support, so I could see my children.
20. Attached as Attachment C is a true and correct copy of the dismissal of all charges
against me that was ordered by Judge Michael Donnelly of the Cuyahoga Court of
Common Pleas with regard to my alleged failure to pay child support. This document
proves that I was never convicted of a crime and the indictment was, in fact, dismissed.
21. On advice of counsel, I had to have a contempt order issued in order to take the disputed
matter of my child support payments to the Court of Appeals Of Ohio, Eighth Appellate
District. However, all contempt orders were dismissed. See Attachments B, C.
22. All of the documentation showing that I had never been convicted of a crime was public
information. In addition, the dismissal and vacating of the contempt order was noted on
the public docket for the Cuyahoga County Domestic Relations Court. A true and correct
copy of the most recent five pages of the docket has been attached as Attachment D.
23. Prior to the above defamatory publication, it had become publicly known, through myself
and others, that I planned to soon file a high profile case in Florida involving the
eligibility of President Barack Obama to run as a candidate in Florida in regard to the
states primary and general election for 2012.
24. Judicial Watch routinely represents individuals and interests with the same legal needs as
those I represent.
25. Ruffleys statement on behalf of Judicial Watch that I was convicted of a crime has
caused me severe emotional distress. I have had problems sleeping and concentrating
during work, which affect me to this day, since the false statements are still on the
Internet.
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26. The statements have also caused harm to my reputation in this district, throughout
Florida, the United States, and globally.
27. Throughout my legal profession, my reputation as an attorney has been of one who has
possessed exceptional morals and ethics. This reputation has been well evidenced
publicly, as seen from just a sampling of articles written about me, which are attached to
this affidavit and referenced in the following paragraphs.
28. Dr. Richard Swier of RedCounty.com, who stated, Larry believes it is more important to
be virtuous than be liked, has called me the One Man Tea Party. A true and correct
copy of Dr. Swier's article has been attached as Attachment E.
29. The Washington Times recently released an article profiling my steadfast principles,
entitled Legal gadfly in NSA surveillance case can sting even his own mother in pursuit
of principles. The article, profiling my recent success fighting for constitutional rights
against the Obama Administration, stated that I remain ready to rumble on behalf of
ethics and morality within the American legal and governmental systems. A true and
correct copy of the Washington Times article has been attached as Attachment F.
30. Joseph Farah of WND.com wrote about my involvement in uncovering the Chinagate
scandal and other legal endeavors in an article entitled, Thank God for Larry Klayman.
A true and correct version of this article has been attached to this affidavit as Attachment
G. In this article, Farah wrote, consistent with my reputation, that, Just when you
assume all hope of accountability for these official criminal acts is gone, Klayman rides
to the rescue wearing the white hat.
31. Farah's other writings also confirm my reputation for having strong morals and ethics. As
another example, a true and correct version of his article, Larry Klayman, My Hero,
has been attached to this affidavit as Attachment H. In this article, Farah wrote, Larry
Klayman will do what is right no matter who is involved. Klayman is a guy who never
8
shrinks from his standards of ethics and morality. Hes a man who looks to no one but
God for guidance and direction.
32. Additionally, Farah publicly endorsed me (as others did) during my U.S. Senate
campaign in 2004. In announcing my endorsement, he referred to me as a man of
character and principle. A true and correct version of this endorsement, Larry
Klayman For U.S. Senate, has been attached to this affidavit as Attachment I. In this
endorsement, Farah wrote, Larry Klayman is my hero because he has integrity enough
to prevent him from blind loyalty to party or ideology and keep him focused on
principle.
33. On January 27, 2014, I conducted a deposition of Paul Orfanedes, Director of Litigation,
Board of Directors Secretary and Treasurer of Judicial Watch. A true and correct version
of the transcript of his deposition has been attached to this affidavit as Attachment J.
34. On January 27, 2014, I conducted a deposition of Christopher Farrell, Director of
Research and Investigation of Judicial Watch. A true and correct version of the transcript
of his deposition has been attached to this affidavit as Attachment K.
35. On January 29, 2014, I conducted a deposition of Thomas J. Fitton, President of Judicial
Watch. A true and correct version of the transcript of his deposition has been attached to
this affidavit as Attachment L.
36. On January 31, 2014, I conducted a deposition of Constance Ruffley. A true and correct
version of the transcript of his deposition has been attached to this affidavit as
Attachment M.
37. A process server made several attempts to serve Taitz beginning within the week of
January 6, 2014. Plaintiff was told that Taitz was out of town, but it became apparent that
Taitz was evading service of process.
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38. Well before the deadline of discovery to be completed, on January 20, 2014, Taitz was
personally served at her business address with a Subpoena Duces Tecum requiring Tatiz
to appear and testify at a deposition scheduled for January 30, 2014.
39. During the week of January 27-31, 2014, I spoke with Taitz with regard to the deposition
scheduled for January 30, 2014.
40. Taitz confirmed to me over the phone that the statements Ruffley had made to her on the
February 22, 2012 event were accurate. Again, Ruffley said, on behalf of Judicial Watch,
Klayman is not licensed in California . . . and that donors should know about litigation
in Ohio, where he was convicted just recentlty [sic] of not paying large amount in child
support.
41. Taitz later stated to me that she would refuse to appear for her deposition scheduled for
January 30, 2014, or at any other time.
42. On February 21, 2014, Magistrate-Judge Andrea Simonton of this Court advised during
a hearing on the issue of the subpoena of Taitz that such a motion to compel compliance
with the subpoena must now, due to a recent change in the Federal Rules of Civil
Procedure, be filed in the court issuing the subpoena in the district of deponent, which in
this case is the U.S. District Court for the Central District of California.
43. On March 4, 2014 I therefore filed a Motion to Compel Compliance with the Subpoena
with the U.S. District Court for the Central District of California. A true and correct
version of the motion is attached as Attachment N.
44. In this Motion to Compel Compliance, I requested expedited handling of the motion. The
earliest available time this court could to hear the motion was on April 7, 2014. I have
been urging the California court to shorten the time to hear the motion, and refer the
motion back to this court, but as of yet it has not done so. Attached as Attachment O, is
the scheduling order of the Central District of California.
10
45. To this date, 57 days after service of the subpoena, Taitz never made or filed any
objections to the subpoena and thus has waived any and all objections to the subpoena
and simply defied it. Judicial Watch did not timely object either. It is crystal clear that it
will be enforced.
46. As stated in Plaintiffs opposition, notwithstanding Taitzs future testimony after she is
ordered to comply with the subpoena, the statements of Ruffley, as published again by
Taitz, are admissible for purposes of opposing Defendants summary judgment motion.
See Opposition at pg. 23.
47. I was damaged monetarily, as well as to my reputation and emotionally, by the
defamatory and other tortious acts of Defendant Judicial Watch as the defamatory
statements were published to donors, as Ruffley suggested to Taitz. As a result, I was not
paid attorneys fees and costs billed and unbilled by those persons who hired me,
including George Miller, who had hired me on behalf of Michael Voeltz, the eligibility
Plaintiff. Miller was raising money from donors to pay for my services but these donors
stopped giving after the subject defamatory statements were published. Thus, I lost about
$20,000.00 of billed attorneys fees and costs and several hundred thousand dollars in
unbilled legal fees, travel expenses, and other costs. Deposition of Klayman at 120-121.
48. Only after Plaintiff moved to compel did Judicial Watch produce the attached email from
Connie Ruffley which stated Gee whiz, it's been just 9 1/2 years since [Plaintiff] left
[Judicial Watch]. Should there be a 10-year anniversary on 9/23? <grin> [sic]. This
is additional evidence that she and Judicial Watch acted with actual malice against me. A
true and correct copy of this produced email is attached as Attachment P to this affidavit.
49. A true and correct copy of Exhibit 3 which was presented at the depositions of Farrell,
Orfanedes, and Fitton is attached as Attachment Q to this affidavit.
Case 1:13-cv-20610-CMA Document 89-3 Entered on FLSD Docket 03/17/2014 Page 10 of
631
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50. A true and correct copy of Exhibit 9 which was presented at the depositions of Farrell,
Orfanedes, and Fitton is attached as Attachment R to this affidavit.

I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct. Executed on March 17, 2014.

/s/ Larry Klayman
Larry Klayman

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Attachment A
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1/7/14 Meet Larry Klayman: Man Behind the NSA Lawsuit - ABC News
abcnews.go.com/Politics/meet-larry-klayman-man-nsa-lawsuit/story?id=21278998&singlePage=true 1/5
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Meet Larry Klayman: Man Behind the NSA
Lawsuit
Dec. 19, 2013
By ALEX LAZAR
214 Like 109 Share
Name: Larry Klayman
Age: 62
Occupation: Founder of Freedom Watch and Judicial Watch as well as a World New Daily
columnist
Claim to fame: As the former head of Judicial Watch, Klayman may be best known for filing
numerous lawsuits against the Clinton Administration during the 1990s especially while the
Monica Lewinsky scandal was unfolding. In 1998, Newsweek wrote an article that claimed Klayman
had once sued his mother - information that he says was given to the magazine by the Clinton
administration. Klayman, a big proponent of the Tea Party and its ideals, has in the past questioned
President Obama's assertions that he was born in the United States. Now, however, Klayman is
back in the public eye as the man who challenged in court the legality of the NSA's authority to
keep and store the metadata of American citizens and won.
ABC News spoke with Klayman about the recent NSA ruling and his other famous lawsuits. The
interview has been edited for clarity and brevity.
ABC News: What are your thoughts on the ruling?
Klayman: "The real victory is to the American people who have developed a deep distrust in their
government. This is the biggest violation of constitutional rights in American history. It has more
than a chilling effect on free speech. We're very gratified that this judge did the courageous thing
and stuck his neck out and in my view he's an American hero. I think it will go to the Supreme
Court and I'm confident that we'll win. You can't have the metadata of over 300 million Americans
and say that's a difficult issue to decide. Metadata is even more intrusive than listening to content in
some ways."
ABC News: What NSA reforms do you think are needed?
Larry Klayman speaks in Melbourne, Fla., May 6, 2004.
Peter Cosgrove/AP Photo
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Klayman: "We're asking the court in our case to do very strict monitoringto make sure that this is
not happening, will not happen again. We didn't challenge the constitutionality of the Patriot Act or
the Foreign Intelligence Surveillance Actwe intend to raise that with the court. I believe those acts
are unconstitutional."
ABC News: Do you still believe President Obama is not by birth an American citizen?
Klayman: "His birth certificate that he put forward is a fraud. We've had experts look at it. He did
not have two American citizen parents by his own admission. Just for the same reason that Rubio
is out and Cruz is out and John McCain people thought that he didn't qualify for that reason
either. See that's why the Republicans don't want to challenge itand no judge wants to touch it so
far."
ABC News: Please tell me about the claim out there that you once sued your mother
Klayman: "My grandmother was dying, and my motherhad dementia. My stepfather had undue
influence on her and took all my grandmom's money and put a do not resuscitate order on her
charts. I had to bring lawsuits to get the do not resuscitate order off her charts and to get her
money back so she could afford to be in a nursing home because her insurance had lapsed
because my mothershe was with dementia, hadn't followed what was going on. It was essentially
a case against my stepfather not against my mother, but I had toname my mother because
legally she was next of kin. That's what it was about."
ABC News: Do you still think Larry Claypool was a parody of you on The West Wing?
Klayman: "There was no question it was me. If you look at the people that were the writers on the
showDeeDee Myers in the White House, Lawrence O'Donnell now with MSNBC, and Pat
Caddell who's a former Carter pollster. I was flattered by it even though they poked fun at me
because we made it into the pop culture."
ABC News: What are your next steps?
Klayman: "We have many lawsuits. We're representing families of SEAL Team Six. We're
advocating protests and peaceful nonviolence, civil disobedience, to try to get the government to
become responsive to the American people. If Gandhi could do it in India, we could do it here. I
will not be deterred by attacks from the left or anyplace else, that actually emboldens me more to
do what I think needs to be done."
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13 comments
Join the discussion
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Reply
Soj ourner56 19 days ago
"ABC News spoke with Klayman"
Might ABC be so kind as to tell its readership who at ABC interviewed Klayman?
Klayman: "His birth certificate that he put forward is a fraud."
ABC: Well golly gee, I can't for the life of me think of a single followup question . . . so let's
talk about more important issues . . . how about your mother . . . ya, that's it . . . your
mother.

13
Reply
Rhonda Thompson 19 days ago
you go larry klayman you rock

18

1
Reply
CaMaven 19 days ago
Larry: As far as I'm concerned, YOU are person of the year!

16

1
Reply
sykes 18 days ago
Is the dam FINALLY starting to break?

9
Reply
Dave Monat 18 days ago
Hopefully Obama's fraud, forgery, identity theft, crimes and treason will get addressed!

7
Reply
Paul Wade 17 days ago Dave Monat
Forget it Dave, Congress is in the game with Barry. Why has no one raised the
question on his constitutional eligibility?
And why has the (inferior) Supreme court refused to hear cases over him?

Reply
aj udi cat or1776 18 days ago
Keep up the good fight, Mr. Klayman! You have my support as well that of milliions of
Americans. The lawlessness of the Obama regime is unprecedented. It has reached
critical-mass. Nixon lied about a third-rate burglarly. Obama lied about the needless
slaughter of four Americans in Benghazi, about "If you like your insurance plan, you can
keep it. Period.", and about his "proof positive" of a Hawaiian birth by his April 27, 2011
release of his bogus LFBC. As a nation, we are WAY beyond the point of appointing a
special prosecutor and beginning impeachment proceedings.

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First To Know
AROUND THEWEB
Reply 2

1
Reply
Ki ng Dari us 18 days ago
ABC News: Do you still believe President Obama is not by birth an American citizen?
The relevant question should be
ABC News: Do you still believe President Obama is not a natural born citizen of America?
A "natural born citizen" is what the US Constitution requires for a person to be eligible to
be President. There are American citizens by birth who are NOT natural born citizens.
ABC News deliberately asked the question as they did so as to deceive readers/viewers
about the difference between natural born citizen and citizen at birth.

2

1
Reply
rt k25301 18 days ago King Darius
You have my attention. What exactly is the difference between "by birth an
American citizen" and "a natural born citizen of America?"

Reply
mauser 98 18 days ago rtk25301
both parents must be US citizens at time of birth to be pres. Obama's
father was never a US citizen. Cruz , Rubio , Jindal all ineligible to be pres.

2

1
Reply
MaryMi t ch 18 days ago mauser 98
Not a court in the country agrees with you.

Reply
Yode 12 days ago
10 bucks sayz the NSA is tracking/monitoring Klayman....another 10 on the results being
fed to WH handlers....

Reply
MaryMi t ch 18 days ago
ha ha ha ha... what an idiot

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Attachment B
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C a s e 1 : 1 3 - c v - 2 0 6 1 0 - C M A D o c u m e n t 8 9 - 3 E n t e r e d o n F L S D D o c k e t 0 3 / 1 7 / 2 0 1 4 P a g e 1 9 o f
6 3 1
C a s e 1 : 1 3 - c v - 2 0 6 1 0 - C M A D o c u m e n t 8 9 - 3 E n t e r e d o n F L S D D o c k e t 0 3 / 1 7 / 2 0 1 4 P a g e 2 0 o f
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Attachment C
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Attachment D
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1/6/14 Cuyahoga County Clerk of Courts - Case Docket

cpdocket.cp.cuyahogacounty.us/CV_CaseInformation_Docket.aspx?q=a9enDx7OnB4TE7spac9nQw2&isprint=Y 1/42
Print
CASE INFORMATION
DR-07-316840 LARRY ELLIOT KLAYMAN vs. STEPHANIE ANN LUCK
Docket Informati on
Fi l i ng Date Si de Type Descri pti on Image
10/09/2013 D1 $$ PAYMENT ON ACCOUNT MADE ON BEHALF OF LUCK/STEPHANIE/ANN IN THE
AMOUNT OF $37.00
08/08/2013 N/A CS COURT COST ASSESSED LARRY ELLIOT KLAYMAN BILL AMOUNT 4057.3 PAID
AMOUNT 206 AMOUNT DUE 3851.3 STEPHANIE ANN LUCK BILL AMOUNT 449.25
PAID AMOUNT 412.25 AMOUNT DUE 37 NOTE: ANY ADDITIONAL COURT COST
WILL BE BILLED AT A LATER DATE
05/16/2013 N/A JE *********C/A************ SUA SPONTE, APPEAL IS DISMISSED PER ENTRY NO.
464777. O.S.J. NOTICE ISSUED
05/16/2013 N/A JE **********C/A********* APPELLANT'S NOTICE OF WITHDRAWAL OF APPEAL IS
TREATED AS A MOTION TO WITHDRAW APPEAL AND IS GRANTED. DISMISSAL
OF APPEALS AE WITH PREJUDICE. O.S.J. NOTICE ISSUED
03/15/2013 P1 CA APPELLANT'S 9A RECORD TRANSMITTED TO THE COURT OF APPEALS
CONSISTING OF THE TRANSCRIPT OF THE DOCKET, JOURNAL ENTRIES AND
THE ORIGINAL PAPERS ON CA NO. 99517.
03/13/2013 N/A JE IT IS THERFORE ORDERED THAT THE G.A.L.'S MOTION TO SHOW CAUSE
(#344094) IS HEREBY DISMISSED W/O PREJUDICE. DEFT'S MOTION'S FILED
ON FEBRUARY 15, 2013 ARE DISMISSED AS MOOT. COURT COSTS ADJUGED
AGAINST PTLF. AND DEFT. EQUALLY. O.S.J. NOTICE ISSUED
03/08/2013 D4 OT D4 JENNIFER L MALENSEK, GUARDIAN AD LITEM AND COUNSEL FOR MINOR
CHILDREN NOTICE OF DISMISSAL (W). JENNIFER L MALENSEK 0069646
02/20/2013 P JE CA FROM THE SUPREME COURT OF OHIO UPON CONSIDERATION OF THE
JURISDICTIONAL MEMORANDA FILED IN THIS CASE THE COURT DECLINES TO
ACCEPT JURISDICTION OF THE APPEAL PURSUANT TO S. CT. PRAC.R. 7.08(B)
(4). (CUYAHOGA COUNTY COURT OF APPEALS; NO. 97074) NOTICE ISSUED
O.S.J. NOTICE ISSUED
02/15/2013 P1 MO P1 LARRY ELLIOT KLAYMAN MOTION TO ORDER GRANTED PRIOR MOTION TO
TERMINATE BY DEFAULT, AND IF NECCESSARY, RENEWED MOTION TO
QUASH, AND MOTION TO DISMISS GUARDIAN AD LITEM'S MOTION TO SHOW
CAUSE ..... PRO SE 9999999
02/07/2013 P1 CA -------------------- NOTICE OF APPEAL -------------------- CA NO. 99517 NOTICE OF
APPEAL FILED BY THE PLTF. APPELLANT W/A 9A PRAECIPE AND DOCKETING
STATEMENT ON THE REGULAR CALENDAR. COPIES MAILED.
01/31/2013 P1 SR CERTIFIED MAIL RECEIPT NO. 20613735 RETURNED 01/31/2013 FAILURE OF
SERVICE ON DEFENDANT KLAYMAN/LARRY ELLIOT/ - UNCLAIMED NOTICE
MAILED TO DEFENDANT(S) ATTORNEY
01/24/2013 N/A JE THIS MATTER HAS BEEN RESET BEFORE MAGISTRATE EILEEN T. GERITY ON
FEB. 26, 2013 AT 10:00 A.M. IN CRT ROOM 137, LAKESIDE COURTHOUSE..
O.S.J. NOTICE ISSUED
01/23/2013 N/A SR HEARING SCHEDULED, NOTICE(S) SENT
01/23/2013 N/A SC GENERAL HEARING SET FOR 02/26/2013 AT 10:00 IN ROOM 137 BEFORE
MAGISTRATE EILEEN T. GERITY. MO.# 344094 FILED ON 12/17/2012 MOTION TO
SHOW CAUSE FOR FAILURE TO PAY GAL FEES
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01/18/2013 P1 MO P1 LARRY ELLIOT KLAYMAN MOTION TO TERMINATE PROCEEDING ........W......
PRO SE 9999999
01/16/2013 P1 MO P1 LARRY ELLIOT KLAYMAN MOTION FOR CLARIFICATION AND CONTINUANCE
ON ANY HEARING OF JAN 23, 2013 PRO SE 9999999
01/08/2013 N/A JE IT IS ORDERED THAT PETITIONER'S MOTION TO DISMISS AND/OR DENY ANY
CONTEMPT MOTION, #340012 IS HEREBY DISMISSED AS MOOT..PETITIONER
TO PAY THE COSTS OF THESE PROCEEDINGS.. O.S.J. NOTICE ISSUED
12/21/2012 N/A SC GENERAL HEARING SET FOR 01/23/2013 AT 10:30 IN ROOM 137 BEFORE
MAGISTRATE EILEEN T. GERITY. MO.# 344094 FILED ON 12/17/2012 MOTION TO
SHOW CAUSE FOR FAILURE TO PAY GAL FEES MO.# 340012 FILED ON
09/06/2012 MOTION TO DISMISS
12/21/2012 D1 $$ PAYMENT ON ACCOUNT MADE ON BEHALF OF LUCK/STEPHANIE/ANN IN THE
AMOUNT OF $64.25
12/18/2012 P1 SR MOTION(20613735) SENT BY CERTIFIED MAIL. TO: LARRY ELLIOT KLAYMAN
2020 PENNSYLVANIA AVE NW STE 345 WASHINGTON, DC 20006-0000
12/17/2012 D4 MO D4 JENNIFER L MALENSEK, GUARDIAN AD LITEM AND COUNSEL FOR MINOR
CHILDREN GUARDIAN AD LITEM'S MOTION TO SHOW CAUSE...... JENNIFER L
MALENSEK 0069646
12/17/2012 P1 SR INSTRUCTION FOR SERVICE ON GUARDIAN AS LITEM'S MOTION TO SHOW
CAUSE VIA CERTIFIED MAIL TO LARRY ELLIOT KLAYMAN. FILED.
10/18/2012 P1 OT P1 LARRY ELLIOT KLAYMAN NOTICE OF INTENT TO FILE APPEAL AND
PETITION FOR WRIT OF MANDAMUS. PRO SE 9999999
10/16/2012 P JE CAMOTIN BY APPELLANT TO SET ASIDE JUDGMENT ENTRY OF OCT 3, 2012
AND GRANT EN BANC REVIEW IS DENIED. NOTICE ISSUED O.S.J. NOTICE
ISSUED
10/05/2012 P JE ***CA*** MOTION BY APPELLANT TO SET ASIDE JUDGMENT ENTRY OF SEPT.
18,2012 IS DENIED. THE SEPT. 18 DECISION DENIED APPELLANT'S
APPLICATION FOR EN BANC REHEARING AS UNTIMELY. APPELLANT NOW
ARGUES THE APPLICATION WAS A TIMELY REQUEST FOR EN BANC
CONSIDERATION OF THE PANEL'S SEPT. 5,2012 DECISION DENYING HIS
MOTION FO R RECONSIDERATION . THE APPLICATION REQUESTED EN BANC
CONSIDERATION OF THE JULY 26, 2012 PANEL DECISION, NOT THE SEPT.
5,2012 RULING. THEREFORE, THE APPLICATION WAS UNTIMELY. NOTICE
ISSUED. O.S.J. NOTICE ISSUED
09/21/2012 N/A JE *****C/A***** COA NOS. 97074 AND 97075...APPLICATION BY APPELLANT FOR
EN BANC REHEARING FILED 09/14/12 WAS NOT TIMELY FILED WITHIN TWN
DAYS AFTER THE CLERK MAILED THE JUDGMENT TO THE PARTIES AND
MADE A NOTE OF THE MAILING ON THE DOCKET. ACCORDINGLY, THE
APPLICATION IS DISMISSED AS UNTIMELY.. O.S.J. NOTICE ISSUED
09/06/2012 P1 MO P1 LARRY ELLIOT KLAYMAN MOTION TO DISMISS AND/OR DENY ANY
CONTEMPT MOTION PRO SE 9999999
08/29/2012 P1 SR MOTION(19987825) SENT BY REGULAR MAIL SERVICE. TO: LARRY ELLIOT
KLAYMAN 2020 PENNSYLVANIA AVE NW STE 345 WASHINGTON, DC 20006-
0000
08/29/2012 P JE DEFT'S MOTION FOR EXTENSION OF TIME TO RESPOND TO MOTION OF PLTF
TO DISMISS AND/OR DENY CONTEMPT MOTION AND TO OBJECT TO AND TO
QUASH SUBPOENAS TO PRODUCE DOCUMENTS IS HEREBY DENIED AS
MOOT. O.S.J. NOTICE ISSUED
08/28/2012 P1 SR INSTRUCTION FOR SERVICE ON RESPONDENT'S MOTION TO SHOW CAUSE
(PETITIONERS VIOLATION OF JUDGMENT ENTRY OF JUNE 22, 2011); MOTION
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TO INCLUDE INTEREST AT STATUTORY RATES; AND MOTION FOR ATTORNEY
FEES VIA ORDINARY MAIL TO LARRY ELLIOT KLAYMAN. FILED.
08/27/2012 P JE THE COURT DOES HEREBY DISMISS RESPONDENT'S MOTION TO SHOW
CAUSE (NONCOMPLIANCE WITH JUDGMENT ENTRY) RESPONDENT MOTION
TO INCLUDE INTEREST AT STATUTORY RATES IS DISMISSED AS MOOT.
RESPONDENTS MOTION FOR ATTORNEY FEES IS DISMISSED SUE SPONTE. IT
IS FURTHER ORDER ADJUDGED AND DECREED THAT PETITIONER'S MOTION
TO DISMISS AND OR DENY CONTEMPT MOTION IS DISMISSED AND
PETITIONER'S MOTION TO QUASH SUBPOENAS AS TO PRODUCE
DOCUMENTS IS SUSTAINED AS MOOT. THE COURT DOES DISMISS THE
ENTIRETY OF PETITIONER'S MOTION N AS IT IS AN EXACT DUPLICATE OF THE
MOTIONS ASSIGNED 339098 AND 339099 SUPRA. RESPONDENT TO PAY THE
COSTS OF THESE PROCEEDINGS. O.S.J. NOTICE ISSUED
08/24/2012 D1 MO D1 STEPHANIE ANN LUCK MOTION FOR EXTENSION OF TIME TO RESPOND TO
MOTION OF PLTF TO DISMISS AND/OR DENY CONTEMPTMOTION AND TO
OBJECT TO AND TO QUASH SUBPOENAS TO PRODUCE DOCUMENTS (W)
JAMES H. ROLLINSON 0080442
08/23/2012 P1 SR EXPRESS MAIL (EQ 135242570 US) REFUSED BY EMPLOYEE M. ROGERS ON
BEHALF OF LARRY E. KLAYMAN.
08/23/2012 D1 CS CLERK FEE POSTAGE FOR EXPRESS MAIL TO LARRY E. KLAYMAN 18.95 &
2.35 (GREEN CARD)
08/21/2012 P1 MO P1 LARRY ELLIOT KLAYMAN MOTION TO DISMISS AND/OR DENY CONTEMPT
MOTION ......W...... PRO SE 9999999
08/20/2012 P1 SR MOTION(19913516) SENT BY EXPRESS MAIL. TO: LARRY ELLIOT KLAYMAN
08/20/2012 P1 MO PLTF, LARRY KLAYMAN, PRO SE MTN TO DISMISS AND / OR DENY
CONTEMPT MTN AND TO OBJECT TO AND TO QUASH SUBPOENA TO
PRODUCE DOCUMENTS PRO SE (9999999)
08/14/2012 D1 SR SUBPOENA FOR: PAY PAL, INC C/O NATIONAL REGISTERED AGENTS, INC .
08/13/2012 P1 SR INSTRUCTION FOR SERVICE ON MOTION TO SHOW CAUSE (PETITIONERS
VIOLATION OF JUDGMENT ENTRY OF JUNE 22, 2011), MOTION TO INCLUDE
INTEREST AT STATUTORY RATES; AND MOTION FOR ATTORNEY FEES VIA US
EXPRESS MAIL TO LARRY ELLIOT KLAYMAN. FILED.
VIOLATION OF JUDGMENT ENTRY OF JUNE 22, 2011), MOTION TO INCLUDE
INTEREST AT STATUTORY RATES; AND MOTION FOR ATTORNEY FEES VIA
08/10/2012 D1 CS CLERK FEE POSTAGE FOR EXPRESS MAIL
08/07/2012 D1 MO MOTION TO SHOW CAUSE AND FOR ATTORNEY FEES AND TO INCLUD
INTEREST AT STATUTORY RATES. FILED. BAKER & HOSTETLER(0062007)
08/07/2012 D1 SF DEPOSIT AMOUNT PAID
08/07/2012 D1 SR SUBPOENA FOR: CUYAHOGA SUPPORT ENFORCEMENT AGENCY (ATTN:
CUSTODIAN OF RECORDS) .
08/07/2012 D1 SR SUBPOENA FOR: EBAY, INC. CO NATIONAL REGISTERED AGENTS, INC. .
VIOLATION OF JUDGMENT ENTRY OF JUNE 22, 2011); MOTION TO INCLUDE
INTEREST AT STATUTORY RATES; AND MOTION FOR ATTORNEY FEES VIA
07/30/2012 P JE ****CA**** JUDGMENT: AFFIRMED. O.S.J. NOTICE ISSUED
05/11/2012 N/A SH CUYAHOGA COUNTY SHERIFF DEPT DISPOSITION: SUBJECTED APPEAR IN
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COURT. CAPIAS RETURNED UNEXECUTED. SERVICE FEE $6.00
05/03/2012 N/A JE PLTF, LARRY ELLIOT KLAYMAN HAVING APPEARED, THE DOMESTIC
RELATIONS CAPIAS IS RELEASED. COURT COSTS ADJUDGED AGAINST
LARRY ELLIOT KLAYMAN O.S.J. NOTICE ISSUED
04/25/2012 N/A JE THE COURT ADOPTS THE MAGISTRATE'S DECISION FILED 04/28/2011 IN ITS
ENTIRETY. NO TIMELY OBJECTIONS WERE FILED AND THEREFORE PARTIES
ARE FOUND TO HAVE WAIVED THEIR RIGHT TO ANY FURTHER HEARING
THEREON. THE GAL'S MOTION FO RFEES #310671, IS GRANTED. PLTF SHALL
PAY TO THE GAL THE SUM OF $18,487.50 AS AND FOR GAL FEES..DEFT
SHALL PAY $1,000.00 FOR WHICH JUDGMENT IS RENDERED AND EXECUTION
SHALL ISSUE. COSTS ADJUDGED AGAINST PLTF O.S.J. NOTICE ISSUED
04/20/2012 P JE AGREED JUDGMENT ENTRY REGARDING CHILD SUPPORT ARREARAGE AND
WITHDRAWAL OF CAPIAS. O. S. J. NOTICE ISSUED
04/19/2012 P1 MO P1 LARRY ELLIOT KLAYMAN JOINT MOTION TO VACATE CAPIAS... ROGER L
KLEINMAN 0022272
04/12/2012 N/A JE ********C/A********** MOTION BY APPELLANT TO SUPPLEMENT THE RECORD IS
DENIED. NOTICE ISSUED. O.S.J. NOTICE ISSUED
03/06/2012 N/A JE **********C/A*********** MOTION BY APPELLEE FOR LEAVE TO SUBMIT
SUPPLEMENTAL SUPPORT, IS DENIED AND STRICKEN FROM THE RECORD.
NOTICE ISSUED. O.S.J. NOTICE ISSUED
03/06/2012 N/A JE **********C/A********* MOTION BY APPELLANT TO STRIKE ATTEMPTED
WITHDRAWAL TO MOTION TO SUPPLEMENT IS DENIED AS MOOT. THIS COURT
GRANTED THE MOTION TO WITHDRAW SUPPLEMENTAL SUPPORT AND
ORDERED THAT THE MOTION AND OPPOSITION TO BE STRICKEN FROM THE
RECORD. NOTICE ISSUED. O.S.J. NOTICE ISSUED
03/01/2012 N/A JE APPELLEE'S NOTICE OF WITHDRAWAL OF MOTION FOR LEAVE TO SUBMIT
SUPP. SUPPORT IS GRANTED. THE MOTION FILED FEBRUARY 8, 2012 AND
THE OPPOSITION FILED FEBRUARY 2,1 2012 ARE STRICKEN FROM THE
RECORD. O.S.J. NOTICE ISSUED
02/23/2012 P JE FOR GOOD CAUSE SHOW, PURSUANT TO APPELLATE RULE 9(E) THE
RECORD SHALL BE SUPPLEMENTED WITH THE FULL TRANSCRIPT OF THE
PROCEEDINS BEFORE MAGISTRATE LAWRENCE L LOEB. THIS COURT IS OF
THE UNDERSTANDING THAT THE FULL TRANSCRIPT WAS FILED WITH THE
COURT OF APPEALS ON FEB 8, 2012. O.S.J. NOTICE ISSUED
02/08/2012 P1 CA NOTICE OF FILING TRANSCRIPTS OF PROCEEDINGS.
02/08/2012 P1 CA TRANSCRIPT OF PROCEEDINGS FILED AND TRANSMITTED TO THE COURT OF
APPEALS ON CA NO. 97074 & 97075. 17 VOLUMES
02/07/2012 P1 MO P1 LARRY ELLIOT KLAYMAN MOTION TO SUPPLEMENT THE RECORD....W......
ROGER L KLEINMAN 0022272
10/13/2011 P JE ORDER FOR CAPIAS - PETITIONER CASH BOND $5,000.00 IN THE EVENT
PETITIONER POSTS SAID BOND AND IS RELEASED. SAID PERSON SHALL
APPEAR IN ROOM 187 AT 9:00 AM ON THE COURTS NEXT SCHEDULED
BUSINESS DAY. FAILURE TO APPEAR SHALL RESULT IN REISSUE OF CAPIAS.
COSTS ADJUDGED AGAINST PETITIONER O.S.J. NOTICE ISSUED
10/13/2011 P JE CAPIAS ORDERED FOR PETITIONER HOLD IN CUSTODY COSTS ADJUDGED
AGAINST LARRY ELLIOT KLAYMAN O.S.J. NOTICE ISSUED
09/21/2011 N/A JE *******C/A******** MOTION BY APPELLANT TO EXTEND TIME TO FILE THE
RECORD IS DENIED AS MOOT. THE RECORD WAS FILED AUGUST 30, 2011.
APPELLANT'S BRIEF IS DUE SEPTEMPBER 30, 2011. NOTICE ISSUED. O.S.J.
NOTICE ISSUED
09/21/2011 N/A JE ********C/A******* MOTION BY APPPELLEE TO DISMISS APPEAL IS DENIED.
NOTICE ISSUED. O.S.J. NOTICE ISSUED
09/21/2011 N/A JE ******C/A******** MOTION BY APPELLANT FOR STAY OF EXECUTION PENDING
APPEAL IS DENIED. NOTICE ISSUED. O.S.J. NOTICE ISSUED
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08/18/2011 P1 CA APPELLANT'S 9B RECORD TRANSMITTED TO THE COURT OF APPEALS
08/18/2011 P1 CA APPELLANT'S 9B RECORD TRANSMITTED TO THE COURT OF APPEALS
08/15/2011 N/A AF AFFIDAVIT OF STEPHANIE DELUCA FILED
08/04/2011 P JE PLTF'S MOTION TO STAY EXECUTION IS DENIED. O.S.J. NOTICE ISSUED
08/01/2011 N/A JE * * * * C/A * * * * SUA SPONTE, APPEAL NUMBERS 97074 AND 97075 ARE
CONSOLIDATED FOR RECORD BRIEFING, HEARING, AND DISPOSTION.
RECORD DUE BY AUGUST 30, 2011. O.S.J. NOTICE ISSUED
08/01/2011 P1 CA TRANSCRIPT OF PROCEEDINGS FILED AND TRANSMITTED TO THE COURT OF
APPEALS ON CA NO. 97074 & 97075. 2 BOXES OF EXHIBITS.
07/29/2011 P1 MO P1 LARRY ELLIOT KLAYMAN MOTION FOR STAY OF EXECUTION PENDING
APPEAL ROGER L KLEINMAN 0022272
APPEAL FILED BY THE PLTF. APPELLANT W/A 9B PRAECIPE AND DOCKETING
APPEAL FILED BY THE PLTF. APPELLANT W/A 9B PRAECIPE AND DOCKETING
07/13/2011 N/A CS COURT COST ASSESSED LARRY ELLIOT KLAYMAN BILL AMOUNT 3632.8 PAID
AMOUNT 206 AMOUNT DUE 3426.8 NOTE: ANY ADDITIONAL COURT COST WILL
BE BILLED AT A LATER DATE
06/24/2011 N/A JE THE COURT ADOPTS THE MAGISTRATE'S DECISION FILED 07/02/2010 IN ITS
ENTIRETY. OBJECTIONS WERE FILED TO MAGISTRATES DECISION PURSUANT
TO RULE 53. AFTER CONSIDERATION; SAID OBJECTIONS ARE HEREBY
OVERRULED AND THE DECISION OF THE MAGISTRATE HEREBY ADOPTED.
PETITIONER'S MOTION TO WITHDRAW CAPIA ( #291722) IS DISMISSED W/O
PREJ. THE GAL'S MOTION FOR GAL FEES ( #292173) IS DISMISSED W/O PREJ.
RESPONDENT'S MTN TO SHOW CAUSE FOR CON'T NON PYMT ( #289099)
FILED OCT. 15, 2009, IS GRANTED. PETITIONER/OBLIGOR LARRY KLAYMAN IS
IN CONTEMPT OF COURT FOR FAILING TO COMPLY W/ THIS COURT'S ORDER
OF AUG. 28, 2007. COSTS PETITIONER, LARRY E. KLAYMAN. O.S.J. NOTICE
ISSUED
06/22/2011 P JE THE COURT ADOPTS THE MAGISTRATE'S DECISION FILED JUNE 9, 2010 IS ITS
ENTIRETY. IT IS HEREBY ORDERED: AFTER CONSIDERING THE MAGISTRATE'S
DECISION FILED JUNE 9, 2010, PLEADINGS, EXHIBITS, AND COMPLETE
TRANSCRIPT, PETITIONER'S HEREBY OVERRULED AND THE DECISION OF THE
MAGISTRATE ADOPTED WITHOUT MODIFICATION ... COSTS ADJUDGED
AGAINST THE PLTF ... O.S.J. NOTICE ISSUED
06/13/2011 P JE PLTF'S MOTION FOR LEAVE TO FILE REPLY BRIEF IN SUPPORT OF
OBJECTIONS #318345 IS HEREBY DENIED. O.S.J. NOTICE ISSUED
06/07/2011 P1 MO P1 LARRY ELLIOT KLAYMAN MTN FOR LEVE TO FILE REPLY BRIEF IN
SUPPORT OF OBJECTIONS ROGER L KLEINMAN 0022272
05/23/2011 D1 OT D1 STEPHANIE ANN LUCK RESPONSE TO SUPPLEMENTAL OBJECTIONS TO
MAG'S LOEB'S 06-09-10 DECISION .......W........ SUZANNE M JAMBE 0062007
05/17/2011 P1 OB P1 LARRY ELLIOT KLAYMAN OBJECTIONS TO MAGISTRATE'S DECISION.
ROGER L KLEINMAN 0022272
05/11/2011 P JE NUNC PRO TUNC ..... O.S.J. NOTICE ISSUED
05/05/2011 P JE RESPONDENT'S MOTION FOR TIME EXTENSION IS GRANTED. RESPONSES
SHALL BE DUE BY MAY 12 2011.... O.S.J. NOTICE ISSUED
05/03/2011 D1 MO D1 STEPHANIE ANN LUCK MOTION FOR EXTENSION OF TIME FOR
RESPONDENT TO RESPOND TO PETITIONER'S SUPPLEMNTAL OBJECTIONS
REQUEST FOR ORAL ARGUMENT FILED ON APRIL 22,2011 "W" SUZANNE M
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Attachment E
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1/8/14 Larry Klayman - The One Man TEA Party | Red County
https://web.archive.org/web/20120419054811/http://www.redcounty.com/content/larry-klayman-one-man-tea-party 1/4
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Larry Klayman - The One Man TEA Party
8371
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comments
By Dr. Richard Swier (Scribe) on July 31st, 2010
Long before there was a TEA Party, Glenn Beck 912 movement, 13 Patriots and thousands of others, there was Larry Klayman. Larry believes it is more important to be virtuous than be liked.
Larry believes there is an ultimate right and wrong.
Some of you may not know Larry Klayman but you should. If you believe in the Constitution of the United States and that the Executive, Legislative and Judicial branches of our federal government
are corrupt to the core then you need to read Larry's book, WHORES: Why and How I Came to Fight the Establishment. (/web/20120419054811/http://www.amazon.com/WHORES-Why-Came-Fi ght-
Establ i shment/dp/0979201225)
If you see our courts legislating from the bench rather than enforcing the law as in Arizona then you will love Larry Klayman. If you love politics and want to understand what really happens behind
the scenes get his book. I just finished reading WHORES (/web/20120419054811/http://www.amazon.com/WHORES-Why-Came-Fi ght-Establ i shment/dp/0979201225) and could not put it down. It is a mosaic of
both the man and his struggles against an out of control government bent on aggrandizing itself at the expense of the people and the law. It is about corruption on the part of both parties writ large. I
found it particularly interesting because of Larry's insights into Florida politics. You see Larry ran for the very same U.S. Senate seat Marco Rubio is seeking. Larry ran against, among others, Bill
McCollum and Mel Martinez. If you want to learn more about Florida politics and political insiders, read this book.
Larry is the founder of Judicial Watch (/web/20120419054811/http://www.j udi ci al watch.org/) and Freedom Watch USA(/web/20120419054811/http://www.freedomwatchusa.org/about-us/) . Freedom Watch USA " is the only group that speaks
through actions, rather than just words." When reading his book I found it a fascinating personal and professional journey that reflects the work of a real patriot. Larry has won my patriot award for being a thorn in the side of Iran,
Hugo Chavez, Bill and Hillary Clinton, Dick Cheney, George W. Bush and Barack Obama. Not a bad record if I say so myself.
I really felt a symbiotic relationship with Larry as I read his story. When you speak truth to power you are always attacked. The progressive model is identify the target, marginalize it and then demonize it. That is the cross that
Larry, TEA Party members and others who are like minded bear today.
Larry was fighting the establishment since the early 1990s and he continues to do so even today with the filing of a lawsuit against Elena Kagan, President Obama' s nominee for the U.S. Supreme Court.
According to the WorldNetDaily.com column, Papers prepped to disbar Elena Kagan (/web/20120419054811/http://www.wnd.com/?pageId=184317) :
[Larry Klayman] One of Washington, D.C.'s most feared and fearless corruption watchers has told WND he intends to file an ethics complaint to have Supreme Court nominee Elena Kagan disbarred from practicing before the
court she aspires to join and possibly subjected to criminal prosecution for her role in an escalating controversy over partial-birth abortion.
As WND reported (/web/20120419054811/http://www.worl dnetdai l y.com/i ndex.php?fa=PAGE.vi ew&pageId=184165) , dozens of pro-life organizations are already asking the Senate to investigate Kagan's 1997 amendment to an
American College of Obstetricians and Gynecologists report, which was then used by the Supreme Court as justification for overturning Nebraska's partial-birth abortion ban in 2000.
In her confirmation hearings, Kagan defended the amendment, saying, "My only dealings with (the College) were about talking with them about how to ensure that their statement expressed their views."
Several analyses have concluded, however, that Kagan's amendment dramatically changed the meaning of the organization statement, and court records show the statement was passed off on the Supreme Court
as official scientific opinion, even though the organization's panel of scientists never approved Kagan's wording.
Klayman told WND he believes Kagan's behind-the-scenes work constitutes "conspiracy to defraud the Supreme Court," and he intends to take the evidence that has been compiled by the pro-life groups
(/web/20120419054811/http://www.aul .org/featured-i mages/Kagan-Ethi cs-Report.pdf) to file a complaint before the clerk's office of the U.S. Supreme Court, seeking to have Kagan disbarred as a practicing
Supreme Court.
So the battle goes on for Larry, you and me. I hope you will read Larry's book (/web/20120419054811/http://www.amazon.com/WHORES-Why-Came-Fi ght-Establ i shment/dp/0979201225) and make it a point to learn more about the
great work he is doing to stop corruption in our courts, at the White House and in Congress. Larry has been a one man TEA Party, now it is time for us to join with him as we together fight in the same cause - a
grass roots revolution to save the Republic.
Attached files:
larry klayman.jpg (/web/20120419054811/http://www.redcounty.com/si tes/defaul t/fi l es/l arry%20kl ayman.j pg)
Tags : (/web/20120419054811/http://www.redcounty.com/rel ated-content/)
Comments
Time for TRUE leaders... (/web/20120419054811/http://www.redcounty.com/content/larry-klayman-one-man-tea-party#comment-52359)
Submi t t ed by Anonymous (not ver i f i ed) on Sun, 2010-08-01 12: 01.
...like Larry Klayman. If ever there was a time to "Sweep the Bums Out" it is this November. We need to quit accepting excuses from career politicians, Republican or Democrat.
Unless they have a provable record of speaking and voting against the terrible policies which got us in this quagmire, they need to go.

We need to support people like Klayman who accurately sounded warnings, but sadly were drowned out by the P.R. machines.
52 Share
631
Sweep the bums out- when? (/web/20120419054811/http://www.redcounty.com/content/larry-klayman-one-man-tea-party#comment-70459)
Submi t t ed by Geor ge Mi l l er (/web/20120419054811/http://venturacountyteaparty.com/) (not ver i f i ed) on Tue, 2011-12-13 11: 24.
The time to sweep them out starts in the primary season. Otherwise in Novemnber, it may be a bum vs an almost certainly Progressive bum and maybe some third party
candidates
CITIZEN'S GRAND JURY (/web/20120419054811/http://www.redcounty.com/content/larry-klayman-one-man-tea-party#comment-53534)
Submi t t ed by SONDRA (not ver i f i ed) on Fr i , 2010-08-27 11: 42.
CITIZEN' S GRAND JURY is a great idea. How is this done and where do we find out the legal papers ( or whatever is needed ) to organize one ? If the government will not act, it
is time the People did. Save America !!!! Pray for America !!!!! GOD BLESS AMERICA !!!!!!
Highly recommend this book... (/web/20120419054811/http://www.redcounty.com/content/larry-klayman-one-man-tea-party#comment-55113)
Submi t t ed by Mar i a (not ver i f i ed) on Thu, 2010-10-07 19: 49.
Excellent title and so true.
Larry Klayman is the original One Man Tea Party. I could not put his book down. He hold to his convictions and I respect his integrity. Highly recommend his book, Whores
and give it to all my friends to read about a true patriot. Larry will always fight for what is right.
Remember the Bastille (/web/20120419054811/http://www.redcounty.com/content/larry-klayman-one-man-tea-party#comment-59950)
Submi t t ed by Anonymous (not ver i f i ed) on Sat , 2011-01-15 21: 50.
Remember the Bastille (/web/20120419054811/http://www.wnd.com/i ndex.php?fa=PAGE.vi ew&pageId=251053) : http://www.wnd.com/index.php?fa=PAGE.view&pageId=251053
(/web/20120419054811/http://www.wnd.com/i ndex.php?fa=PAGE.vi ew&pageId=251053)

I do not like the way this op-ed makes me feel. The writer is in many ways inviting civil unrest.

Watch You Tube- It's almost the same tone. Rush Limbaugh: http://www.youtube.com/watch?v=5iPM3TGcef4&feature=player_embedded
(/web/20120419054811/http://www.youtube.com/watch?v=5i PM3TGcef4&feature=pl ayer_embedded)

He also believes that WikiLeaks is just fine for America. Tell the man I think he is way over the top with his sarcastic verbiage. I am a Reagan conservative who understands a
bully when I read one.
Remember the Bastille (/web/20120419054811/http://www.redcounty.com/content/larry-klayman-one-man-tea-party#comment-59972)
Submi t t ed by Lar r y Kl ayman (not ver i f i ed) on Sun, 2011-01-16 23: 39.
I have been wanting to thank Red Country for the Dr.'s kind words.

As for my latest column, "Remember the Bastille," I am just opining on what I see reality to be. If people like me are not allowed or permitted to talk freely, there will be civil
unrest. If it comes to it, I would resort to civil disobedience, Ghandi style. I do not believe in violence. But the government and its so called leaders have brought on the likelihood
for this; the nation is angry because it is run by "Whores" who have brought us to our knees, financially, in international affairs, and morally. Although I am not a big fan of
President Truman, I think he said something to the effect that its too bad if you can't take the truth.
Lets all pray and act on behalf of our great nation and the world we live in...

Larry Klayma
Remember the Bastillie (/web/20120419054811/http://www.redcounty.com/content/larry-klayman-one-man-tea-party#comment-65051)
Submi t t ed by Anonymous (not ver i f i ed) on Mon, 2011-05-09 15: 27.
The only Bully here is our Gangster tyrannical Resident NObama- & the corrupt semi circles around that protect.
Larry has been around the hood for quite some time and and probably understands better than us how and whby we are being pushed into a dictated corner.
There has never been more of a critical need to protect what our freedoms than now. Lots at stake, win or lose- ask or take.
Citizens Grand Jury? Might be only think that could work. Here to help make that happen.
We're all on our way to a virtual prison-(have u seen whats on legislative horizon?) so what do we have to lose?
Civil rest is what I really fear today.
Thanks for your efforts and books and for taking on FB Larry! You're a real hero!
631
Related Articles
Thanks for your efforts and books and for taking on FB Larry! You're a real hero!
Comic relief (/web/20120419054811/http://www.redcounty.com/content/larry-klayman-one-man-tea-party#comment-68031)
Submi t t ed by smt ot h (not ver i f i ed) on Thu, 2011-07-28 05: 16.
http://americanloons.blogspot.com/2011/05/213-larry-klayman.html (/web/20120419054811/http://ameri canl oons.bl ogspot.com/2011/05/213-l arry-kl ayman.html )
He does provide comic relief with his frivolous lawsuits.
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Attachment F
631
1/6/14 Legal gadfly in NSA surveillance case can sting even his own mother in pursuit of principles - Washington Times
www.washingtontimes.com/news/2013/dec/17/legal-gadfly-in-nsa-surveillance-case-can-sting-ev/?page=all 1/2
Search
EDITORS' PICKS:
0 PRINT
By Jennifer Harper - The Washington Times Tuesday, December 17, 2013
Theres still a fire in his belly and multiple causes in his heart. Lawyer and longtime conservative legal
gadfly Larry Klayman(/topics/larry-klayman/) , the man behind the first successful lawsuit against the
National Security Agency(/topics/national-security-agency/) s mass surveillance programs, remains
ready to rumble on behalf of ethics and morality within the American legal and governmental systems.
Mr. Klayman(/topics/larry-klayman/) emerged as an unlikely champion of constitutional freedoms this
week when a federal judge agreed with his contention that the NSA(/topics/national-security-agency/)
exceeded its constitutional authority by systematically gathering the telephone records of millions of
Americans.
It was the first major setback for the federal government in court after the sensational revelations by
former NSA(/topics/national-security-agency/) contractor Edward Snowden(/topics/edward-snowden/) .
It was not, however, Mr. Klayman(/topics/larry-klayman/) s first time in court. During his career, Mr.
Klayman(/topics/larry-klayman/) has battled the Clinton, George W. Bush(/topics/george-w-bush/) and
Obama administrations, as well as varied targets such as OPEC(/topics/organization-of-petroleum-
exporting-countries/) , Facebook(/topics/facebook/) and in a dispute over health care expenses for
his grandmother his own mother.
Journalist Geraldo Rivera(/topics/geraldo-rivera/) once called him a legal wild man, and Bill
Clinton(/topics/bill-clinton/) strategist James Carville(/topics/james-carville/) referred to him as a little
twerp. An opposing lawyer described him as snide and argumentative, and a Midwestern newspaper
claimed he was akin to a bad case of chiggers.
But Mr. Klayman(/topics/larry-klayman/) said in an interview that his latest legal triumph was founded on
a bedrock of principle.
I think this attitude is something youre born with. I dont like when people lie to me. It gets under my
skin, said Mr. Klayman(/topics/larry-klayman/) , 62. I was a Justice Department(/topics/department-of-
justice/) lawyer. I saw a government that I truly believed in get corrupted, and I took offense. I still take
offense. Thats what keeps me going.
After Mr. Snowden(/topics/edward-snowden/) s leaks this year concerning vast government collection
programs of Americans phone records and metadata, Mr. Klayman(/topics/larry-klayman/) filed suit
June 6 saying his own rights had been violated by the secret snooping programs.
The case was heard in November. On Monday, District Court Judge Richard J. Leon sided with the
veteran lawyer and activist, ruling that the clandestine agency(/topics/national-security-agency/) s
collection of citizen phone calls likely violated the Fourth Amendment. Although the administration
strongly rejected the ruling and the judge stayed his own decision in the face of a near-certain
appeal, Mr. Klayman(/topics/larry-klayman/) had scored an unlikely courtroom win.
This judge is a hero, and there are not many of them out there, Mr. Klayman(/topics/larry-klayman/)
said.
The ruling shows no signs of curbing Mr. Klayman(/topics/larry-klayman/) s natural exuberance or his
willingness to take on virtually any opponent. In the calmest of voices, the lawyer offered a caustic
Legal gadfly in NSA surveillance case can sting even his own
mother in pursuit of principles
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1/6/14 Legal gadfly in NSA surveillance case can sting even his own mother in pursuit of principles - Washington Times
www.washingtontimes.com/news/2013/dec/17/legal-gadfly-in-nsa-surveillance-case-can-sting-ev/?page=all 2/2
criticism of the state of the nations capital.
President Obama is the most corrupt and compromised leader to ever occupy the White House, Mr.
Klayman(/topics/larry-klayman/) said in a matter-of-fact tone.
He is more concerned with the results than with making friends or avoiding offense.
In this case, I want the NSA(/topics/national-security-agency/) and other agencies to be kept under
control and to be watched by the courts in a way that is transparent to the public. And I want people to
know what is at stake here. Weve learned that every American is under surveillance and many
believe that there will be retaliation against them. Its like a police state worse than anything George
Orwell ever conceived of.
He is careful to maintain some parameters, however, where surveillance is justified.
The NSA(/topics/national-security-agency/) has a legitimate right to pursue the collection of metadata if
there are genuine links to terrorism, Mr. Klayman(/topics/larry-klayman/) said. Still, I want the courts to
step in, or we as a nation could go into a state of violent revolution.
Although multiple polls reveal that the majority of Americans perceive Mr. Snowden(/topics/edward-
snowden/) , now living in exile in Russia as more NSA(/topics/national-security-agency/) secrets are
spilled, to be a criminal or traitor, Mr. Klayman(/topics/larry-klayman/) disagrees.
We owe a debt a gratitude to Edward Snowden(/topics/edward-snowden/) . He shouldnt have
collaborated with Russia. But he forced the NSA(/topics/national-security-agency/) to admit to what they
were doing, he said.
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Attachment G
631
THANK GOD FOR LARRY KLAYMAN

Published: 11/25/1998 at 1:00 AM
JOSEPH FARAH (HTTP://WWW.WND.COM/AUTHOR/JFARAH/) About | Email (mailto:jfarah@worldnetdaily.com) |
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0
Fact: The biggest donor to Bill Clintons 1992 presidential campaign bigger than the teachers union or any
political action committee was the Riady family, long suspected of being Chinese intelligence agents.
Fact: The Riadys had been sponsors of Clintons political campaigns since the 1970s when he first ran for attorney
general in the state of Arkansas.
Fact: The largest individual donor to the 1996 Clinton re-election effort was Bernard Schwartz, chairman and chief
executive officer of the Loral Corp. One of Lorals biggest business partners and investors is the government of
China through a front company called China Telecom.
Fact: In 1996, a presidential election year, President Clinton placed an area in Utah the size of Connecticut rich in
clean-burning coal off limits to mining by executive order. The biggest beneficiary of that action was the Riady family,
with coal interests in Indonesia, the only other major source of clean-burning coal in the world.
Fact: Webster Hubbell stopped cooperating with prosecutors after James Riady met with him, then President
Clinton, then dropped off a check to Hubbell for $100,000 for work that was never performed.
Fact: The FBI reported to the White House that the Chinese government had made a concerted effort to influence
the 1996 U.S. elections, yet Clinton did nothing he didnt expel the Chinese ambassador, he didnt invoke trade
sanctions, he didnt even harshly rebuke Beijing.
On and on it goes. From the sweetheart treatment of the COSCO shipping company to the back channels of White
House access provided by John Huang, the China-gate scandal remains, without doubt, a cover-up of historic
proportions. These are but a few of the startling and undeniable truths of life with regard to the selling of the presidency,
1992-1998.
Attorney General Janet Reno performed perhaps her penultimate tap dance yesterday when she announced her
decision not to name an independent counsel to investigate Vice President Al Gores involvement with illegal campaign
fund-raising that involves the China connection. The final act for Reno, before she resigns her post for health reasons,
will be to deny the appointment of an independent counsel to investigate Clinton.
If all goes according to plan, the greatest crime in American history will then be complete.
But thank God for Larry Klayman and Judicial Watch. Just when you assume all hope of accountability for these official
criminal acts is gone, Klayman rides to the rescue wearing the white hat.
An hour before Reno announced her decision yesterday, Judicial Watch filed the civil lawsuit focusing on the China-gate
scandal. Named as defendants in the shareholder derivative, civil conspiracy and RICO action are Loral Chairman and
CEO Bernard Schwartz, Clinton, first lady Hillary Clinton, Gore, Huang, the DNC, the Democratic Senatorial Campaign
Committee, the Democratic Congressional Campaign Committee and others.
As corrupt as Renos investigations into this subject have been, the Republicans hardly look better. Rep. Chris Cox, R-
CA, appointed by Speaker Newt Gingrich to head an inquiry into the sale of sensitive technology, the flow of campaign
contributions from China and the possibility of bribes and influence peddling, has shown little indication his probe is
going anywhere fast.
(http://www.wnd.com/1998/11/1257/print/)
631
Its time to step up and take your best shot, Mr. Cox. Do it now, while theres still a chance America can recover from the
national-security damage done by this administration. If youre not prepared to tell us what you found and add to the list
of impeachment counts, step aside and let Larry Klayman do the job.
Likewise, Ken Starr, if youre all through with Filegate and have decided to exonerate the president of wrongdoing, why
not let Larry Klayman have a shot at interviewing those witnesses you overlooked and examining the evidence you
determined to be insufficient.
* * *
When it comes to justice in America, its not easy maintaining your faith in the system anymore. But thats why this
Thanksgiving season, Im grateful for the courageous and determined work of Larry Klayman and a few other gutsy,
independent, relentless freedom fighters. Its amazing the impact committed individuals can make when they put their
mind to it.
I thank God there are still a few heroes left. Likewise, I thank God for Jerome Zeifman, the former Watergate chief
counsel, who, unlike Sam Dash, maintains one simple standard for impeachable offenses one not colored by which
political party happens to be in charge of the White House at any given time.
I also thank God for all my colleagues at WorldNetDaily who have made this fantastic muckraking journey through
cyberspace possible and enjoyable.
Lastly, I thank God for my wife, Elizabeth, who stands by me no matter who my enemies are, and no matter what the cost
who maintains her own passion for justice and feeds mine.
Who says theres nothing to be thankful for?
(Rate this)
Note: Read our discussion guidelines (/discussion-guidelines/) before commenting.

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631

Attachment H
631
LARRY KLAYMAN, MY HERO


3
People sometimes ask me who my heroes are. After all, Id be
hard-pressed to name any contemporary politicians I trust or look to for
leadership and courage.
There is such a man. Hes not a politician. He is an activist. But he
is one who has integrity enough to prevent him from blind loyalty to
party or ideology and keep him focused on principle.
His name is Larry Klayman and he founded the organization known as
Judicial Watch. (http://www.judicialwatch.org)
Some people have asked me if Larry is crazy, if hes a zealot, or if
he has all of his oars in the water. If you dont know Larry personally,
it might be easy to confuse him with a loose cannon. Thats because he
is fearless and relentless in the pursuit of justice. Thats a rare
commodity today in America. It wasnt always like that. There were other
men like Larry early in American history. Their names were Washington,
Jefferson, Madison and Henry. They dont make em like that any more. At
least not many. Larry is an exception.
So, why am I telling you all about my friend and my attorney, Larry
Klayman?
A couple of reasons. I believe that in the next several weeks you
will see an intensification of the establishment political attacks on
him. Im not sure what form they will take. They might be physical
attacks. They might be character assaults. All I can tell you is Larry
Klayman is a dangerous man if you are a corrupt politician. And this
country is a breeding ground of corrupt politicians.
The Democratic National Committee is investigating Larry the way they
once investigated me running the Lexis-Nexis searches, collecting
dossiers and preparing a muckraking report for journalists eager to do
the bidding of partisan hatchet wielders.
Just know this: No matter what you hear, no matter what you read, no
matter what you see about Larry Klayman in the coming weeks and months,
let it not be filtered through any lens but the truth. And the truth is
Larry Klayman is an American hero.
I dont make that statement lightly. I dont make that statement
frequently. But I make it without any reservations about Larry Klayman.
One thing about these Clintonistas: When you expose them, they come
after you. Theres nothing subtle about the way this administration goes
after its enemies.
631
Klaymans been a target before, and he will be a target again. I

remember when they came after him the last time with an orchestrated
smear campaign in the media.
You can bet the White Houses team of private investigators (they
were called plumbers in another disgraced administration) dug up the
dirt.
Just a week or so ago, Clinton himself referenced Larry Klayman by
name as a source of irritation so great it forced him to rethink his
illegal deal to purchase a home with a loan that could only be
characterized as a bribe from a major political contributor.
Why are they coming after Larry now? Because, in many ways, Larry and
Judicial Watch represent the only game in town. The independent counsel
is gone. The Justice Department is thoroughly corrupt. The Congress is
hopelessly compromised and fearful. The media, by and large, are sitting
this one out.
Everyone is just waiting for Clintons term to expire except Larry
Klayman.
And hes got some important cases on his plate. Hes in the thick of
exposing virtually every major scandal involving the White House and
some most people have never even heard about. Hell be taking some
critical depositions in the coming weeks. And the Clinton forces are
preparing, as James Carville would say, for war.
Dont worry about Larry Klayman backing down in the face of such
pressures. They will only serve to embolden him. Larry Klayman will do
what is right no matter who is involved. Klayman is a guy who never
shrinks from his standards of ethics and morality. Hes a man who looks
to no one but God for guidance and direction. Hes just the kind of
person we need in times like this.
Which is why I am also pleased to tell you the next piece of news: I
am happy to report that Judicial Watchs Larry Klayman will be joining
WorldNetDaily as a regular weekly columnist next week. I am honored that
he would choose this forum to share his keen insights with the American
public. Look for his column each Tuesday.
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Attachment I
631
LARRY KLAYMAN FOR U.S. SENATE


1
People sometimes ask me who my heroes are. After all, Id be hard-pressed to name any contemporary politicians I trust
or look to for leadership and courage.
There is such a man. Hes not a politician. But he is running for office the U.S. Senate from the state of Florida.
His name is Larry Klayman and he founded the organization known as Judicial Watch (http://www.judicialwatch.org).
Larry Klayman is my hero because he has integrity enough to prevent him from blind loyalty to party or ideology and
keep him focused on principle.
Some people have asked me if Larry is crazy, if hes a zealot, or if he has all of his oars in the water. If you dont know
Larry personally, it might be easy to confuse him with a loose cannon. Thats because he is fearless and relentless in
the pursuit of justice. Thats a rare commodity today in America. It wasnt always like that. There were other men like
Larry early in American history. Their names were Washington, Jefferson, Madison and Henry. They dont make em like
that any more. At least not many. Larry is an exception.
Thats why I am doing something very unusual for me today I am formally and personally endorsing Larry Klayman in
his uphill bid for the U.S. Senate. The primary election is next Tuesday and you still have a chance to send him a
contribution (http://www.klaymansenate.com) or at least hold him up in your prayers in the next few days.
Why do I think its so important to elect Larry Klayman to the U.S. Senate?
Because Larry Klayman is an anti-establishment candidate. He is in nobodys pocket. Hes a man of character and
principle. We need men like that in the U.S. Senate and elsewhere in government.
The Senate will be a stronger institution with his admission, and America will be a better nation with him in the Senate.
To be honest with you, I never thought I would see the day that Larry Klayman was actually a serious candidate for the
U.S. Senate. We all have an opportunity to make a real difference, a real impact on American government by getting him
elected.
Larry Klayman is not running for the U.S. Senate because he wants to participate in a debating society. Hes running
because he wants to get America back on track with its constitutional form of government. One of the cornerstones of
his campaign is a promise to fight to get the United States out of the United Nations.
When was the last time you heard of a Senate campaign built around that promise?
But thats my friend Larry Klayman. He doesnt listen to polls. He listens to his heart and his mind. And he listens to the
Constitution and the law of the land.
Larry Klayman is an American hero. I dont make that statement lightly. I dont make that statement frequently. But I
make it without any reservations about Larry Klayman.
Dont worry about Larry Klayman backing down in the face of the pressures and temptations of the Beltway. Trust me.
They will only serve to embolden him. Larry Klayman will do what is right no matter who is involved. Klayman is a guy
who never shrinks from his standards of ethics and morality. Hes a man who looks to no one but God for guidance and
direction. Hes just the kind of person we need in times like this.
631
Thats why I am standing behind Larry Klayman for the U.S. Senate.
(Rate this)
1 comment
Join the discussion
Reply
Rembrandt Q. Ei nst ei n 3 months ago
"To be honest with you, I never thought I would see the day that Larry Klayman was actually a serious
candidate for the U.S. Senate."
You still haven't.

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631

Attachment J
631
In The Matter of:

LARRY E. KLAYMAN
vs.
JUDICIAL WATCH, INC.
___________________________________________________
PAUL ORFANEDES, ESQUIRE
January 27, 2014
___________________________________________________

631
PAUL ORFANEDES, ESQUIRE - 1/27/2014

800-292-4789 www.merrillcorp.com/law
Merrill LAD
Page 1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
------------------------x
LARRY E. KLAYMAN, )
Plaintiff, ) Case No.
v. ) 13-20610-CIV-ALTONAGA/
JUDICIAL WATCH, INC., ) Simonton
Defendant. )
------------------------x
VIDEOTAPED DEPOSITION OF PAUL ORFANEDES, ESQUIRE
Washington, D.C.
Monday, January 27, 2014
9:22 a.m.
Job No.: 2-244101
Pages 1 - 164
Reported By: Joan V. Cain
631

Merrill LAD
Page 2
1 Videotaped Deposition of PAUL ORFANEDES,
2 ESQUIRE, held at the offices of:
3
4 MERRILL LAD
5 Suite 200
6 1325 G Street, Northwest
7 Washington, D.C. 20005
8 (202) 861-3410
9
10 Pursuant to Notice, before Joan V. Cain,
11 Court Reporter and Notary Public in and for the
12 District of Columbia.
13
14
15
16
17
18
19
20
21
22
631

Merrill LAD
Page 3
1 A P P E A R A N C E S
2
3 ON BEHALF OF PLAINTIFF PRO SE:
4 LARRY KLAYMAN, ESQUIRE
5 LARRY KLAYMAN, ATTORNEY AT LAW
6 Suite 345
7 2020 Pennsylvania Avenue, Northwest
9 Telephone: (310) 595-0800
10
11 ON BEHALF OF DEFENDANT:
12 DOUGLAS J. KRESS, ESQUIRE
13 SCHWED KAHLE & KRESS, P.A.
14 Suite 100
15 11410 North Jog Road
16 Palm Beach Gardens, Florida 33418
17 Telephone: (561) 694-0070
18
19
20 ALSO PRESENT:
21 Akim Graham, Videographer
22 Dina James
631

Merrill LAD
Page 4
1 C O N T E N T S
2
3 EXAMINATION OF PAUL ORFANEDES PAGE
4 By Mr. Klayman 7
5
6 E X H I B I T S
7 (Attached to the Transcript.)
8 PLAINTIFF'S DEPOSITION EXHIBITS PAGE
9 EXHIBIT 1 Printout from the Orly Taitz 14
10 Web Site, Bates No.'d JW000013
11 through '24
13 Web Site, Bates No.'d JW000001
14 through '12
15 EXHIBIT 3 E-mail Chain dated 3/5/12 and 45
16 Copy of Letter from Mr. Driscoll
17 to Mr. Klayman, 3/5/12
19 Web Site
20 EXHIBIT 5 Printout from the Birther Report 146
21 Web Site
22
631

Merrill LAD
Page 5
1 E X H I B I T S C O N T I N U E D
2 (Attached to the Transcript.)
3 PLAINTIFF'S DEPOSITION EXHIBITS PAGE
4 EXHIBIT 6 Printout from the Oh, For 146
5 Goodness Sake Web Site
6 EXHIBIT 7 Printout from the Free Republic 147
7 Web Site
8 EXHIBIT 8 Printout from the Free Republic 147
9 Web Site
10 EXHIBIT 9 E-mail Chain dated 8/28/12 and 148
11 Copy of Letter from Mr. Driscoll
12 to Mr. Klayman, 3/5/12
13
14
15
16
17
18
19
20
21
22
631

Merrill LAD
Page 6
1
09:22:04
P R O C E E D I N G S
2
09:22:04
THE VIDEOGRAPHER: Here begins Videotape
3
09:22:06
No. 1 in the deposition of Paul Orfanedes in the
4
09:22:10
matter of Larry E. Klayman versus Judicial Watch,
5
09:22:12
Incorporated in the United States District Court for
6
09:22:16
the Southern District of Florida, Case No.
7
09:22:22
13-20610-CIV.
8
09:22:22
Today's date is January 27th, 2014. The
9
09:22:26
time on the video monitor is 9:22 a.m. and the video
10
09:22:31
operator -- excuse me -- the video operator today is
11
09:22:33
Akim Graham. This video deposition is taking place
12
09:22:37
at 1325 G Street, Northwest in Washington, D.C.
13
09:22:39
Counsel, please voice identify yourselves
14
09:22:44
and state whom you represent.
15
09:22:45
MR. KLAYMAN: I'm Larry Klayman. I am
16
09:22:47
counsel for the plaintiff pro se.
17
09:22:49
MR. KRESS: Douglas Kress, counsel for
18
09:22:53
Judicial Watch, Inc.
19
09:22:54
THE VIDEOGRAPHER: The court reporter today
20
09:22:55
is Joan Cain of Merrill LAD. Would the reporter
21
09:22:57
please swear in the witness.
22
09:22:57
PAUL ORFANEDES
631

Merrill LAD
Page 7
1
09:22:57
having been duly sworn, was examined and did testify
2
09:23:07
as follows:
3
09:23:08
EXAMINATION BY COUNSEL FOR PLAINTIFF PRO SE
4
09:23:08
BY MR. KLAYMAN:
5
09:23:09
Q Please state your name.
6
09:23:09
A Paul Joseph Orfanedes.
7
09:23:11
Q Mr. Orfanedes, when did you graduate from
8
09:23:14
law school?
9
09:23:16
A 1990.
10
09:23:17
Q Okay. You've been a lawyer continuously
11
09:23:20
since then?
12
09:23:21
A Mm-hmm.
13
09:23:21
Q Can you list for us just briefly your
14
09:23:23
professional background, where you've worked?
15
09:23:31
A Certainly. I started off working -- I was
16
09:23:35
a law clerk -- do you want -- does that include --
17
09:23:41
Q Everything you've done in your legal
18
09:23:42
capacity.
19
09:23:43
A I was a law clerk for a guy named Steve
20
09:23:47
Trattner while I was in law school. I don't
21
09:23:50
remember for how long. It was primarily trademark
22
09:23:54
work. I worked at a law clinic while I was at AU.
631

Merrill LAD
Page 8
1
09:24:02
We did a variety of different types of work. I was
2
09:24:04
a law clerk at a law firm called Connerton Ray &
3
09:24:09
Simon here in Washington. They hired me as an
4
09:24:13
attorney when I passed the bar.
5
09:24:14
Q And what date did you pass the bar?
6
09:24:16
A Oh, I don't remember.
7
09:24:17
Q What year was that?
8
09:24:18
A 1990. I worked there for a couple years,
9
09:24:25
and then I went to work at Klayman & Associates,
10
09:24:28
your firm, I believe it was September 1992. At some
11
09:24:31
point I became an employee of Judicial Watch. I
12
09:24:35
don't remember when. There was some overlap in my
13
09:24:39
capacity as an attorney for Klayman & Associates and
14
09:24:42
an attorney for Judicial Watch. At some point I
15
09:24:44
became a full-time attorney with Judicial Watch and
16
09:24:47
I've been there ever since.
17
09:24:48
Q I left Judicial Watch on September 19,
18
09:24:52
2003. Do you recollect that?
19
09:24:53
A Yes.
20
09:24:53
Q So at that point you'd been working with me
21
09:24:56
for about 11 years?
22
09:24:57
A Yes.
631

Merrill LAD
Page 9
1
09:24:58
Q Okay. And during the time that you worked
2
09:25:01
with me, you found me to be reputable, correct?
3
09:25:06
A No.
4
09:25:06
Q Okay. In terms of -- why did you stay so
5
09:25:12
long working with me then?
6
09:25:13
A It was an interesting opportunity. I
7
09:25:16
enjoyed the work. I had a lot of freedom to do a
8
09:25:19
lot of work that I liked.
9
09:25:21
THE VIDEOGRAPHER: Excuse me. I'm getting
10
09:25:22
a little bit of interference maybe from someone's
11
09:25:25
phone.
12
09:25:25
MR. KRESS: Could be mine.
13
09:25:26
BY MR. KLAYMAN:
14
09:25:28
Q During that time period we tried some cases
15
09:25:31
together, correct?
16
09:25:32
A Yes.
17
09:25:32
Q Where did we try those cases together?
18
09:25:37
A Florida, Miami.
19
09:25:41
Q That was a case involving swimming pools?
20
09:25:44
A Pool fences. Yeah, it was a trademark
21
09:25:48
dispute, Lanham Act claim; Washington, D.C.;
22
09:25:54
Seattle. I don't remember other places, maybe
631

Merrill LAD
Page 10
1
09:25:57
California.
2
09:25:59
Q And when was Judicial Watch started?
3
09:26:02
A July 29th, 1994.
4
09:26:06
Q And during that time we brought several
5
09:26:08
cases concerning the government, correct?
6
09:26:12
A Judicial Watch you mean?
7
09:26:13
Q Yes.
8
09:26:14
A Yes.
9
09:26:14
Q And we had developed a certain notoriety in
10
09:26:21
terms of what we were doing, particularly with
11
09:26:23
regard to the Clinton Administration, correct?
12
09:26:25
A Oh, I don't know about notoriety.
13
09:26:30
Q We became known?
14
09:26:32
A Yes.
15
09:26:36
Q And in the conservative community, we had a
16
09:26:38
very good reputation; did we not?
17
09:26:40
A I think it depends on who you talk to.
18
09:26:42
Q Well, if we didn't have a good reputation,
19
09:26:45
why did you stay with Judicial Watch?
20
09:26:47
A I said I enjoyed the work. I enjoyed some
21
09:26:49
of the people. I had a lot of freedom. It was a
22
09:26:52
decent -- it was a good choice for me.
631

Merrill LAD
Page 11
1
09:26:54
Q So you'll continue to work with people you
2
09:26:56
don't think are reputable if you enjoy the work?
3
09:27:00
A Can you ask me that one again?
4
09:27:02
Q You would continue to work with someone who
5
09:27:05
you didn't think was reputable if you enjoyed that
6
09:27:08
work that he was doing and you were doing?
7
09:27:09
A Oh, I think it depends on the
8
09:27:11
circumstances.
9
09:27:15
Q Would you work with a law firm that you
10
09:27:17
thought is unethical?
11
09:27:20
A No.
12
09:27:21
Q Would you work with a public interest group
13
09:27:24
that you thought was unethical?
14
09:27:25
A No.
15
09:27:27
Q And you're still working for Judicial
16
09:27:29
Watch, aren't you?
17
09:27:29
A Yes.
18
09:27:30
Q What's your position?
19
09:27:32
A I have several titles. I am the corporate
20
09:27:37
secretary. I'm the corporate treasurer. I'm the
21
09:27:40
director of litigation, the head of the legal
22
09:27:43
department, the chief lawyer for the organization,
631

Merrill LAD
Page 12
1
09:27:47
and I'm a member of the Board of Directors.
2
09:27:50
Q Who else is -- is on the Board of
3
09:27:53
Directors?
4
09:27:53
A Tom Fitton and Chris Farrell.
5
09:27:57
Q Has there been anyone else that's been on
6
09:27:59
the Board of Directors since I left Judicial Watch
7
09:28:01
in 2003?
8
09:28:02
A No.
9
09:28:04
Q And what is Chris Farrell's position with
10
09:28:06
Judicial Watch?
11
09:28:07
A Well, I had just said he's on the Board of
12
09:28:10
Directors and he is the head of the research and
13
09:28:12
investigations department.
14
09:28:12
Q And what is Tom Fitton's position?
15
09:28:16
A He's on the Board of Directors and he's the
16
09:28:18
president of the organization.
17
09:28:19
Q Is there a chairman of the organization?
18
09:28:20
A No.
19
09:28:21
Q In fact, I was chairman; was I not?
20
09:28:23
A Well, it was a title that you gave
21
09:28:26
yourself. There was never an official position, I
22
09:28:29
believe, under the bylaws that was called chairman.
631

Merrill LAD
Page 13
1
09:28:32
Q Did you ever refute the fact that I was
2
09:28:34
chairman when I was working with you?
3
09:28:36
A Well, like I said, it was a title that you
4
09:28:38
used. I don't think it was -- I don't believe that
5
09:28:41
there was an official position called chairman as
6
09:28:46
set forth in the bylaws of the organization.
7
09:28:49
Q So the three people that you just
8
09:28:51
mentioned, yourself, Chris Farrell, Tom Fitton,
9
09:28:54
you're the ones that make the decisions at Judicial
10
09:28:56
Watch, correct?
11
09:28:56
A Yes.
12
09:28:57
Q There's nobody else?
13
09:29:01
A Well, I think there are lots of people who
14
09:29:03
make lots of decisions. We --
15
09:29:07
Q I'm talking about in terms of the
16
09:29:08
governance of Judicial Watch.
17
09:29:09
A Yes, that would be the three of us.
18
09:29:13
Q Okay. Now, let's go back to the time of
19
09:29:18
the issue that we're here today about, okay, the
20
09:29:21
publication in Orly Taitz's web site, World's
21
09:29:30
Leading Obama Eligibility Challenge Web Site.
22
09:29:31
You're aware of that web site?
631

Merrill LAD
Page 14
1
09:29:33
A No, I'm not.
2
09:29:34
Q Have you ever read that web site?
3
09:29:35
A I think I read it after you wrote
4
09:29:39
something -- my recollection is you sent us
5
09:29:42
something complaining about a comment that was
6
09:29:44
posted on the web site, and I looked at it then.
7
09:29:47
Q Okay. I'm going to show you what I'll ask
8
09:29:50
the court reporter to mark as Plaintiff's Exhibit 1.
9
09:29:53
(Plaintiff's Deposition Exhibit 1 was
10
09:29:53
marked for identification and was attached to the
11
09:30:21
deposition transcript.)
12
09:30:21
MR. KRESS: Can we go off the record for
13
09:30:23
one second?
14
09:30:23
THE VIDEOGRAPHER: Going off the record.
15
09:30:25
The time is 9:30 a.m.
16
09:30:30
(Recess.)
17
09:31:13
THE VIDEOGRAPHER: Back on the record. The
18
09:31:15
time is 9:31 a.m.
19
09:31:27
BY MR. KLAYMAN:
20
09:31:27
Q Have you ever seen this document before?
21
09:31:29
A I believe I have.
22
09:31:29
Q When did you first see it?
631

Merrill LAD
Page 15
1
09:31:32
A It was after you had sent us whatever
2
09:31:38
communication you sent us complaining about a
3
09:31:40
posting on the web site.
4
09:31:43
Q Did Mr. Fitton review it as well?
5
09:31:49
A I don't know.
6
09:31:49
Q Did Mr. Farrell review it as well?
7
09:31:52
A I don't remember.
8
09:31:53
Q You had no discussion?
9
09:31:54
A I don't remember, and if I did it, it would
10
09:31:56
be attorney-client privilege or attorney work
11
09:31:59
product.
12
09:31:59
Q The fact that you had a discussion would
13
09:32:04
not be attorney-client privilege.
14
09:32:06
A Of course it would be.
15
09:32:06
Q Not that you had a discussion. The content
16
09:32:08
of that discussion you could perhaps --
17
09:32:09
A Okay. Yes. You're right about that. If I
18
09:32:11
did have a discussion, and I don't recall any
19
09:32:13
specific discussions with Mr. Farrell or Mr. Fitton,
20
09:32:16
those discussions would have been privileged or
21
09:32:17
subject to attorney work product.
22
09:32:20
Q You had no discussions because you were
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09:32:22
really not really concerned what Ms. Ruffley had
2
09:32:26
said about me, correct?
3
09:32:27
A I don't know what Ms. Ruffley said, if
4
09:32:28
anything, about you.
5
09:32:31
Q Oh, let's review it.
6
09:32:32
A Okay.
7
09:32:33
Q And this is the second posting, as counsel
8
09:32:35
said, and I'm reading from it. I'm looking at the
9
09:32:38
second page. "My yesterday's presentation to CCIR
10
09:32:41
and update on article2superPAC - Larry Klayman
11
09:32:47
$25,000 fundraising for non-existent law suit
12
09:32:51
affair."
13
09:32:52
A I'm sorry. I don't know what -- I don't
14
09:32:54
seem to be on the same page.
15
09:32:55
Q It's the second page.
16
09:32:56
MR. KRESS: We have different documents.
17
09:32:57
That is not what this document says.
18
09:33:00
MR. KLAYMAN: Okay. Yeah, mark that as
19
09:33:07
Exhibit 2.
20
09:33:08
21
09:33:08
22
09:33:18
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09:33:18
THE WITNESS: Okay.
2
09:33:20
BY MR. KLAYMAN:
3
09:33:20
Q Do you see where I read, "My yesterday's
4
09:33:20
presentation to CCIR and update on article2superPAC
5
09:33:20
- Larry Klayman $25,000 fundraising for non-existent
6
09:33:32
law suit affair"?
7
09:33:33
A Yes, I see what you're referring to.
8
09:33:35
Q Okay. And in that article it states,
9
09:33:36
"Posted on "February 23, 2012."
10
09:33:45
Can I see the first one you marked? It
11
09:34:01
states, Article2superpac $25,000 solicitation for
12
09:34:01
Larry Klayman, Screen shot $25,000 solicitation for
13
09:34:01
Larry Klayman lawsuits, February 10, 2012.
14
09:34:16
Yesterday I gave a 2-hour presentation on
15
09:34:19
my platform as a candidate for the U.S. Senate. The
16
09:34:22
presentation was given to some 100 California voters
17
09:34:24
in the Women's club of Garden Grove. I was told
18
09:34:27
that a representative of the Judicial Watch drove
19
09:34:30
for over an hour from San Marino to hear me speak
20
09:34:34
and talk to me. I got a very warm reception. After
21
09:34:37
my presentation people stood up and applauded.
22
09:34:40
The member of the Judicial Watch approached
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09:34:42
me and gave me her card. Her name is Constance
2
09:34:46
Ruffley and she is an office administrator for the
3
09:34:49
Judicial Watch in their Western Regional
4
09:34:51
Headquarters at 2540 Huntington drive, San Marino.
5
09:34:55
She told me that she used to work for the FBI and
6
09:34:58
that she worked for the Judicial Watch for many
7
09:35:00
years. She actually initiated the discussion about
8
09:35:02
Larry Klayman and told me that she had heard that he
9
09:35:04
is involved in birther cases.
10
09:35:07
I told her that this group,
11
09:35:08
article2superpac, was soliciting money and they sent
12
09:35:11
an e-mail and posted on their site an advertisement
13
09:35:14
on February 10th asking for $25,000, claiming that
14
09:35:18
they need to raise $25,000 in 96 hours, as the cases
15
09:35:22
in Florida and California need to be filed within a
16
09:35:25
week. I told her that it was a hard sell, they
17
09:35:28
wrote -- they wrote it is now or never, saying
18
09:35:33
finally Obama's team met their match, dissing 4
19
09:35:39
years of my tireless work in the process, and in the
20
09:35:42
end nothing was filed by Larry Klayman. It is not
21
09:35:44
clear what happened to all the money that was
22
09:35:47
raised, who got it.
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09:35:49
Ms. Ruffley actually advised me that Larry
2
09:35:51
Klayman is not licensed in California. She told me
3
09:35:54
that he no longer works with the Judicial Watch and
4
09:35:56
that donors should know about the litigation in Ohio
5
09:35:59
where he was convicted just recently of not paying a
6
09:36:02
large amount in child support. She provided a lot
7
09:36:05
of other information. I will publish only what is
8
09:36:08
in the public record. I am not publishing anything
9
09:36:11
that is not in public record.
10
09:36:13
Okay. Do you see that?
11
09:36:15
A I see it on this document, yes.
12
09:36:17
Q Right. This is the document that you
13
09:36:18
reviewed at the time that you've just referenced,
14
09:36:21
correct?
15
09:36:21
A I believe I did review it.
16
09:36:23
Q Okay. And when you reviewed it, you
17
09:36:25
discussed it with Mr. Fitton, correct?
18
09:36:29
A I'm not getting into the substance of any
19
09:36:31
discussion I had with --
20
09:36:31
Q I'm asking whether you had a discussion
21
09:36:33
with Mr. Fitton.
22
09:36:34
A You tried to characterize the discussion.
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09:36:35
Q How long have you been a lawyer?
2
09:36:37
A I think we've just been through that.
3
09:36:38
Q Okay. You know that the fact that you had
4
09:36:40
a discussion is not covered by attorney-client
5
09:36:42
privilege.
6
09:36:44
A I've acknowledged that I had a
7
09:36:46
discussion -- well, I don't remember what my -- I
8
09:36:50
don't believe I have a specific recollection of a
9
09:36:51
discussion with Mr. Fitton about this article.
10
09:36:54
Q During the Clinton years, the Clinton
11
09:36:57
people used to claim they had no specific
12
09:37:01
recollection. Do you remember that?
13
09:37:02
MR. KRESS: Objection to the form.
14
09:37:03
THE WITNESS: Do you have a question for
15
09:37:04
me?
16
09:37:05
BY MR. KLAYMAN:
17
09:37:05
Q You sat in some depositions; did you not?
18
09:37:08
A Do you have a question for me?
19
09:37:10
Q Yeah, is that where you're getting the
20
09:37:11
phrase, "I have no specific recollection"? What
21
09:37:13
does no specific recollection mean? You have a
22
09:37:21
recollection but you can't remember now; is that
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09:37:23
what it means?
2
09:37:23
A I don't recall any specific recollection
3
09:37:25
with Mr. Fitton about this posting.
4
09:37:26
Q What -- if you don't have a specific
5
09:37:29
recollection, tell me your general recollection.
6
09:37:31
A I have a general recollection -- I -- I
7
09:37:34
don't even recall -- I'm saying I may have had a
8
09:37:37
discussion with him about it. I don't recall if I
9
09:37:40
had a discussion with him about it.
10
09:37:42
Q You didn't think this was very important,
11
09:37:44
did you?
12
09:37:54
A The substance of it, no.
13
09:37:57
Q You don't think it's important that Connie
14
09:37:59
Ruffley told Orly Taitz that I was convicted of a
15
09:38:03
crime?
16
09:38:03
MR. KRESS: Objection to form. You can
17
09:38:04
answer.
18
09:38:05
THE WITNESS: I don't know that Connie
19
09:38:06
Ruffley made any such statement to Orly Taitz.
20
09:38:09
BY MR. KLAYMAN:
21
09:38:09
Q Let's assume for hypothetical that she did.
22
09:38:12
A I'm not here to testify about
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1
09:38:15
hypotheticals.
2
09:38:16
Q Well, you -- that's permissible under the
3
09:38:17
rules of evidence. Now, if someone makes a
4
09:38:19
statement that a lawyer committed a crime, that's
5
09:38:22
significant; is it not?
6
09:38:23
MR. KRESS: Objection to form.
7
09:38:25
THE WITNESS: Not necessarily.
8
09:38:25
BY MR. KLAYMAN:
9
09:38:25
Q No? You're aware that lawyers can lose
10
09:38:28
their bar license if they're convicted of a crime,
11
09:38:30
correct?
12
09:38:30
A Yes.
13
09:38:31
Q In fact do, correct?
14
09:38:32
A Sometimes.
15
09:38:33
Q And the crime that's being referenced here
16
09:38:36
is a felony; is it not?
17
09:38:37
A I don't know. I'm not a -- I'm not
18
09:38:39
familiar with Ohio law, but it would seem to be a
19
09:38:42
substantial offense.
20
09:38:43
Q So, therefore, it was a significant
21
09:38:45
statement?
22
09:38:46
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1
09:38:49
You can answer.
2
09:38:52
THE WITNESS: I don't know that Connie made
3
09:38:55
this statement as alleged.
4
09:38:56
BY MR. KLAYMAN:
5
09:38:56
Q Have you ever talked to Connie Ruffley
6
09:38:58
about it?
7
09:39:00
A I don't recall if I had a specific
8
09:39:02
conversation with her at the time that you had sent
9
09:39:06
this note complaining about the posting.
10
09:39:10
Q Did you have a general conversation with
11
09:39:12
her?
12
09:39:12
A I don't recall. I might have, but I don't
13
09:39:15
recall.
14
09:39:15
Q You realize you're under oath,
15
09:39:17
Mr. Orfanedes? You think that's funny?
16
09:39:22
A I think your attempt to intimidate people
17
09:39:26
is amateurish.
18
09:39:28
Q No, I'm not attempting to intimidate you.
19
09:39:31
I just asked for a straight answer. Will you give
20
09:39:34
me a straight answer?
21
09:39:34
A I gave you my answer.
22
09:39:36
Q What does specific recollection mean to
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1
09:39:38
you? Please define it.
2
09:39:41
A I don't recall any particular details of a
3
09:39:44
conversation I may have had with Connie about this
4
09:39:48
posting. I may have had a conversation --
5
09:39:51
Q Do you recall a conversation?
6
09:39:52
A I may have had a conversation about her. I
7
09:39:54
don't recall.
8
09:39:54
Q You and Orfanedes and Farrell got on a
9
09:39:58
conference call with her; did you not?
10
09:40:00
A I am Orfanedes.
11
09:40:02
Q Yeah, you and Mr. Farrell and Mr. Fitton
12
09:40:05
got on an a conference call?
13
09:40:07
A No. I would remember that. I don't
14
09:40:08
remember that.
15
09:40:08
Q You sent e-mails to her; did you not?
16
09:40:10
A I don't remember sending e-mails to her
17
09:40:12
about this posting. I communicate with her fairly
18
09:40:14
regularly.
19
09:40:15
Q You haven't searched your computer for
20
09:40:17
e-mails to Connie Ruffley in around this time
21
09:40:19
period, have you?
22
09:40:20
A Which computer?
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1
09:40:21
Q Well, what computers do you have?
2
09:40:22
A My computer at work, yes, I did search it.
3
09:40:26
Q Did you see any e-mails to Ms. Ruffley at
4
09:40:29
this time?
5
09:40:29
A Not about this issue -- and actually not
6
09:40:33
generally. I tend not to save stuff on my computer,
7
09:40:36
but I did look, and there was nothing there.
8
09:40:39
Q Well, you realize that you can recall
9
09:40:42
e-mails on a hard drive, correct? Did you ask
10
09:40:45
anybody to do that?
11
09:40:45
A No, I did not.
12
09:40:51
Q Let's make it simple. Okay, what happened
13
09:40:54
after you read this at Judicial Watch? I'm not
14
09:40:58
trying to be provocative, but when you give me
15
09:41:01
answers that -- like the Clinton people gave me --
16
09:41:04
gave us at the time, then obviously it raises
17
09:41:06
questions as to whether you're telling me
18
09:41:09
everything. So tell me what you know happened after
19
09:41:11
you read this at Judicial Watch.
20
09:41:13
21
09:41:14
You can answer.
22
09:41:15
THE WITNESS: What I recall doing is
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1
09:41:16
sending it to our lawyer, your letter, your
2
09:41:19
communication complaining about the posting. I
3
09:41:22
think I sent it to our attorney, and I believe he
4
09:41:24
wrote a response back to you.
5
09:41:28
BY MR. KLAYMAN:
6
09:41:28
Q What -- this was brought -- this posting
7
09:41:31
was brought to the attention of Mr. Fitton; was it
8
09:41:34
not?
9
09:41:34
A I don't know. I don't remember.
10
09:41:35
Q After this --
11
09:41:39
A Well, as you -- I don't know if you're -- I
12
09:41:43
don't -- is your question -- was it directed only to
13
09:41:46
Mr. Fitton or was it directed to Mr. Farrell and
14
09:41:48
Mr. Fitton and myself? I don't remember.
15
09:41:49
Q Any or all of them.
16
09:41:51
A I don't remember who it was directed to. I
17
09:41:53
don't really remember the communication itself.
18
09:41:58
Q Now, as the former -- as the founder -- I
19
09:42:01
was the founder of Judicial Watch, correct?
20
09:42:03
A You call yourself the founder, yes.
21
09:42:08
Q Were you the founder of Judicial Watch?
22
09:42:10
A I played a very substantial role in its
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1
09:42:13
development and its success.
2
09:42:15
Q Are you claiming to be the founder of
3
09:42:17
Judicial Watch?
4
09:42:18
A I don't call myself the founder.
5
09:42:20
Q Okay. In nineteen ninety -- in July 29,
6
09:42:24
1994, was Mr. Fitton even with Judicial Watch?
7
09:42:26
A No, he wasn't.
8
09:42:27
Q Was there anyone with Judicial Watch
9
09:42:29
besides you and me?
10
09:42:30
A No.
11
09:42:30
Q Okay. So by deduction I was the founder,
12
09:42:36
correct?
13
09:42:37
A It's debatable.
14
09:42:38
Q I conceived of it, correct?
15
09:42:40
A It was your idea. The idea to have an
16
09:42:42
organization called Judicial Watch was your idea,
17
09:42:44
yes.
18
09:42:44
Q Okay. And I'm the one who authorized
19
09:42:47
preparation of Articles of Incorporation and
20
09:42:50
incorporation of the company, et cetera?
21
09:42:52
A I think so.
22
09:42:53
Q And you were working for me at the time at
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1
09:42:55
Klayman law firm, correct?
2
09:42:57
A That's right.
3
09:42:57
Q You weren't working for Judicial Watch
4
09:42:59
then?
5
09:42:59
A I was not an employee of Judicial Watch,
6
09:43:01
but I did work for Judicial Watch.
7
09:43:03
Q Right. Okay. So given -- and over the
8
09:43:11
next many years up into 2003, September 19th, I
9
09:43:16
served as the head of Judicial Watch, correct?
10
09:43:21
A You were the -- you had different titles
11
09:43:23
over time. You called yourself chairman. I believe
12
09:43:28
after Tom Fitton came in we made him the president.
13
09:43:32
Q And I was the president before that,
14
09:43:34
correct?
15
09:43:34
A I think you were. I don't really remember.
16
09:43:36
Q Okay. So what I'm getting at,
17
09:43:39
Mr. Orfanedes, is that wasn't it of concern to you
18
09:43:42
that someone who had founded and run Judicial Watch
19
09:43:46
for almost 10 years was being accused of a crime?
20
09:43:55
A I had been aware that there was an arrest
21
09:43:58
warrant issued for you in the state of Ohio. I was
22
09:44:02
very concerned that that could bear negatively on
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1
09:44:06
the organization. I don't remember when I became
2
09:44:09
aware of that arrest warrant. So that was of
3
09:44:17
concern to me.
4
09:44:17
Q How did you become aware of the arrest
5
09:44:19
warrant?
6
09:44:19
A I don't remember.
7
09:44:21
Q You and Mr. Fitton and Mr. Farrell made it
8
09:44:23
a point of tracking my activities for those 10
9
09:44:27
years, correct?
10
09:44:27
A No.
11
09:44:27
Q You were fixated on me, correct?
12
09:44:32
A No, I wouldn't say it that way. You have
13
09:44:38
filed multiple lawsuits against us, had other people
14
09:44:41
bring lawsuits against us, filed bar complaints, I
15
09:44:46
believe, or had been instrumental in the filing of
16
09:44:48
bar complaints against me. So your actions towards
17
09:44:54
Judicial Watch and Mr. Fitton and Mr. Farrell and I
18
09:44:59
took up a fair amount of our time in the 10 years
19
09:45:01
after you left Judicial Watch.
20
09:45:03
Q And as a result of these actions, which you
21
09:45:06
testify I took against you, you developed an animus
22
09:45:09
toward me, correct?
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1
09:45:11
2
09:45:13
You can answer.
3
09:45:14
BY MR. KLAYMAN:
4
09:45:14
Q A dislike?
5
09:45:17
A I don't know. I don't know the best way to
6
09:45:21
characterize my thinking on that. It's really sort
7
09:45:25
of an opinion. I don't know how to characterize it.
8
09:45:29
Q You have to answer. There's no privilege
9
09:45:32
here.
10
09:45:33
A I guess I don't know how to answer.
11
09:45:36
Q No specific recollection?
12
09:45:38
13
09:45:39
THE WITNESS: Well, your question was
14
09:45:40
whether I dislike you, I believe --
15
09:45:40
BY MR. KLAYMAN:
16
09:45:40
Q What I'm saying is --
17
09:45:43
A -- and I don't have a recollection or not
18
09:45:46
recollection about whether I like or dislike you.
19
09:45:48
Q You were concerned that Connie Ruffley
20
09:45:51
saying that I have been convicted of a crime could
21
09:45:54
reflect negatively on Judicial Watch at the time it
22
09:45:56
was made, correct?
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1
09:45:57
2
09:45:58
You can answer.
3
09:45:59
THE WITNESS: No, that's not what I was
4
09:46:00
saying.
5
09:46:00
BY MR. KLAYMAN:
6
09:46:01
Q Didn't really matter?
7
09:46:02
8
09:46:04
You can answer.
9
09:46:06
THE WITNESS: I don't even -- I'm not
10
09:46:08
really -- I don't really understand where we are.
11
09:46:10
Your question is convoluted and I don't understand
12
09:46:13
it.
13
09:46:14
BY MR. KLAYMAN:
14
09:46:14
Q No, it's very simple. Your concern at the
15
09:46:16
time that you read what I just read to you from Orly
16
09:46:21
Taitz's web site that the allegation -- or the
17
09:46:23
statement of the allegation that I had committed a
18
09:46:24
crime and was convicted of it could reflect
19
09:46:27
negatively on Judicial Watch?
20
09:46:38
A At some point I became aware that you had
21
09:46:40
been indicted in Ohio. I was concerned that that
22
09:46:44
could affect negatively on Judicial Watch.
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09:46:49
Q You were aware that I was never convicted
2
09:46:51
of a crime?
3
09:46:53
A I don't -- I don't know if you've been
4
09:46:55
convicted of a crime or not, Larry.
5
09:47:00
Q You've taken the time to review the court
6
09:47:02
record in Ohio; have you not?
7
09:47:04
A Oh, subsequent to this, yes, I've looked at
8
09:47:08
the court record and I understand that you resolved
9
09:47:11
whatever -- you resolved the allegations in the
10
09:47:14
indictment.
11
09:47:17
Q All I'm getting at is, at the time that you
12
09:47:20
read this, you were concerned that this could
13
09:47:23
reflect on Judicial Watch. Simple question.
14
09:47:27
MR. KRESS: What's the this? I'm confused.
15
09:47:30
MR. KLAYMAN: The statement by Ms. Ruffley.
16
09:47:33
MR. KRESS: Okay, thank you.
17
09:47:35
THE WITNESS: Well, at the time I read
18
09:47:41
this, I bel- -- you had communicated -- you had sent
19
09:47:43
us something saying -- taking issue with this
20
09:47:46
posting. My concern was primarily with your
21
09:47:51
allegations -- your new allegations against Judicial
22
09:47:54
Watch and Ms. Ruffley.
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09:48:00
BY MR. KLAYMAN:
2
09:48:00
Q And what were those allegations?
3
09:48:02
A I think you were alleging that she had
4
09:48:04
defamed you and that Judicial Watch had defamed you.
5
09:48:08
Q And that she was also interfering with my
6
09:48:10
business, correct?
7
09:48:11
A I don't remember that allegation.
8
09:48:14
Q Well, look at what she said, okay.
9
09:48:18
"Ms. Ruffley actually advised me that Larry Klayman
10
09:48:20
is not licensed in California, she told me that he
11
09:48:23
no longer works with the Judicial Watch and that
12
09:48:26
donors should know about litigation in Ohio, where
13
09:48:29
he was convicted just recently of not paying large
14
09:48:32
amount in child support."
15
09:48:35
So Ms. Ruffley was telling Orly Taitz,
16
09:48:38
based on what is stated here, please tell donors
17
09:48:41
that Larry Klayman's been convicted of a crime,
18
09:48:43
correct?
19
09:48:43
20
09:48:44
THE WITNESS: I don't know what, if
21
09:48:46
anything, Ms. Ruffley said to Ms. Taitz.
22
09:48:50
BY MR. KLAYMAN:
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09:48:51
Q Let's look at what was just written here.
2
09:48:53
A Right.
3
09:48:53
Q Okay. You read that, correct?
4
09:48:55
A Yes. You read it out loud.
5
09:48:56
Q And you saw, that according to Orly Taitz,
6
09:49:00
that Ms. Ruffley was telling her that donors should
7
09:49:05
be informed that Larry Klayman was convicted of a
8
09:49:07
crime. That's what it says, right?
9
09:49:13
A That is what Ms. Taitz wrote in her
10
09:49:16
posting, yes, that's correct. I think that's
11
09:49:17
correct.
12
09:49:17
Q You're aware of the legal ramifications if
13
09:49:20
Ms. Ruffley was wrong of telling donors that Larry
14
09:49:24
Klayman was convicted of a crime; you were aware of
15
09:49:26
that, correct, based on your experience as a lawyer?
16
09:49:38
A I don't know what you mean by the
17
09:49:39
ramifications.
18
09:49:41
Q Are people going to want to contri- --
19
09:49:43
based on your experience, are people going to want
20
09:49:47
to contribute to somebody who's been convicted of a
21
09:49:49
crime?
22
09:49:49
A You know, there can be no such thing --
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09:49:51
sometimes there's no such thing as bad publicity, so
2
09:49:54
I don't know what motivates people to donate.
3
09:49:56
Q You think being convicted of a crime is
4
09:49:59
good publicity?
5
09:50:00
A It probably has worked for some people.
6
09:50:02
Q Who has it worked for?
7
09:50:07
A G. Gordon Liddy.
8
09:50:13
Q What I'm getting at is that you were
9
09:50:15
concerned about what Orly Taitz had written,
10
09:50:19
correct?
11
09:50:19
MR. KRESS: I'm sorry. Did you say were or
12
09:50:22
were not?
13
09:50:22
MR. KLAYMAN: You were.
14
09:50:23
MR. KRESS: Okay.
15
09:50:26
THE WITNESS: I would say the focus of my
16
09:50:28
concern was that you were making yet another
17
09:50:30
allegation against Judicial Watch.
18
09:50:34
BY MR. KLAYMAN:
19
09:50:34
Q How is what Orly Taitz wrote of what Connie
20
09:50:39
Ruffley told her an allegation of mine?
21
09:50:40
A Because you were writing to us complaining
22
09:50:45
about this posting and saying my -- it was --
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09:50:54
it's -- to me it was yet another threat that you
2
09:50:57
were filing -- you were making against Judicial
3
09:51:00
Watch. You've done this repeatedly and consistently
4
09:51:03
since 2003.
5
09:51:06
Q Now, you are aware that Connie Ruffley was
6
09:51:16
at a meeting with Orly Taitz, as reflected in this
7
09:51:19
document, correct?
8
09:51:27
A I'm not -- it's just such a difficult
9
09:51:34
question the way you phrased it.
10
09:51:36
Q Phrase it the way you want to phrase it.
11
09:51:38
She was at the meeting, correct, you've discerned
12
09:51:42
that since you saw this publication?
13
09:51:44
A I was not aware at the time that you sent
14
09:51:46
your complaint that Ms. Ruffley had gone to a
15
09:51:48
meeting in Garden Grove.
16
09:51:49
Q But you became aware of that subsequent?
17
09:51:51
A I became aware of an allegation by you with
18
09:51:57
respect to this posting that Ms. Ruffley had done
19
09:52:00
that, and I believe, in the course of this
20
09:52:04
litigation, Ms. Ruffley had said she went to this
21
09:52:07
meeting.
22
09:52:08
Q And she went there as a representative of
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09:52:10
Judicial Watch, correct?
2
09:52:13
A I don't know that. Like I said, I
3
09:52:17
didn't -- I was not aware that she had gone to the
4
09:52:19
meeting until I heard -- well, until there was this
5
09:52:29
posting, this posting that you were complaining
6
09:52:32
about.
7
09:52:33
Q You have subsequently, after you saw this
8
09:52:36
and I alerted you to it, asked Ms. Ruffley how --
9
09:52:42
what capacity she was at the meeting, correct?
10
09:52:44
A That would be subject to an attorney-client
11
09:52:46
privilege if any such communication took place.
12
09:52:51
MR. KLAYMAN: Off the record.
13
09:52:52
14
09:52:53
15
09:52:58
(Discussion off the record.)
16
09:54:39
17
09:54:41
time is 9:54 a.m.
18
09:54:45
BY MR. KLAYMAN:
19
09:54:45
Q After you reviewed what I had sent of what
20
09:54:53
Ms. Constance Ruffley was claimed to have said by
21
09:54:57
Ms. Taitz, you did learn that she was there as a
22
09:55:01
representative at that meeting of Judicial Watch,
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09:55:04
correct?
2
09:55:09
A No.
3
09:55:10
Q You learned that she purported to go in her
4
09:55:15
capacity as a representative of Judicial Watch?
5
09:55:17
A I don't know that I learned that, and any
6
09:55:19
discussions I had with her about that would be
7
09:55:22
subject to an attorney-client privilege.
8
09:55:27
Q Are you disclaiming that she was there as a
9
09:55:28
representative of Judicial Watch?
10
09:55:31
A I don't know if we've claimed that or not
11
09:55:34
in our litigation.
12
09:55:35
Q I'm asking you. I'm not asking anyone
13
09:55:37
else. What are you claiming? You're the head of
14
09:55:43
the legal department of Judicial Watch.
15
09:55:44
MR. KRESS: If you know.
16
09:55:46
THE WITNESS: I can't answer that question.
17
09:55:47
I don't -- I don't know.
18
09:55:48
BY MR. KLAYMAN:
19
09:55:48
Q You don't know one way or the other?
20
09:55:49
A I don't know what you're asking and I don't
21
09:55:51
know what -- I don't know how to answer it.
22
09:55:55
Q There was a table there at that event where
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09:55:57
she was manning that table with literature about
2
09:56:01
3
09:56:02
A I don't know. I wasn't there.
4
09:56:05
Q But you did discuss this with her; did you
5
09:56:07
not?
6
09:56:08
A I may have discussed it with her, but,
7
09:56:10
again, any discussions I have would be subject to
8
09:56:13
attorney-client privilege.
9
09:56:14
Q You were concerned that statements were
10
09:56:16
being made on behalf of Judicial Watch at that
11
09:56:18
meeting, correct?
12
09:56:23
MR. KRESS: Objection, form.
13
09:56:25
You can answer.
14
09:56:25
BY MR. KLAYMAN:
15
09:56:26
Q You were concerned of the statements that
16
09:56:29
Ms. Taitz said that Constance Ruffley made to her
17
09:56:32
that were made at that meeting and that Ms. Ruffley
18
09:56:38
was an employee of Judicial Watch, correct?
19
09:56:40
20
09:56:41
THE WITNESS: I don't understand your
21
09:56:42
question.
22
09:56:44
BY MR. KLAYMAN:
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09:56:44
Q At the time that -- how long has
2
09:56:49
Ms. Ruffley been with Judicial Watch?
3
09:56:50
A I'm trying to remember that. I think maybe
4
09:56:54
1999, 2000 she started with us.
5
09:56:59
Q And since that time she's been the office
6
09:57:01
administrator of Judicial Watch's West Coast office?
7
09:57:04
A Yes.
8
09:57:05
Q And she's in a managerial position out
9
09:57:07
there; is she not?
10
09:57:08
A No.
11
09:57:09
Q Is there anyone else working with her
12
09:57:11
currently in the San Marino office?
13
09:57:13
A Ernie.
14
09:57:14
Q Ernie Norris?
15
09:57:17
A Mm-hmm.
16
09:57:17
Q Isn't Ernie Norris full time?
17
09:57:19
A No, he's not.
18
09:57:20
Q And at the time that this statement was
19
09:57:21
made to Ms. Taitz, what was Ms. -- Mr. Norris's
20
09:57:25
position with Judicial Watch in the West Coast
21
09:57:28
office?
22
09:57:28
A He's an attorney.
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09:57:30
Q And how much time does he put in per
2
09:57:33
week --
3
09:57:34
A It depends on the time of year.
4
09:57:35
Q -- around that time.
5
09:57:40
A He's semi-retired. He has a cabin in
6
09:57:46
Wyoming and he tends to spend most of his time there
7
09:57:50
between maybe March and September, and from there he
8
09:57:56
works occasionally for Judicial Watch. The other
9
09:58:05
parts of the year, I would say late September, early
10
09:58:08
October through the end of March, he works 3 days a
11
09:58:12
week in the San Marino office.
12
09:58:15
Q In and around February 23rd, 2012, what was
13
09:58:17
he doing for Judicial Watch, if anything?
14
09:58:20
A I don't know what he was doing any
15
09:58:22
particular day, but if it was February in 2012, then
16
09:58:29
my guess is he would be -- he would have been on his
17
09:58:33
3-day-a-week schedule working in the San Marino
18
09:58:36
office.
19
09:58:37
Q Doing what?
20
09:58:37
A Oh, he does a variety of things. He fields
21
09:58:43
phone calls. He works with me on litigation.
22
09:58:49
People contact us with all kinds of problems and
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09:58:52
issues and thoughts and ideas. You know, it
2
09:58:58
depends, the day-to-day operations of an office.
3
09:59:00
Q He's doing legal work, correct?
4
09:59:02
A Yes.
5
09:59:02
Q He's not doing administrative work,
6
09:59:04
correct?
7
09:59:05
A No. Connie provides that support for him.
8
09:59:08
Q He's not managing the office, is he,
9
09:59:12
particularly since he's part time?
10
09:59:13
A No, I wouldn't say he's the manager of the
11
09:59:15
office. He's in charge of the office when he's
12
09:59:18
there.
13
09:59:23
Q You keep telephone records?
14
09:59:25
A Do I?
15
09:59:25
Q Yeah.
16
09:59:26
A No. You mean like telephone logs?
17
09:59:30
Q Judicial Watch?
18
09:59:30
A No.
19
09:59:31
MR. KLAYMAN: Okay. I'm going to
20
09:59:33
request -- given in light of this testimony,
21
09:59:35
telephone records between Ms. Ruffley and
22
09:59:38
Mr. Orfanedes. If I could get straight responses, I
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1
09:59:41
wouldn't need to do that.
2
09:59:42
MR. KRESS: You can make the request.
3
09:59:44
MR. KLAYMAN: Okay.
4
09:59:58
BY MR. KLAYMAN:
5
09:59:58
Q I'm going to show you what I'll ask the
6
10:00:01
court reporter to mark as composite Exhibit -- well,
7
10:00:04
let's go to -- let's go to Exhibit 2 first.
8
10:00:09
MR. KRESS: This is Exhibit 2.
9
10:00:13
MR. KLAYMAN: The one we were just looking
10
10:00:14
at?
11
10:00:14
MR. KRESS: Yes.
12
10:00:15
BY MR. KLAYMAN:
13
10:00:27
Q Showing you Exhibit 1, Exhibit 1 is the
14
10:00:33
subsequent posting on Orly Taitz's web site, World's
15
10:00:41
Leading Obama Eligibility Challenge Web Site,
16
10:00:41
correct?
17
10:00:41
A That's what it appears to be. I'm not
18
10:00:43
familiar with the web site personally.
19
10:00:45
Q And you saw that too, correct?
20
10:00:46
A I believe when we received your
21
10:00:48
communication complaining about the posting, that I
22
10:00:52
saw this subsequent posting. So my recollection is
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1
10:00:58
this had been posted at the time you were
2
10:01:04
complaining to us.
3
10:01:09
Q Did you review -- you reviewed the comments
4
10:01:12
of these postings -- these two postings, correct,
5
10:01:14
Exhibits 1 and 2?
6
10:01:16
A Oh, I don't remember if I reviewed the
7
10:01:18
comments. Are there comments?
8
10:01:19
Q Yes.
9
10:01:22
A Oh, okay. I see there are some comments.
10
10:01:26
Okay. There are comments.
11
10:01:28
Q You reviewed them; did you not?
12
10:01:30
A I don't remember reviewing them.
13
10:01:33
Q You don't know one way or the other?
14
10:01:36
A I don't know that I've reviewed them.
15
10:01:38
Q You may have?
16
10:01:39
A I don't recall if I reviewed them or not,
17
10:01:42
so I'm not going to speculate as to whether I may
18
10:01:45
have.
19
10:01:45
Q Basically your whole approach here, this
20
10:01:47
was not something that really concerned you very
21
10:01:49
much?
22
10:01:49
A It concerned me that you were making yet
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1
10:01:51
another threat against the organization. We would
2
10:01:53
have to figure out how to address it.
3
10:01:55
Q Well, let's see what you claim are threats.
4
10:02:03
I'll show you what I'll ask the court reporter to
5
10:02:04
mark as Exhibit 3, composite Exhibit 3.
6
10:02:21
7
10:02:21
8
10:02:21
9
10:02:21
MR. KRESS: Can I look at that first?
10
10:02:24
THE WITNESS: Sure.
11
10:02:25
BY MR. KLAYMAN:
12
10:02:35
Q Let's turn --
13
10:02:36
MR. KRESS: Wait. I need a second to
14
10:02:38
review this. By the way, I've not seen this before,
15
10:02:40
and this was not produced in discovery.
16
10:02:42
MR. KLAYMAN: I sent it to you.
17
10:02:43
MR. KRESS: I don't think it was --
18
10:02:45
MR. KLAYMAN: I e-mailed it to you.
19
10:02:47
MR. KRESS: I don't think it was included,
20
10:02:48
but nonetheless.
21
10:03:50
BY MR. KLAYMAN:
22
10:03:50
Q Turn to the second-to-last page, please.
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1
10:03:59
Top of the page, an e-mail from Larry Klayman to
2
10:04:06
rdriscoll@driscollseltzer.com. Who is R. Driscoll?
3
10:04:08
A He's a lawyer for Judicial Watch.
4
10:04:10
Q He's the lawyer that's representing
5
10:04:13
Judicial Watch in the other litigation that we have,
6
10:04:15
correct?
7
10:04:15
A One of the other pieces of litigation, yes.
8
10:04:18
I don't know that he's been our lawyer in all of the
9
10:04:20
various lawsuits you've brought against us.
10
10:04:22
Q Okay. How many lawsuits have I brought
11
10:04:26
against you, personally?
12
10:04:28
A Oh. You personally?
13
10:04:33
Q Yeah.
14
10:04:34
A Do you com- do you include bar complaints
15
10:04:36
and lawsuits against our lawyers?
16
10:04:38
Q I'm not here to answer your question. You
17
10:04:41
answer mine.
18
10:04:42
A I'm just trying to understand the scope of
19
10:04:43
your question.
20
10:04:43
Q How long have you been a lawyer,
21
10:04:46
Mr. Orfanedes?
22
10:04:46
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10:04:46
THE WITNESS: I'm just trying to understand
2
10:04:48
the scope of your question.
3
10:04:49
BY MR. KLAYMAN:
4
10:04:49
Q How many have I brought personally against
5
10:04:51
you?
6
10:04:51
A You brought the lawsuit against Judge
7
10:04:53
Kollar- -- you brought the lawsuit pending in front
8
10:04:54
of Judge Kollar-Kotelly. You sued us in Florida, I
9
10:05:00
believe, over something about you didn't like that
10
10:05:04
we referred to you as a former employee. I think
11
10:05:08
you --
12
10:05:08
Q What lawsuit's that?
13
10:05:09
A You know, it's hard to keep track of all
14
10:05:13
the threats and allegations and lawsuits that you've
15
10:05:15
brought against us.
16
10:05:16
Q Since you've claimed that there was one,
17
10:05:18
please cite what lawsuit you're talking about.
18
10:05:20
A I believe it was a false light invasion of
19
10:05:28
privacy case, and it was -- it was stayed for a
20
10:05:30
while and the Florida Supreme Court was considering
21
10:05:33
whether false light is a recognized concept in
22
10:05:35
Florida law. I think it's that one.
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10:05:37
Q What other cases are you talking about?
2
10:05:38
A I believe there was a third lawsuit in
3
10:05:40
Florida, but I don't recall that one specifically.
4
10:05:42
There was a small claims lawsuit that you brought
5
10:05:44
against us here in D.C.
6
10:05:45
Q Stop there.
7
10:05:47
MR. KRESS: So you don't want him to
8
10:05:49
continue?
9
10:05:49
MR. KLAYMAN: No. No. That's fine. I
10
10:05:51
want to ask him about a question about that.
11
10:05:53
BY MR. KLAYMAN:
12
10:05:54
Q That was about getting copies of
13
10:05:57
drawings -- of Cortland drawings?
14
10:05:59
A Yeah. We had hearings in small claims
15
10:06:00
court, mediation and all that stuff.
16
10:06:00
Q Severance agreement said that you had to
17
10:06:02
let me make copies, didn't it?
18
10:06:06
A No, it didn't.
19
10:06:06
Q Go on.
20
10:06:08
A You represented Louise Benson in a lawsuit
21
10:06:12
against us. You encouraged her to file --
22
10:06:16
Q Let's --
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1
10:06:17
A You encouraged her to file it and then you
2
10:06:17
represented her. You encouraged Peter Paul to file
3
10:06:20
a lawsuit against us, and then you represented him
4
10:06:22
in that. You brought a lawsuit against our lawyer
5
10:06:25
David Barmak in the context of your lawsuit against
6
10:06:28
us here in D.C. in front of Judge Kollar-Kotelly.
7
10:06:33
You actually sued Judge Kollar-Kotelly. I think
8
10:06:37
you've been instrumental in having bar complaints
9
10:06:39
filed against me in Maryland, D.C. You've had bar
10
10:06:45
complaints filed against Rich Driscoll. I don't
11
10:06:49
know.
12
10:06:49
Q As a result of all of that, you hate my
13
10:06:52
guts, correct?
14
10:06:53
15
10:06:54
THE WITNESS: I -- no, I don't hate your
16
10:06:57
guts, Larry. I don't hate anyone.
17
10:06:59
BY MR. KLAYMAN:
18
10:06:59
Q Okay. You are -- you dislike me?
19
10:07:02
20
10:07:02
THE WITNESS: I think you're a very
21
10:07:04
troubled soul, Larry.
22
10:07:05
BY MR. KLAYMAN:
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1
10:07:06
Q Okay. When I left Judicial Watch, did you
2
10:07:10
not authorize Barmak to send a letter that I could
3
10:07:14
not even refer to myself as founder of Judicial
4
10:07:17
Watch?
5
10:07:17
A I don't remember that.
6
10:07:18
Q You don't remember that?
7
10:07:19
A No.
8
10:07:19
Q That that was trademark violation?
9
10:07:26
A I don't remember having Barmak send you a
10
10:07:31
letter about that, but there's an issue there.
11
10:07:33
Q To say I was founder is an issue?
12
10:07:35
A To repeatedly make use of the name
13
10:07:39
"Judicial Watch" in a way that causes confusion
14
10:07:43
among supporters and in the media raises a question
15
10:07:47
about trademark issue.
16
10:07:50
Q In fact, people -- some people are still
17
10:07:53
communicating with Judicial Watch thinking that I'm
18
10:07:55
still there, correct?
19
10:08:01
A I think some people are confused, yes.
20
10:08:04
Q So for that very reason, you were concerned
21
10:08:06
about what Connie Ruffley said about Larry Klayman,
22
10:08:09
correct, because people still think I'm associated
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10:08:14
with Judicial Watch?
2
10:08:15
A I don't know what people think. I mean,
3
10:08:17
it's --
4
10:08:18
Q I asked you what you think. You're
5
10:08:19
concerned?
6
10:08:21
A I am concerned that your being indicted for
7
10:08:28
failure to pay child support could reflect
8
10:08:32
negatively on Judicial Watch.
9
10:08:34
Q And you would be concerned if someone said,
10
10:08:37
even worse, that I was convicted of that, correct?
11
10:08:42
12
10:08:43
THE WITNESS: I don't know that the concern
13
10:08:44
would be any greater or any less.
14
10:08:46
BY MR. KLAYMAN:
15
10:08:46
Q There's a difference between indictment and
16
10:08:48
conviction; is there not?
17
10:08:49
A There is.
18
10:08:50
Q You know what the difference is, correct?
19
10:08:51
A I know what the difference is.
20
10:08:53
Q What's the difference?
21
10:08:54
A An indictment is an allegation. A
22
10:08:56
conviction is a conviction, a final adjudication.
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Q And in this country you're innocent until
2
10:09:01
proven guilty?
3
10:09:02
A In the criminal context.
4
10:09:04
Q Yes. Okay. So indictment doesn't mean
5
10:09:07
you're guilty of a crime?
6
10:09:08
A An indictment, you know, can be -- you can
7
10:09:13
have indictments -- you can indict someone in a
8
10:09:16
court of public opinion. Indictment can be a loose
9
10:09:20
phrase. It doesn't always have the technical
10
10:09:22
meaning that you seem to be imputing to it here.
11
10:09:26
Q Well, you just told me that you were aware
12
10:09:29
that I was indicted in the criminal justice system,
13
10:09:32
not in the court of public opinion, correct; you
14
10:09:35
were aware of that?
15
10:09:36
A I thought your question was about the word
16
10:09:38
"indictment" in general, and I was responding to
17
10:09:40
that.
18
10:09:40
Q No. I was asking you the question in the
19
10:09:43
context of being indicted in a criminal context as
20
10:09:45
opposed to being convicted in the criminal context.
21
10:09:48
There's a difference, correct?
22
10:09:50
A You sort of -- now I'm lost as to where we
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10:09:54
are with all this back and forth.
2
10:09:54
Q You don't know the difference between being
3
10:09:58
indicted in a criminal court as opposed to being
4
10:10:00
convicted in a criminal court?
5
10:10:02
A Yes, I know what --
6
10:10:03
Q What's the difference?
7
10:10:04
A An indictment is an allegation. A
8
10:10:06
conviction is a final adjudication.
9
10:10:08
Q And for an indictment, you're innocent
10
10:10:11
until proven guilty, correct?
11
10:10:12
A In the criminal context, yes.
12
10:10:15
Q So if someone makes a statement as a
13
10:10:17
Judicial Watch employee, office administrator, that
14
10:10:21
a former head of Judicial Watch was convicted, that
15
10:10:24
has a serious affect, potential serious affect on
16
10:10:29
Judicial Watch if people still think he's there,
17
10:10:31
correct?
18
10:10:31
19
10:10:32
You can answer.
20
10:10:33
THE WITNESS: I don't understand the
21
10:10:33
question and --
22
10:10:36
BY MR. KLAYMAN:
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10:10:36
Q Well, you just testified that there --
2
10:10:38
A No, Larry, I'm not --
3
10:10:39
Q -- there is confusion --
4
10:10:41
A I'm not going to play these word games with
5
10:10:43
you. If you have an articulable intelligible
6
10:10:48
question --
7
10:10:48
Q Well, let's break it down.
8
10:10:49
A -- ask that and I'll be happy to answer it.
9
10:10:52
Q Let's break it down. You just testified
10
10:10:54
that there's confusion some people think --
11
10:10:55
supporters think and others that I'm still at
12
10:10:57
13
10:10:58
A I believe some people are confused about
14
10:11:00
that.
15
10:11:00
Q So, therefore, if a statement's being made
16
10:11:02
in a web site which goes all over the country and
17
10:11:05
internationally that Larry Klayman was convicted of
18
10:11:08
a crime, that reflects negatively on Judicial Watch;
19
10:11:11
does it not?
20
10:11:13
21
10:11:15
You can answer.
22
10:11:15
THE WITNESS: There were multiple things in
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1
10:11:17
that, and I don't understand your question, so I
2
10:11:19
can't answer it.
3
10:11:20
BY MR. KLAYMAN:
4
10:11:20
Q Well, do your best. You don't want to
5
10:11:24
answer?
6
10:11:24
A I don't understand your question, Larry.
7
10:11:27
It was compound. It had multiple, inconsistent --
8
10:11:30
Q No, I broke it down. Go ahead finish.
9
10:11:34
A No. It had multiple --
10
10:11:34
Q Let me try again.
11
10:11:36
A -- inconsistent clauses and I don't
12
10:11:37
understand it.
13
10:11:38
Q I'm going to sit here until you understand
14
10:11:42
it. Okay, first question: There are people who
15
10:11:43
still believe -- there are people in -- out there
16
10:11:45
who follow the activities of Judicial Watch, the
17
10:11:49
supporters and others, that Larry Klayman is still
18
10:11:51
with Judicial Watch; there's confusion to that,
19
10:11:54
correct?
20
10:11:56
A Judicial Watch is in the news. You
21
10:12:02
sometimes say that you -- you make -- actually not
22
10:12:04
sometimes. You frequently make use of the words
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1
10:12:07
"founder of Judicial Watch." I don't know if people
2
10:12:10
who contact us who are confused or who might think
3
10:12:15
you are with Judicial Watch are supporters of the
4
10:12:16
organization. I don't know what their thought
5
10:12:18
process is.
6
10:12:19
Q You've talked to some of them, haven't you?
7
10:12:21
A Generally, no. I don't speak to many.
8
10:12:26
Q But you have talked to some of them?
9
10:12:29
A This is an indefinite question. I don't --
10
10:12:32
I don't -- I talked -- there's lots of people in the
11
10:12:39
world. You asked me if I talk to some of them.
12
10:12:42
It's a nonsensical question.
13
10:12:44
Q Have you or haven't you?
14
10:12:46
A I don't know your question at this point.
15
10:12:48
Q Have you talked to some people who have
16
10:12:51
called in or written in that said, Larry Klayman's
17
10:12:55
still with Judicial Watch or asked if Larry
18
10:12:57
Klayman's still with Judicial Watch?
19
10:13:00
A I don't recall talking to anyone about
20
10:13:04
that, no, in years.
21
10:13:05
Q You are aware that Mr. Fitton has had those
22
10:13:07
discussions with individuals, correct?
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1
10:13:10
A No, I'm not aware.
2
10:13:12
Q You're aware Mr. Farrell's had those
3
10:13:14
discussions, correct?
4
10:13:15
A No, I'm not aware that they have those --
5
10:13:18
they have had them and I don't -- I don't know that
6
10:13:20
they have.
7
10:13:24
MR. KLAYMAN: We'll be requesting
8
10:13:25
documentation to this effect. If I can get a
9
10:13:27
straight answer, I don't have to do it.
10
10:13:29
MR. KRESS: I think -- I think those are
11
10:13:31
very straight answers. You asked him if he knows if
12
10:13:34
people have asked Fitton and Farrell those questions
13
10:13:38
and he said he doesn't know.
14
10:13:39
MR. KLAYMAN: I'm asking about him too and
15
10:13:41
he doesn't know that either, so he claims, but then
16
10:13:45
he said he has conversations but he has no
17
10:13:49
recollection.
18
10:13:50
BY MR. KLAYMAN:
19
10:13:50
Q I don't understand what you're saying,
20
10:13:51
Mr. Orfanedes. You want to straighten it out?
21
10:13:53
A I don't understand your questions,
22
10:13:54
Mr. Klayman. So if you could ask an intelligible
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1
10:13:58
question I'll be happy to answer it.
2
10:13:59
Q Let's try it again. People have called
3
10:14:02
into Judicial Watch or written into Judicial Watch
4
10:14:04
and asked if Larry Klayman is still there, correct?
5
10:14:06
MR. KRESS: Objection, asked and answered.
6
10:14:08
You can answer.
7
10:14:09
THE WITNESS: Yes -- well, I don't know. I
8
10:14:12
don't know how to characterize -- I have seen people
9
10:14:17
inquire of us. I don't know what their thinking is.
10
10:14:24
I don't know if they think you're still here or if
11
10:14:27
they think you are part of Judicial Watch, meaning I
12
10:14:31
don't know if someone who knew you were with
13
10:14:33
Judicial Watch and left is now contacting us or if
14
10:14:38
someone who wasn't aware of Judicial Watch or you
15
10:14:42
learned of Judicial Watch or you and contacted us
16
10:14:46
then.
17
10:14:46
BY MR. KLAYMAN:
18
10:14:47
Q There have been people that have contacted
19
10:14:48
Judicial Watch asking for me, correct, in the 10
20
10:14:52
years since I've been gone?
21
10:14:53
A Yes.
22
10:14:55
Q Okay. And what did you tell them?
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1
10:15:01
A I believe that Judicial Watch says that you
2
10:15:03
are no longer with the organization.
3
10:15:04
Q Okay. Now, with regard to -- let's go back
4
10:15:16
to this letter, top of the second page at the end.
5
10:15:21
I'm writing to Mr. Driscoll. Rich, I am being
6
10:15:25
defamed by an employee and agent of Judicial Watch,
7
10:15:28
Connie Ruffley. Please call me to discuss. Thank
8
10:15:31
you, Larry.
9
10:15:33
Now, that's not a threat, is it?
10
10:15:35
A I think it is.
11
10:15:36
Q The fact that I'm being defamed is a
12
10:15:39
threat?
13
10:15:39
A It's in all caps, it's in bold. I mean,
14
10:15:39
you used the word "defamed" which is a legal word,
15
10:15:42
and you also have to take it in the context of the
16
10:15:44
history of the allegations that you've made against
17
10:15:46
the organization repeatedly over the last 10 years.
18
10:15:49
Q Let's go further.
19
10:15:50
A Yes, I think it is a threat.
20
10:15:52
Q Does defamation occur?
21
10:15:54
A Does it occur?
22
10:15:55
Q Yeah, does it occur in our society?
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1
10:15:57
A Sure. There's a cause of action for
2
10:16:00
defamation.
3
10:16:00
Q Right. And is there not -- if in fact
4
10:16:08
Ms. Ruffley had defamed me, wouldn't you want to
5
10:16:10
correct it?
6
10:16:15
A Oh, Larry, that's a hypothetical question.
7
10:16:17
I'm not prepared to get into that. I don't --
8
10:16:20
Ms. Ruffley didn't defame you so --
9
10:16:22
Q Say I was convicted of a crime is not
10
10:16:25
defamation?
11
10:16:26
A Ms. Ruffley didn't -- I don't know what
12
10:16:28
Ms. Ruffley said, if anything.
13
10:16:30
Q But if he she had that, wouldn't that be --
14
10:16:32
A I'm not getting into these hypotheticals
15
10:16:35
with you.
16
10:16:35
MR. KRESS: I'm going to object to the
17
10:16:36
form.
18
10:16:36
BY MR. KLAYMAN:
19
10:16:37
Q Let's go to the next one. Richard Driscoll
20
10:16:39
to Larry Klayman. I attempted to contact you but it
21
10:16:42
went unanswered and the message box was full. Will
22
10:16:45
you be in witness interview for remainder of the
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1
10:16:47
day, Richard W. Driscoll.
2
10:16:50
Have you ever seen these e-mails before?
3
10:16:53
Mr. Driscoll forwarded them to you, didn't he?
4
10:16:56
A You know, I had thought you contacted us,
5
10:16:59
but maybe you contacted Rich directly. I don't
6
10:17:01
remember. I had thought you contacted us, but maybe
7
10:17:04
I'm wrong. I'm sure I became aware of this at some
8
10:17:08
point, this allegation, so he must have contacted
9
10:17:10
us.
10
10:17:11
Q Let's go to the next one.
11
10:17:13
A Or you contacted us directly.
12
10:17:15
Q My response to Mr. Driscoll on February
13
10:17:18
23rd at 11:03 a.m. Let's talk after. In the
14
10:17:21
meantime, thanks for advising Judicial Watch and
15
10:17:24
Ruffley what I informed you about. I will explain
16
10:17:27
more when we talk. It's over the Obama citizenship
17
10:17:32
issue and Ruffley is out making false statements
18
10:17:35
about me and my personal life, et cetera. I have a
19
10:17:35
record of what was said and done. Best, Larry
20
10:17:38
Klayman.
21
10:17:38
Does that sound provocative, best, Larry
22
10:17:41
Klayman?
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1
10:17:41
A "Ruffley is out making false statements
2
10:17:44
about me and my personal life," yes, that sounds
3
10:17:48
provocative, especially coming from you, someone who
4
10:17:50
has sued the organization repeatedly and been
5
10:17:52
instrumental in bringing multiple lawsuits against
6
10:17:55
the organization.
7
10:17:55
Q Well, you just -- you reviewed what Taitz
8
10:17:56
had written that Connie said, correct?
9
10:17:58
A Yes.
10
10:17:58
Q I didn't write that, correct?
11
10:18:00
A Yes, you did not write it.
12
10:18:01
Q Right. That was someone else?
13
10:18:03
A I assume so. I assume Taitz wrote it. I
14
10:18:05
don't know Taitz and I haven't spoken with her.
15
10:18:07
Q I didn't manufacture that document; you're
16
10:18:09
aware of that. Okay.
17
10:18:13
And then this is Richard Driscoll coming
18
10:18:18
back to me: I have no information regarding your
19
10:18:20
assertions and concede nothing. Rich Driscoll,
20
10:18:24
right?
21
10:18:24
A Yes.
22
10:18:25
Q Next page, I contact Driscoll --
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1
10:18:33
MR. KRESS: I think you're on different
2
10:18:34
pages.
3
10:18:35
BY MR. KLAYMAN:
4
10:18:36
Q No, back of it. It's in reverse. Okay.
5
10:18:44
Larry Klayman to Rich Driscoll, "Tied up now. Call
6
10:18:56
later."
7
10:18:57
A Oh, that's -- okay. I don't know. I'm
8
10:19:01
sort of confused as to how these e-mail chains are
9
10:19:03
to be read.
10
10:19:04
Q Look at the last page. It got a little bit
11
10:19:11
out of order.
12
10:19:12
A Yeah, Rich's call -- tied up now. Call
13
10:19:15
later was from the next day.
14
10:19:17
Q Right.
15
10:19:19
A Okay.
16
10:19:19
Q Look at the last page, okay. They're all
17
10:19:22
in sequence in terms of time so even if the page is
18
10:19:27
out. This is from me to Rich Driscoll. "Didn't
19
10:19:29
expect you as their counsel to concede anything.
20
10:19:32
But if you want to learn what is at issue call me.
21
10:19:35
Hopefully, matters can be resolved appropriately
22
10:19:38
without further harm. Best, Larry."
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10:19:40
Do you see that?
2
10:19:41
A Uh-huh.
3
10:19:42
Q You saw this e-mail at the time I wrote it
4
10:19:44
to your counsel, didn't you?
5
10:19:46
A I don't remember -- I don't remember it
6
10:19:47
specifically. The issue came to my attention
7
10:19:49
somehow. I had thought that you had e-mailed us,
8
10:19:51
but this now makes me think that perhaps you
9
10:19:54
e-mailed our lawyer directly.
10
10:19:55
Q Let's just talk about what was said. I'm
11
10:19:58
asking, am I not, to resolve things appropriately.
12
10:20:01
There's no threat of suit there, is there?
13
10:20:03
A I think when you call up someone's lawyer
14
10:20:06
and you send an e-mail to someone's lawyer and you
15
10:20:07
say, I'm being defamed and false statements are
16
10:20:09
being made against me, there's a threat there.
17
10:20:12
Q You're trying to rectify the situation; are
18
10:20:15
you not?
19
10:20:15
A You asked me if I thought this was a threat
20
10:20:17
at some point. I said I think it's a threat, and I
21
10:20:19
continue to think it's a threat.
22
10:20:21
Q Well, let's read the e-mail of February 24,
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Merrill LAD
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1
10:20:23
2012, from Larry Klayman, myself, to Rich. "Is
2
10:20:31
there a time today when you are free to speak?"
3
10:20:33
A Mm-hmm.
4
10:20:33
Q Have you communicated with your clients,
5
10:20:36
Judicial Watch, Fitton, et al.? This matter is
6
10:20:39
serious and much damage has been done through Connie
7
10:20:43
Ruffley, Fitton, and others, individually on behalf
8
10:20:46
of Judicial Watch. And, this is not the only recent
9
10:20:48
instance where I have been defamed and held in a
10
10:20:51
false light in the last few months. I will explain
11
10:20:53
when we talk. The French have an expression; the
12
10:20:55
more things change, the more they remain the same.
13
10:20:55
While the french government just removed
14
10:20:59
the word "mademoiselle" from government documents,
15
10:21:02
this French proverb still applies -- I'm trying to
16
10:21:05
be funny -- particularly when it comes to Fitton and
17
10:21:08
company. Let me know. Rather than just filing
18
10:21:09
suit, I'm attempting to discuss having your clients
19
10:21:11
mitigate the damage and to try to resolve matters if
20
10:21:14
we can.
21
10:21:15
You see that, "sincerely, Larry Klayman"?
22
10:21:17
A Yes, I see it.
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Merrill LAD
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1
10:21:18
Q Taken on face value, I'm asking to resolve
2
10:21:21
it to mitigate it, that I don't want to file suit,
3
10:21:25
correct?
4
10:21:25
A You're threatening us.
5
10:21:26
Q How is that a threat?
6
10:21:27
A You're making allegations against us and
7
10:21:29
you're apparently demanding compensation. I think
8
10:21:31
that's a threat.
9
10:21:32
Q Where is there a demand for compensation?
10
10:21:34
A You're talking about rather than filing a
11
10:21:36
lawsuit, and you're talking about -- where do you
12
10:21:38
say --
13
10:21:42
Q Tell me where there's demand for
14
10:21:44
compensation.
15
10:21:45
A Much damage. The matter is serious and
16
10:21:47
much damage has been done. I mean, when lawyers
17
10:21:49
talk to each other, they're usually talking about
18
10:21:51
money in that regard.
19
10:21:52
Q When you make an allegation of someone's
20
10:21:56
convicted of a crime, based on your experience,
21
10:21:59
that's libel per se is it not?
22
10:22:03
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1
10:22:04
THE WITNESS: I object to your form -- the
2
10:22:05
form and your characterization. I don't know. No
3
10:22:07
one has accused you of being -- Ms. Ruffley has not
4
10:22:11
alleged that you were convicted of anything. You
5
10:22:13
have alleged that Ms. Ruffley said that to
6
10:22:15
Ms. Taitz.
7
10:22:19
BY MR. KLAYMAN:
8
10:22:19
Q So you did have a conversation with
9
10:22:22
Ms. Ruffley?
10
10:22:22
A No.
11
10:22:23
Q So how do you know she didn't say that?
12
10:22:30
MR. KRESS: If it calls for attorney-client
13
10:22:32
privilege, you can't answer it.
14
10:22:34
MR. KLAYMAN: You can't have it both ways,
15
10:22:36
Doug, okay. If it's attorney-client privilege, he
16
10:22:40
just waived it.
17
10:22:41
THE WITNESS: I don't --
18
10:22:41
MR. KRESS: No, he didn't.
19
10:22:42
THE WITNESS: I don't recall having any --
20
10:22:42
I don't specifically recall having any discussions
21
10:22:45
with Ms. Ruffley about this. I may have discussed
22
10:22:47
it with her. You are making an allegation that she
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10:22:49
said certain things. You wrote threatening e-mails
2
10:22:52
to our lawyer. I perceive them as threats. If you
3
10:22:54
want to characterize them in some other way, that's
4
10:22:57
your prerogative.
5
10:22:58
Given the history between you and Judicial
6
10:23:02
Watch and all the various lawsuits and allegations
7
10:23:04
and threats and demands and claims and accusations
8
10:23:08
you've made against Judicial Watch over the years, I
9
10:23:10
considered this another threat.
10
10:23:12
BY MR. KLAYMAN:
11
10:23:13
Q Well, is it a threat when Judicial Watch
12
10:23:16
had a $15,000 contribution from Louise Benson when I
13
10:23:21
was with Judicial Watch to build a building and then
14
10:23:23
never built a building and you had to give back her
15
10:23:27
money? Was that a threat?
16
10:23:29
17
10:23:30
THE WITNESS: I don't understand what
18
10:23:31
you're talking about, Larry.
19
10:23:32
BY MR. KLAYMAN:
20
10:23:33
Q Remember that we raised money -- we were
21
10:23:35
raising money shortly before I left to buy the
22
10:23:37
building that we were in at 501 School Street,
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10:23:40
correct?
2
10:23:40
A I remember there was an -- there was a
3
10:23:41
building campaign. I remember there was a
4
10:23:43
contribution by Ms. Benson. I remember there were
5
10:23:46
false allegations you made on behalf of Ms. Benson
6
10:23:49
about her contribution and that we returned the
7
10:23:52
contribution.
8
10:23:54
Q If they were false, why'd you return the
9
10:23:56
contribution?
10
10:23:56
A To make it go away.
11
10:23:58
Q Because you were concerned about it?
12
10:24:00
A No, I was not concerned about it.
13
10:24:02
Q You were concerned about taking her money
14
10:24:04
under false pretenses, correct?
15
10:24:06
A I was concerned about more of the
16
10:24:07
organization's scarce time and resources being
17
10:24:11
wasted on your frivolous allegations, Larry.
18
10:24:13
Q Has Judicial Watch ever bought a building?
19
10:24:15
A No, Judicial Watch has not bought a
20
10:24:17
building, and we're not here to litigate that matter
21
10:24:20
that's pending in front of Judge Kollar-Kotelly.
22
10:24:24
Q I'm raising it in the state of Illinois.
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10:24:28
A Past litigation that has already -- that
2
10:24:29
has already been finaled.
3
10:24:30
Q What I'm saying is you were concerned about
4
10:24:32
that allegation, that you'd taken money under false
5
10:24:35
pretenses, and therefore you gave Louise Benson her
6
10:24:38
money back.
7
10:24:39
8
10:24:39
THE WITNESS: No, I don't believe so at
9
10:24:41
all. I believe at the time we had decided to
10
10:24:43
make -- give the money back the -- the lawsuit in
11
10:24:44
which Ms. Benson had -- made you on behalf of
12
10:24:48
Ms. Benson had made the allegations had been over.
13
10:24:51
I think it was dismissed or dropped. I don't -- I
14
10:24:53
don't remember all the circumstances of it right
15
10:24:56
now, but I think that litigation had concluded.
16
10:24:59
BY MR. KLAYMAN:
17
10:25:00
Q That's inaccurate but fine. Give me your
18
10:25:02
testimony. It's inaccurate. The --
19
10:25:05
A I could be wrong. I don't remember, but --
20
10:25:06
Q Well, you are wrong.
21
10:25:08
MR. KRESS: Objection to the --
22
10:25:09
THE WITNESS: My recollection is that it
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was concluded.
2
10:25:11
BY MR. KLAYMAN:
3
10:25:11
Q So the use of the word "mitigate damage,"
4
10:25:14
is it not true that someone if they commit an act
5
10:25:16
which is tortious has a duty to mitigate; you're
6
10:25:21
aware of that as a lawyer?
7
10:25:22
8
10:25:23
THE WITNESS: No. I think the mitigation
9
10:25:25
applies to the person bringing the claim.
10
10:25:28
BY MR. KLAYMAN:
11
10:25:28
Q Well, if I'm asking you to correct a false
12
10:25:31
statement, I am attempting to mitigate; am I not?
13
10:25:34
A I don't know what -- I think you're -- I
14
10:25:36
interpreted these e-mails as being yet more threats
15
10:25:38
from you, yet more distractions caused by your
16
10:25:43
baseless threats.
17
10:25:44
Q About 15 minutes ago you couldn't remember
18
10:25:46
whether you saw the e-mails. Now you're saying you
19
10:25:50
interpreted them to be threats. Which is it?
20
10:25:51
A Well, you just showed them to me.
21
10:25:54
Q No. You're -- you just testified, "I
22
10:25:56
interpreted." That's past tense, correct? Record
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10:26:02
will speak for itself.
2
10:26:04
A During the course of our discussion here,
3
10:26:05
you asked -- I've read these and I characterized
4
10:26:10
them as being a threat.
5
10:26:11
Q All right. Let's go to the next one.
6
10:26:18
A Which is the next? Are we going forward or
7
10:26:20
backward?
8
10:26:21
Q Forward.
9
10:26:24
A Okay.
10
10:26:25
Q "Richard" -- well, let me -- let's go to
11
10:26:29
the very first page. Letter of March 5th, 2012 to
12
10:26:36
Larry Klayman by e-mail and first class mail.
13
10:26:41
Putative claim for defamation, et cetera. "Dear
14
10:26:45
Mr. Klayman: This firm represents Judicial Watch
15
10:26:47
relating to the above-referenced matter. Through a
16
10:26:50
series of e-mails and again during our conversation
17
10:26:52
on Tuesday, February 28, 2012, you advanced vague
18
10:26:55
and unsupported allegations that Judicial Watch, its
19
10:26:58
President Tom Fitton and an employee are
20
10:27:01
participants in a conspiracy to defame and disparage
21
10:27:04
you based on the recent indictment handed down in
22
10:27:05
Ohio. To date, you have produced no evidence to
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10:27:07
support these truly outrageous allegations.
2
10:27:10
As I stated to you during our conversation,
3
10:27:12
Judicial Watch did not authorize, make, or
4
10:27:14
participate in the making of any statements
5
10:27:16
regarding your indictment for criminal non-support.
6
10:27:18
For this reason, it's not necessary for Judicial
7
10:27:20
Watch to take any action to clarify or correct the
8
10:27:23
statements of others. Sincerely, Driscoll &
9
10:27:28
Seltzer, PLLC, Richard W. Driscoll." Copy to Paul
10
10:27:34
Orfanedes?
11
10:27:35
Now, you saw this letter at the time
12
10:27:36
Driscoll sent it, correct?
13
10:27:38
A Probably.
14
10:27:38
Q And you approved this letter by Driscoll,
15
10:27:40
correct?
16
10:27:40
A I don't remember that.
17
10:27:41
Q So you would have a lawyer send a letter on
18
10:27:43
behalf of Judicial Watch and yourself that you
19
10:27:45
didn't review and approve?
20
10:27:47
A Oh, it depends. I've worked with Rich for
21
10:27:50
quite a while so I trust him. I don't know that I
22
10:27:52
approved it.
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Q Did you ever tell him that what he wrote
2
10:27:55
was incorrect?
3
10:27:56
A No, I did not, and I don't believe it is.
4
10:28:02
Q So the position of Judicial Watch is that
5
10:28:06
it had no obligation to correct or clarify or do
6
10:28:10
anything with regard to what Connie Ruffley told
7
10:28:13
Orly Taitz?
8
10:28:14
9
10:28:15
THE WITNESS: You keep getting back to this
10
10:28:17
what Connie Ruffley told Orly Taitz, and I don't
11
10:28:20
know what Connie Ruffley told Orly Taitz and it's
12
10:28:21
not been established what Connie Ruffley told Orly
13
10:28:25
Taitz. So I object to the way you're trying to put
14
10:28:27
words into my mouth. I don't think this -- I think
15
10:28:31
this letter speaks for itself. It says, Judicial
16
10:28:33
Watch did not authorize, make or participate in
17
10:28:36
making of any statements, and therefore it's not
18
10:28:38
necessary for Judicial Watch to take any action.
19
10:28:40
BY MR. KLAYMAN:
20
10:28:40
Q So you're in fact disassociating yourself
21
10:28:44
from Constance Ruffley?
22
10:28:47
A No, not at all.
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10:28:53
Q If you're -- you're disassociating yourself
2
10:28:55
from what Constance Ruffley said to Orly Taitz,
3
10:28:59
yourself meaning Judicial Watch?
4
10:29:01
A Larry, I think the issue in your lawsuit,
5
10:29:03
if I can characterize your -- your allegations, is
6
10:29:06
you're making an allegation about what Connie told
7
10:29:10
Orly. I don't know what Connie told Orly. I wasn't
8
10:29:15
there.
9
10:29:15
Q Are you saying that in fact I should go
10
10:29:18
back and make a motion with the court that we should
11
10:29:22
reinstitute Connie as a defendant, Connie Ruffley?
12
10:29:25
13
10:29:26
BY MR. KLAYMAN:
14
10:29:26
Q Is that what you're saying?
15
10:29:28
A No, I don't --
16
10:29:28
Q That she's responsible for this, not you or
17
10:29:32
Judicial Watch or any of the other directors; are
18
10:29:34
you saying that?
19
10:29:36
20
10:29:37
THE WITNESS: That's not my testimony.
21
10:29:39
BY MR. KLAYMAN:
22
10:29:39
Q You're holding Connie Ruffley out to dry?
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1
10:29:41
2
10:29:42
THE WITNESS: My -- my testimony was I
3
10:29:43
don't know what, if anything, Connie said.
4
10:29:46
BY MR. KLAYMAN:
5
10:29:47
Q But if she said what she said --
6
10:29:48
A I'm not talking -- I'm not getting into
7
10:29:51
hypotheticals about what somebody might have done if
8
10:29:53
they did it. That's not the purpose of discovery.
9
10:29:55
Q Well, you want it both ways, don't you?
10
10:29:56
A No.
11
10:29:57
Q You want it, we had nothing to do with what
12
10:30:00
Connie Ruffley said, but then again since we don't
13
10:30:02
know what she said, you don't have an action against
14
10:30:04
Connie Ruffley either. That's your position, isn't
15
10:30:06
it?
16
10:30:07
A No.
17
10:30:07
18
10:30:08
BY MR. KLAYMAN:
19
10:30:08
Q Are you taking responsibility for -- is
20
10:30:09
Judicial Watch taking responsibility for what Connie
21
10:30:10
Ruffley said, whatever she said?
22
10:30:14
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10:30:18
THE WITNESS: I don't -- I don't know how
2
10:30:19
to answer that.
3
10:30:20
BY MR. KLAYMAN:
4
10:30:20
Q You are aware that Ms. Ruffley submitted an
5
10:30:22
affidavit in this case where she said she doesn't
6
10:30:24
remember what she said?
7
10:30:24
8
10:30:27
THE WITNESS: I'm not sure that's -- her
9
10:30:29
affidavit says what it says.
10
10:30:31
BY MR. KLAYMAN:
11
10:30:32
Q The affidavit doesn't disclaim that she had
12
10:30:34
a conversation with Orly Taitz, does it?
13
10:30:36
A I don't believe it does.
14
10:30:39
Q And it doesn't disclaim that she had a
15
10:30:41
conversation about me, Larry Klayman, with Orly
16
10:30:44
Taitz?
17
10:30:44
A I don't know. I'd have to review it.
18
10:30:45
Q You reviewed that affidavit before it was
19
10:30:48
submitted to the Court, did you not?
20
10:30:48
A Yes.
21
10:30:48
Q You are the chief legal officer of Judicial
22
10:30:50
Watch?
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10:30:50
A Yes.
2
10:30:51
Q And you were at the time that this
3
10:30:52
statement was allegedly made, correct, about Larry
4
10:30:54
Klayman to Orly Taitz?
5
10:30:56
A Yes.
6
10:30:57
Q Okay. And that's why Mr. Driscoll's
7
10:31:01
communicating with you because it's your
8
10:31:03
responsibility at Judicial Watch to review legal
9
10:31:05
matters and to recommend action?
10
10:31:06
A I believe Mr. Driscoll was communicating
11
10:31:09
with you.
12
10:31:10
Q Well, he's copying you.
13
10:31:11
A Oh, okay. Is that what you're referring
14
10:31:13
to?
15
10:31:14
Q Yes.
16
10:31:14
A I wasn't sure.
17
10:31:15
Q This falls on your shoulders, you're the
18
10:31:17
chief legal officer, correct?
19
10:31:18
A He's informing me, he's sending me a copy
20
10:31:21
of his communication to you.
21
10:31:24
Q Just to make it crystal clear, you approved
22
10:31:27
what he said in this letter of March 5, 2012?
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10:31:30
A I don't remember if I approved it. I read
2
10:31:31
it and I think it's completely accurate.
3
10:31:35
Q So you washed your -- you washed your hands
4
10:31:36
of anything that may have been said about me to Orly
5
10:31:39
Taitz and being convicted of a crime --
6
10:31:41
7
10:31:42
You can answer.
8
10:31:42
BY MR. KLAYMAN:
9
10:31:42
Q -- you meaning Judicial Watch and Paul
10
10:31:46
Orfanedes?
11
10:31:46
A I don't understand your -- I don't
12
10:31:48
understand your question.
13
10:31:48
Q You didn't really care what, if anything,
14
10:31:51
Connie Ruffley said to Orly Taitz about Larry
15
10:31:54
Klayman?
16
10:31:54
A I read the posting and I didn't think it
17
10:31:57
was defamatory.
18
10:31:59
Q In the course of -- how many years have you
19
10:32:01
been a lawyer?
20
10:32:03
A You've asked me this several times today.
21
10:32:05
Q Well, I'm just trying lay the foundation.
22
10:32:08
A Do the math, Larry. I said 1990.
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1
10:32:11
Q So you've been a lawyer for 24 years?
2
10:32:13
A Yeah.
3
10:32:14
Q In the course of being a lawyer, you've
4
10:32:17
worked on cases involving defamation and First
5
10:32:20
Amendment rights?
6
10:32:21
A I have.
7
10:32:21
Q And you're aware of the law?
8
10:32:23
A Yep.
9
10:32:24
Q Okay. And you don't think -- you are aware
10
10:32:26
of the law of libel per se?
11
10:32:30
A Not all of it.
12
10:32:31
Q You are aware that libel per se is when you
13
10:32:35
accuse someone in a misleading or false way of being
14
10:32:39
convicted of a crime?
15
10:32:40
A I wouldn't agree with your definition, and
16
10:32:43
I don't think that's complete.
17
10:32:44
Q What's the definition?
18
10:32:45
A I'm not prepared to recite it right now.
19
10:32:48
Q I want to know what your state of mind was
20
10:32:51
when you approved Driscoll's letter.
21
10:32:53
A I think that's irrelevant.
22
10:32:56
Q I want to know what your experience was
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1
10:32:57
when you approved Driscoll's letter.
2
10:33:01
A I've been working -- I've been a lawyer for
3
10:33:02
24 years. At the time Rich wrote this letter I said
4
10:33:05
I didn't recall approving it.
5
10:33:06
Q Subsequent to him writing the letter and
6
10:33:08
sending it to me, you told him to correct it?
7
10:33:11
A No. I think it's exactly right. I think
8
10:33:13
it's a completely accurate letter.
9
10:33:15
Q Have you asked Connie Ruffley if she made
10
10:33:19
this statement?
11
10:33:19
A That would be subject to attorney-client
12
10:33:21
privilege.
13
10:33:21
Q No, not if you --
14
10:33:25
THE WITNESS: No, I'm not --
15
10:33:25
MR. KRESS: It depends on --
16
10:33:26
BY MR. KLAYMAN:
17
10:33:27
Q Have you asked her whether she made the
18
10:33:28
statement?
19
10:33:28
MR. KRESS: I'm going -- I'm going to
20
10:33:29
object, and it also depends if it's after the
21
10:33:32
lawsuit or if it's after -- well, really if it's
22
10:33:36
after -- at any point I think it is attorney-client
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1
10:33:39
privilege if you're asking him about the substance
2
10:33:40
of the communication.
3
10:33:41
THE WITNESS: That's correct.
4
10:33:41
MR. KLAYMAN: I'm not asking about the
5
10:33:42
substance. I said, did you ask her she made this
6
10:33:47
communication to --
7
10:33:47
THE WITNESS: I think that's a substance
8
10:33:49
question.
9
10:33:49
BY MR. KLAYMAN:
10
10:33:49
Q Did you have a -- you felt that -- did you
11
10:33:50
feel you had an obligation to ask her that question
12
10:33:53
when I wrote -- when I raised this issue with
13
10:33:57
Richard Driscoll?
14
10:33:58
15
10:33:59
THE WITNESS: I don't understand that.
16
10:33:59
BY MR. KLAYMAN:
17
10:33:59
Q Did you, as the chief legal officer of
18
10:34:01
Judicial Watch and Judicial Watch itself, have an
19
10:34:04
obligation to do due diligence to see whether or not
20
10:34:06
Connie Ruffley had made that statement to Orly
21
10:34:08
Taitz?
22
10:34:08
MR. KRESS: I'm also going to object here.
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1
10:34:10
I -- I believe if you're asking him how he -- his
2
10:34:13
state of mind in responding to what he has perceived
3
10:34:15
as a threat, I think that could -- that's work
4
10:34:18
product, so I don't think he can answer that.
5
10:34:21
MR. KLAYMAN: No, that's an issue as to
6
10:34:23
whether or not there is a -- whether in his mind
7
10:34:26
there was a legal obligation to make that inquiry
8
10:34:29
and whether in Judicial Watch's venue there was an
9
10:34:35
obligation to make that inquiry, not what was said,
10
10:34:40
whether there was an obligation to do it, based on
11
10:34:42
his experience as a lawyer.
12
10:34:44
MR. KRESS: I think that's work product.
13
10:34:46
THE WITNESS: I also think -- I'm not here
14
10:34:49
as an expert. I'm here as a fact witness and you're
15
10:34:51
asking about --
16
10:34:52
BY MR. KLAYMAN:
17
10:34:52
Q I'm not asking you as an expert. I'm
18
10:34:54
asking you based on your experience.
19
10:34:57
A And I'm not answering it either way.
20
10:34:58
Q I'm asking for your opinion. I'm asking
21
10:35:00
you what you thought.
22
10:35:01
A I don't understand your question.
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1
10:35:01
Q I'm asking what you thought.
2
10:35:02
A It's vague. I'm confused.
3
10:35:03
Q Let me ask it again. Someone -- if you
4
10:35:06
perceive that someone such as me is threatening
5
10:35:11
litigation if an alleged defamatory statement is not
6
10:35:16
corrected, in the ordinary course as the chief legal
7
10:35:19
officer of Judicial Watch, did you not have an
8
10:35:21
obligation to make an inquiry to see whether or not
9
10:35:24
this alleged statement was made?
10
10:35:26
MR. KRESS: I'm going to object. I think
11
10:35:30
you're getting into -- into work product, what his
12
10:35:33
duties are in responding to litigation.
13
10:35:38
MR. KLAYMAN: Are you instructing him not
14
10:35:40
to answer?
15
10:35:40
MR. KRESS: I believe I am. I mean, are
16
10:35:43
you asking him -- especially when you're --
17
10:35:45
especially if you're asking him with respect to the
18
10:35:48
facts of this case, in particular your claim. I
19
10:35:51
suppose it might be different if you're asking him
20
10:35:53
in general if he has to -- he responds to
21
10:35:58
litigation, but I think when you get into the facts
22
10:36:01
of this case, you're getting into his legal thought
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process as counsel for -- for Judicial Watch, and I
2
10:36:08
think that's classic work product privilege.
3
10:36:13
BY MR. KLAYMAN:
4
10:36:13
Q Judicial Watch is an organization which
5
10:36:16
prides itself on ethics, correct?
6
10:36:18
A Yeah.
7
10:36:18
Q It always has, correct?
8
10:36:20
A Mm-hmm.
9
10:36:21
Q It was founded to be an ethical watchdog,
10
10:36:25
correct?
11
10:36:29
A I don't really know what your thinking was.
12
10:36:31
I thought the idea was to watch the judiciary when
13
10:36:36
the original idea of forming an organization called
14
10:36:42
Judicial Watch. I thought that was the first idea.
15
10:36:43
Things morphed over time. At some point we began to
16
10:36:47
focus more on ethics.
17
10:36:49
Q Okay. Well, if someone makes a statement
18
10:36:52
that is not true that someone is convicted of a
19
10:36:57
crime, would it not be the ethical thing to do, if
20
10:37:01
that statement was made by a Judicial Watch
21
10:37:02
employee, to make an inquiry to correct it, see
22
10:37:06
whether it should be corrected?
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A This is a hypothetical question. It's too
2
10:37:11
many variables. I don't understand at all.
3
10:37:11
Q Take -- take Larry Klayman --
4
10:37:13
A I can't answer that.
5
10:37:14
Q Take Larry Klayman out of the equation. If
6
10:37:17
someone's making a false allegation about someone
7
10:37:18
and they're an employee of Judicial Watch, is there
8
10:37:20
not an obligation to see whether or not that
9
10:37:22
happened to correct it?
10
10:37:23
A I don't know. I'm not -- I'm here as a
11
10:37:24
fact witness. If you'd ask me some questions I can
12
10:37:27
answer about your allegations in this lawsuit, I'm
13
10:37:29
happy to. I don't know what you're doing now. I
14
10:37:33
don't know what you've done throughout this
15
10:37:34
deposition. Please ask me some intelligible
16
10:37:39
questions. I'll try to answer them to the best of
17
10:37:42
my ability.
18
10:37:43
Q Mr. Orfanedes, you've appeared as counsel
19
10:37:45
in front of the Supreme Court; have you not?
20
10:37:47
A Yes, I have.
21
10:37:48
Q You're a highly intelligent person; are you
22
10:37:50
not?
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A That's debatable.
2
10:37:52
Q You were with me for almost 10 years,
3
10:37:54
correct?
4
10:37:54
A More than that.
5
10:37:55
Q More than that, 14 years?
6
10:37:58
A 11.
7
10:37:59
Q 11, okay. Good. During the time that you
8
10:38:12
and I worked together, did I ever make a false
9
10:38:16
allegation about you?
10
10:38:16
A I think you did.
11
10:38:17
Q What was that? What was that?
12
10:38:20
A I don't know, but you did something. I
13
10:38:22
remember something. I don't remember the whole
14
10:38:23
context of it.
15
10:38:24
Q Was it in the context of Mr. Fitton?
16
10:38:32
A Oh, yeah, I mean was that before or after?
17
10:38:36
You used to -- you used to allege that we were
18
10:38:38
lovers. No. I don't remember when that was, and
19
10:38:41
we're not and never have been.
20
10:38:42
Q That created animus towards me; did it not?
21
10:38:48
A It was ridiculous, but that doesn't really
22
10:38:51
create animus. I mean, it's what you do, Larry.
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Some people find that endearing.
2
10:38:53
Q Did I ever make that allegation while I was
3
10:38:55
at Judicial Watch?
4
10:38:56
A I don't remember.
5
10:38:56
Q Okay.
6
10:38:57
A I think --
7
10:38:58
Q Did I ever say that to you?
8
10:39:00
A I think it was in that period of time
9
10:39:02
when -- while we were nego- -- trying to negotiate
10
10:39:04
your severance and figure out, there was -- there
11
10:39:07
was what happened in May and we dispute what
12
10:39:09
happened in May, and then the negotiations --
13
10:39:12
Q Well, up to that point. Up to that point,
14
10:39:14
did I ever say anything negative about you?
15
10:39:17
A Oh, sure. I mean, I'm sure you did. I
16
10:39:19
don't know.
17
10:39:19
Q What do you know that I ever said negative
18
10:39:23
about you?
19
10:39:23
A We worked together for years. I mean, it's
20
10:39:24
just back and forth between two people, 11 years, of
21
10:39:30
course you did.
22
10:39:30
Q I might have criticized your work from time
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to time.
2
10:39:32
A Yeah, that's a negative, sure.
3
10:39:34
Q Right. In a positive way, correct?
4
10:39:36
A It wasn't always positive but, you know,
5
10:39:38
when you work together with somebody for 11 years
6
10:39:41
there's ups and downs.
7
10:39:42
Q Okay. So if I'd done something really
8
10:39:44
terrible, you would have left, right?
9
10:39:46
A Yeah.
10
10:39:47
Q Okay. Judicial Watch deals with a lot of
11
10:40:03
lawsuits, correct; that's one of the things it does,
12
10:40:08
it files lawsuits?
13
10:40:08
A Mm-hmm.
14
10:40:09
Q And Connie Ruffley, you are aware that she
15
10:40:13
is knowledgeable about issues in the law, correct,
16
10:40:16
because of her work at Judicial Watch?
17
10:40:20
A She has a limited understanding. She's not
18
10:40:22
a lawyer, so she doesn't have all the -- she doesn't
19
10:40:26
have a complete understanding. Most lawyers don't
20
10:40:28
have a complete understanding, but --
21
10:40:30
Q She's worked with you and Ernie Norris and
22
10:40:33
others at Judicial Watch on legal matters?
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A She provides admin support, yeah. She'll
2
10:40:44
file things at the courthouse. She'll put together
3
10:40:47
pleadings and copy pleadings and things like that,
4
10:40:50
but I mean, in terms of the substance of the legal
5
10:40:51
work, no. She doesn't -- she doesn't do that.
6
10:40:54
Q Has she ever discussed Orly Taitz with you?
7
10:40:58
MR. KRESS: And I'll just -- if it's
8
10:41:01
anything related to this lawsuit, I think that's
9
10:41:03
attorney-client privilege but --
10
10:41:04
MR. KLAYMAN: Discussing is not, Doug, and
11
10:41:06
you know that, okay? I'm not getting into the
12
10:41:08
substance. Did she ever discuss Orly Taitz with
13
10:41:13
you?
14
10:41:13
MR. KRESS: If it's -- well, I'll let him
15
10:41:16
answer but I think -- I still think if you're
16
10:41:18
talking about the issues in this lawsuit with a
17
10:41:21
lawyer then that's attorney-client privilege.
18
10:41:21
BY MR. KLAYMAN:
19
10:41:23
Q I'm not asking for the substance, not yet.
20
10:41:25
I'm just asking did you ever discuss Orly Taitz with
21
10:41:29
Connie Ruffley?
22
10:41:29
A See, now I would say that's a substantive
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question.
2
10:41:35
MR. KRESS: I think that's a substantive
3
10:41:37
question too.
4
10:41:37
THE WITNESS: I cannot wear my lawyer hat
5
10:41:38
here, but to answer it, before this, you know,
6
10:41:39
however you want to call it -- I call it a threat
7
10:41:41
that you sent to our lawyer, before that arose, I
8
10:41:44
don't recall ever having discussed Orly Taitz with
9
10:41:47
her. I'm not even sure when I became aware of Orly
10
10:41:50
Taitz.
11
10:41:51
BY MR. KLAYMAN:
12
10:41:51
Q What do you know about Orly Taitz today?
13
10:41:54
A She's a lawyer and a dentist and she's
14
10:41:58
somewhere in -- is it Rancho Santa Margarita? And
15
10:42:02
she does a lot of these birther lawsuits -- or she
16
10:42:05
did in the past. I don't -- I don't know what she's
17
10:42:08
done over the last couple of years.
18
10:42:18
Q You are aware that I brought eligibility --
19
10:42:21
lawsuits challenging President Obama's eligibility
20
10:42:26
in Florida, correct?
21
10:42:33
A I think I became aware of that in the
22
10:42:34
course of this lawsuit.
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Q And what do you know about it?
2
10:42:38
A I thought I saw, from reviewing your
3
10:42:42
answers to interrogatories the other day, that there
4
10:42:44
were three and that they've been dismissed, but
5
10:42:47
that's my vague understanding.
6
10:42:54
Q You are aware that Orly Taitz, one of her
7
10:42:59
primary areas of interest, is filing lawsuits
8
10:43:01
concerning the eligibility of President Obama?
9
10:43:04
A I know she used to do that. I don't know
10
10:43:06
what she's doing currently. I don't know that she's
11
10:43:09
practicing law currently.
12
10:43:18
Q During the time that I was at Judicial
13
10:43:20
Watch, we worked on a case together, did we not,
14
10:43:23
where we sued Fidel Castro over the shoot down of --
15
10:43:28
A Yes. Did we sue him personally or did we
16
10:43:31
sue Cuba?
17
10:43:31
Q Well, we sued --
18
10:43:33
A I don't remember. There was an issue
19
10:43:35
involving Cuba and Brothers to the Rescue.
20
10:43:38
Q Tell us a little bit about that lawsuit
21
10:43:40
situation.
22
10:43:41
A I don't remember. That was something that
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Ed Forez (phonetic) worked on primarily I think, but
2
10:43:47
we represented Jos Basulto, founder of Brothers to
3
10:43:52
the Rescue and I don't remember who we sued as
4
10:43:54
defendants, but it was Cuban government officials
5
10:43:57
and/or the Cuban government. There were also some
6
10:44:01
other lawsuits against Cuba, though.
7
10:44:04
Q Which ones were they?
8
10:44:05
A There were some family --
9
10:44:05
Q Let's back up.
10
10:44:07
A -- members of prisoners --
11
10:44:08
Q Let's back up before we do that. Let's
12
10:44:10
back up before that. We did at Judicial Watch
13
10:44:11
obtain a $1.8 million verdict against Cuba, correct?
14
10:44:16
A Right. That Brothers to the Rescue
15
10:44:18
lawsuit, whoever the defendants were, we got a
16
10:44:20
default judgment. It was -- I don't remember the
17
10:44:23
exact amount. It was something over a million
18
10:44:25
dollars.
19
10:44:27
Q And it was for the shoot down of Jos
20
10:44:31
Basulto's brothers by Castro's Air Force, correct?
21
10:44:34
A Well, it was from that whole incident
22
10:44:36
involving the Cuban Air Force chasing the Brothers
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to the Rescue. Jos Basulto was chased and fired
2
10:44:44
at, I believe. He wasn't shot down, his comrades
3
10:44:49
were shot down and I think they were killed during
4
10:44:52
that incident.
5
10:44:52
Q And our victory in that case obviously was
6
10:44:55
popular in the Cuban community, correct?
7
10:44:56
A I don't know. I know Jos Basulto was very
8
10:45:01
grateful for our work.
9
10:45:02
Q And it was very popular in the Miami
10
10:45:05
community --
11
10:45:05
A I don't --
12
10:45:05
Q -- which is largely Cuban, correct?
13
10:45:07
A I don't know.
14
10:45:08
Q You're not aware of the Cuban population of
15
10:45:10
Miami?
16
10:45:11
A I'm aware it's changing over time. I know
17
10:45:14
that Cuba -- or I know that whole south Florida area
18
10:45:18
has a mix of all sorts of people from all kinds of
19
10:45:20
different areas.
20
10:45:21
Q You're aware that while I was at Judicial
21
10:45:22
Watch, shortly before I left, that we took a -- that
22
10:45:25
I took a trip to Europe with victims of Castro?
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A Yes, I remember your --
2
10:45:32
Q And we appeared in front of the French
3
10:45:35
parliament and the Italian parliament?
4
10:45:37
A I think that's right.
5
10:45:38
Q We lobbied to get the Europeans to take
6
10:45:42
stronger actions against Castro for persecuting
7
10:45:45
dissidents and reporters?
8
10:45:46
A I think that's right. I wasn't along, but
9
10:45:48
I did.
10
10:45:48
Q And that was very popular in the Cuban
11
10:45:51
community too; was it not?
12
10:45:52
A I don't know.
13
10:45:53
Q You're aware that shortly after 9/11 I took
14
10:45:56
a trip with other victims of Castro to Belgium to
15
10:45:59
file a criminal complaint against Castro there in
16
10:46:03
its court system?
17
10:46:04
A I kind of remember that. I don't --
18
10:46:06
Q And that was popular in the Miami community
19
10:46:09
too; was it not?
20
10:46:10
A I don't know.
21
10:46:11
Q You are aware that after I left Judicial
22
10:46:17
Watch, I brought a lawsuit on behalf of a victim of
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10:46:23
Hugo Chavez of Venezuela in Miami?
2
10:46:27
A After you left Judicial Watch?
3
10:46:28
Q Yes.
4
10:46:30
A I don't remember that. I thought -- I
5
10:46:32
thought there was something 9/11 related that
6
10:46:36
Judicial Watch filed involving Venezuela. I
7
10:46:41
don't -- I don't remember the details of it.
8
10:46:50
Q And you are aware that during the time I
9
10:46:52
was at Judicial Watch that we intervened and
10
10:46:58
participated in the case Gore v. Bush over the 2000
11
10:47:03
elections in Florida?
12
10:47:08
A Oh, I know we did lots of public records
13
10:47:11
requests, and we had some litigation pending in
14
10:47:12
different county Circuit Courts in Florida trying to
15
10:47:16
get access to the ballots, and I remember that you
16
10:47:18
went up and you watched the proceedings in
17
10:47:21
Tallahassee.
18
10:47:23
Q You are aware that the judge allowed me to
19
10:47:25
participate in the public interest on behalf of
20
10:47:28
Judicial Watch?
21
10:47:28
A I don't remember what capacity. I know you
22
10:47:32
were there. I don't know what, if anything, the
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judge said.
2
10:47:34
Q That's a very famous case, isn't it, Gore
3
10:47:38
v. Bush, decided a Presidential election?
4
10:47:40
A I guess. I remember the judge telling you
5
10:47:42
to sit down once because you were on -- you would
6
10:47:45
always -- you'd always walk in front of the camera
7
10:47:47
so you could be wherever the camera would be. You
8
10:47:53
would be in front of the camera, and the judge told
9
10:47:55
you to sit down --
10
10:47:56
Q You're aware we invited that judge and gave
11
10:47:58
him an award after the event?
12
10:47:59
A Yes, that's right.
13
10:47:59
Q We went on a cruise --
14
10:48:02
A I don't remember.
15
10:48:02
Q -- when we no longer had litigation with
16
10:48:05
him?
17
10:48:05
A I don't remember that. I remember the
18
10:48:07
award, but I don't remember the cruise.
19
10:48:08
Q You're aware that I became friends with
20
10:48:10
that judge?
21
10:48:10
A No, I'm not aware of that.
22
10:48:11
Q You don't remember that we took him and his
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wife on a cruise?
2
10:48:14
A No. I remember the award. I don't
3
10:48:16
remember the cruise.
4
10:48:18
Q You remember the hearing that we had with
5
10:48:20
that judge, Judge Sanders Sauls where I asked him to
6
10:48:24
intervene and he said, Mr. Klayman I don't know of
7
10:48:27
any right to intervene, but I'll grant you a right
8
10:48:30
to hang around. Remember that?
9
10:48:31
A Oh, I remember -- I remember that language.
10
10:48:33
I don't -- you know, I don't remember the event, but
11
10:48:35
I recall the you have a right to hang around, and I
12
10:48:39
don't know where that -- I guess -- if you say it
13
10:48:41
came from Judge Sauls then that's fine.
14
10:48:44
Q And you're aware that he allowed me to
15
10:48:46
speak during that trial?
16
10:48:48
A No, I don't remember that he allowed you to
17
10:48:49
speak. Like I said, my recollection of the trial
18
10:48:52
was you always -- you wanted to be wherever the
19
10:48:54
camera was, so you would move around, and at one
20
10:48:56
point he said sit down Mr. Klayman, or something to
21
10:48:58
that effect.
22
10:48:58
Q Were you aware that I couldn't move around.
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I was sitting in the jury box, right?
2
10:49:02
A I don't remember. I wasn't there.
3
10:49:03
Q You're aware that the C-SPAN camera was
4
10:49:06
faced at the jury box, correct?
5
10:49:08
A I don't remember. I just remember that one
6
10:49:11
saying.
7
10:49:11
Q Okay. All right. You're aware that
8
10:49:22
Judicial Watch and I also represented the family of
9
10:49:24
Elian Gonzalez during that time period?
10
10:49:28
A Judicial Watch did, yes. I did too.
11
10:49:31
Q That was a very -- also a very famous
12
10:49:33
matter, particularly in Miami?
13
10:49:35
A Some people would say infamous.
14
10:49:37
Q What was infamous about it?
15
10:49:40
A A lot of people didn't like what the family
16
10:49:42
was trying to do.
17
10:49:42
Q You didn't like what the family was trying
18
10:49:45
to do?
19
10:49:45
A I said I a lot of people didn't.
20
10:49:47
Q How about you?
21
10:49:48
A I supported what the family was doing. I
22
10:49:50
worked very hard for the family.
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Q Conservative community liked what we were
2
10:49:54
doing; did it not?
3
10:49:55
A I don't know. I don't remember. And the
4
10:49:57
conservative community is a broad thing. I --
5
10:49:57
Q You don't know what conservative is?
6
10:50:00
A -- can't speak for the conservative
7
10:50:02
community. I think it's a lot of different people
8
10:50:02
with a lot of different views.
9
10:50:02
Q People who are upset at Bill Clinton for
10
10:50:06
sending Elian back to Cuba?
11
10:50:08
A I remember people upset -- people being
12
10:50:10
upset with Janet Reno. I don't remember them being
13
10:50:13
upset with Bill Clinton.
14
10:50:15
Q Janet Reno worked for Bill Clinton, did she
15
10:50:19
not, she was his attorney general?
16
10:50:20
A Yes, she did. Yes, she did.
17
10:50:22
Q You remember a lawyer named Gregory Craig?
18
10:50:25
A I do.
19
10:50:25
Q And he was counsel for the National Council
20
10:50:30
of Churches, correct, at the time?
21
10:50:31
A I don't remember who he -- he was
22
10:50:39
representing the father in some capacity. I don't
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know who he -- I thought he was Elian Gonzalez's
2
10:50:44
father's lawyer.
3
10:50:44
Q And he played a role in having Elian sent
4
10:50:48
back to Cuba, did he not? You're aware of that?
5
10:50:50
A He represented the father in whatever court
6
10:50:54
proceedings were going on, so --
7
10:50:54
Q The father wanted the child back in Cuba,
8
10:50:56
correct?
9
10:50:56
A Yes.
10
10:50:57
Q Gregory Craig later became Clinton's
11
10:51:01
impeachment lawyer, correct, remember that -- in the
12
10:51:03
White House?
13
10:51:03
A I think that's correct.
14
10:51:03
Q And you're aware Gregory Craig was a
15
10:51:06
classmate of Hillary Clinton at Yale -- Yale Law
16
10:51:10
School?
17
10:51:10
A No, I'm not aware. I don't know anything
18
10:51:12
about where he went to law school or who he went to
19
10:51:14
law school with.
20
10:51:15
Q You're aware after I left Judicial Watch I
21
10:51:17
brought a lawsuit against a mosque in Fort
22
10:51:21
Lauderdale?
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A No, I'm not aware of that.
2
10:51:22
Q Not aware of that? Okay. You're aware
3
10:51:23
that I ran for the U.S. Senate in Florida?
4
10:51:25
A Yes.
5
10:51:42
Q Now, Judicial Watch has authored a book
6
10:51:45
which came out a year or so ago called Corruption
7
10:51:50
Chronicles. You remember that?
8
10:51:50
A Mm-hmm.
9
10:51:51
Q Okay. And there's not one mention of my
10
10:51:52
name in that book, is there?
11
10:51:57
A I don't know. I don't -- I think you --
12
10:51:58
you wrote to us complaining about that so I don't
13
10:52:01
know. I didn't check.
14
10:52:01
Q Do you remember seeing my name in the book?
15
10:52:04
A Well, you know, you -- you tend to threaten
16
10:52:07
us when we mention your name and you threaten us
17
10:52:09
when we don't mention your name, so we're kind of --
18
10:52:12
it's a catch-22.
19
10:52:13
Q You're aware that you and Fitton and
20
10:52:19
Farrell -- Farrell took total credit for what went
21
10:52:21
on at Judicial Watch when I was there, correct?
22
10:52:22
MR. KRESS: I'm going to object to the form
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10:52:24
and to the relevancy of this book.
2
10:52:27
THE WITNESS: I don't -- I don't think
3
10:52:28
that's a fair characterization, but I do get back to
4
10:52:30
my law- -- the lawsuit where you sued us because we
5
10:52:34
referred to you as a former employee. So, you know,
6
10:52:37
I don't know what we're supposed to do with you.
7
10:52:39
You sue us if we refer to you. You threaten to sue
8
10:52:44
us if we don't refer to you. It's just --
9
10:52:46
BY MR. KLAYMAN:
10
10:52:46
Q I take issue with the characterization.
11
10:52:49
A It's not all about you. It --
12
10:52:49
Q Let's talk about --
13
10:52:51
A -- doesn't matter.
14
10:52:51
Q Let's talk about that, Mr. Orfanedes. All
15
10:52:52
of a sudden you have a memory, right?
16
10:52:53
A I'm sorry?
17
10:52:55
Q You have a memory now, correct? Now that
18
10:52:57
we're past the issue of my alleged defamation for
19
10:53:00
being convicted of a crime, now all of a sudden you
20
10:53:04
have a memory of what I did, correct?
21
10:53:06
MR. KRESS: Object -- Objection to the
22
10:53:07
form.
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THE WITNESS: I don't understand what
2
10:53:07
you're talking about.
3
10:53:08
BY MR. KLAYMAN:
4
10:53:08
Q Well, before you had no specific
5
10:53:09
recollection of things?
6
10:53:10
A Oh, you were -- when you were asking me
7
10:53:12
specific questions about certain things involving
8
10:53:14
this, I did not -- I do not have specific -- some
9
10:53:17
specific recollections.
10
10:53:18
Q The issue of this lawsuit, you have no
11
10:53:20
specific recollection?
12
10:53:21
13
10:53:22
THE WITNESS: What do you mean? I'm here.
14
10:53:24
I recall. I'm here. I know there's a lawsuit
15
10:53:26
pending.
16
10:53:26
BY MR. KLAYMAN:
17
10:53:27
Q You know you're sitting here so you have
18
10:53:28
recollection that you're sitting here right now?
19
10:53:30
A I know you sued us in 2013 and we've been
20
10:53:33
litigating it ever since, and I know you've given us
21
10:53:35
nothing in terms of discovery and I know you've
22
10:53:38
waited till the last minute before you want to take
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10:53:40
any depositions.
2
10:53:42
Q So you remember all that?
3
10:53:43
A Yeah.
4
10:53:45
Q But otherwise you don't remember anything?
5
10:53:47
6
10:53:51
BY MR. KLAYMAN:
7
10:53:51
Q You don't remember what went on with
8
10:53:54
Ruffley, you don't remember what went on with
9
10:53:56
Driscoll, you don't remember anything else, but now
10
10:53:59
you remember everything else, correct?
11
10:54:00
12
10:54:02
THE WITNESS: No, that's not correct. My
13
10:54:05
testimony is what it has been. When you've asked me
14
10:54:07
specific questions I've tried to answer you. If I
15
10:54:09
didn't recall, I didn't recall. If I had a general
16
10:54:11
recollection, I told you.
17
10:54:22
BY MR. KLAYMAN:
18
10:54:22
Q Do you have a laptop computer?
19
10:54:24
A I have a one at home, yes.
20
10:54:26
Q Do you use that sometimes for Judicial
21
10:54:28
Watch matters?
22
10:54:29
A No.
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10:54:31
Q What kind of computer did you have in and
2
10:54:33
around February 23rd, 2012? Is it the same one you
3
10:54:38
have now?
4
10:54:39
A No. The one I have now is relatively new.
5
10:54:43
Q When did you get this new computer?
6
10:54:45
A A couple months ago, I think.
7
10:54:47
Q What kind is it?
8
10:54:48
A I don't know.
9
10:54:49
Q You don't know what brand it is?
10
10:54:51
A No. I don't pay that much attention to
11
10:54:53
that stuff.
12
10:54:58
Q It's sitting in front of you on your desk,
13
10:55:00
isn't it?
14
10:55:00
A It's a black box. It's -- actually it's
15
10:55:03
sitting on the floor. You know, one black box --
16
10:55:06
Q What kind of monitor do you have?
17
10:55:08
A It's rectangular. I don't know.
18
10:55:10
Q Does it say Apple? Does it say Dell?
19
10:55:14
A No. If it doesn't --
20
10:55:14
Q Does it say Acer?
21
10:55:18
A I don't know.
22
10:55:19
Q You have no idea? You work long hours,
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10:55:22
don't you?
2
10:55:22
A I do.
3
10:55:24
Q And you're staring at that computer all the
4
10:55:27
time, right?
5
10:55:27
A I have nice speakers. I bought myself, but
6
10:55:33
I don't remember what brand though of the monitor I
7
10:55:34
have.
8
10:55:34
Q What kind of laptop do you have? What's
9
10:55:38
the brand?
10
10:55:39
A I think it's a Toshiba.
11
10:55:41
Q How old is it?
12
10:55:42
A Couple years.
13
10:55:44
Q What happened -- when you changed your desk
14
10:55:47
computer, where is the old one?
15
10:55:49
A I don't know. Our computer guy swapped it
16
10:55:51
out at night.
17
10:55:52
Q Who's the computer guy?
18
10:55:53
A His name is Carlos.
19
10:55:54
Q Carlos what?
20
10:55:56
A It starts with a B. I don't remember.
21
10:56:03
Q Did he swap Fitton's out at the same time?
22
10:56:06
A I don't believe so. I don't know.
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10:56:07
Q Farrell's?
2
10:56:09
A I don't know. I don't think so. I think,
3
10:56:16
oh, we have a whole process involving computers and
4
10:56:18
periodic, you know, reviews. I was having some
5
10:56:20
trouble loading some, you know, programs on mine.
6
10:56:22
They looked at it. They determined it was sort of
7
10:56:25
old and slow and that they would bring in another
8
10:56:27
one, and they did.
9
10:56:36
10
10:56:38
11
10:56:39
12
10:56:47
(Recess.)
13
11:07:35
THE VIDEOGRAPHER: Back on the record.
14
11:07:39
Here marks the beginning of Volume 1, Tape No. 2 in
15
11:07:41
the deposition of Paul Orfanedes. The time is 11:07
16
11:07:45
a.m.
17
11:07:48
BY MR. KLAYMAN:
18
11:07:49
Q In and around February 23rd, 2012, what
19
11:07:51
kind of cell phone did you have?
20
11:07:56
A I've got one of these things. I don't know
21
11:08:00
if I had it back then (indicating). It's a black
22
11:08:04
box, not very technical.
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11:08:06
Q Who makes it?
2
11:08:07
A It says Sprint on it. I don't know who
3
11:08:10
makes it.
4
11:08:10
Q So you were using -- Judicial Watch was
5
11:08:12
using Sprint at that time?
6
11:08:15
A I know I was, I guess. I don't -- I don't
7
11:08:18
remember when I got this.
8
11:08:19
Q And you said --
9
11:08:20
A I probably had this in 2012.
10
11:08:22
Q You send e-mails and texts off that phone,
11
11:08:25
correct?
12
11:08:27
A I'm not very -- I'm not -- I don't really
13
11:08:30
text very much.
14
11:08:31
Q You send e-mails off that phone?
15
11:08:36
A Not usually.
16
11:08:37
Q But sometimes?
17
11:08:39
A You know, I'm pretty bad with those
18
11:08:41
screens. I tend to use -- you know those little
19
11:08:44
screens, I tend to use my computer but it's linked
20
11:08:47
up to the computer anyway.
21
11:08:48
Q Are you saying -- are you saying you've
22
11:08:49
never sent an e-mail with Sprint service?
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11:08:51
A I might have. I don't -- I'm not very good
2
11:08:55
at that. I hate those little screens, so I try to
3
11:08:59
communicate -- in e-mail I use my Outlook on my
4
11:09:02
computer instead, and I'm usually at my desk, so it
5
11:09:04
makes more sense to do that anyway.
6
11:09:06
Q Your computer in and around February 23rd
7
11:09:09
of 2012 had Outlook?
8
11:09:11
A Yeah, I think -- I think so.
9
11:09:13
Q So you have a backup system for e-mails?
10
11:09:23
Outlook has backup system to retain e-mails, does it
11
11:09:25
not?
12
11:09:26
A I don't know anything about that stuff.
13
11:09:27
Q You said you don't keep e-mails; is that
14
11:09:30
correct?
15
11:09:30
A Yes, I generally don't keep them.
16
11:09:32
Q But you have -- they would be kept on
17
11:09:34
Outlook, correct?
18
11:09:35
A No. If -- if something is significant, I
19
11:09:38
will tend to print it out and put it in the -- you
20
11:09:40
know, the relevant correspondence file. I don't
21
11:09:48
generally save e-mails for anything past, you know,
22
11:09:50
a month or 2 months unless, like I've just talked
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11:09:54
about, I've printed it and put it in a
2
11:09:57
correspondence file. That's always been my practice
3
11:10:00
because I hate having all that stuff floating around
4
11:10:03
in an e-mail account.
5
11:10:04
Q Have you deleted from Outlook since
6
11:10:06
February 23rd, 2012?
7
11:10:08
A Oh, probably. I mean, that's my regular
8
11:10:10
practice is not to keep stuff in my --
9
11:10:14
Q So you deleted both from -- from the hard
10
11:10:16
drive and from Outlook?
11
11:10:18
A I don't know about the hard -- I don't know
12
11:10:20
what you mean by the hard drive. I don't know how
13
11:10:22
all that stuff works. All I know is I use -- I
14
11:10:26
guess it's Outlook. I get e-mail. If something is
15
11:10:29
significant, case related, I'll print it out, a lot
16
11:10:33
of the stuff otherwise I just delete without
17
11:10:35
printing out.
18
11:10:36
Q I'm going to ask you not to delete further
19
11:10:38
until we approach the court on getting access to
20
11:10:40
your computer and having looked at by a computer
21
11:10:46
expert your computers. You're on notice.
22
11:10:49
A Okay. I mean, just those are more Larry
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11:10:52
Klayman threats.
2
11:10:52
Q Not threats. I'm just asking you not to do
3
11:10:55
it so you don't have a misunderstanding.
4
11:10:58
A When you tell someone you're on notice,
5
11:10:59
that's not a threat?
6
11:11:00
Q Yeah. That's called a notice.
7
11:11:03
A It's kind of like the please govern
8
11:11:05
yourselves accordingly letter that you sent with
9
11:11:12
Rich. It's just a notice. Okay.
10
11:11:12
Q You've never seen other lawyers use please
11
11:11:16
govern yourself accordingly?
12
11:11:18
A Very few. It's usually you, and it usually
13
11:11:22
makes me chuckle because it's so Larry.
14
11:11:25
Q Could be worse, right?
15
11:11:39
The -- you made reference to a lawsuit that
16
11:11:41
I brought on behalf of Peter Paul, correct?
17
11:11:43
A Yes.
18
11:11:44
Q In fact, I didn't bring that lawsuit, did
19
11:11:48
I?
20
11:11:49
A I think you were instrumental in
21
11:11:51
bringing -- in having Mr. Paul bring it.
22
11:11:53
Q But another law firm brought that lawsuit
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1
11:11:55
for --
2
11:11:55
A Right, the same law firm that was
3
11:11:57
representing you initially in your lawsuit against
4
11:12:00
Judicial Watch based in Pennsylvania sued us on
5
11:12:02
behalf of Mr. Paul, and then at some point they
6
11:12:06
withdrew and then you represented Mr. Paul.
7
11:12:09
Q You're aware at the time that Mr. Paul had
8
11:12:11
no money?
9
11:12:14
A Oh, I don't want to get into Mr. Paul and
10
11:12:18
his money. I don't --
11
11:12:19
Q You're aware that he was under house
12
11:12:21
arrest?
13
11:12:25
A Those are all loose terms, and I don't know
14
11:12:27
what the timing you're referring to.
15
11:12:29
Q And did not have means of making money at
16
11:12:34
that time, you're aware of that, right?
17
11:12:36
A Which time frame are you talking about? I
18
11:12:40
mean, I want to --
19
11:12:40
Q When you claim that I came into the case on
20
11:12:42
behalf of Mr. Paul.
21
11:12:44
A I believe at that point he had been
22
11:12:47
indicted for stock manipulation, stock fraud issue,
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and he had been extradited from Brazil and he was --
2
11:12:59
one of the conditions for him not being in jail was
3
11:13:01
that he was on -- staying in his apartment in North
4
11:13:05
Carolina on an ankle bracelet.
5
11:13:08
Q And had no means of income at that time?
6
11:13:12
A You know, that was a big source of dispute.
7
11:13:15
Q Were you aware or not?
8
11:13:19
A You know, I really -- I just don't want to
9
11:13:22
get into that because what I'm aware of came from
10
11:13:24
Mr. Paul in the context of an attorney-client
11
11:13:27
communication or in the context of an
12
11:13:31
attorney-client relationship, and I don't think it's
13
11:13:33
appropriate for me to have to testify about that.
14
11:13:35
Q Well, you raised it. That's why I'm
15
11:13:37
getting into it.
16
11:13:38
A No. I raised the idea that -- that you
17
11:13:39
represented Mr. Paul in a lawsuit against Judicial
18
11:13:42
Watch and that you were instrumental in causing
19
11:13:44
Mr. Paul to raise that lawsuit. I didn't -- I
20
11:13:46
didn't raise anything about Mr. Paul's sources of
21
11:13:48
income.
22
11:13:49
Q Well, you are aware that Judicial Watch
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1
11:13:51
agreed to represent Mr. Paul with regard to his
2
11:13:56
possible indictment and then indictment for
3
11:14:00
securities and bank fraud and that we promised to
4
11:14:05
provide representation for him, correct?
5
11:14:08
MR. KRESS: I'm not aware of the substance
6
11:14:11
of these -- what the answers are, but it appears to
7
11:14:15
be approaching attorney-client privileged
8
11:14:16
information. So I would just caution you that --
9
11:14:20
not to reveal attorney-client privilege, if you can.
10
11:14:22
THE WITNESS: I don't -- I'm not -- this is
11
11:14:25
all sort of unusual. I don't know how to get into
12
11:14:28
this stuff in a way that preserves any
13
11:14:30
attorney-client communications.
14
11:14:32
BY MR. KLAYMAN:
15
11:14:32
Q Well, you raised it, correct?
16
11:14:34
A No. I raised the idea that you were
17
11:14:36
instrumental in causing the former Judicial Watch
18
11:14:38
client to file a lawsuit against the organization,
19
11:14:40
and then you represented Mr. Paul in that lawsuit.
20
11:14:43
Q Well, and this raises the question --
21
11:14:47
MR. KRESS: But I don't think that allows
22
11:14:48
you to get into --
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11:14:49
MR. KLAYMAN: Let me ask the question and
2
11:14:50
you'll see why, because he opened the door to this,
3
11:14:53
and --
4
11:14:53
THE WITNESS: No, I did not open the door
5
11:14:54
to anything.
6
11:14:55
BY MR. KLAYMAN:
7
11:14:55
Q You opened the door to this. And in fact,
8
11:14:59
Judicial Watch, after I left, abandoned Mr. Paul and
9
11:15:00
he had no representation in the criminal proceeding,
10
11:15:02
correct?
11
11:15:02
MR. KRESS: I'm going to object. If you
12
11:15:06
know, I suppose you can answer -- I'm going to
13
11:15:09
object to the use of the word "abandoned."
14
11:15:14
THE WITNESS: Well, it's also completely
15
11:15:15
irrelevant to anything having to do with a 2012
16
11:15:19
alleged defamatory statement.
17
11:15:22
BY MR. KLAYMAN:
18
11:15:22
Q Well then, why did you raise it,
19
11:15:24
Mr. Orfanedes?
20
11:15:24
A You were -- I believe the whole thing came
21
11:15:26
up in the context of you were asking me how I
22
11:15:32
learned of the posting, and I referenced the threat
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1
11:15:34
you made to the organization. And then we got into
2
11:15:36
what's a threat, and then I was trying to articulate
3
11:15:39
that, given the number of lawsuits and actions that
4
11:15:43
you had brought and caused to be brought against the
5
11:15:45
organization and me and the other directors, when we
6
11:15:51
got the kind of correspondence -- when we got this
7
11:15:54
correspondence from you about the February 2012
8
11:16:00
matter, we interpreted it as yet another threat.
9
11:16:05
And I think you started asking me why it
10
11:16:07
was a threat, and I was trying to explain that you
11
11:16:12
had made threats against us in the past and filed
12
11:16:16
lawsuits against us.
13
11:16:16
Q Now, let's back up.
14
11:16:21
A Okay.
15
11:16:24
Q Whether or not what I was doing in
16
11:16:26
contacting Mr. Driscoll was a threat, you, Paul
17
11:16:33
Orfanedes as the legal officer of Judicial Watch and
18
11:16:35
Judicial Watch itself and as an ethics group, had an
19
11:16:40
obligation to correct anything that may have been
20
11:16:41
defamatory that was in the public record, correct?
21
11:16:44
A You know, I -- I don't know anything about
22
11:16:46
that, but I do know I reviewed the postings at some
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1
11:16:49
point after you contacted us, and I looked at both
2
11:16:52
of them because I believe Ms. Taitz's subsequent
3
11:16:58
posting of a few days later was up -- up being put
4
11:17:03
on the internet -- I looked at all of this. I
5
11:17:06
didn't see that there was anything defamatory. I
6
11:17:08
didn't see that there was anything harmful. I
7
11:17:13
didn't see that there was any issue, and I
8
11:17:15
interpreted all of this as yet another part of your
9
11:17:17
ongoing campaign of harassment against Judicial
10
11:17:20
Watch.
11
11:17:20
Q Okay, so saying publicly that someone's
12
11:17:23
convicted of a crime when he's not, there's nothing
13
11:17:27
harmful about that in your opinion, is there?
14
11:17:30
A I looked at the posting -- I don't know
15
11:17:34
where the posting is.
16
11:17:35
MR. KRESS: I think -- do you need to see
17
11:17:37
them?
18
11:17:37
THE WITNESS: No, but, I mean, the posting
19
11:17:39
says what it says. I think the posting also makes
20
11:17:42
clear that it contains other statements saying that
21
11:17:47
you were only indicted, and then Ms. Taitz posted
22
11:17:51
her subsequent, you know, posting 2 days later that
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1
11:17:55
says she was wrong. You had only been indicted and
2
11:17:58
not convicted of this child support issue.
3
11:18:03
I mean, I looked at all that and I saw no
4
11:18:05
issue. And given your history of threats and
5
11:18:09
allegations, false allegations against the
6
11:18:13
organization and the number of lawsuits that you've
7
11:18:15
already filed against the organization, I saw this
8
11:18:18
whole matter that you were raising with Rich, you
9
11:18:22
were raising with Judicial Watch as just another of
10
11:18:25
the pattern of harassment and threats you've been
11
11:18:29
making against the organization for 10 years.
12
11:18:37
BY MR. KLAYMAN:
13
11:18:37
Q Let's take a look at Exhibit 2. Look at
14
11:19:03
the comments on Exhibit 2.
15
11:19:05
MR. KRESS: He doesn't have it in front of
16
11:19:07
him.
17
11:19:07
THE WITNESS: I don't have anything in
18
11:19:08
front of me.
19
11:19:32
MR. KRESS: Okay.
20
11:19:34
BY MR. KLAYMAN:
21
11:19:34
Q Exhibit 2 February 26 -- wait. Excuse me,
22
11:19:39
February 23rd.
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11:19:41
MR. KRESS: This is the first posting.
2
11:19:43
THE WITNESS: Okay, yeah.
3
11:19:43
BY MR. KLAYMAN:
4
11:19:44
Q Look at the comments. Bloodless coup.
5
11:19:47
We're talking -- we're looking at page 4 into that
6
11:19:51
document. JW 0004. Okay?
7
11:19:54
A Okay.
8
11:19:55
Q Bloodless coup, February 23rd, 2012. "I
9
11:19:58
was initially excited about Larry Klayman, and
10
11:20:00
helped the news about him to go viral. Now I am
11
11:20:03
wondering about him and what his true motives might
12
11:20:05
be."
13
11:20:07
You understand that this is not a positive
14
11:20:09
remark with regard to me, correct?
15
11:20:12
A I don't know anything about this comment
16
11:20:13
other than it's this ink on a page.
17
11:20:17
Q So you think I made this up?
18
11:20:19
A I don't know that you didn't. I don't know
19
11:20:21
anything about it.
20
11:20:21
Q Well, you had an opportunity to review
21
11:20:25
this, did you not, at the time?
22
11:20:25
MR. KRESS: I think he --
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11:20:29
THE WITNESS: That doesn't have anything to
2
11:20:31
do with anything.
3
11:20:31
MR. KRESS: I think his testimony was he
4
11:20:34
didn't know if he read the comments.
5
11:20:36
MR. KLAYMAN: Please don't give him
6
11:20:37
testimony.
7
11:20:37
THE WITNESS: Well, that -- that was my
8
11:20:38
testimony.
9
11:20:38
MR. KLAYMAN: Please don't coach him, okay?
10
11:20:41
MR. KRESS: I'm not coaching him. That's
11
11:20:45
another problem.
12
11:20:45
THE WITNESS: It's bush league threats and
13
11:20:48
intimidation. Maybe it worked in Philadelphia or
14
11:20:50
wherever -- wherever you practiced back in the day,
15
11:20:52
but come on, Larry.
16
11:20:53
BY MR. KLAYMAN:
17
11:20:54
Q I'm just asking for honest responses.
18
11:20:56
A Oh, I know you are.
19
11:20:57
Q Yeah.
20
11:20:58
A You're just trying to harass us some more
21
11:21:01
because --
22
11:21:01
Q I'm not harassing.
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1
11:21:03
A -- you're still mad about what happened in
2
11:21:05
2003.
3
11:21:05
Q Look at the second one. "I smelled a rat
4
11:21:09
from the get-go. Asking for $25,000 for 2 lawsuits
5
11:21:13
sounded way out of the ballpark for me, so I did not
6
11:21:17
bite. Seemed like attempt to scam money on the
7
11:21:17
backs of people wanting to expose Obama, and nothing
8
11:21:22
more. Glad Orly stays on top of things like this
9
11:21:27
for us. WHERE DOES SHE FIND THE TIME?? Talk about
10
11:21:27
multi-tasking, I think Orly is the queen of that as
11
11:21:31
well!"
12
11:21:40
A Is that it, those two?
13
11:21:42
Q Yeah. I'm reading them to you.
14
11:21:43
A Oh, okay. You read well.
15
11:21:46
Q Now, that's not a positive remark either,
16
11:21:49
is it?
17
11:21:49
A What's that?
18
11:21:51
Q What I just read you.
19
11:21:52
A Larry, if you want to ask me some questions
20
11:21:58
about the facts of this case, that's fine, but to
21
11:22:01
read me statements and ask -- that I have no idea
22
11:22:04
what their origin is, I don't know who these people
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1
11:22:09
are, there's multiple levels of hearsay here and you
2
11:22:12
ask me if that's positive, you know, I don't know.
3
11:22:14
It's just -- it's silly. I'm not going to answer
4
11:22:16
that.
5
11:22:16
Q Well, it deals with your state of mind and
6
11:22:19
wanting to correct what Ms. Ruffley --
7
11:22:22
A No.
8
11:22:22
Q -- was reported to say, correct?
9
11:22:24
A No, it doesn't. I told you what my state
10
11:22:27
of mind was. I looked at all this. I saw no issue.
11
11:22:30
I figured this was -- I concluded this was yet
12
11:22:32
another part of your long campaign of harassment
13
11:22:35
against the organization.
14
11:22:51
Q I want you to take a look at Exhibit 1,
15
11:23:03
third page. It's JW 00015.
16
11:23:09
MR. KRESS: I think that's -- he doesn't
17
11:23:12
have that in front of him, I don't think. He does
18
11:23:21
not have that in front of him.
19
11:23:23
BY MR. KLAYMAN:
20
11:23:31
Q Let me read it to you, and I'll show it to
21
11:23:33
you.
22
11:23:44
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1
11:23:45
2
11:23:46
3
11:24:42
(Recess.)
4
11:28:25
5
11:28:27
time is 11:28 a.m.
6
11:28:38
BY MR. KLAYMAN:
7
11:28:38
Q Please turn to the third page of this, JW
8
11:28:41
15, on Exhibit 1.
9
11:28:43
A Mm-hmm.
10
11:28:44
Q Paragraph 4, posted by Orly Taitz
11
11:28:49
presumptively. I'm going to read this to you. "I
12
11:28:53
read the first post I made in regards to Mr. Klayman
13
11:28:56
and I saw that indeed there was an error. I wrote,
14
11:28:58
that Ms. Ruffley stated that Mr. Klayman was just
15
11:29:02
recently convicted of non payment of child support.
16
11:29:02
The link and the article right under it stated, that
17
11:29:08
he was indicted in 2 counts of criminal non-support,
18
11:29:09
that he owes $78,861.76 and arrignment (sic) was
19
11:29:13
scheduled for February 7, 2012. So, there was an
20
11:29:16
error. Mr. Klayman was indicted in the state of
21
11:29:21
Ohio on two counts of criminal non-support, but he
22
11:29:23
was not convicted yet. I am making this correction.
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1
11:29:26
Ms. Ruffley made an error." Ms. Ruffley made an
2
11:29:30
error.
3
11:29:30
A That's what she says.
4
11:29:31
Q I didn't ask you a question. I'm just
5
11:29:34
reading it to you.
6
11:29:35
A Oh, I'm just emphasizing what it says.
7
11:29:38
Q It was also -- I will ask you some
8
11:29:39
questions. Let me finish.
9
11:29:40
A Okay.
10
11:29:40
Q It was also self evident in the February
11
11:29:43
23rd, 2012 article, as I posted the link right
12
11:29:46
underneath and the link stated, that he was indicted
13
11:29:49
and arraignment scheduled. The article was
14
11:29:53
published a couple of days ago on February 23 and I
15
11:29:56
corrected it to today on February 26, 2012. Are you
16
11:29:58
saying that Ms. Ruffley did not make an error?
17
11:30:02
A I'm saying that's what Ms. Taitz seems to
18
11:30:05
say here. I remember reading this posting back when
19
11:30:07
you read this -- you were complaining to Rich or you
20
11:30:11
brought the matter to our attention.
21
11:30:15
Q Are you saying that Ms. Ruffley, when she
22
11:30:17
made the purported statement to Ms. Taitz did not
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1
11:30:20
make an error?
2
11:30:21
A I don't know what Ms. Ruffley said. All I
3
11:30:31
know is that Ms. Taitz posted something claiming
4
11:30:34
that Ms. Ruffley said that you had been convicted.
5
11:30:36
Q Did you make an effort --
6
11:30:37
A Now, later on in that article Ms. Taitz
7
11:30:40
also said you'd been indicted and that an
8
11:30:42
arrangement was scheduled. You could read that
9
11:30:45
whole posting as a whole as being ambiguous at best,
10
11:30:53
and then Ms. Taitz issued this retraction,
11
11:30:56
clarification, acknowledgment that there was an
12
11:30:58
error. She attributed the error to Connie, but I
13
11:31:02
don't know. I don't know what Connie said. The
14
11:31:04
error could have been in Ms. Taitz's perception of
15
11:31:07
what Connie said.
16
11:31:10
I don't know what happened. But I read the
17
11:31:12
whole posting exchange and I concluded there was
18
11:31:14
nothing to it, that it was part of the pattern of
19
11:31:19
harassment that you had engaged in against Judicial
20
11:31:22
Watch and its officers and directors and employees
21
11:31:24
since 2003.
22
11:31:24
Q Did you or Judicial Watch make an effort to
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1
11:31:27
find out whether or not Connie Ruffley said that?
2
11:31:30
A I think we went over this. I may have
3
11:31:32
spoken with Connie, and anything she told me would
4
11:31:35
be subject to attorney-client privilege.
5
11:31:41
Q We're in litigation right now over this
6
11:31:43
issue, correct?
7
11:31:44
A Which issue is that?
8
11:31:45
Q Whether or not Connie Ruffley said these
9
11:31:47
matters on behalf of Judicial Watch, whether or not
10
11:31:50
she said I was convicted of a crime and that
11
11:31:52
information should be given to donors?
12
11:31:54
A Oh, there's multiple issues there, so
13
11:31:57
you've just comp- -- complicated your own question.
14
11:32:00
Q So it wasn't just a question of she's
15
11:32:02
saying that I should be -- excuse me. It just
16
11:32:06
wasn't a question of her saying I was convicted,
17
11:32:09
Connie Ruffley, of a crime but also that that
18
11:32:11
information should be provided to donors, correct?
19
11:32:13
20
11:32:14
THE WITNESS: I -- I guess I didn't
21
11:32:15
understand that that's -- you were making an issue
22
11:32:17
of that, but if you're making an issue of that,
631

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1
11:32:20
okay, you're making an issue of that. Whether
2
11:32:22
Connie said that, I don't know if she said that or
3
11:32:24
not. Like I said, I wasn't there.
4
11:32:26
BY MR. KLAYMAN:
5
11:32:28
Q You just said you can't testify to that
6
11:32:30
because of attorney-client privilege, but now you
7
11:32:32
say you don't know if she said that or not. Which
8
11:32:35
is it?
9
11:32:35
A I was not present at the meeting that
10
11:32:37
allegedly took place on February -- whenever it
11
11:32:40
was -- in Garden Grove, California. I'm not a
12
11:32:44
witness to that.
13
11:32:45
Q Let's take Larry Klayman out of the whole
14
11:32:47
equation, okay?
15
11:32:48
A How can you ever do that, Larry?
16
11:32:50
Q As a member of -- you want to be serious or
17
11:32:54
not, Mr. Orfanedes?
18
11:32:55
A I'm very serious.
19
11:32:56
Q You think this is a joke? You think it's a
20
11:32:59
joke to be accused of someone being accused of a
21
11:33:04
crime?
22
11:33:04
A I think your questions today is ridiculous,
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Merrill LAD
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1
11:33:07
just like I think your lawsuit is ridiculous.
2
11:33:10
Q You think it's a joke?
3
11:33:11
A Part of a continuing campaign of harassment
4
11:33:14
against Judicial Watch and its officers and
5
11:33:15
directors and employees.
6
11:33:16
Q You think putting out into public domain
7
11:33:18
that a lawyer's been convicted of a crime when he's
8
11:33:20
not is a joke?
9
11:33:21
10
11:33:22
THE WITNESS: I've answered the question.
11
11:33:25
BY MR. KLAYMAN:
12
11:33:25
Q Well, you were laughing. I want to find
13
11:33:28
out whether you think that's funny.
14
11:33:29
A I was laughing at your absurd attempts to
15
11:33:32
be intimidating.
16
11:33:33
Q I haven't raised my voice once during this
17
11:33:35
deposition, have I?
18
11:33:36
A I think you did, yeah, a couple times.
19
11:33:38
Q Really? When was that?
20
11:33:40
A Earlier today.
21
11:33:41
Q Okay. We'll let the record speak for
22
11:33:44
itself, but I'm asking you the question --
631

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1
11:33:44
A The videotape will.
2
11:33:48
Q -- as a member of Judicial Watch --
3
11:33:48
A Mm-hmm.
4
11:33:50
Q -- you have a fiduciary duty to Judicial
5
11:33:52
Watch; do you not?
6
11:33:53
A I believe I do.
7
11:33:54
Q And if someone makes an allegation that
8
11:33:57
Judicial Watch is accusing someone of a crime
9
11:33:59
falsely, you have an obligation to investigate that;
10
11:34:01
do you not?
11
11:34:02
12
11:34:03
BY MR. KLAYMAN:
13
11:34:04
Q As a director?
14
11:34:05
A No, I'm going to object. I don't -- I
15
11:34:07
don't know what all my obligations are within the
16
11:34:09
scope of my fiduciary duty if they would include
17
11:34:12
something like that, but even if it were, you know,
18
11:34:15
that's not the scenario. That's not the facts that
19
11:34:17
we're here to talk about today. We're not talking
20
11:34:20
about hypothetical cases. We're talking about this
21
11:34:22
case in which you claim, based on nothing more than
22
11:34:28
a posting that has been -- that itself is ambiguous,
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Merrill LAD
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1
11:34:32
that Connie made certain statements to Orly Taitz.
2
11:34:38
That's what this lawsuit is about.
3
11:34:39
Q I'm talking about your fiduciary duty --
4
11:34:41
A You want to ask questions about that
5
11:34:43
lawsuit, I'm happy to answer them.
6
11:34:44
Q I'm talking about your fiduciary duty to
7
11:34:47
Judicial Watch.
8
11:34:47
A In a hypothetical context, and I'm not
9
11:34:51
going to answer that.
10
11:34:52
Q I'm asking you in a specific context. If
11
11:34:54
one of Judicial Watch's employees makes a statement
12
11:34:57
which is false and it's in the public domain, to
13
11:34:59
protect Judicial Watch you have an opportunity to do
14
11:35:01
due diligence and find out whether that statement
15
11:35:02
was made, correct?
16
11:35:03
A Not necessarily. It depends. There's so
17
11:35:06
many circumstances, so many variables that could
18
11:35:09
exist in your hypothetical that I can't even answer
19
11:35:11
the question.
20
11:35:11
Q The difference is if it's Larry Klayman is
21
11:35:14
involved then you're not going to do it, correct?
22
11:35:15
A No. The difference is that that provides
631

Merrill LAD
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1
11:35:18
additional facts such that a lawyer or a court
2
11:35:22
trying to reach a conclusion about a fiduciary
3
11:35:25
obligation has more on which it could base a
4
11:35:28
conclusion. Number one, that's not the purpose of
5
11:35:31
this deposition; number two, that's not the question
6
11:35:33
that you posed.
7
11:35:38
Q Let me ask it again.
8
11:35:40
A You can keep asking the same question. I
9
11:35:42
suggest your question is a bad question and you
10
11:35:45
should just move on to something that's relevant.
11
11:35:47
Q You are -- you are a member of the Board of
12
11:35:49
Directors and you're the chief legal officer of
13
11:35:51
14
11:35:51
A Mm-hmm.
15
11:35:52
Q Okay. You have a fiduciary obligation to
16
11:35:57
Judicial Watch, do you not, to find out whether or
17
11:36:00
not Connie Ruffley made that statement about Larry
18
11:36:03
Klayman, that he was convicted of a crime and the
19
11:36:05
information should be given to donors?
20
11:36:07
21
11:36:09
BY MR. KLAYMAN:
22
11:36:09
Q On behalf of Judicial Watch to protect
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Merrill LAD
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1
11:36:11
Judicial Watch, you have that obligation, correct?
2
11:36:13
3
11:36:14
THE WITNESS: I don't know that I'll say
4
11:36:15
that I have that. I don't know that I have a
5
11:36:18
fiduciary obligation in those circumstances. I
6
11:36:21
don't know, especially when I have something in
7
11:36:24
front of me, the postings, that make clear to me
8
11:36:28
that it's ambiguous at best what was said, if
9
11:36:34
anything.
10
11:36:34
BY MR. KLAYMAN:
11
11:36:34
Q Is there anything ambiguous about the
12
11:36:36
word "convicted"?
13
11:36:38
A Well, I think what you're ignoring is the
14
11:36:40
fact that -- I don't know how many paragraphs below,
15
11:36:47
but it is not very many, one -- actually, it's --
16
11:36:57
well, I don't know. I would say the second
17
11:37:00
paragraph below it, "Larry Klayman was indicted on
18
11:37:02
two counts of criminal nonsupport," blah, blah,
19
11:37:06
blah. Arraignment is scheduled for February 7th.
20
11:37:10
You know, I don't know. To me that's
21
11:37:12
saying you were convicted -- I'm sorry. See, I
22
11:37:15
misspoke. It's easy to misspeak as well. It says
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1
11:37:20
that you were indicted, and then there's other stuff
2
11:37:26
goes further on about a bar complaint against you.
3
11:37:29
You know, this is -- raises a host of different --
4
11:37:33
there's a number of factual statements about that --
5
11:37:36
about you here.
6
11:37:36
Q Has Ms. Ruffley been -- have you
7
11:37:39
communicated with her and tell her to be careful in
8
11:37:42
the future what she says about individuals?
9
11:37:43
A Any such communications would be governed
10
11:37:45
by attorney-client privilege and would be subject to
11
11:37:49
a litigation privilege as well.
12
11:37:50
Q Was she disciplined over these alleged
13
11:37:53
statements?
14
11:37:53
15
11:37:54
THE WITNESS: Do I need to answer that?
16
11:37:57
That's a personnel matter too. I don't know -- I
17
11:38:03
don't know what to do.
18
11:38:05
MR. KRESS: Could we have a moment to talk?
19
11:38:08
MR. KLAYMAN: Mm-hmm.
20
11:38:08
21
11:38:10
22
11:38:13
(Recess.)
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1
11:39:44
2
11:39:45
time is 11:39 a.m.
3
11:39:47
(The reporter read the record as
4
11:39:53
requested.)
5
11:39:53
THE WITNESS: No.
6
11:39:53
BY MR. KLAYMAN:
7
11:39:57
Q Was she criticized over these alleged
8
11:39:59
statements?
9
11:39:59
A No.
10
11:40:02
Q Was she cautioned not to make statements
11
11:40:04
like that in the future?
12
11:40:14
MR. KRESS: I'm going to -- I think that is
13
11:40:15
more getting into attorney-client privilege or work
14
11:40:21
product, if that's -- if it's anything in --
15
11:40:23
MR. KLAYMAN: It's the same question. It's
16
11:40:25
just a corollary of it.
17
11:40:27
MR. KRESS: Is it -- I don't know if it's
18
11:40:30
really a corollary, if you're getting into
19
11:40:32
communications that are related to the litigation.
20
11:40:40
If it's related -- because I think there
21
11:40:45
were no communications until after there's already
22
11:40:49
what we've called a threat of a lawsuit, and so I
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think -- I think it's work product. You're a lawyer
2
11:41:04
too, though.
3
11:41:11
THE WITNESS: Can you read back the
4
11:41:12
question.
5
11:41:12
6
11:41:22
requested.)
7
11:41:22
MR. KRESS: I'll continue to object. I
8
11:41:23
think it's also -- well, I'll continue to object.
9
11:41:29
Do we need to talk about this one too?
10
11:41:31
MR. KLAYMAN: You're not instructing him
11
11:41:32
not to answer, though, are you?
12
11:41:34
MR. KRESS: Well, I want to -- I think -- I
13
11:41:38
think we may need to confer about it again. I'm
14
11:41:41
sorry. I don't mean to --
15
11:41:41
MR. KLAYMAN: Go ahead.
16
11:41:41
MR. KRESS: I don't mean to delay your
17
11:41:42
deposition, but let's go off the record again.
18
11:41:44
19
11:41:46
20
11:41:49
(Recess.)
21
11:43:11
22
11:43:22
time is 11:43 a.m.
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11:43:24
2
11:43:36
requested.)
3
11:43:36
THE WITNESS: My answer would be as
4
11:43:40
follows: First of all, you didn't use the word
5
11:43:42
"alleged" in your question. I mean, we dispute that
6
11:43:45
she made the statement that is attributed to her by
7
11:43:48
Ms. Taitz. I don't recall if she was cautioned in
8
11:43:51
any manner that you suggest. Generally, I would
9
11:43:57
tell employees to be very careful about any
10
11:44:00
statements or anything they say about you because
11
11:44:02
you have this pattern and history of bringing --
12
11:44:05
making threats and bringing lawsuits against the
13
11:44:09
organization.
14
11:44:12
BY MR. KLAYMAN:
15
11:44:12
Q So all of a sudden, in the context of that
16
11:44:14
question, you're willing to testify hypothetically,
17
11:44:18
as you put it?
18
11:44:18
A No. I'm trying to answer the question that
19
11:44:21
I would generally caution employees about saying
20
11:44:23
anything about you in public because you have such a
21
11:44:27
history of bringing threats and lawsuits and
22
11:44:31
baseless allegations against Judicial Watch and its
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11:44:34
employees.
2
11:44:35
Q So your testimony is you don't remember
3
11:44:37
whether or not you told -- you cautioned her not to
4
11:44:40
make statements like the alleged statements in the
5
11:44:42
future?
6
11:44:43
A Yeah, I don't remember that and --
7
11:44:46
Q Okay.
8
11:44:47
A I don't remember that specifically.
9
11:44:48
Q Are you serving as the attorney for
10
11:44:55
Ms. Ruffley in this proceeding?
11
11:44:56
A No. Mr. Kress is.
12
11:44:58
Q So how can you claim attorney-client
13
11:45:00
privilege on conversations you had with Ms. Ruffley?
14
11:45:04
A Well, I'm the -- I'm the chief lawyer for
15
11:45:06
Judicial Watch.
16
11:45:06
Q So you're claiming that you represent her
17
11:45:09
in this case?
18
11:45:13
A I represent Judicial Watch in an in-house
19
11:45:15
capacity, yes. She's an employee of Judicial Watch
20
11:45:17
so, yes.
21
11:45:17
Q So anything that you discuss with anyone
22
11:45:19
because you're a lawyer is -- is subject to
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attorney-client privilege?
2
11:45:23
A I don't think it's quite -- that's not a
3
11:45:25
fair articulation of the privilege, but I think I'm
4
11:45:28
invoking the privilege to its full extent.
5
11:45:31
Q So, given the operative facts of this case,
6
11:45:35
because you're a lawyer you don't have to discuss
7
11:45:37
what went on with Judicial Watch and Connie Ruffley
8
11:45:39
and Larry Klayman?
9
11:45:41
10
11:45:42
BY MR. KLAYMAN:
11
11:45:42
Q That's your position?
12
11:45:43
A My position is communications I had with
13
11:45:48
Judicial Watch employees about this matter are
14
11:45:50
subject to attorney-client privilege because I'm
15
11:45:56
chief in-house counsel to Judicial Watch.
16
11:45:57
Q You were the point person, in effect, in
17
11:46:03
dealing with this issue with regard to Rich
18
11:46:06
Driscoll, Larry Klayman, and Connie Ruffley,
19
11:46:08
correct?
20
11:46:08
A I'm the point person within Judicial Watch
21
11:46:10
for dealing with all legal matters concerning the
22
11:46:12
organization.
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11:46:15
Q Did Fitton get into a discussion with
2
11:46:17
Driscoll about the matter that we're here today?
3
11:46:20
A I don't know.
4
11:46:23
Q Did Farrell?
5
11:46:26
A I would doubt it.
6
11:46:29
Q So it all rested on your shoulders,
7
11:46:31
correct?
8
11:46:31
A Well, it's my job.
9
11:46:33
Q Okay. So, therefore, we'll never been able
10
11:46:36
to find out what went on between Ruffley and you
11
11:46:39
with regard to these statements that were made
12
11:46:41
concerning Larry Klayman, because no one else can
13
11:46:45
testify to it and you're invoking privilege?
14
11:46:49
MR. KRESS: I'm going to object to the
15
11:46:51
form.
16
11:46:51
THE WITNESS: Is that a question?
17
11:46:51
BY MR. KLAYMAN:
18
11:46:52
Q Yeah.
19
11:46:55
MR. KRESS: I'm not sure what the question
20
11:46:56
is.
21
11:46:57
THE WITNESS: I don't know -- I don't know
22
11:46:57
if that's a question.
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11:46:58
BY MR. KLAYMAN:
2
11:46:58
Q You don't have to testify because you're an
3
11:47:00
attorney and the rest of them don't know anything.
4
11:47:02
A I've been testifying for hours now.
5
11:47:11
Q Based on your position at Judicial Watch,
6
11:47:13
do you not believe that Judicial Watch had a duty to
7
11:47:16
mitigate any damage to Larry Klayman as a result of
8
11:47:19
these alleged statements?
9
11:47:20
10
11:47:22
THE WITNESS: I think that's a legal
11
11:47:23
conclusion, and I would disagree with your legal
12
11:47:26
conclusion. I think it's the plaintiff's burden to
13
11:47:28
mitigate damage.
14
11:47:29
BY MR. KLAYMAN:
15
11:47:29
Q If a plaintiff is defamed, it's his burden
16
11:47:32
to mitigate the damage?
17
11:47:34
A Usually. Isn't mitigation something that
18
11:47:36
weighs against the plaintiff?
19
11:47:43
Q In a defamation case, is that what you're
20
11:47:44
saying?
21
11:47:45
A I think so. I mean, that's mitigation.
22
11:47:47
Q Did you consult the law before you decided
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11:47:49
to do nothing with regard to the alleged statements
2
11:47:51
concerning me?
3
11:47:52
4
11:47:53
THE WITNESS: I object to your question
5
11:47:55
too.
6
11:47:55
BY MR. KLAYMAN:
7
11:47:58
Q Did you?
8
11:48:00
A Of course I consulted the law. I relied on
9
11:48:02
my 22 years of experience at that point because it
10
11:48:06
was 2012.
11
11:48:07
Q And what -- what did you determine in
12
11:48:11
consulting the law and your 22 years of experience?
13
11:48:14
A That would be attorney work product.
14
11:48:26
MR. KLAYMAN: I have no further questions
15
11:48:27
at this time. I'm going to leave the deposition
16
11:48:29
open subject to hopefully obtaining documentation.
17
11:48:33
Hopefully, Doug, to your consulting with your client
18
11:48:36
and reconsidering whether he should be answering
19
11:48:38
some of these questions so we don't have to go to
20
11:48:40
the court and waste unnecessary time and resource.
21
11:48:42
MR. KRESS: I -- I think that we have
22
11:48:43
answered questions other than questions that were
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protected by attorney-client privilege or work
2
11:48:48
product. We've produced the documents we have in
3
11:48:50
response to -- and I've stated objections to the
4
11:48:54
document requests, and those speak for themselves.
5
11:48:59
I don't think I need to restate them. So we can --
6
11:49:03
I believe we have fully -- more than fully complied
7
11:49:06
with our obligations in responding to documents.
8
11:49:14
And the document requests, in effect,
9
11:49:22
came -- they did not give us the 30 days to respond.
10
11:49:26
They gave us, I think -- I don't know -- less
11
11:49:28
than -- a couple weeks, 2, 3 weeks. So we in good
12
11:49:31
faith produced those documents, and I think we
13
11:49:33
exceeded our obligations in producing documents to
14
11:49:37
you, and for those reasons and the other reasons
15
11:49:43
stated in our objections.
16
11:49:44
MR. KLAYMAN: I have a few more questions,
17
11:49:47
but the deposition will be left open. I have a few
18
11:49:51
more.
19
11:50:02
MR. KRESS: I will object to continuing
20
11:50:03
questions. You said you were done, but we'll let
21
11:50:05
you continue.
22
11:50:24
MR. KLAYMAN: I'll show you what I'll ask
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11:50:25
the court reporter to mark as Exhibit 4.
2
11:50:27
3
11:50:27
4
11:50:41
5
11:50:52
BY MR. KLAYMAN:
6
11:50:52
Q Have you ever seen Exhibit 4 before?
7
11:51:33
A I don't know. I don't believe so. This is
8
11:51:35
different from the one we marked before, right?
9
11:51:37
This is -- this is her responding to some comments,
10
11:51:41
something that you sent to her?
11
11:51:42
Q I'm just asking if you've seen it before.
12
11:51:45
A Did you threaten her too?
13
11:51:47
Q I'm not asking -- I'm not answering the
14
11:51:48
questions; you are.
15
11:51:49
A Oh, I'm just trying to understand the
16
11:51:50
context of this.
17
11:51:51
Q I asked you if you ever saw the document
18
11:51:53
before.
19
11:51:54
A She seems to be responding -- am I right in
20
11:51:57
thinking that she's responding to something you
21
11:51:59
wrote her, which I assume given it was you,
22
11:52:02
threatened her.
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11:52:06
MR. KRESS: Can I see that for a second?
2
11:52:08
THE WITNESS: Yeah, I don't remember seeing
3
11:52:09
that.
4
11:52:10
MR. KLAYMAN: By the way, these documents
5
11:52:11
were sent to you, Doug, by e-mail.
6
11:52:13
MR. KRESS: Okay.
7
11:52:40
This is exhibit -- this appears to be the
8
11:52:43
same thing as Exhibit 1 in a slightly different
9
11:52:45
format but --
10
11:52:46
THE WITNESS: Is it? Oh, okay. Well,
11
11:52:53
maybe -- I don't know. I'm confused by the format.
12
11:53:05
I remember seeing this paragraph 4 on page 2 of
13
11:53:11
Exhibit 4, which I also guess is the same as
14
11:53:16
paragraph 4 on page 3 of Exhibit 1. So I don't
15
11:53:24
know. I'm just confused by the format.
16
11:53:25
BY MR. KLAYMAN:
17
11:53:26
Q Have you seen it before?
18
11:53:28
A I don't know. I remember seeing this
19
11:53:31
paragraph 4 in both Exhibit 4 and Exhibit 1. I
20
11:53:37
don't remember necessarily seeing these comments.
21
11:53:41
Maybe they were there and I didn't focus on them. I
22
11:53:43
don't know.
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11:53:43
Q Okay. I'll show you what I ask to be
2
11:53:48
marked as Exhibit 5, Plaintiff's Exhibit 5.
3
11:53:51
4
11:53:51
5
11:54:05
6
11:54:13
THE WITNESS: Is there a question?
7
11:54:13
BY MR. KLAYMAN:
8
11:54:15
Q Have you ever seen that document before?
9
11:54:17
A I think, if I'm not wrong, this is
10
11:54:20
something you produced to us a few days ago, and I
11
11:54:25
believe that's the first time I saw it.
12
11:54:29
MR. KLAYMAN: Ask the court reporter to
13
11:54:31
mark this Exhibit 6.
14
11:54:32
15
11:54:32
16
11:54:46
17
11:54:46
BY MR. KLAYMAN:
18
11:54:46
19
11:54:47
A I remember this picture of Obama on the
20
11:54:50
tricycle in the production that you made on
21
11:54:53
Saturday. Was it Saturday?
22
11:54:54
MR. KRESS: Friday to me. I probably
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11:54:56
forwarded it to you on Saturday.
2
11:54:57
THE WITNESS: Saturday, so that's when I
3
11:54:59
remember seeing it.
4
11:55:00
MR. KLAYMAN: Okay. Ask the following
5
11:55:02
exhibit be marked Exhibit 7.
6
11:55:05
7
11:55:05
8
11:55:15
9
11:55:16
BY MR. KLAYMAN:
10
11:55:16
11
11:55:24
A I don't believe so. Maybe it was one of
12
11:55:34
the production you had the other day, but I don't --
13
11:55:36
I don't remember that one.
14
11:55:37
MR. KLAYMAN: I'll ask that the following
15
11:55:39
document be marked as Plaintiff's Exhibit 8.
16
11:55:40
17
11:55:40
18
11:56:07
19
11:56:07
THE WITNESS: Is there a question?
20
11:56:07
BY MR. KLAYMAN:
21
11:56:08
22
11:56:09
A No. I don't remember receiving it in your
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1
11:56:17
document production.
2
11:56:20
MR. KLAYMAN: I'll ask that the following
3
11:56:21
exhibit be marked as Exhibit 9, Plaintiff's Exhibit
4
11:56:24
9.
5
11:56:24
6
11:56:24
7
11:56:34
8
11:56:34
BY MR. KLAYMAN:
9
11:56:34
Q I'm going to ask you specific questions on
10
11:56:36
that. If you'd like, we can make another copy of
11
11:56:38
it. It's documents that you provided to us,
12
11:56:43
Judicial Watch.
13
11:56:44
A Okay.
14
11:56:44
MR. KRESS: Okay.
15
11:56:46
MR. KLAYMAN: Can I have it back, please?
16
11:56:47
MR. KRESS: I want to take a look at it for
17
11:56:49
a second.
18
11:57:15
Okay.
19
11:57:25
MR. KLAYMAN: Let's make a copy of this.
20
11:57:35
Off the record.
21
11:57:36
22
11:57:38
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11:57:40
(Recess.)
2
12:00:33
3
12:00:36
time is 12 p.m.
4
12:00:51
BY MR. KLAYMAN:
5
12:00:52
Q Exhibit 9 is a composite exhibit. The
6
12:00:54
first page -- and these documents were produced by
7
12:00:57
Judicial Watch in this case. The first page is the
8
12:01:00
Driscoll letter, copy to Paul Orfanedes. The second
9
12:01:05
page, that's Judicial Watch Exhibit JW 000505, at
10
12:01:10
least that's the Bates number, purports to be an
11
12:01:12
e-mail from Paul Orfanedes to Connie Ruffley, but
12
12:01:22
the letterhead is Tom Fitton. Can you explain to me
13
12:01:26
why it's configured that way and what this is?
14
12:01:29
A Yeah, because Tom printed it out. I didn't
15
12:01:31
save it so I didn't have it.
16
12:01:32
Q So you forwarded this e-mail from Connie
17
12:01:35
Ruffley to Tom Fitton?
18
12:01:37
A No. I responded to -- well, I guess you
19
12:01:41
got to follow the chain of command. This is a
20
12:01:45
multipage one. Looks like Steve Anderson, who is
21
12:01:48
our director of development, sent it to Tom, Chris,
22
12:01:51
and me, CC'd to Susan. I responded to Connie and I
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1
12:01:56
CC'd it on Tom, Chris, Steve, and Susan. Tom had it
2
12:02:06
in his e-mail account or on his computer when we did
3
12:02:10
the document production; I didn't. Like I say, I
4
12:02:14
don't save stuff, so he produced it.
5
12:02:20
Q The e-mail from you to Connie --
6
12:02:26
A Mm-hmm.
7
12:02:27
Q -- says, "We've had a couple of inquiries
8
12:02:29
about this posting. Can you make clear to Ms. Taitz
9
12:02:32
or whomever is responsible for the posting that she
10
12:02:32
was invited by UROC and not 'the Judicial Watch.'
11
12:02:36
The posting also needs to be corrected to avoid any
12
12:02:39
further confusion. Thanks. PJO."
13
12:02:41
Those are your initials, correct?
14
12:02:45
A Mm-hmm.
15
12:02:45
Q What's this about? Just describe it for us
16
12:02:48
briefly. What's this whole issue?
17
12:02:50
A Oh, it looks like -- well, Connie for quite
18
12:02:52
a long time has been -- I don't know what her title
19
12:02:54
is with UROC, United Republicans Of California.
20
12:02:59
It's a conservative political organization and she
21
12:03:02
has some leadership role with that organization.
22
12:03:04
She does this outside of Judicial Watch.
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12:03:07
I think UROC asked -- I mean, I'm just
2
12:03:11
going based on my recollection of my review of these
3
12:03:16
documents. I think UROC might have asked Orly to
4
12:03:20
come speak at an event, and it sounds like she
5
12:03:23
misunderstood that, Orly did, and was saying that
6
12:03:28
the request came from Judicial Watch. So people
7
12:03:34
apparently were contacting us about Orly Taitz's
8
12:03:37
appearance, and we needed to tell Connie to correct
9
12:03:41
that because we can't be involved in political
10
12:03:44
organizations.
11
12:03:44
Q So it concerned you that Orly Taitz
12
12:03:47
believed that Judicial Watch had invited her to a --
13
12:03:51
to a political event?
14
12:03:52
A No. It concerned me that it created a
15
12:03:54
false appearance that Judicial Watch had invited
16
12:03:57
Orly Taitz to speak at some event.
17
12:04:01
Q And this e-mail was kept in the ordinary
18
12:04:05
course of Judicial Watch's recordkeeping?
19
12:04:07
A I guess it was. I mean, Tom must have kept
20
12:04:10
it; I didn't. So that might be better directed to
21
12:04:13
him.
22
12:04:18
Q Was there a concern that Orly Taitz having
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1
12:04:22
been involved in an issue involving me, Larry
2
12:04:26
Klayman, thought that Judicial Watch was inviting
3
12:04:29
her to an event?
4
12:04:29
A I don't know. It does seem to demonstrate
5
12:04:31
a pattern of misunderstanding on the part of
6
12:04:34
Ms. Taitz, however.
7
12:04:35
Q I'm not asking about Ms. Taitz. We'll get
8
12:04:37
to Ms. Taitz. I'm talking about you, Judicial
9
12:04:41
Watch. Was there a concern that you didn't want to
10
12:04:43
be associated with Ms. Taitz because of what had
11
12:04:45
happened with me?
12
12:04:46
A No. The concern was that -- like I just
13
12:04:54
tried to articulate, the concern was that this
14
12:04:56
political organization, not Judicial Watch, had
15
12:05:01
invited Ms. Taitz. Ms. Taitz, you know, I think she
16
12:05:06
was a candidate. I don't know. But we try to be
17
12:05:10
very careful about making sure we don't -- aren't
18
12:05:14
affiliated with political organizations. UROC is a
19
12:05:17
political organization.
20
12:05:18
You know, we're very protective of our
21
12:05:22
501(c)(3) status that we not become involved in
22
12:05:26
electoral issues. UROC is involved in electoral
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12:05:30
issues. It created a false impression that Judicial
2
12:05:33
Watch was sponsoring this candidate speaking, not
3
12:05:37
UROC, so we needed that corrected.
4
12:05:38
Q So with regard to a so-called false
5
12:05:40
impression that Judicial Watch was inviting Orly
6
12:05:43
Taitz to a political event --
7
12:05:43
A Mm-hmm.
8
12:05:46
Q -- at UROC, you found it necessary to
9
12:05:48
communicate with Ms. Ruffley and caution her,
10
12:05:52
correct?
11
12:05:53
12
12:05:54
THE WITNESS: I don't think I was
13
12:05:55
cautioning her. I think -- this e-mail or this
14
12:06:02
e-mail chain seems to show that Ms. Taitz is saying
15
12:06:04
she was invited to a Judicial Watch function when it
16
12:06:08
was truly a UROC function, and I was asking Connie
17
12:06:11
to make sure that that was clarified. This is not a
18
12:06:13
cautioning to Connie. This is can you make sure
19
12:06:17
this is clarified, sort of. That's exactly what I
20
12:06:20
said.
21
12:06:20
BY MR. KLAYMAN:
22
12:06:21
Q So with regard to something that concerns
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1
12:06:24
Judicial Watch and an appearance of political
2
12:06:27
activity, you and Judicial Watch were concerned that
3
12:06:32
that not appear on a posting, correct?
4
12:06:38
A I don't know. Like I said, we were very --
5
12:06:40
I think this has nothing to do with, you know, the
6
12:06:44
convicted versus indicted confusion in Ms. Taitz's
7
12:06:48
prior posting. We're very protective of our
8
12:06:53
501(c)(3) status. We wanted it to be clear this was
9
12:06:57
not a Judicial Watch function she was speaking at.
10
12:06:59
This was a UROC function, and we asked Connie to
11
12:07:02
clarify that.
12
12:07:03
Q So when Judicial Watch's interests are
13
12:07:05
concerned, you will communicate with Ms. Taitz, but
14
12:07:07
when Larry Klayman is involved and he's being
15
12:07:10
allegedly accused of committing a crime, you have no
16
12:07:13
interest in communicating with -- with Ruffley?
17
12:07:15
A Judicial Watch wasn't communicating with
18
12:07:17
Orly Taitz.
19
12:07:19
Q But you did find a need to correct this
20
12:07:21
posting, correct?
21
12:07:23
A We asked Connie to make clear, like I said,
22
12:07:27
to Ms. Taitz or whoever is responsible that she's
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1
12:07:30
being invited by UROC, not by Judicial Watch.
2
12:07:32
Q But Judicial Watch and yourself made no
3
12:07:35
effort to have the posting corrected with regard to
4
12:07:37
Larry Klayman by Ms. Taitz, correct?
5
12:07:39
MR. KRESS: Objection to form. Asked and
6
12:07:41
answered.
7
12:07:42
You can answer.
8
12:07:42
BY MR. KLAYMAN:
9
12:07:43
Q That was not of concern to you --
10
12:07:44
11
12:07:45
BY MR. KLAYMAN:
12
12:07:45
Q -- because it involved me and not you?
13
12:07:47
14
12:07:48
THE WITNESS: I think I've already answered
15
12:07:49
that.
16
12:07:49
BY MR. KLAYMAN:
17
12:07:50
Q Turn to Judicial Watch Bates No. 508.
18
12:07:56
A Mm-hmm.
19
12:07:56
Q This is a -- this purports to be an e-mail
20
12:08:01
from Constance Ruffley dated January 7, 2013,
21
12:08:05
relatively recent, correct -- no. Excuse me -- a
22
12:08:09
year ago, correct?
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1
12:08:10
A More than a year ago.
2
12:08:11
Q To Tom Fitton, Paul Orfanedes, and Chris
3
12:08:15
Farrell, subject: Judge orders eligibility attorney
4
12:08:18
to stay away.
5
12:08:20
A I guess, yeah.
6
12:08:21
Q This is an e-mail that all three of you,
7
12:08:24
Fitton, Orfanedes, and Farrell received from Connie
8
12:08:27
Ruffley?
9
12:08:27
A Apparently. I don't remember it.
10
12:08:28
Q And it starts off by saying, from my
11
12:08:33
sister-in-law in parens, and then Connie writes,
12
12:08:38
"Klayman is at it again! Read if you're interested.
13
12:08:40
The truly disturbing thing, however, is that the
14
12:08:46
judge DID refer to a fictitious movie to make his
15
12:08:50
ruling!"
16
12:08:50
That's what Connie wrote to you. Is that
17
12:08:53
correct?
18
12:08:53
A That's what it says.
19
12:08:54
Q Did you discuss this e-mail with Mr. Fitton
20
12:08:56
or Mr. Farrell?
21
12:08:57
A No, I have no recollection of whatsoever of
22
12:08:59
this e-mail.
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1
12:09:00
Q This document was kept in the ordinary
2
12:09:02
course of Judicial Watch's recordkeeping?
3
12:09:03
A I don't know. You'd have to ask Mr. Fitton
4
12:09:05
that. I think Connie seems to be more concerned
5
12:09:09
about what the judge is doing, which was very
6
12:09:12
Judicial Watch related.
7
12:09:13
Q I'm not asking you a question,
8
12:09:14
Mr. Orfanedes, on this.
9
12:09:17
A Okay.
10
12:09:17
Q I'll get to the question. This document
11
12:09:19
was produced from Tom Fitton's computer?
12
12:09:22
A That's my assumption. I believe so.
13
12:09:24
Q What kind of computer does he have?
14
12:09:26
A I don't know. I'm not in charge of the
15
12:09:27
computers.
16
12:09:31
Q "Klayman is at it again!" That shows that
17
12:09:33
Ms. Ruffley is very concerned about what I'm doing,
18
12:09:35
correct?
19
12:09:36
20
12:09:37
BY MR. KLAYMAN:
21
12:09:37
Q Is that the way you took it?
22
12:09:38
A No. I don't even remember it. I didn't
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1
12:09:40
take it any way.
2
12:09:45
Q What difference does it make what I'm doing
3
12:09:47
to Judicial Watch?
4
12:09:48
A None.
5
12:09:48
Q Why did Ms. Ruffley write that to you?
6
12:09:52
A I don't know.
7
12:09:52
8
12:09:55
THE WITNESS: I don't know.
9
12:09:56
BY MR. KLAYMAN:
10
12:09:56
Q Did you caution Ms. Ruffley stay away from
11
12:09:59
Klayman after you saw this e-mail?
12
12:10:01
A I don't -- I don't remember seeing this
13
12:10:02
e-mail until just recently, Larry.
14
12:10:04
Q Do you know whether Fitton or Farrell told
15
12:10:07
Connie, get off of Klayman. Get on to something
16
12:10:13
else?
17
12:10:13
A Number one, I don't think she's on Klayman;
18
12:10:15
and number 2, no, I don't believe they did.
19
12:10:19
Q Because you don't care that she's somehow
20
12:10:21
preoccupied with me?
21
12:10:22
22
12:10:23
THE WITNESS: I don't think she's
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1
12:10:25
preoccupied with you. I mean, it could be --
2
12:10:25
BY MR. KLAYMAN:
3
12:10:26
Q How did you take it Klayman is it at again?
4
12:10:29
A I don't know. Maybe she likes whatever
5
12:10:31
work you were doing here. I don't know. I have no
6
12:10:32
idea, Larry. I don't know what this e-mail is, like
7
12:10:35
I said.
8
12:10:35
Q Okay.
9
12:10:37
A Did the judge -- I mean, is this something
10
12:10:38
about a judge in your case and did you really refer
11
12:10:41
to a movie in making his decision?
12
12:10:45
MR. KLAYMAN: We'll leave the deposition
13
12:10:47
open.
14
12:10:48
THE WITNESS: I object to that. You've had
15
12:10:51
ample opportunity to ask me all kinds of questions
16
12:10:53
and I object to it being opened.
17
12:10:54
MR. KLAYMAN: You didn't answer them.
18
12:10:55
THE WITNESS: I answered everything to the
19
12:10:57
best of my ability.
20
12:10:58
MR. KRESS: We're not agreeing to anything,
21
12:10:59
but the deposition's over and we'll reserve the
22
12:11:01
right to read.
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1
12:11:05
THE VIDEOGRAPHER: Here marks the end of
2
12:11:06
Volume 1, Tape No. 2 in the deposition of Paul
3
12:11:09
Orfanedes. Going off the record. The time is 12:11
4
12:11:12
p.m.
5
12:11:13
(Signature having not been waived, the
6
12:11:13
deposition of Paul Joseph Orfanedes, Esquire was
7
12:12:19
concluded at 12:11 p.m.)
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
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Page 161
1 * * *
2 ACKNOWLEDGMENT OF DEPONENT
3 I, Paul Joseph Orfanedes, Esquire, do hereby
4 acknowledge that I have read and examined the
5 foregoing testimony, and the same is a true, correct
6 and complete transcription of the testimony given by
7 me, and any corrections appear on the attached
8 Errata sheet signed by me.
9
10 _________________________ _____________________
11 (DATE) (SIGNATURE)
12
13
14
15
16
17
18
19
20
21
22
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Page 162
1 CERTIFICATE OF SHORTHAND REPORTER-NOTARY PUBLIC
2 I, Joan V. Cain, Court Reporter, the officer
3 before whom the foregoing deposition was taken, do
4 hereby certify that the foregoing transcript is a
5 true and correct record of the testimony given; that
6 said testimony was taken by me stenographically and
7 thereafter reduced to typewriting under my direction
8 and that I am neither counsel for, related to, nor
9 employed by any of the parties to this case and have
10 no interest, financial or otherwise, in its outcome.
11 IN WITNESS WHEREOF, I have hereunto set my
12 hand and affixed my notarial seal this 30th day of
13 January 2014.
14
15 My commission expires:
16 June 14, 2014
17 ____________________________
18 NOTARY PUBLIC IN AND FOR THE
19 DISTRICT OF COLUMBIA
20
21
22
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1 E R R A T A S H E E T
2 IN RE: Klayman v. Judicial Watch
3 RETURN BY: ________________________________________
4 ===================================================
5 PAGE LINE CORRECTION AND REASON
6 ===================================================
7 ____ ____ ___________________________________
8 ____ ____ ___________________________________
9 ____ ____ ___________________________________
10 ____ ____ ___________________________________
11 ____ ____ ___________________________________
12 ____ ____ ___________________________________
13 ____ ____ ___________________________________
14 ____ ____ ___________________________________
15 ____ ____ ___________________________________
16 ____ ____ ___________________________________
17 ____ ____ ___________________________________
18 ____ ____ ___________________________________
19 ____ ____ ___________________________________
20 ____ ____ ___________________________________
21 _______________ ___________________________________
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1 E R R A T A S H E E T C O N T I N U E D
3 RETURN BY: _________________________________________
4 ====================================================
6 ====================================================
7 ____ ____ ___________________________________
8 ____ ____ ___________________________________
9 ____ ____ ___________________________________
10 ____ ____ ___________________________________
11 ____ ____ ___________________________________
12 ____ ____ ___________________________________
13 ____ ____ ___________________________________
14 ____ ____ ___________________________________
15 ____ ____ ___________________________________
16 ____ ____ ___________________________________
17 ____ ____ ___________________________________
18 ____ ____ ___________________________________
19 ____ ____ ___________________________________
20 ____ ____ ___________________________________
21 _______________ ___________________________________
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A
abandoned
116:8,13
ability
86:17 159:19
able
140:9
above-referenced
72:15
absurd
129:14
access
96:15 111:19
account
111:4 150:2
accurate
79:2 81:8
accusations
68:7
accuse
80:13
accused
28:19 67:3 128:20,20
154:15
accusing
130:8
Acer
106:20
acknowledge
161:4
acknowledged
20:6
acknowledgment
126:11 161:2
act
9:21 71:4
action
60:1 73:7 74:18 76:13
78:9
actions
29:16,20 95:6 117:3
activities
29:8 55:16
activity
154:2
additional
132:1
address
45:2
adjudication
51:22 53:8
admin
90:1
Administration
10:11
administrative
42:5
administrator
18:2 40:6 53:13
advanced
72:17
advertisement
18:12
advised
19:1 33:9
advising
61:14
affair
16:12 17:6
affect
31:22 53:15,15
affidavit
77:5,9,11,18
affiliated
152:18
affixed
162:12
agent
59:6
ago
71:17 102:6 106:6
125:14 146:10
155:22 156:1
agree
80:15
agreed
115:1
agreeing
159:20
agreement
48:16
ahead
55:8 136:15
Air
93:20,22
Akim
3:21 6:11
al
65:5
alerted
37:8
allegation
31:16,17 33:7 35:17
35:20 36:17 51:21
53:7 61:8 66:19
67:22 70:4 75:6 86:6
87:9 88:2 130:7
allegations
32:9,21,21 33:2 47:14
59:16 66:6 68:6 69:5
69:17 70:12 72:18
73:1 75:5 86:12
119:5,5 137:22
allege
87:17
alleged
23:3 67:4,5 84:5,9
103:18 116:16
134:12 135:7 137:5
138:4 141:8 142:1
allegedly
78:3 128:10 154:15
alleging
33:3
allowed
96:18 98:14,16
allows
115:21
amateurish
23:17
ambiguous
126:9 130:22 133:8,11
Amendment
80:5
amount
19:6 29:18 33:14
93:17
ample
159:15
Anderson
149:20
and/or
93:5
animus
29:21 87:20,22
ankle
114:4
answer
21:17 23:1,19,20,21
25:21 30:2,8,10 31:2
31:8 38:16,21 39:13
46:16,17 53:19 54:8
54:21 55:2,5 57:9
58:1,6 67:13 77:2
79:7 83:4 84:14 86:4
86:12,16 90:15 91:5
105:14 116:12 123:3
131:5,9,18 134:15
136:11 137:3,18
155:7 159:17
answered
58:5 129:10 142:22
155:6,14 159:18
answering
83:19 142:18 144:13
answers
25:15 57:11 92:3
115:6
anybody
25:10
anyway
109:20 110:5
apartment
114:3
apparently
66:7 151:7 156:9
appear
154:3 161:7
appearance
151:8,15 154:1
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appeared
86:18 95:2
appears
43:17 115:6 145:7
applauded
17:21
Apple
106:18
applies
65:15 71:9
approach
44:19 111:19
approached
17:22
approaching
115:7
appropriate
114:13
appropriately
63:21 64:11
approve
73:19
approved
73:14,22 78:21 79:1
80:20 81:1
approving
81:4
area
94:17
areas
92:7 94:19
aren't
11:16 152:17
arose
91:7
arraignment
125:13 133:19
arrangement
126:8
arrest
28:20 29:2,4 113:12
arrignment
124:18
article
17:8 20:9 124:16
125:11,13 126:6
Articles
27:19
article2superpac
16:10 17:4,11 18:11
articulable
54:5
articulate
117:2 152:13
articulation
139:3
asked
23:19 37:8 51:4 56:11
56:17 57:11,12 58:4
58:5 64:19 72:3
79:20 81:9,17 98:5
105:13 144:17 151:1
151:3 154:10,21
155:5
asking
18:13 19:20 38:12,12
38:20 52:18 57:14
58:19 64:11 66:1
71:11 82:1,4 83:1,15
83:17,18,20,20 84:1
84:16,17,19 90:19,20
104:6 112:2 116:21
117:9 121:17 122:4
129:22 131:10 132:8
144:11,13 152:7
153:16 157:7
assertions
62:19
associated
50:22 152:10
Associates
8:9,13
assume
21:21 62:13,13 144:21
assumption
157:12
attached
4:7 5:2 14:10 16:21
45:7 144:3 146:4,15
147:7,17 148:6 161:7
attempt
23:16 122:6
attempted
60:20
attempting
23:18 65:18 71:12
attempts
129:14
attention
26:7 64:6 106:10
125:20
attorney
3:5 8:4,13,14,15 15:10
15:21 26:3 40:22
100:15 138:9 141:3
142:13 156:3
attorney-client
15:10,13 20:4 37:10
38:7 39:8 67:12,15
81:11,22 90:9,17
114:10,12 115:7,9,13
127:4 128:6 134:10
135:13 138:12 139:1
139:14 143:1
attributed
126:12 137:6
AU
7:22
authored
102:5
authorize
50:2 73:3 74:16
authorized
27:18
Avenue
3:7
avoid
150:11
award
97:11,18 98:2
aware
13:22 22:9 28:20 29:2
29:4 31:20 32:1
34:12,14 36:5,13,16
36:17 37:3 52:11,14
56:21 57:1,2,4 58:14
61:7 62:16 71:6 77:4
80:7,9,12 89:14 91:9
91:18,21 92:6 94:14
94:16,20 95:13,21
96:8,18 97:10,19,21
98:14,22 99:3,7
101:4,14,17,20 102:1
102:2,2,19 113:7,11
113:16 114:7,9,22
115:5
a.m
1:14 6:9 14:15,18
37:14,17 61:13
108:11,16 124:2,5
134:21 135:2 136:19
136:22 148:22
B
B
4:6 5:1 107:20
back
13:18 14:17 26:4
37:16 53:1 59:3
62:18 63:4 68:14
70:6,10 74:9 75:10
88:20 93:9,11,12
100:10 101:4,7 103:3
108:13,21 117:13
121:14 124:4 125:18
135:1 136:3,21
148:15 149:2
background
7:14
backs
122:7
backup
110:9,10
backward
72:7
bad
35:1 109:17 132:9
ballots
96:15
ballpark
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122:5
bank
115:3
bar
8:4,5 22:10 29:14,16
46:14 49:8,9 134:2
Barmak
49:5 50:2,9
base
132:3
based
33:16 34:15,19 66:20
72:21 83:10,18 113:4
130:21 141:5 151:2
baseless
71:16 137:22
Basically
44:19
Basulto
93:2 94:1,7
Basulto's
93:20
Bates
4:10,13 149:10 155:17
Beach
3:16
bear
28:22
began
85:15
beginning
108:14
begins
6:2
behalf
3:3,11 39:10 65:7 69:5
70:11 73:18 95:22
96:19 112:16 113:5
113:20 127:9 132:22
bel
32:18
Belgium
95:14
believe
8:10 12:22 13:4 14:21
19:15 20:8 26:3
28:11 29:15 30:14
36:19 43:20 47:9,18
48:2 54:13 55:15
59:1 70:8,9 74:3
77:13 78:10 83:1
84:15 94:2 107:22
113:21 116:20 118:2
130:6 141:6 143:6
144:7 146:11 147:11
157:12 158:18
believed
151:12
Benson
48:20 68:12 69:4,5
70:5,11,12
best
30:5 55:4 61:19,21
63:22 86:16 126:9
133:8 159:19
better
151:20
big
114:6
Bill
100:9,13,14
birther
4:20 18:9 91:15
bit
9:10 63:10 92:20
bite
122:6
black
106:14,15 108:21
blah
133:18,18,19
Bloodless
120:4,8
Board
12:1,2,6,11,15 132:11
bold
59:13
book
102:5,10,14 103:1
bought
69:18,19 107:5
box
60:21 99:1,4 106:14
106:15 108:22
bracelet
114:4
brand
106:9 107:6,9
Brazil
114:1
break
54:7,9
briefly
7:13 150:16
bring
29:14 108:7 112:18,21
bringing
62:5 71:9 112:21
137:11,12,21
broad
100:4
broke
55:8
brothers
92:19 93:2,14,20,22
brought
10:4 26:6,7 46:9,10
47:4,6,7,15 48:4 49:4
91:18 95:22 101:21
112:16,22 117:4,4
125:20
build
68:13
building
68:13,14,22 69:3,18
69:20
built
68:14
burden
141:12,15
bush
96:10 97:3 121:12
business
33:6
buy
68:21
bylaws
12:22 13:6
C
C
3:1 4:1 5:1 6:1 164:1
cabin
41:5
Cain
1:22 2:10 6:20 162:2
California
10:1 17:16 18:15 19:2
33:10 128:11 150:19
call
24:9,12 26:20 27:4
59:7 63:5,12,12,20
64:13 91:6,6
called
8:2 12:22 13:5 27:16
28:11 56:16 58:2
85:13 102:6 112:6
135:22
calls
41:21 67:12
camera
97:6,7,8 98:19 99:3
campaign
69:3 118:9 123:12
129:3
candidate
17:15 152:16 153:2
can't
20:22 38:16 55:2
67:13,14 86:4 100:6
128:5 131:18 151:9
capacity
7:18 8:13 37:9 38:4
96:21 100:22 138:19
caps
59:13
card
18:1
care
79:13 158:19
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careful
134:7 137:9 152:17
Carlos
107:18,19
Carolina
114:4
case
1:5 6:6 9:19 47:19
77:5 84:18,22 92:13
94:5 96:10 97:2
111:15 113:19
122:20 130:21
138:17 139:5 141:19
149:7 159:10 162:9
cases
9:14,17 10:5 18:9,14
48:1 80:4 130:20
Castro
92:14 94:22 95:6,14
95:15
Castro's
93:20
catch-22
102:18
cause
60:1
caused
71:15 117:4
causes
50:13
causing
114:18 115:17
caution
115:8 137:19 153:9
158:10
cautioned
135:10 137:7 138:3
cautioning
153:13,18
CCIR
16:9 17:4
CC'd
149:22 150:1
cell
108:19
certain
10:9 68:1 104:7 131:1
Certainly
7:15
CERTIFICATE
162:1
certify
162:4
cetera
27:20 61:18 72:13
chain
4:15 5:10 149:19
153:14
chains
63:8
chairman
12:17,19,22 13:2,5
28:11
Challenge
13:21 43:15
challenging
91:19
change
65:12
changed
107:13
changing
94:16
characterization
67:2 103:3,10
characterize
19:22 30:6,7 58:8 68:3
75:5
characterized
72:3
charge
42:11 157:14
chased
94:1
chasing
93:22
Chavez
96:1
check
102:13
chief
11:22 77:21 78:18
82:17 84:6 132:12
138:14 139:15
child
19:6 33:14 51:7 101:7
119:2 124:15
choice
10:22
Chris
12:4,9 13:8 149:21
150:1 156:2
Chronicles
102:7
chuckle
112:13
Churches
100:20
Circuit
96:14
circumstances
11:8 70:14 131:17
133:5
cite
47:17
citizenship
61:16
claim
9:21 20:11 45:3 71:9
72:13 84:18 113:19
130:21 138:12
claimed
37:20 38:10 47:16
claiming
18:13 27:2 38:13
126:3 138:16
claims
48:4,14 57:15 68:7
clarification
126:11
clarified
153:17,19
clarify
73:7 74:5 154:11
class
72:12
classic
85:2
classmate
101:15
clauses
55:11
clear
18:21 78:21 118:20
133:7 150:8 154:8,21
clerk
7:16,19 8:2
client
115:18 142:17
clients
65:4,18
clinic
7:22
Clinton
10:11 20:10,10 25:15
100:9,13,14 101:15
Clinton's
101:10
club
17:17
coach
121:9
coaching
121:10
Coast
40:6,20
Columbia
2:12 162:19
com
46:14
come
121:15 151:4
comes
65:16
coming
62:3,17
command
149:19
comment
14:5 120:15
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comments
44:3,7,7,9,10 119:14
120:4 121:4 144:9
145:20
commission
162:15
commit
71:4
committed
22:4 31:17
committing
154:15
communicate
24:17 110:3 153:9
154:13
communicated
32:18 65:4 134:7
communicating
50:17 78:7,10 154:16
154:17
communication
15:2 26:2,17 37:11
43:21 78:20 82:2,6
114:11
communications
115:13 134:9 135:19
135:21 139:12
community
10:15 94:6,10 95:11
95:18 100:1,4,7
comp
127:13
company
27:20 65:17
compensation
66:7,9,14
complaining
14:5 15:2 23:9 26:2
35:21 37:5 43:21
44:2 102:12 125:19
complaint
36:14 95:15 134:2
complaints
29:14,16 46:14 49:8
49:10
complete
80:16 89:19,20 161:6
completely
79:2 81:8 116:14
complicated
127:13
complied
143:6
composite
43:6 45:5 149:5
compound
55:7
computer
24:19,22 25:2,6
105:18 106:1,5 107:3
107:14,15,17 109:19
109:20 110:4,6
111:20,20 150:2
157:11,13
computers
25:1 108:3 111:21
157:15
comrades
94:2
concede
62:19 63:19
conceived
27:14
concept
47:21
concern
28:17 29:3 31:14
32:20 35:16 51:12
151:22 152:9,12,13
155:9
concerned
16:1 28:22 30:19
31:21 32:12 35:9
39:9,15 44:20,22
50:20 51:5,6,9 69:11
69:12,13,15 70:3
151:11,14 154:2,13
157:4,17
concerning
10:5 92:8 139:21
140:12 142:2
concerns
153:22
concluded
70:15 71:1 123:11
126:17 160:7
conclusion
132:2,4 141:11,12
conditions
114:2
confer
136:13
conference
24:9,12
configured
149:13
confused
32:14 50:19 54:13
56:2 63:8 84:2
145:11,15
confusion
50:13 54:3,10 55:18
150:12 154:6
Connerton
8:2
Connie
21:13,18 23:2,5 24:3
24:20 30:19 35:19
36:5 42:7 50:21 59:7
62:8 65:6 74:6,10,11
74:12 75:6,7,11,11
75:22 76:3,12,14,20
79:14 81:9 82:20
89:14 90:21 126:12
126:13,15 127:1,3,8
127:17 128:2 131:1
132:17 139:7,18
149:11,16,22 150:5
150:17 151:8 153:16
153:18 154:10,21
156:7,11,16 157:4
158:15
conservative
10:15 100:1,4,5,6
150:20
considered
68:9
considering
47:20
consistently
36:3
conspiracy
72:20
Constance
18:1 37:20 39:16
74:21 75:2 155:20
consult
141:22
consulted
142:8
consulting
142:12,17
contact
41:22 56:2 60:20
62:22
contacted
58:15,18 61:4,5,6,8,11
118:1
contacting
58:13 117:16 151:7
contains
118:20
content
15:15
context
49:5 52:3,19,19,20
53:11 59:15 87:14,15
114:10,11 116:21
131:8,10 137:15
144:16
continue
11:1,4 48:8 64:21
136:7,8 143:21
continuing
129:3 143:19
continuously
7:10
contri
34:18
contribute
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contribution
68:12 69:4,6,7,9
conversation
23:8,10 24:3,4,5,6
67:8 72:16 73:2
77:12,15
conversations
57:16 138:13
convicted
19:5 21:14 22:10
30:20 31:18 32:1,4
33:13,17 34:7,14,20
35:3 51:10 52:20
53:4,14 54:17 60:9
66:20 67:4 79:5
80:14 85:18 103:19
118:12 119:2 124:15
124:22 126:4 127:10
127:16 129:7 132:18
133:12,21 154:6
conviction
51:16,22,22 53:8
convoluted
31:11
copies
48:12,17
copy
4:16 5:11 73:9 78:19
90:3 148:10,19 149:8
copying
78:12
corollary
135:16,18
corporate
11:19,20
correct
9:2,15 10:5,11 13:10
16:2 19:14,17 22:11
22:13 25:9 26:19
27:12,14 28:1,9,14
29:9,11,22 30:22
33:6,18 34:3,10,11
34:15 35:10 36:7,11
37:1,9 38:1 39:2,11
39:18 42:3,6 43:16
43:19 44:4 46:6
49:13 50:18,22 51:10
51:18 52:13,21 53:10
53:17 54:12 55:19
56:22 57:3 58:4,19
60:5 62:8,10 66:3
69:1,14 71:11,22
73:7,12,15 74:5 78:3
78:18 81:6 82:3 85:5
85:7,10,21 86:9 87:3
89:3,11,15 91:20
93:13,20 94:6,12
99:4 100:20 101:8,11
101:13 102:21
103:17,20 105:10,12
109:11 110:14,17
112:16 115:4,15
116:10 117:19,20
120:14 123:6,8 127:6
127:18 131:15,21
132:13 133:1 139:19
140:7 150:13 151:8
153:10 154:3,19,20
155:4,21,22 156:17
157:18 161:5 162:5
corrected
84:6 85:22 125:15
150:11 153:3 155:3
correction
124:22 163:5 164:5
corrections
161:7
correspondence
110:20 111:2 117:6,7
Corruption
102:6
Cortland
48:13
couldn't
71:17 98:22
Council
100:19
counsel
6:13,16,17 7:3 16:7
63:19 64:4 85:1
86:18 100:19 139:15
162:8
country
52:1 54:16
counts
124:17,21 133:18
county
96:14
coup
120:4,8
couple
8:8 91:17 106:6
107:12 125:14
129:18 143:11 150:7
course
15:14 36:19 72:2
79:18 80:3 84:6
88:21 91:22 142:8
151:18 157:2
court
1:1 2:11 6:5,19 14:8
32:5,8 43:6 45:4
47:20 48:15 52:8,13
53:3,4 75:10 77:19
86:19 95:16 101:5
111:19 132:1 142:20
144:1 146:12 162:2
courthouse
90:2
Courts
96:14
covered
20:4
Craig
100:17 101:10,14
create
87:22
created
87:20 151:14 153:1
credit
102:20
crime
21:15 22:4,10,15
28:19 30:20 31:18
32:2,4 33:17 34:8,14
34:21 35:3 52:5
54:18 60:9 66:20
79:5 80:14 85:19
103:19 118:12
127:10,17 128:21
129:7 130:8 132:18
154:15
criminal
52:3,12,19,20 53:3,4
53:11 73:5 95:15
116:9 124:17,21
133:18
criticized
88:22 135:7
cruise
97:13,18 98:1,3
crystal
78:21
Cuba
92:16,19 93:6,13
94:17 100:10 101:4,7
Cuban
93:4,5,22 94:6,12,14
95:10
currently
40:12 92:10,11
C-SPAN
99:3
D
d
4:10,13 5:1 6:1 164:1
damage
65:6,19 66:15,16 71:3
141:7,13,16
date
6:8 8:5 72:22 161:11
163:22 164:22
dated
4:15 5:10 155:20
David
49:5
day
41:15 61:1 63:13 92:3
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121:14 147:12
162:12
days
41:10 118:3,22 125:14
143:9 146:10
day-to-day
42:2
dealing
139:17,21
deals
89:10 123:5
Dear
72:13
debatable
27:13 87:1
decent
10:22
decided
70:9 97:3 141:22
decision
159:11
decisions
13:9,14
deduction
27:11
defamation
59:20 60:2,10 72:13
80:4 103:18 141:19
defamatory
79:17 84:5 116:16
117:20 118:5
defame
60:8 72:20
defamed
33:4,4 59:6,11,14 60:4
64:15 65:9 141:15
default
93:16
defendant
1:8 3:11 75:11
defendants
93:4,15
define
24:1
definition
80:15,17
delay
136:16
delete
111:16,18
deleted
111:5,9
Dell
106:18
demand
66:9,13
demanding
66:7
demands
68:7
demonstrate
152:4
dentist
91:13
department
11:22 12:13 38:14
depends
10:17 11:7 41:3 42:2
73:20 81:15,20
131:16
DEPONENT
161:2
deposition
1:11 2:1 4:8 5:3 6:3,11
14:9,11 16:20,22
45:6,8 86:15 108:15
129:17 132:5 136:17
142:15 143:17 144:2
144:4 146:3,5,14,16
147:6,8,16,18 148:5
148:7 159:12 160:2,6
162:3
depositions
20:17 105:1
deposition's
159:21
describe
150:15
desk
106:12 107:13 110:4
details
24:2 96:7
determine
142:11
determined
108:6
developed
10:9 29:21
development
27:1 149:21
didn't
10:18 11:5 21:10 31:6
37:3 47:9 48:17,18
60:8,11 61:3 62:10
62:15 63:18 64:4
67:11,18 73:19 79:13
79:16 81:4 99:15,17
99:19 102:13 105:15
105:15 112:18
114:19,20 118:5,6,7
120:18 121:4 125:4
127:20 137:4 145:21
149:14,15 150:3
151:20 152:9 157:22
159:17
difference
51:15,18,19,20 52:21
53:2,6 131:20,22
158:2
different
8:1 16:16 28:10 63:1
84:19 94:19 96:14
100:7,8 134:3 144:8
145:8
difficult
36:8
diligence
82:19 131:14
Dina
3:22
directed
26:12,13,16 151:20
direction
162:7
directly
61:5,11 64:9
director
11:21 130:13 149:21
directors
12:1,3,6,12,15 75:17
117:5 126:20 129:5
132:12
disagree
141:11
disassociating
74:20 75:1
discerned
36:11
disciplined
134:12
disclaim
77:11,14
disclaiming
38:8
discovery
45:15 76:8 104:21
discuss
39:4 59:7 65:18 90:12
90:20 138:21 139:6
156:19
discussed
19:17 39:6 67:21 90:6
91:8
Discussing
90:10
discussion
15:8,12,15,16,18 18:7
19:19,20,22 20:4,7,9
21:8,9 37:15 72:2
140:1
discussions
15:19,20,22 38:6 39:7
56:22 57:3 67:20
dislike
30:4,14,18 49:18
dismissed
70:13 92:4
disparage
72:20
dispute
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9:21 88:11 114:6
137:5
dissidents
95:7
dissing
18:18
distractions
71:15
District
1:1,2 2:12 6:5,6
162:19
disturbing
156:13
document
14:20 16:17 19:11,12
36:7 62:15 120:6
143:4,8 144:17 146:8
146:18 147:10,15,21
148:1 150:3 157:1,10
documentation
57:8 142:16
documents
16:16 65:14 143:2,7
143:12,13 145:4
148:11 149:6 151:3
doesn't
52:4,9 57:13,15 77:5
77:11,14 87:21 89:18
89:18 90:5,5 103:13
106:19 119:15 121:1
123:9,16
doing
10:10 11:6,6 25:22
41:13,14,19 42:3,5
86:13 92:10 99:21
100:2 117:15 157:5
157:17 158:2 159:5
dollars
93:18
domain
129:6 131:12
donate
35:2
donors
19:4 33:12,16 34:6,13
127:11,18 132:19
don't
7:20 8:6,12 9:22 10:12
11:2 13:4,4 15:5,7,9
15:18 16:3,13,13
20:7,8 21:2,4,7,8,13
21:18 22:17 23:2,7
23:12,12 24:2,7,13
24:16 26:9,9,11,12
26:14,16,17 27:4
28:15 29:1,6 30:5,5,7
30:10,17 31:9,10,11
32:3,3 33:7,20 34:16
35:2 37:2 38:5,10,17
38:17,19,20,20,21
39:3,20 41:14 44:6
44:12,13,14,16 45:17
45:19 46:8 48:3,7
49:10,15,16 50:5,6,9
51:2,12 53:2,20 55:1
55:4,6,11 56:1,4,7,9
56:10,14,19 57:5,5,9
57:19,21 58:7,8,9,10
58:12 60:7,11 61:5
62:14 63:7 64:5,5
66:2 67:2,17,19,20
68:17 70:8,13,14,19
71:13 73:16,21 74:3
74:10,14 75:7,15
76:3,9,12,13 77:1,1
77:13,17 79:1,11,11
80:9,16 82:15 83:4
83:22 85:11 86:2,10
86:13,14 87:12,13,18
88:4,16 89:19 91:8
91:16,16 92:9,10,18
92:22 93:3,16 94:7
94:11,13 95:12,17,20
96:4,7,7,21,22 97:14
97:17,18,22 98:2,6
98:10,10,12,16 99:2
99:5 100:3,3,5,12,21
100:22 101:17
102:11,11,12,17
103:2,2,6,8 104:1
105:4,7,8,9 106:8,9
106:10,17,21 107:1,6
107:15,20,22,22
108:2,2,20 109:2,6,6
109:12 110:1,12,13
110:15,20 111:11,11
111:12 112:3 113:9
113:10,13 114:8,12
115:10,11,21 117:21
118:14 119:17
120:15,18,18 121:5,9
122:22 123:2,17
126:2,13,13,16 128:2
128:7 130:14,15
133:3,4,6,14,16,20
134:16,17 135:17
136:14,16 137:7
138:2,6,8 139:2,6
140:3,21,21 141:2,3
142:19 143:5,10
144:7,7 145:2,11,14
145:18,20,22 147:11
147:12,13,22 150:4
150:18 152:4,16,17
153:12 154:4 156:9
157:3,14,22 158:6,8
158:12,12,17,18,19
158:22 159:4,5,6
door
116:2,4,7
doubt
140:5
Doug
67:15 90:10 142:17
145:5
Douglas
3:12 6:17
downs
89:6
drawings
48:13,13
Driscoll
4:16 5:11 46:2 49:10
59:5 60:19 61:1,3,12
62:17,19,22 63:5,18
73:8,9,12,14 78:10
82:13 105:9 117:16
139:18 140:2 149:8
Driscoll's
78:6 80:20 81:1
drive
18:4 25:9 111:10,12
dropped
70:13
drove
17:18
dry
75:22
due
82:19 131:14
duly
7:1
duties
84:12
duty
71:5 130:4,16 131:3,6
141:6
D.C
1:12 2:7 3:8 6:12 9:21
48:5 49:6,9
E
E
1:4 3:1,1 4:1,6 5:1,1
6:1,1,4 163:1,1,1
164:1,1,1,1
Earlier
129:20
early
41:9
easy
133:22
Ed
93:1
effect
57:8 98:21 139:16
143:8
effort
126:5,22 155:3
either
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election
97:3
elections
96:11
electoral
152:22,22
Elian
99:9 100:10 101:1,3
eligibility
13:21 43:15 91:18,19
92:8 156:3
emphasizing
125:6
employed
162:9
employee
8:11 28:5 39:18 47:10
53:13 59:6 72:19
85:21 86:7 103:5
138:19
employees
126:20 129:5 131:11
137:9,19 138:1
139:13
encouraged
48:21 49:1,2
endearing
88:1
engaged
126:19
enjoy
11:2
enjoyed
9:7 10:20,20 11:5
equation
86:5 128:14
Ernie
40:13,14,16 89:21
Errata
161:8
error
124:13,20 125:1,2,16
126:1,12,12,14
especially
62:3 84:16,17 133:6
Esquire
1:11 2:2 3:4,12 160:6
161:3
established
74:12
et
27:20 61:18 65:5
72:13
ethical
85:9,19
ethics
85:5,16 117:18
Europe
94:22
Europeans
95:5
event
38:22 97:11 98:10
151:4,13,16 152:3
153:6
evidence
22:3 72:22
evident
125:10
exact
93:17
exactly
81:7 153:19
EXAMINATION
4:3 7:3
examined
7:1 161:4
exceeded
143:13
exchange
126:17
excited
120:9
excuse
6:10 9:9 119:21
127:15 155:21
exhibit
4:9,12,15,18,20 5:4,6
5:8,10 14:8,9 16:19
16:20 43:6,7,8,13,13
45:5,5,6 119:13,14
119:21 123:14 124:8
144:1,2,6 145:7,8,13
145:14,19,19 146:2,2
146:3,13,14 147:5,5
147:6,15,16 148:3,3
148:3,5 149:5,5,9
Exhibits
4:8 5:3 44:5
exist
131:18
expect
63:19
experience
34:15,19 66:20 80:22
83:11,18 142:9,12
expert
83:14,17 111:21
expires
162:15
explain
61:15 65:10 117:10
149:12
expose
122:7
expression
65:11
extent
139:4
extradited
114:1
e-mail
4:15 5:10 18:12 46:1
63:8 64:3,14,22
72:12 109:22 110:3
111:4,14 145:5
149:11,16 150:2,5
151:17 153:13,14
155:19 156:6,19,22
158:11,13 159:6
e-mailed
45:18 64:7,9
e-mails
24:15,16,20 25:3,9
61:2 68:1 71:14,18
72:16 109:10,14
110:9,10,13,21
F
face
66:1
faced
99:4
fact
12:19 13:1 15:12 20:3
22:13 50:16 59:11
60:3 74:20 75:9
83:14 86:11 112:18
116:7 133:14
facts
84:18,21 122:20
130:18 132:1 139:5
factual
134:4
failure
51:7
fair
29:18 103:3 139:3
fairly
24:17
faith
143:12
falls
78:17
false
47:18,21 61:17 62:1
64:15 65:10 69:5,8
69:14 70:4 71:11
80:13 86:6 87:8
119:5 131:12 151:15
153:1,4
falsely
130:9
familiar
22:18 43:18
family
93:8 99:8,15,17,21,22
famous
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Farrell
12:4 13:8 15:6,19 24:8
24:11 26:13 29:7,17
57:12 102:20,20
140:4 156:3,7,20
158:14
Farrell's
12:9 57:2 108:1
father
100:22 101:5,7
father's
101:2
FBI
18:5
February
17:9,13 18:13 41:12
41:15 61:12 64:22
72:17 106:2 108:18
110:6 111:6 117:7
119:21,22 120:8
124:19 125:10,14,15
128:10 133:19
feel
82:11
felony
22:16
felt
82:10
fences
9:20
fictitious
156:14
Fidel
92:14
fiduciary
130:4,16 131:3,6
132:2,15 133:5
fields
41:20
figure
45:2 88:10
figured
123:11
file
48:21 49:1,2 66:2 90:2
95:15 110:20 111:2
115:18
filed
18:15,20 29:13,14
49:9,10 96:6 117:11
119:7
files
89:12
filing
29:15 36:2 65:17
66:10 92:7
final
51:22 53:8
finaled
70:2
finally
18:18
financial
162:10
find
88:1 122:9 127:1
129:12 131:14
132:16 140:10
154:19
fine
48:9 70:17 98:13
122:20
finish
55:8 125:8
fired
94:1
firm
8:2,10 11:9 28:1 72:14
112:22 113:2
first
14:22 17:10 43:7 45:9
55:14 72:11,12 80:4
85:14 120:1 124:12
137:4 146:11 149:6,7
Fitton
12:4 13:8 15:4,19
19:17,21 20:9 21:3
24:11 26:7,13,14
27:6 28:12 29:7,17
56:21 57:12 65:5,7
65:16 72:19 87:15
102:19 140:1 149:12
149:17 156:2,7,19
157:3 158:14
Fitton's
12:14 107:21 157:11
fixated
29:11
floating
111:3
floor
106:15
Florida
1:2 3:16 6:6 9:18
18:15 47:8,20,22
48:3 91:20 94:17
96:11,14 102:3
focus
35:15 85:16 145:21
follow
55:16 149:19
following
147:4,14 148:2
follows
7:2 137:4
Force
93:20,22
foregoing
161:5 162:3,4
Forez
93:1
form
20:13 21:16 22:6,22
25:20 30:1,12 31:1,7
33:19 39:12,19 46:22
49:14,19 51:11 53:18
54:20 60:17 66:22
67:1,2 68:16 70:7
71:7 74:8 75:12,19
76:1,17,22 77:7 79:6
82:14 102:22 103:22
104:12 105:5,11
127:19 129:9 130:11
132:20 133:2 134:14
139:9 140:15 141:9
142:3 153:11 155:5
155:10,13 157:19
158:7,21
format
145:9,11,15
former
26:18 47:10 53:14
103:5 115:17
forming
85:13
Fort
101:21
forth
13:6 53:1 88:20
forward
72:6,8
forwarded
61:3 147:1 149:16
found
9:2 153:8
foundation
79:21
founded
28:18 85:9
founder
26:18,19,20,21 27:2,4
27:11 50:3,11 56:1
93:2
frame
113:17
fraud
113:22 115:3
free
5:6,8 65:2
freedom
9:7 10:21
french
65:11,13,15 95:2
frequently
55:22
Friday
146:22
friends
97:19
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frivolous
69:17
front
47:7 49:6 69:21 86:19
95:2 97:6,8 106:12
119:15,18 123:17,18
133:7
full
40:16 60:21 139:4
fully
143:6,6
full-time
8:15
function
153:15,16 154:9,10
fundraising
16:11 17:5
funny
23:15 65:16 129:13
further
59:18 63:22 111:18
134:2 142:14 150:12
future
134:8 135:11 138:5
G
G
2:6 6:1,12 35:7
games
54:4
Garden
17:17 36:15 128:11
Gardens
3:16
general
21:5,6 23:10 52:16
84:20 100:15 105:15
generally
25:6 56:7 110:15,21
137:8,19
getting
9:9 19:18 20:19 28:16
32:11 35:8 48:12
60:14 74:9 76:6
84:11,22 90:11
111:19 114:15
135:13,18
get-go
122:4
give
23:19 25:14 68:14
70:10,17 121:5 143:9
given
17:16 28:7 42:20 68:5
104:20 117:3 119:4
127:11 132:19 139:5
144:21 161:6 162:5
Glad
122:8
go
13:18 14:12 38:3 43:7
43:7 48:19 55:8 59:3
59:18 60:19 61:10
69:10 72:5,10 75:9
120:10 136:15,17
142:19
goes
54:16 134:2
going
14:7,14 34:18,19
37:13 42:19 43:5
44:17 54:4 55:13
60:16 72:6 81:19,19
82:22 84:10 101:6
102:22 108:10
111:18 116:11,12
123:3 124:1,11
130:14 131:9,21
134:20 135:12
136:18 140:14
142:15 148:9,21
151:2 160:3
Gonzalez
99:9
Gonzalez's
101:1
good
10:16,18,22 35:4 87:7
110:1 143:11
Goodness
5:5
Gordon
35:7
Gore
96:10 97:2
govern
112:7,11
governance
13:16
governed
134:9
government
10:5 65:13,14 93:4,5
graduate
7:7
Graham
3:21 6:11
grant
98:7
grateful
94:8
greater
51:13
Gregory
100:17 101:10,14
group
11:12 18:10 117:18
Grove
17:17 36:15 128:11
guess
30:10 41:16 97:4
98:12 109:6 111:14
127:20 145:13
149:18 151:19 156:5
guilty
52:2,5 53:10
guts
49:13,16
guy
7:19 107:15,17
H
H
4:6 5:1 163:1 164:1
hand
162:12
handed
72:21
hands
79:3
hang
98:8,11
happened
18:21 25:12,18 86:9
88:11,12 107:13
122:1 126:16 152:11
happy
54:8 58:1 86:13 131:5
harass
121:20
harassing
121:22
harassment
118:9 119:10 123:12
126:19 129:3
hard
18:16 25:9 47:13
99:22 111:9,11,12
harm
63:22
harmful
118:6,13
hat
91:4
hate
49:12,15,16 110:2
111:3
haven't
24:19 56:6,13 62:14
129:16
head
11:21 12:12 28:9
38:13 53:14
Headquarters
18:4
hear
17:19
heard
18:8 37:4
hearing
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98:4
hearings
48:14
hearsay
123:1
held
2:2 65:9
helped
120:10
hereunto
162:11
he's
12:11,15,15 40:17,22
41:5 42:3,5,8,9,10,11
42:11 46:3,4,8 53:16
78:12,19,19 118:12
129:7 154:14
highly
86:21
Hillary
101:15
hired
8:3
history
59:16 68:5 119:4
137:11,21
holding
75:22
home
105:19
honest
121:17
hopefully
63:21 142:16,17
host
134:3
hour
17:19
hours
18:14 106:22 141:4
house
101:12 113:11
Hugo
96:1
Huntington
18:4
hypothetical
21:21 60:6 86:1
130:20 131:8,18
hypothetically
137:16
hypotheticals
22:1 60:14 76:7
I
idea
27:15,15,16 85:12,13
85:14 106:22 114:16
115:16 122:21 159:6
ideas
42:1
identification
14:10 16:21 45:7
144:3 146:4,15 147:7
147:17 148:6
identify
6:13
ignoring
133:13
Illinois
69:22
impeachment
101:11
important
21:10,13
impression
153:1,5
imputing
52:10
inaccurate
70:17,18
incident
93:21 94:4
include
7:16 46:14 130:16
included
45:19
income
114:5,21
inconsistent
55:7,11
Incorporated
6:5
incorporation
27:19,20
incorrect
74:2
indefinite
56:9
indicating
108:21
indict
52:7
indicted
31:21 51:6 52:12,19
53:3 113:22 118:21
119:1 124:17,20
125:12 126:7 133:17
134:1 154:6
indictment
32:10 51:15,21 52:4,6
52:8,16 53:7,9 72:21
73:5 115:2,2
indictments
52:7
individually
65:7
individuals
56:22 134:8
infamous
99:13,14
information
19:7 62:18 115:8
127:11,18 132:19
informed
34:7 61:15
informing
78:19
initially
113:3 120:9
initials
150:13
initiated
18:7
ink
120:16
innocent
52:1 53:9
inquire
58:9
inquiries
150:7
inquiry
83:7,9 84:8 85:21
instance
65:9
instructing
84:13 136:10
instrumental
29:15 49:8 62:5
112:20 114:18
115:17
intelligent
86:21
intelligible
54:5 57:22 86:15
interest
11:12 92:7 96:19
154:16 162:10
interested
156:12
interesting
9:6
interests
154:12
interference
9:10
interfering
33:5
internationally
54:17
internet
118:4
interpreted
71:14,19,22 117:8
118:8
interrogatories
92:3
intervene
98:6,7
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intervened
96:9
interview
60:22
intimidate
23:16,18
intimidating
129:15
intimidation
121:13
invasion
47:18
investigate
130:9
investigations
12:13
invited
97:10 150:10 151:12
151:15 152:15
153:15 155:1
inviting
152:2 153:5
invoking
139:4 140:13
involved
18:9 131:21 151:9
152:1,21,22 154:14
155:12
involving
9:19 80:4 92:19 93:22
96:6 104:7 108:3
152:1
in-house
138:18 139:15
irrelevant
80:21 116:15
isn't
40:16 76:14 97:2
106:13 141:17
issue
13:19 25:5 32:19
50:10,11,15 61:17
63:20 64:6 75:4
82:12 83:5 92:18
103:10,18 104:10
113:22 118:7 119:2,4
123:10 127:6,7,21,22
128:1 139:17 150:16
152:1
issued
28:21 126:10
issues
42:1 89:15 90:16
127:12 152:22 153:1
Italian
95:3
it's
16:15 21:13 27:13
30:6 31:14 36:1,8
47:13,22 51:3 56:12
59:13,13 61:16 63:4
64:20,21 67:15 70:18
73:6 74:11,17 78:7
79:2 81:7,8,20,21,21
84:2 86:1 87:22
88:19 90:7,14 94:16
100:7 102:18 103:8
103:11 106:12,14,14
106:14,17 107:10
108:21 109:19
111:14 112:7,9,12,13
114:12 116:14
120:16 121:12 123:3
123:3,15 128:19
129:2 131:12,20
133:8,15,22 135:14
135:15,15,17,20
136:1,8 139:2 140:8
141:12,15 148:11
149:13 150:20
I'd
77:17 89:7
I'll
14:7 43:5 45:4,4 54:8
58:1 86:16 90:7,14
98:7 111:15 123:20
133:3 136:7,8 143:22
143:22 146:1 147:14
148:2 157:10
I'm
6:15 9:9 11:20,20 12:1
13:15 14:1,7 16:8,8
16:13 19:18,20 21:7
21:22 22:17,17 23:18
25:13 27:18 28:16
30:16 31:9 32:11,14
35:8,11 36:8 38:12
38:12 40:3 42:19
43:5,17 44:17 46:16
46:18 47:1 50:17,22
52:22 54:2,4,11
55:13 57:1,4,14 59:5
59:11 60:7,14,16
61:7,7 63:7 64:10,15
65:15,18 66:1 69:22
70:3 71:11 76:6,6
77:8 79:21 80:18
81:14,19,19 82:4,22
83:13,14,17,17,19,20
83:20 84:1,2,10
86:10,10,12 88:15
90:11,19,20 91:9
94:16 97:21 101:17
102:1,22 103:16
104:13,14 109:12,12
109:17 110:1,4
111:18 112:2 114:9
114:14 115:5,10
116:11,12 121:10,17
121:22 122:13 123:3
124:11 125:4,6,17
128:11,18 129:22
130:14 131:3,5,6,8
131:10 133:21
135:12 136:13
137:18 138:14,14
139:3,14,20 140:14
140:19 142:15
144:11,13,13,15
145:11,15 146:9
148:9 151:1 152:7,8
157:7,14,17 158:2
I've
8:16 20:6 32:7 44:14
45:14 58:20 72:3
73:20 81:2,2 105:14
108:20 110:22 111:1
129:10 141:4 143:3
155:14
J
J
3:12
jail
114:2
James
3:22
Janet
100:12,14
January
1:13 6:8 155:20
162:13
Joan
1:22 2:10 6:20 162:2
job
1:20 140:8
Jog
3:15
joke
128:19,20 129:2,8
Joseph
7:6 160:6 161:3
Jos
93:2,19 94:1,7
judge
47:6,8 49:6,7 69:21
96:18 97:1,4,8,10,20
98:5,5,13 156:3,14
157:5 159:9,10
judgment
93:16
Judicial
1:7 6:4,18 8:11,14,15
8:17 10:2,6,19 11:15
12:6,10 13:9,16
17:18,22 18:3,6 19:3
25:13,19 26:19,21
27:3,6,8,16 28:3,5,6
28:9,18 29:17,19
30:21 31:19,22 32:13
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32:21 33:4,11 35:17
36:2 37:1,22 38:4,9
38:14 39:2,10,18
40:2,6,20 41:8,13
42:17 46:3,5 50:1,3
50:13,17 51:1,8
53:13,14,16 54:12,18
55:16,18,20 56:1,3
56:17,18 58:3,3,11
58:13,14,15,19 59:1
59:6 61:14 65:5,8
68:5,8,11,13 69:18
69:19 72:14,18 73:3
73:6,18 74:4,15,18
75:3,17 76:20 77:21
78:8 79:9 82:18,18
83:8 84:7 85:1,4,14
85:20 86:7 88:3
89:10,16,22 92:12
93:12 94:20 95:21
96:2,6,9,20 99:8,10
101:20 102:5,21
105:20 109:4 113:4
114:17,22 115:17
116:8 117:17,18
118:9 119:9 126:19
126:22 127:9 129:4
130:2,4,8 131:7,11
131:13 132:13,16,22
133:1 137:22 138:15
138:18,19 139:7,13
139:15,20 141:5,6
148:12 149:7,9
150:10,22 151:6,12
151:15,18 152:2,8,14
153:1,5,15 154:1,2,9
154:12,17 155:1,2,17
157:2,6 158:3 163:2
164:2
judiciary
85:12
July
10:3 27:5
June
162:16
jury
99:1,4
justice
52:12
JW
120:6 123:15 124:7
149:9
JW000001
4:13
JW000013
4:10
K
KAHLE
3:13
keep
42:13 47:13 74:9
110:13,15 111:8
132:8
kept
110:16 151:17,19
157:1
killed
94:3
kind
95:17 102:17 106:1,7
106:16 107:8 108:19
112:7 117:6 157:13
kinds
41:22 94:18 159:15
Klayman
1:4 3:4,5 4:4,17 5:12
6:4,15,15 7:4 8:9,13
9:13 14:19 16:10,18
17:2,5,12,13 18:8,20
19:2 20:16 21:20
22:8 23:4 26:5 28:1
30:3,15 31:5,13
32:15 33:1,9,22 34:7
34:14 35:13,18 37:12
37:18 38:18 39:14,22
42:19 43:3,4,9,12
45:11,16,18,21 46:1
47:3 48:9,11 49:17
49:22 50:21 51:14
53:22 54:17 55:3,17
57:7,14,18,22 58:4
58:17 60:18,20 61:20
61:22 63:3,5 65:1,21
67:7,14 68:10,19
70:16 71:2,10 72:12
72:14 74:19 75:13,21
76:4,18 77:3,10,15
78:4 79:8,15 81:16
82:4,9,16 83:5,16
84:13 85:3 86:3,5
90:10,18 91:11 98:6
98:20 103:9 104:3,16
105:6,17 108:9,17
112:1 115:14 116:1,6
116:17 119:12,20
120:3,9 121:5,9,16
123:19,22 124:6,12
124:14,20 128:4,13
129:11 130:12
131:20 132:18,21
133:10,17 134:19
135:6,15 136:10,15
137:14 139:8,10,18
140:12,17 141:1,7,14
142:6,14 143:16,22
144:5 145:4,16 146:7
146:12,17 147:4,9,14
147:20 148:2,8,15,19
149:4 152:2 153:21
154:14 155:4,8,11,16
156:12 157:16,20
158:9,11,15,17 159:2
159:3,12,17 163:2
164:2
Klayman's
33:17 56:16,18
knew
58:12
know
10:12 15:5 16:3,13
19:4 20:3 21:18
22:17 23:2 25:18
26:9,11 30:5,5,7,10
32:3 33:12,20 34:16
34:22 35:2 37:2 38:5
38:10,15,17,19,20,21
38:21 39:3 41:14
42:1 44:13,14 46:8
47:13 49:11 51:2,12
51:18,19 52:6 53:2,5
56:1,4,14 57:5,13,15
58:7,8,9,10,12 60:11
61:4 62:14 63:7
65:17 67:2,11 71:13
73:21 74:11 75:7
76:3,13 77:1,17
80:19,22 85:11 86:10
86:13,14 87:12 88:16
88:17 89:4 90:11
91:5,12,16 92:1,9,9
92:10 94:7,7,13,16
94:17 95:12,20 96:12
96:21,22 98:6,10,12
100:3,5 101:1,17
102:11,13,15 103:5,6
104:14,17,19,20,21
106:8,9,15,17,21
107:15,22 108:2,4,5
108:20 109:2,6,17,18
110:12,20,21 111:11
111:11,12,13 113:13
114:6,8 115:11
116:12 117:21,21,22
118:14,22 120:15,18
120:18 121:4,18
122:22 123:2,2 126:2
126:3,13,13,16 128:2
128:7 130:15,17
133:3,4,6,14,16,20
133:20 134:3,16,17
135:17 140:3,21,21
141:3 143:10 144:7
145:11,15,18,22
150:18 152:4,15,16
152:20 154:4,5 157:3
157:14 158:6,8,14
159:4,5,6
knowledgeable
89:15
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known
10:13
knows
57:11
Kollar
47:7
Kollar-Kotelly
47:8 49:6,7 69:21
Kress
3:12,13 6:17,17 9:12
14:12 16:16 20:13
21:16 22:6,22 25:20
30:1,12 31:1,7 32:14
32:16 33:19 35:11,14
38:15 39:12,19 43:2
43:8,11 45:9,13,17
45:19 46:22 48:7
49:14,19 51:11 53:18
54:20 57:10 58:5
60:16 63:1 66:22
67:12,18 68:16 70:7
70:21 71:7 74:8
75:12,19 76:1,17,22
77:7 79:6 81:15,19
82:14,22 83:12 84:10
84:15 90:7,14 91:2
102:22 103:21
104:12 105:5,11
115:5,21 116:11
118:16 119:15,19
120:1,22 121:3,10
123:16 127:19 129:9
130:11 132:20 133:2
134:14,18 135:12,17
136:7,12,16 138:11
139:9 140:14,19
141:9 142:3,21
143:19 145:1,6
146:22 148:14,16
153:11 155:5,10,13
157:19 158:7,21
159:20
L
LAD
2:4 6:20
language
98:9
Lanham
9:21
laptop
105:18 107:8
large
19:6 33:13
largely
94:12
Larry
1:4 3:4,5 6:4,15 16:10
17:5,12,13 18:8,20
19:1 32:4 33:9,17
34:7,13 46:1 49:16
49:21 50:21 54:2,17
55:6,17 56:16,17
58:4 59:8 60:6,20
61:19,21 63:5,22
65:1,21 68:18 69:17
72:12 75:4 77:15
78:3 79:14,22 86:3,5
87:22 111:22 112:13
120:9 121:15 122:19
128:13,15 131:20
132:17 133:17 139:8
139:18 140:12 141:7
152:1 154:14 155:4
158:13 159:6
late
41:9
Lauderdale
101:22
laughing
129:12,14
law
3:5 7:8,16,19,20,22
8:2,2 11:9 16:11
17:6 22:18 28:1
47:22 80:7,10 89:15
92:11 101:15,18,19
103:4 112:22 113:2
141:22 142:8,12
lawsuit
47:6,7,17 48:2,4,20
49:3,4,5 66:11 70:10
75:4 81:21 86:12
90:8,16 91:22 92:20
93:15 95:22 101:21
103:4 104:10,14
112:15,18,22 113:3
114:17,19 115:18,19
129:1 131:2,5 135:22
lawsuits
17:13 29:13,14 46:9
46:10,15 47:14 62:5
68:6 89:11,12 91:15
91:19 92:7 93:6
117:3,12 119:6 122:4
137:12,21
lawsuit's
47:12
lawyer
7:10 11:22 20:1 22:4
26:1 34:15 46:3,4,8
46:20 49:4 64:9,13
64:14 68:2 71:6
73:17 79:19 80:1,3
81:2 83:11 89:18
90:17 91:4,7,13
100:17 101:2,11
132:1 136:1 138:14
138:22 139:6
lawyers
22:9 46:15 66:16
89:19 112:10
lawyer's
129:7
lay
79:21
leadership
150:21
Leading
13:21 43:15
league
121:12
learn
37:21 63:20
learned
38:3,5 58:15 116:22
leave
142:15 159:12
left
8:17 12:6 29:19 50:1
58:13 68:21 89:8
94:21 95:21 96:2
101:20 116:8 143:17
legal
7:17 11:21 34:12
38:14 42:3 59:14
77:21 78:8,18 82:17
83:7 84:6,22 89:22
90:4 117:17 132:12
139:21 141:10,11
letter
4:16 5:11 26:1 50:2,10
59:4 72:11 73:11,14
73:17 74:15 78:22
80:20 81:1,3,5,8
112:8 149:8
letterhead
149:12
let's
13:18 16:5 21:21
25:12 34:1 43:7,7
45:3,12 48:22 54:7,9
58:2 59:3,18 60:19
61:10,13 64:10,22
72:5,10 93:9,11,11
103:12,14 117:13
119:13 128:13
136:17 148:19
levels
123:1
libel
66:21 80:10,12
license
22:10
licensed
19:2 33:10
Liddy
35:7
life
61:18 62:2
631

Merrill LAD
Page 16
light
42:20 47:18,21 65:10
liked
9:8 100:1
likes
159:4
limited
89:17
LINE
163:5 164:5
link
124:16 125:11,12
linked
109:19
list
7:13
literature
39:1
litigate
69:20
litigating
104:20
litigation
11:21 19:4 33:12
36:20 38:11 41:21
46:5,7 70:1,15 84:5
84:12,21 96:13 97:15
127:5 134:11 135:19
little
9:10 63:10 92:20
109:18 110:2
loading
108:5
lobbied
95:5
logs
42:16
long
7:21 9:5 20:1 40:1
46:20 106:22 123:12
150:18
longer
19:3 33:11 59:2 97:15
look
25:7 33:8 34:1 45:9
63:10,16 119:13,13
120:4 122:3 123:14
148:16
looked
14:6 32:7 108:6
111:20 118:1,4,14
119:3 123:10
looking
16:8 43:9 120:5
looks
149:20 150:17
loose
52:8 113:13
lose
22:9
lost
52:22
lot
9:7,8 10:21 19:6 89:10
91:15 99:15,19 100:7
100:8 111:15
lots
13:13,14 56:10 96:12
loud
34:4
Louise
48:20 68:12 70:5
lovers
87:18
M
mad
122:1
mademoiselle
65:14
mail
72:12
making
35:16 36:2 44:22
61:17 62:1 66:6
67:22 73:4 74:17
75:6 86:6 113:15
119:11 124:22
127:21,22 128:1
137:12 152:17
159:11
manager
42:10
managerial
40:8
managing
42:8
manipulation
113:22
manner
137:8
manning
39:1
manufacture
62:15
March
41:7,10 72:11 78:22
Margarita
91:14
Marino
17:19 18:4 40:12
41:11,17
mark
14:8 16:18 43:6 45:5
144:1 146:13
marked
14:10 16:21 17:10
45:7 144:3,8 146:2,4
146:15 147:5,7,15,17
148:3,6
marks
108:14 160:1
Maryland
49:9
match
18:18
math
79:22
matter
6:4 31:6 65:5 66:15
69:20 72:15 99:12
103:13 117:8 119:8
125:20 134:16
139:13 140:2
matters
63:21 65:19 78:9
89:22 105:21 127:9
139:21
may
21:7 24:3,4,6 39:6
44:15,17 67:21 79:4
88:11,12 117:19
127:2 136:13
mean
10:6 20:21 23:22
34:16 42:16 51:2
52:4 59:13 66:16
84:15 87:16,22 88:15
88:19 90:4 104:13
111:7,12,22 113:18
118:18 119:3 136:14
136:16 137:5 141:21
151:1,19 159:1,9
meaning
52:10 58:11 75:3 79:9
means
21:1 113:15 114:5
media
50:14
mediation
48:15
meeting
36:6,11,15,21 37:4,9
37:22 39:11,17 128:9
member
12:1 17:22 128:16
130:2 132:11
members
93:10
memory
103:15,17,20
mention
102:9,16,17
mentioned
13:8
Merrill
2:4 6:20
message
60:21
met
631

Merrill LAD
Page 17
18:18
Miami
9:18 94:9,15 95:18
96:1 99:12
million
93:13,17
mind
80:19 83:2,6 123:5,10
mine
9:12 35:20 46:17
108:5
minute
104:22
minutes
71:17
misleading
80:13
misspeak
133:22
misspoke
133:22
misunderstanding
112:3 152:5
misunderstood
151:5
mitigate
65:19 66:2 71:3,5,12
141:7,13,16
mitigation
71:8 141:17,21
mix
94:18
Mm-hmm
7:12 40:15 65:3 85:8
89:13 102:8 124:9
130:3 132:14 134:19
150:6,14 153:7
155:18
moment
134:18
Monday
1:13
money
18:11,21 66:18 68:15
68:20,21 69:13 70:4
70:6,10 113:8,10,15
122:6
monitor
6:9 106:16 107:6
month
110:22
months
65:10 106:6 110:22
morphed
85:15
mosque
101:21
motion
75:10
motivates
35:2
motives
120:11
mouth
74:14
move
98:19,22 132:10
movie
156:14 159:11
multipage
149:20
multiple
29:13 54:22 55:7,9
62:5 123:1 127:12
multi-tasking
122:10
N
N
3:1 4:1,1 5:1,1 6:1
164:1,1
name
7:5 18:1 50:12 102:10
102:14,16,17 107:18
named
7:19 100:17
National
100:19
necessarily
22:7 131:16 145:20
necessary
73:6 74:18 153:8
need
18:14,15 43:1 45:13
118:16 134:15 136:9
136:13 143:5 154:19
needed
151:8 153:3
needs
150:11
negative
88:14,17 89:2
negatively
28:22 30:21 31:19,22
51:8 54:18
nego
88:9
negotiate
88:9
negotiations
88:12
neither
162:8
never
12:21 18:17 32:1
68:14 87:19 109:22
112:10 140:9
new
32:21 106:4,5
news
55:20 120:10
nice
107:5
night
107:16
nineteen
27:5
ninety
27:5
non
124:15
nonsensical
56:12
nonsupport
133:18
non-existent
16:11 17:5
non-support
73:5 124:17,21
Norris
40:14,16 89:21
Norris's
40:19
North
3:15 114:3
Northwest
2:6 3:7 6:12
notarial
162:12
Notary
2:11 162:18
note
23:9
notice
2:10 111:21 112:4,6,9
notoriety
10:9,12
number
117:3 119:6 132:4,5
134:4 149:10 158:17
158:18
O
O
4:1 5:1 6:1 164:1
oath
23:14
Obama
13:21 43:15 61:16
92:8 122:7 146:19
Obama's
18:18 91:19
object
60:16 67:1 74:13
81:20 82:22 84:10
102:22 103:21
116:11,13 130:14
136:7,8 140:14 142:4
143:19 159:14,16
Objection
631

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20:13 21:16 22:6,22
25:20 30:1,12 31:1,7
33:19 39:12,19 46:22
49:14,19 51:11 53:18
54:20 58:5 66:22
68:16 70:7,21 71:7
74:8 75:12,19 76:1
76:17,22 77:7 79:6
82:14 103:21 104:12
105:5,11 127:19
129:9 130:11 132:20
133:2 134:14 139:9
141:9 142:3 153:11
155:5,10,13 157:19
158:7,21
objections
143:3,15
obligation
74:5 82:11,19 83:7,9
83:10 84:8 86:8
117:19 130:9 132:3
132:15 133:1,5
obligations
130:15 143:7,13
obtain
93:13
obtaining
142:16
obviously
25:16 94:5
occasionally
41:8
occur
59:20,21,22
October
41:10
offense
22:19
office
18:2 40:5,6,12,21
41:11,18 42:2,8,11
42:11 53:13
officer
77:21 78:18 82:17
84:7 117:17 132:12
162:2
officers
126:20 129:4
offices
2:2
official
12:21 13:5
officials
93:4
oh
5:4 8:6 10:12 11:7
16:5 32:7 41:20 44:6
44:9 46:12 60:6 63:7
73:20 78:13 87:16
88:15 96:12 98:9
104:6 108:3 111:7
113:9 121:18 122:14
125:6 127:12 144:15
145:10 150:17
Ohio
19:4 22:18 28:21
31:21 32:6 33:12
72:22 124:21
okay
7:10 9:1,4 13:18,19
14:7 15:17 16:6,18
17:1,8 19:10,16 20:3
25:12 27:5,11,18
28:7,16 32:16 33:8
34:3 35:14 42:19
43:3 44:9,10 46:10
49:18 50:1 52:4
55:14 58:22 59:3
62:16 63:4,7,15,16
67:15 72:9 78:6,13
80:9 85:17 87:7 88:5
89:7,10 90:11 99:7
102:2,9 111:22 112:9
117:14 118:11
119:19 120:2,6,7
121:9 122:14 125:9
128:1,14 129:21
132:15 138:7 140:9
145:6,10 146:1 147:4
148:13,14,18 157:9
159:8
old
107:11,14 108:7
once
97:5 129:16
ones
13:9 93:7
ongoing
118:9
open
116:4 142:16 143:17
159:13
opened
116:2,7 159:16
operations
42:2
operative
139:5
operator
6:10,10
opinion
30:7 52:8,13 83:20
118:13
opportunity
9:6 120:20 131:13
159:15
opposed
52:20 53:3
order
63:11
orders
156:3
ordinary
84:6 151:17 157:1
Orfanedes
1:11 2:1 4:3 6:3,22 7:6
7:7 23:15 24:8,10
28:17 42:22 46:21
57:20 73:10 79:10
86:18 103:14 108:15
116:19 117:17
128:17 149:8,11
156:2,7 157:8 160:3
160:6 161:3
organization
11:22 12:16,17 13:6
27:16 29:1 45:1 56:4
59:2,17 62:4,6 85:4
85:13 115:18 117:1,5
119:6,7,11 123:13
137:13 139:22
150:20,21 152:14,19
organizations
151:10 152:18
organization's
69:16
origin
122:22
original
85:13
Orly
4:9,12,18 13:20 21:14
21:19 31:15 33:15
34:5 35:9,19 36:6
43:14 74:7,10,11,12
75:2,7,7 77:12,15
78:4 79:4,14 82:20
90:6,12,20 91:8,9,12
92:6 122:8,10 124:10
131:1 151:3,5,7,11
151:16,22 153:5
154:18
outcome
162:10
Outlook
110:3,7,10,17 111:5
111:10,14
outrageous
73:1
outside
150:22
overlap
8:12
owes
124:18
P
P
3:1,1 6:1
page
631

Merrill LAD
Page 19
4:3,8 5:3 16:9,14,15
45:22 46:1 59:4
62:22 63:10,16,17
72:11 120:5,16
123:15 124:7 145:12
145:14 149:6,7,9
163:5 164:5
pages
1:21 63:2
Palm
3:16
paragraph
124:10 133:17 145:12
145:14,19
paragraphs
133:14
parens
156:11
parliament
95:3,3
part
42:9 58:11 118:8
123:12 126:18 129:3
152:5
participants
72:20
participate
73:4 74:16 96:19
participated
96:10
particular
24:2 41:15 84:18
particularly
10:10 42:9 65:16
99:12
parties
162:9
parts
41:9
pass
8:5
passed
8:4
pattern
119:10 126:18 137:11
152:5
Paul
1:11 2:1 4:3 6:3,22 7:6
49:2 73:9 79:9
108:15 112:16,21
113:5,6,7,9,20
114:10,17,19 115:1
115:19 116:8 117:16
149:8,11 156:2 160:2
160:6 161:3
Paul's
114:20
pay
51:7 106:10
paying
19:5 33:13
payment
124:15
pending
47:7 69:21 96:13
104:15
Pennsylvania
3:7 113:4
people
10:21 11:1 13:7,13
17:21 20:11 23:16
25:15 29:13 34:18,19
35:2,5 41:22 50:16
50:16,19,22 51:2
53:16 54:10,13 55:14
55:15 56:1,10,15
57:12 58:2,8,18 88:1
88:20 94:18 99:13,15
99:19 100:7,9,11,11
122:7,22 151:6
perceive
68:2 84:4
perceived
83:2
perception
126:14
period
9:14 24:21 88:8 99:9
periodic
108:4
permissible
22:2
persecuting
95:6
person
71:9 86:21 139:16,20
personal
61:18 62:2
personally
43:18 46:11,12 47:4
92:15
personnel
134:16
Peter
49:2 112:16
Philadelphia
121:13
phone
9:11 41:21 108:19
109:10,14
phonetic
93:1
phrase
20:20 36:10,10 52:9
phrased
36:9
picture
146:19
pieces
46:7
PJO
150:12
place
6:11 37:11 128:10
places
9:22
plaintiff
1:5 3:3 6:16 7:3
141:15,18
plaintiff's
4:8 5:3 14:8,9 16:20
45:6 141:12 144:2
146:2,3,14 147:6,15
147:16 148:3,5
platform
17:15
play
54:4
played
26:22 101:3
pleadings
90:3,3
please
6:13,21 7:5 24:1 33:16
45:22 47:17 59:7
86:15 112:7,10 121:5
121:9 124:7 148:15
PLLC
73:9
point
8:11,14,20 29:8 31:20
56:14 61:8 64:20
81:22 85:15 88:13,13
98:20 113:5,21 118:1
139:16,20 142:9
political
150:20 151:9,13
152:14,18,19 153:6
154:1
Pool
9:20
pools
9:19
popular
94:6,9 95:10,18
population
94:14
posed
132:6
position
11:18 12:9,14,21 13:5
40:8,20 74:4 76:14
139:11,12 141:5
positive
89:3,4 120:13 122:15
123:2
possible
115:2
post
124:12
631

Merrill LAD
Page 20
posted
14:6 17:9 18:12 44:1
118:21 124:10
125:11 126:3
posting
15:3 16:7 21:3 23:9
24:4,17 26:2,6 32:20
34:10 35:22 36:18
37:5,5 43:14,21,22
79:16 116:22 118:3
118:14,15,18,19,22
120:1 125:18 126:9
126:17 130:22 150:8
150:9,11 154:3,7,20
155:3
postings
44:4,4 117:22 133:7
potential
53:15
practice
111:2,8
practiced
121:14
practicing
92:11
preoccupied
158:20 159:1
preparation
27:19
prepared
60:7 80:18
prerogative
68:4
present
3:20 128:9
presentation
16:9 17:4,14,16,21
preserves
115:12
president
12:16 28:12,13 72:19
91:19 92:8
Presidential
97:3
presumptively
124:11
pretenses
69:14 70:5
pretty
109:17
prides
85:5
primarily
7:21 32:20 93:1
primary
92:7
print
110:19 111:15
printed
111:1 149:14
printing
111:17
Printout
4:9,12,18,20 5:4,6,8
prior
154:7
prisoners
93:10
privacy
47:19
privilege
15:10,13 20:5 30:8
37:11 38:7 39:8
67:13,15 81:12 82:1
85:2 90:9,17 115:9
127:4 128:6 134:10
134:11 135:13
138:13 139:1,3,4,14
140:13 143:1
privileged
15:20 115:7
pro
3:3 6:16 7:3
probably
35:5 73:13 109:9
111:7 146:22
problem
121:11
problems
41:22
proceeding
116:9 138:10
proceedings
96:16 101:6
process
18:19 56:5 85:1 108:3
produced
45:15 72:22 143:2,12
146:10 149:6 150:4
157:11
producing
143:13
product
15:11,21 83:4,12
84:11 85:2 135:14
136:1 142:13 143:2
production
146:20 147:12 148:1
150:3
professional
7:14
programs
108:5
promised
115:3
protect
131:13 132:22
protected
143:1
protective
152:20 154:7
proven
52:2 53:10
proverb
65:15
provide
115:4
provided
19:6 127:18 148:11
provides
42:7 90:1 131:22
provocative
25:14 61:21 62:3
public
2:11 11:12 19:8,9 52:8
52:13 96:12,19
117:20 129:6 131:12
137:20 162:1,18
publication
13:20 36:12
publicity
35:1,4
publicly
118:11
publish
19:7
published
125:14
publishing
19:8
purported
38:3 125:22
purports
149:10 155:19
purpose
76:8 132:4
Pursuant
2:10
put
41:1 74:13 90:2
110:19 111:1 118:3
137:17
Putative
72:13
putting
129:6
P.A
3:13
p.m
149:3 160:4,7
Q
queen
122:10
question
20:14,18 26:12 30:13
31:11 32:13 36:9
38:16 39:21 46:16,19
47:2 48:10 50:14
52:15,18 53:21 54:6
631

Merrill LAD
Page 21
55:1,6,14 56:9,12,14
58:1 60:6 79:12 82:8
82:11 83:22 86:1
91:1,3 115:20 116:1
125:4 127:13,14,16
129:10,22 131:19
132:5,8,9,9 135:15
136:4 137:5,16,18
140:16,19,22 142:4
146:6 147:19 157:7
157:10
questions
25:17 57:12,21 86:11
86:16 104:7 105:14
122:19 125:8 128:22
131:4 142:14,19,22
142:22 143:16,20
144:14 148:9 159:15
quite
73:21 139:2 150:17
R
R
3:1 6:1 46:2 163:1,1
164:1,1
raise
18:14 114:19,20
116:18
raised
18:22 68:20 82:12
114:14,16 115:15,16
129:16
raises
25:16 50:14 115:20
134:3
raising
68:21 69:22 119:8,9
ramifications
34:12,17
ran
102:3
Rancho
91:14
rat
122:3
Ray
8:2
rdriscoll@driscollse...
46:2
reach
132:2
read
14:2,3 17:3 25:13,19
31:15,15 32:12,17
34:3,4 63:9 64:22
72:3 79:1,16 121:4
122:14,18,21 123:20
124:11,12 125:19
126:8,16 135:3 136:3
136:5 137:1 156:12
159:22 161:4
reading
16:8 122:13 125:5,18
realize
23:14 25:8
really
16:1,1 26:17 28:15
30:6 31:6,10,10
44:20 79:13 81:21
85:11 87:21 89:7
109:12 114:8 129:19
135:18 159:10
reason
50:20 73:6 163:5
164:5
reasons
143:14,14
recall
15:18 21:2,7,8 23:7,12
23:13 24:2,5,7 25:8
25:22 44:16 48:3
56:19 67:19,20 81:4
91:8 98:11 104:14
105:15,15 137:7
received
43:20 156:7
receiving
147:22
reception
17:20
Recess
14:16 108:12 124:3
134:22 136:20 149:1
recite
80:18
recognized
47:21
recollect
8:18
recollection
14:4 20:8,12,20,21,22
21:2,5,5,6 23:22
30:11,17,18 43:22
57:17 70:22 98:17
104:5,11,18 105:16
151:2 156:21
recollections
104:9
recommend
78:9
reconsidering
142:18
record
14:12,14,17 19:8,9
32:6,8 37:12,13,15
37:16 61:19 71:22
108:9,10,13 117:20
123:22 124:1,4
129:21 134:20 135:1
135:3 136:5,17,18,21
137:1 148:20,21
149:2 160:3 162:5
recordkeeping
151:18 157:2
records
42:13,21 96:12
rectangular
106:17
rectify
64:17
reduced
162:7
refer
50:3 103:7,8 156:14
159:10
reference
112:15
referenced
19:13 22:15 116:22
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47:10 103:5
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17:7 78:13 113:14
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30:21 31:18 32:13
51:7
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36:6
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54:18
refute
13:1
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10:11 59:3 66:18 74:6
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140:11 142:1 153:4
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62:18 73:5
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124:12
Regional
18:3
regular
111:7
regularly
24:18
reinstitute
75:11
related
90:8 96:5 111:15
135:19,20 157:6
162:8
relating
72:15
relationship
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relatively
106:4 155:21
relevancy
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103:1
relevant
110:20 132:10
relied
142:8
remain
65:12
remainder
60:22
remark
120:14 122:15
remember
7:21 8:6,12 9:22 15:7
15:9 20:7,12,22
24:13,14,16 26:9,14
26:16,17 28:15 29:1
29:6 33:7 40:3 44:6
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65:13
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100:12,14
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36:3 50:12 59:17 62:4
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4:20
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1:22 123:8
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2:11 6:19,20 14:8 43:6
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95:7
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162:1
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6:14 115:1 138:16,18
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115:4 116:9
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17:18 36:22 37:22
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48:20 49:2,3 93:2 99:8
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46:4 100:22 113:3
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72:14
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5:6,8
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150:19
reputable
9:2 11:2,5
reputation
10:16,18
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42:20 43:2 151:6
requested
135:4 136:6 137:2
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57:7
requests
96:13 143:4,8
Rescue
92:19 93:3,14 94:1
research
12:12
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159:21
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64:11 65:19 66:1
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32:8,9 63:21
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142:20
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69:16
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36:18 84:17
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143:9
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149:18,22
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52:16 83:2 84:12
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84:20
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26:4 61:12 143:3
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42:22 121:17
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76:19,20 78:8
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75:16 150:9 154:22
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141:3
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143:5
rested
140:6
result
29:20 49:12 141:7
retain
110:10
retraction
126:10
return
69:8 163:3 164:3
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69:6
reveal
115:9
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63:4
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15:4,6 16:5 19:15 32:5
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151:2
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19:13,16 37:19 44:3,6
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44:12 92:2
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108:4
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49:10 59:5 61:5 62:19
63:5,18 65:1 73:20
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60:19 61:1 62:17
72:10 73:9 82:13
Rich's
63:12
ridiculous
87:21 128:22 129:1
right
15:17 19:12 28:2,7
34:2,8 60:3 62:12,20
63:14 70:14 72:5
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93:14 95:4,8 97:12
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103:15 104:18 107:4
112:14 113:2,16
124:16 125:11 127:5
144:8,19 159:22
rights
80:5
Road
3:15
role
26:22 101:3 150:21
Ruffley
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21:14,19 23:5 24:20
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40:2 42:21 50:21
59:7 60:4,8,11,12
61:15,17 62:1 65:7
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74:11,12,21 75:2,11
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82:20 89:14 90:21
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126:4 127:1,8,17
132:17 134:6 138:10
138:13 139:7,18
140:10 149:11,17
153:9 154:16 155:20
156:8 157:17 158:5
158:10
rules
22:3
ruling
156:15
run
28:18
S
S
3:1 4:1,6 5:1 6:1 163:1
164:1
Sake
5:5
San
17:19 18:4 40:12
41:11,17
Sanders
98:5
Santa
91:14
sat
20:17
Saturday
146:21,21 147:1,2
Sauls
98:5,13
save
25:6 110:21 149:15
150:4
saw
34:5 36:12 37:7 43:19
43:22 64:3 71:18
73:11 92:2 119:3,7
123:10 124:13
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158:11
saying
18:17 21:7 30:16,20
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16:17 34:8 59:1 74:15
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156:18
scam
122:6
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69:16
scenario
130:18
schedule
41:17
scheduled
124:19 125:13 126:8
133:19
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7:8,20 68:22 101:16
101:18,19
SCHWED
3:13
scope
46:18 47:2 130:16
Screen
17:12
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109:18,19 110:2
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3:3 6:16 7:3 66:21
80:10,12
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162:12
search
25:2
searched
24:19
Seattle
9:22
second
14:13 16:7,9,15 45:13
59:4 122:3 133:16
145:1 148:17 149:8
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45:22
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11:20
securities
115:3
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14:22 17:3,7,10 19:10
19:11 25:3 44:9 45:3
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102:14 145:2,12,18,20
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14:20 45:14 58:8 61:2
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125:10
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18:16
Seltzer
73:9
semi-retired
41:5
Senate
17:15 102:3
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50:2,9 64:14 73:17
109:10,14
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24:16 26:1 78:19 81:6
100:10
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110:5
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14:4 15:1,2 18:11 23:8
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109:22 112:8 144:10
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September
8:10,17 28:8 41:7,9
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63:17
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72:16
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53:15,15 65:6 66:15
128:16,18
served
28:9
service
109:22
serving
138:9
set
13:6 162:11
severance
48:16 88:10
sheet
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She'll
90:1,2
she's
40:5,8 75:16 89:17,21
91:13,13,16 92:10,10
127:14 138:19
144:20 154:22
158:17,19,22
shoot
92:14 93:19
SHORTHAND
162:1
shortly
68:21 94:21 95:13
shot
17:12 94:2,3
shoulders
78:17 140:6
show
14:7 43:5 45:4 123:20
143:22 146:1 153:14
showed
71:20
Showing
43:13
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157:16
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124:18
Signature
160:5 161:11 163:22
164:22
signed
161:8
significant
22:5,20 110:18 111:15
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123:3
Simon
8:3
Simonton
1:7
simple
25:12 31:14 32:13
sincerely
65:21 73:8
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156:11
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55:13 97:5,9 98:20
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4:10,13,19,21 5:5,7,9
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99:1 104:17,18 106:12
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64:17 92:21
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145:8
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108:7
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48:4,14
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122:3
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59:22
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17:11,12
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18:11
somebody
34:20 76:7 89:5
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9:10 64:13,14 66:19
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16:13 35:11 103:16
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30:6 52:22 63:8 108:6
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94:18
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49:21
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61:21
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122:5
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62:2 151:4
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114:6
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114:20
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94:17
Southern
1:2 6:6
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153:4
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17:19 56:7 65:2 72:1
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107:5
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153:2 154:9
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74:15
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15:19 20:8,11,20,21
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48:3 64:6 67:20 138:8
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44:17
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41:6
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62:14 127:3
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153:2
Sprint
109:2,5,22
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107:3
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107:20 156:10
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6:14 7:5 28:21 69:22
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33:16 73:2 124:14,16
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21:19 22:4,21 23:3
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39:9,15 61:17 62:1
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140:11 141:8 142:1
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54:15
states
1:1 6:5 17:8,11
status
152:21 154:8
stay
9:4 10:19 156:4
158:10
stayed
47:19
staying
114:3
stays
122:8
stenographically
162:6
Steve
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stock
113:22,22
stood
17:21
Stop
48:6
straight
23:19,20 42:22 57:9
57:11
straighten
57:20
Street
2:6 6:12 68:22
stronger
95:6
stuff
25:6 48:15 106:11
110:12 111:3,8,13,16
115:12 134:1 150:4
subject
15:21 37:10 38:7 39:7
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138:22 139:14
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77:4,19
subsequent
32:7 36:16 43:14,22
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subsequently
37:7
substance
19:18 21:12 82:1,5,7
90:4,12,19 115:5
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22:19 26:22
substantive
90:22 91:2
success
27:1
sudden
103:15,19 137:15
sue
92:15,16 103:7,7
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47:8 49:7 62:4 92:14
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132:9 137:8
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16:11 17:6 64:12
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Suite
2:5 3:6,14
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19:6 33:14 42:7 51:7
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99:21
supporters
50:14 54:11 55:17
56:3
suppose
84:19 116:12
supposed
103:6
Supreme
47:20 86:19
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45:10 60:1 61:7 77:8
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Susan
149:22 150:1
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107:21
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107:15
swear
6:21
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9:19
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7:1
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52:12 95:16 110:9,10
T
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4:1,1,6 5:1,1 163:1,1
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38:22 39:1
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4:9,12,18 21:14,19
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13:20 31:16 43:14
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32:5 66:1 70:4 162:3,6
talk
10:17 17:20 56:11
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136:9
talked
23:5 56:6,8,10,15
110:22
talking
13:15 47:17 48:1
56:19 66:10,11,17
68:18 76:6 90:16
104:2 113:17 120:5
130:19,20 131:3,6
152:8
Tallahassee
96:17
Tape
108:14 160:2
team
18:18
technical
52:9 108:22
telephone
3:9,17 42:13,16,21
tell
21:5 25:18 33:16
58:22 66:13 74:1
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25:17 33:15 34:6,13
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tend
25:6 102:15 109:18,19
110:19
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41:6
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71:22
terms
9:4 10:10 13:15 63:17
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89:8
testified
54:1,9 71:21
testify
7:1 21:22 29:21
114:13 128:5 137:16
140:13 141:2
testifying
141:4
testimony
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42:20 70:18 75:20
76:2 105:13 121:3,6
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162:5,6
text
109:13
texts
109:10
thank
32:16 59:7
thanks
61:14 150:12
that's
12:5 22:2,4,15 23:15
28:2 31:3 34:8,10,10
43:17 46:4 48:9 59:9
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there's
13:12 30:8 35:1 50:10
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they're
22:10 63:16 66:17
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92:4
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34:22 35:1 85:19
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41:20 54:22 64:11
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108:2,2 110:8,8
112:20 114:12
115:21 117:9 118:16
118:19 120:17,22
121:3 122:10 123:16
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128:19,22 129:1,2,6
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135:12,20 136:1,1,8
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141:10,12,21 142:21
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151:1,3 152:15
153:12,13 154:5
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thinking
30:6 50:17 58:9 85:11
144:20
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48:2 123:15 124:7
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11:10,13 52:15 56:4
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42:1
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36:1 45:1 59:9,12,19
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66:5,8 68:9,11,15
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116:22 117:2,8,10,16
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102:15,16 103:7
144:12
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144:22
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66:4 68:1 84:4
threats
45:3 47:14 68:2,7
71:14,16,19 112:1,2
117:11 119:4,10
121:12 137:12,21
three
13:7,17 92:4 156:6
tied
63:5,12
till
104:22
time
6:9 9:1,14 10:4 13:18
14:15,18 19:13 23:8
24:20 25:4,16 27:22
28:11 29:18 30:21
31:15 32:5,11,17
36:13 37:14,17 40:1
40:5,16,18 41:1,3,4,6
42:9 44:1 63:17 64:3
65:2 69:16 70:9
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114:5 120:21 122:9
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146:11 148:22 149:3
150:18 160:3
times
79:20 129:18
timing
113:14
tireless
18:19
title
12:20 13:3 150:18
titles
11:19 28:10
today
6:10,19 13:19 65:2
79:20 91:12 125:15
128:22 129:20
130:19 140:2
Today's
6:8
told
17:17 18:5,8,10,16
19:2 21:14 33:10
35:20 52:11 74:6,10
74:11,12 75:6,7 81:6
97:8 105:16 123:9
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Tom
12:4,14 13:8 28:12
72:19 149:12,14,17
149:21 150:1,1
151:19 156:2 157:11
top
46:1 59:4 122:8
tortious
71:5
Toshiba
107:10
total
102:20
track
47:13
tracking
29:8
trademark
7:21 9:20 50:8,15
transcript
4:7 5:2 14:11 16:22
45:8 144:4 146:5,16
147:8,18 148:7 162:4
transcription
161:6
Trattner
7:20
treasurer
11:20
trial
98:15,17
tricycle
146:20
tried
9:14 19:22 105:14
152:13
trip
94:22 95:14
trouble
108:5
troubled
49:21
true
71:4 85:18 120:11
161:5 162:5
truly
73:1 153:16 156:13
trust
73:21
try
9:17 55:10 58:2 65:19
86:16 110:2 152:16
trying
25:14 40:3 46:18 47:1
64:17 65:15 74:13
79:21 88:9 96:14
99:16,17 117:2,10
121:20 132:2 137:18
144:15
Tuesday
72:17
turn
45:12,22 124:7 155:17
two
44:4 88:20 122:12
124:21 132:5 133:18
types
8:1
typewriting
162:7
U
U
5:1 164:1
Uh-huh
64:2
unanswered
60:21
underneath
125:12
understand
31:10,11 32:8 39:20
46:18 47:1 53:20
55:1,6,12,13 57:19
57:21 68:17 79:11,12
82:15 83:22 86:2
104:1 120:13 127:21
144:15
understanding
89:17,19,20 92:5
unethical
11:10,13
United
1:1 6:5 150:19
unnecessary
142:20
unsupported
72:18
unusual
115:11
update
16:10 17:4
ups
89:6
upset
100:9,11,12,13
UROC
150:10,19 151:1,3
152:18,22 153:3,8,16
154:10 155:1
use
50:12 55:22 71:3
105:20 109:18,19
110:3 111:13 112:10
116:13 137:4
usually
66:17 109:15 110:4
112:12,12 141:17
U.S
17:15 102:3
V
v
1:6,22 2:10 96:10 97:3
162:2 163:2 164:2
vague
72:17 84:2 92:5
value
66:1
variables
86:2 131:17
variety
8:1 41:20
various
46:9 68:6
Venezuela
96:1,6
venue
83:8
verdict
93:13
versus
6:4 154:6
victim
95:22
victims
94:22 95:14
victory
94:5
video
6:9,9,10,11
Videographer
3:21 6:2,19 9:9 14:14
14:17 37:13,16
108:10,13 124:1,4
134:20 135:1 136:18
136:21 148:21 149:2
160:1
videotape
6:2 130:1
Videotaped
1:11 2:1
views
100:8
violation
50:8
viral
120:10
voice
6:13 129:16
Volume
108:14 160:2
voters
17:16
W
W
61:1 73:9
wait
45:13 119:21
631

Merrill LAD
Page 28
waited
104:22
waived
67:16 160:5
walk
97:6
want
7:16 34:18,19 36:10
48:7,10 55:4 57:20
60:4 63:20 66:2 68:3
76:9,11 80:19,22
91:6 104:22 113:9,18
114:8 122:19 123:14
128:16 129:12 131:4
136:12 148:16 152:9
wanted
98:18 101:7 154:8
wanting
122:7 123:6
warm
17:20
warrant
28:21 29:2,5
washed
79:3,3
Washington
1:12 2:7 3:8 6:12 8:3
9:21
wasn't
27:7 28:17 39:3 58:14
75:7 78:16 89:4 94:2
95:8 99:2 127:14,16
128:3 154:17
waste
142:20
wasted
69:17
watch
1:7 6:4,18 8:11,14,15
8:17 10:2,6,19 11:16
12:6,10 13:10,16
17:18,22 18:3,6 19:3
25:13,19 26:19,21
27:3,6,8,16 28:3,5,6
28:9,18 29:17,19
30:21 31:19,22 32:13
32:22 33:4,11 35:17
36:3 37:1,22 38:4,9
38:14 39:2,10,18
40:2,20 41:8,13
42:17 46:3,5 50:1,4
50:13,17 51:1,8
53:13,14,16 54:12,18
55:16,18,20 56:1,3
56:17,18 58:3,3,11
58:13,14,15,19 59:1
59:6 61:14 65:5,8
68:6,8,11,13 69:18
69:19 72:14,18 73:3
73:7,18 74:4,16,18
75:3,17 76:20 77:22
78:8 79:9 82:18,18
84:7 85:1,4,12,14,20
86:7 88:3 89:10,16
89:22 92:13 93:12
94:21 95:22 96:2,6,9
96:20 99:8,10 101:20
102:5,21 105:21
109:4 113:4 114:18
114:22 115:17 116:8
117:17,18 118:10
119:9 126:20,22
127:9 129:4 130:2,5
130:8 131:7,13
132:13,16,22 133:1
137:22 138:15,18,19
139:7,13,15,20 141:5
141:6 148:12 149:7,9
150:10,22 151:6,12
151:15 152:2,9,14
153:2,5,15 154:1,2,9
154:17 155:1,2,17
157:6 158:3 163:2
164:2
watchdog
85:9
watched
96:16
Watch's
40:6 83:8 131:11
151:18 154:12 157:2
way
29:12 30:5 36:9,10
38:19 44:13 45:14
50:13 68:3 74:13
80:13 83:19 89:3
115:12 122:5 145:4
149:13 157:21 158:1
ways
67:14 76:9
wear
91:4
web
4:10,13,19,21 5:5,7,9
13:20,21,22 14:2,6
15:3 31:16 43:14,15
43:18 54:16
week
18:16 41:2,11
weeks
143:11,11
weighs
141:18
went
8:9 36:20,22 60:21
96:16 97:13 101:18
101:18 102:20 105:7
105:8 127:2 139:7
140:10
weren't
28:3
West
40:6,20
Western
18:3
we'll
57:7 129:21 140:9
143:20 152:7 159:12
159:21
we're
13:19 69:20 87:19
102:17 103:6,18
120:5,5 127:5 130:19
130:19,20 140:2
152:20 154:7 159:20
we've
20:2 38:10 104:19
135:22 143:2 150:7
whatsoever
156:21
what's
11:18 32:14 51:20
53:6 80:17 107:8
117:2 122:17 150:15
150:16
WHEREOF
162:11
White
101:12
who's
34:20 107:17
why'd
69:8
wife
98:1
willing
137:16
withdrew
113:6
witness
6:21 17:1 20:14 21:18
22:7 23:2 25:22
30:13 31:3,9 32:17
33:20 35:15 38:16
39:20 45:10 47:1
49:15,20 51:12 53:20
54:22 58:7 60:22
67:1,17,19 68:17
70:8,22 71:8 74:9
75:20 76:2 77:1,8
81:14 82:3,7,15
83:13,14 86:11 91:4
103:2 104:1,13
105:12 115:10 116:4
116:14 118:18
119:17 120:2 121:1,7
121:12 127:20
128:12 129:10 133:3
134:15 135:5 136:3
137:3 140:16,21
631

Merrill LAD
Page 29
141:10 142:4 145:2
145:10 146:6 147:2
147:19 153:12
155:14 158:8,22
159:14,18 162:11
Women's
17:17
wondering
120:11
word
52:15 54:4 59:14,14
65:14 71:3 116:13
133:12 137:4
words
55:22 74:14
work
7:22 8:1,9 9:7,8 10:20
11:1,2,4,6,9,12 15:10
15:21 18:5,19 25:2
28:6 42:3,5 83:3,12
84:11 85:2 88:22
89:5,16 90:5 94:8
106:22 135:13 136:1
142:13 143:1 159:5
worked
7:14,22 8:8 9:1 18:6
35:5,6 73:20 80:4
87:8 88:19 89:21
92:13 93:1 99:22
100:14 121:13
working
7:15 8:20 9:5 11:15
13:2 27:22 28:3
40:11 41:17 81:2
works
19:3 33:11 41:8,10,21
111:13
world
56:11
World's
13:20 43:14
worse
51:10 112:14
wouldn't
29:12 42:10 43:1 60:4
60:13 80:15
write
62:10,11 158:5
writes
156:11
writing
35:21 59:5 81:5
written
34:1 35:9 56:16 58:3
62:8
wrong
34:13 61:7 70:19,20
119:1 146:9
wrote
14:3 18:17,17 26:4
34:9 35:19 62:13
64:3 68:1 74:1 81:3
82:12 102:12 124:13
144:21 156:16
Wyoming
41:6
X
x
1:3,9 4:6 5:1
Y
Yale
101:15,15
yeah
9:20 16:18 20:19
24:11 42:15 46:13
48:14 59:22 63:12
80:2 85:6 87:16 89:2
89:9 90:1 105:3
110:8 112:6 120:2
121:19 122:13
129:18 138:6 140:18
145:2 149:14 156:5
year
8:7 41:3,9 102:6
155:22 156:1
years
8:8,21 18:7,19 20:10
28:8,19 29:9,18
56:20 58:20 59:17
68:8 79:18 80:1 81:3
87:2,5 88:19,20 89:5
91:17 107:12 119:11
142:9,12
Yep
80:8
Yesterday
17:14
yesterday's
16:9 17:3
you'd
8:20 70:4 86:11 97:6
126:7 148:10 157:3
you'll
11:1 116:2
you're
11:15 13:9,22 15:17
17:7 20:19 22:9
23:14 25:17 26:11
34:12 38:13,20 47:17
49:20 51:4 52:1,5
53:9 57:2,19 58:10
62:15 63:1 64:17
66:4,6,7,10,11 68:18
71:5,13,18,21 74:13
74:20 75:1,1,6,14,22
78:13,17 80:7 82:1
83:1,14 84:11,16,17
84:19,22 86:13,21
90:15 94:14,20 95:13
97:10,19 98:14 99:3
99:7 101:4,14,20
102:2,19 104:2,17,18
107:3 111:21 112:4
113:7,11,14,16
121:20 122:1 127:22
128:1 131:21 132:12
133:13 135:18 136:1
136:10 137:16
138:16,22 139:6
140:13 141:2,19
156:12
you've
7:10,14,17 19:13 32:3
32:5 36:3,11 46:9
47:14,16 49:8,9 56:6
59:16 68:8 79:20
80:1,3 86:14,18
104:20,21 105:13
109:21 112:10 119:6
119:10 127:13
144:11 159:14
$
$1.8
93:13
$15,000
68:12
$25,000
16:11 17:5,11,12
18:13,14 122:4
$78,861.76
124:18
0
00015
123:15
0004
120:6
000505
149:9
1
1
1:21 4:9 6:3 14:8,9
43:13,13 44:5 108:14
123:14 124:8 145:8
145:14,19 160:2
10
17:13 28:19 29:8,18
58:19 59:17 87:2
119:11
10th
18:13
10:56
108:11
100
3:14 17:16
11
8:21 87:6,7 88:20 89:5
11:03
631

Merrill LAD
Page 30
61:13
11:07
108:15
11:23
124:2
11:28
124:5
11:38
134:21
11:39
135:2
11:41
136:19
11:43
136:22
11:57
148:22
11410
3:15
12
4:14 149:3
12:11
160:3,7
13-20610-CIV
6:7
13-20610-CIV-ALT...
1:6
1325
2:6 6:12
14
4:9 87:5 162:16
144
4:18
146
4:20 5:4
147
5:6,8
148
5:10
15
71:17 124:8
16
4:12
164
1:21
19
8:17
19th
28:8
1990
7:9 8:8 79:22
1992
8:10
1994
10:3 27:6
1999
40:4
2
2
4:12 16:19,20 43:7,8
44:5 108:14 110:22
118:22 119:13,14,21
122:4 124:17 143:11
145:12 158:18 160:2
2-hour
17:14
2-244101
1:20
200
2:5
2000
40:4 96:10
20005
2:7
20006
3:8
2003
8:18 12:7 28:8 36:4
122:2 126:21
2012
17:9,13 41:12,15 65:1
72:11,17 78:22 106:2
108:18 109:9 110:7
111:6 116:15 117:7
120:8 124:19 125:11
125:15 142:10
2013
104:19 155:20
2014
1:13 6:8 162:13,16
202
2:8
2020
3:7
22
142:9,12
23
17:9 125:14
23rd
41:12 61:13 106:2
108:18 110:6 111:6
119:22 120:8 125:11
24
4:11 64:22 80:1 81:3
2540
18:4
26
119:21 125:15
27
1:13
27th
6:8
28
72:17
29
27:5
29th
10:3
3
3
4:15 41:10 45:5,5,6
143:11 145:14
3-day-a-week
41:17
3/5/12
4:15,17 5:12
30
143:9
30th
162:12
310
3:9
33418
3:16
345
3:6
4
4
4:18 18:18 120:5
124:10 144:1,2,6
145:12,13,14,19,19
45
4:15
5
5
4:20 78:22 146:2,2,3
5th
72:11
501
68:22
501(c)(3)
152:21 154:8
508
155:17
561
3:17
595-0800
3:9
6
6
5:4 146:13,14
694-0070
3:17
7
7
4:4 5:6 124:19 147:5,6
155:20
7th
133:19
8
8
5:8 147:15,16
8/28/12
5:10
631

Merrill LAD
Page 31
861-3410
2:8
9
9
5:10 148:3,4,5 149:5
9/11
95:13 96:5
9:22
1:14 6:9
9:30
14:15
9:31
14:18
9:52
37:14
9:54
37:17
96
18:14
631

Attachment K
631
In The Matter of:

LARRY E. KLAYMAN
vs.
___________________________________________________
CHRISTOPHER J. FARRELL
January 27, 2014
___________________________________________________

631
CHRISTOPHER J. FARRELL - 1/27/2014

Merrill LAD
Page 1
------------------------x
LARRY E. KLAYMAN, )
Defendant. )
------------------------x
VIDEOTAPED DEPOSITION OF CHRISTOPHER J. FARRELL
Washington, D.C.
Monday, January 27, 2014
1:18 p.m.
Job No.: 2-244101
Pages 1 - 64
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Merrill LAD
Page 2
1 Videotaped Deposition of CHRISTOPHER J.
2 FARRELL, held at the offices of:
3
4 MERRILL LAD
5 Suite 200
8 (202) 861-3410
9
13
14
15
16
17
18
19
20
21
22
631

Merrill LAD
Page 3
2
6 Suite 345
9 Telephone: (310) 595-0800
10
14 Suite 100
17 Telephone: (561) 694-0070
18
19 ALSO PRESENT:
21 Dina James
22 Paul Orfanedes
631

Merrill LAD
Page 4
1 C O N T E N T S
2
3 EXAMINATION OF CHRISTOPHER J. FARRELL PAGE
4 By Mr. Klayman 6
5
6 E X H I B I T S
7 (No exhibits were marked.)
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
631

Merrill LAD
Page 5
1
13:00:20
P R O C E E D I N G S
2
13:18:08
THE VIDEOGRAPHER: Here begins Videotape
3
13:18:12
No. 1 in the deposition of Christopher Farrell in
4
13:18:16
the matter of Larry E. Klayman versus Judicial
5
13:18:19
Watch, Incorporated in the United States District
6
13:18:21
Court for the Southern District of Florida, Case No.
7
13:18:28
13-20610-CIV.
8
13:18:28
Today's date is January 27th, 2014. The
9
13:18:33
time on the video monitor is 1:18 p.m., and the
10
13:18:37
video operator today is Akim Graham. This video
11
13:18:40
deposition is taking place at 1325 G Street,
12
13:18:45
Northwest in Washington, D.C.
13
13:18:45
Counsel, please voice identify yourselves
14
13:18:47
and state whom you represent.
15
13:18:49
MR. KLAYMAN: Larry Klayman, counsel for
16
13:18:51
plaintiff pro se.
17
13:18:52
MR. KRESS: Doug Kress counsel for Judicial
18
13:18:55
Watch, Inc.
19
13:18:56
THE VIDEOGRAPHER: The court reporter today
20
13:18:57
is Joan Cain of Merrill LAD. Would the reporter
21
13:18:59
please swear in the witness.
22
13:18:59
CHRISTOPHER J. FARRELL
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Merrill LAD
Page 6
1
13:18:59
having been duly sworn, was examined and did testify
2
13:19:10
as follows:
3
13:19:10
EXAMINATION BY COUNSEL FOR PLAINTIFF PRO SE
4
13:19:10
BY MR. KLAYMAN:
5
13:19:11
Q Please state your name.
6
13:19:12
A My name is Christopher Farrell.
7
13:19:14
Q When were you born, Mr. Farrell?
8
13:19:16
A April 29th, 1961.
9
13:19:19
Q Run us through briefly your educational
10
13:19:22
background, just high school and college.
11
13:19:24
A I graduated from Chaminade High School in
12
13:19:28
Mineola, New York in 1979. Then I graduated from
13
13:19:32
Fordham University in the Bronx, New York in 1983.
14
13:19:35
Q What did you do after that?
15
13:19:36
A I was an Army officer.
16
13:19:37
Q And what were your positions with the Army?
17
13:19:39
A Several. It was -- 10-plus years, a
18
13:19:43
variety of locations around the world, but chiefly
19
13:19:46
as a counterintelligence officer.
20
13:19:48
Q And did there come a point in time when you
21
13:19:51
left the military?
22
13:19:52
A Yes.
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Merrill LAD
Page 7
1
13:19:52
Q When was that?
2
13:19:53
A January of 1994.
3
13:19:56
Q What did you do then?
4
13:19:58
A I went to work for a firm called Synectics.
5
13:20:03
Q And where are they located?
6
13:20:05
A At the time, they were in Fairfax,
7
13:20:07
Virginia.
8
13:20:07
Q And what do they do?
9
13:20:08
A They're a defense contracting firm.
10
13:20:11
Q You had a security clearance?
11
13:20:12
A Yes.
12
13:20:12
Q Okay. And how do you spell that name?
13
13:20:15
A S-y-n-e-c-t-i-c-s, Synectics.
14
13:20:23
Q And what were -- what was your position
15
13:20:24
with Synectics?
16
13:20:26
A My title was systems engineer.
17
13:20:30
Q And what were your duties and
18
13:20:31
responsibilities?
19
13:20:31
A I provided advice and assistance to
20
13:20:34
Department of Defense customers of the firm on a
21
13:20:39
number of classified projects.
22
13:20:43
Q What were the general subject matters
631

Merrill LAD
Page 8
1
13:20:44
involved?
2
13:20:46
A Human intelligence.
3
13:20:48
Q Did there come a point in time when you
4
13:20:50
left Synectics?
5
13:20:53
A Yes.
6
13:20:53
Q When was that?
7
13:21:03
A 1995 or '6. I can't tell you exactly when.
8
13:21:09
Q Where did you go then?
9
13:21:10
A Then I worked for myself.
10
13:21:11
Q Doing what?
11
13:21:12
A I helped people write white papers and
12
13:21:15
contract proposals.
13
13:21:16
Q With regard to?
14
13:21:17
A The same general world of defense
15
13:21:19
contracting.
16
13:21:23
Q Did you have any interim employment between
17
13:21:27
you working for yourself and later for Judicial
18
13:21:28
Watch, other employment?
19
13:21:30
A Yes.
20
13:21:31
Q What was that?
21
13:21:32
A I worked as a program manager for a
22
13:21:37
Catholic charity.
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Merrill LAD
Page 9
1
13:21:39
Q Which Catholic charity?
2
13:21:41
A The Paulist National Catholic
3
13:21:46
Evangelization Association.
4
13:21:47
Q Did there come a point in time when you
5
13:21:49
approached me for a job at Judicial Watch?
6
13:21:51
A Yes.
7
13:21:51
Q When was that?
8
13:21:56
A I would say May of 1999.
9
13:22:06
Q And under what circumstance did you
10
13:22:07
approach me? Was it an event or whatever?
11
13:22:10
A It was some sort of a conference or a panel
12
13:22:14
discussion. That was the location, roughly.
13
13:22:20
Q It was in Washington, D.C.?
14
13:22:21
A Correct.
15
13:22:22
Q It was put on by Howard Phillips?
16
13:22:25
A Yes.
17
13:22:25
Q Of his taxpayer group?
18
13:22:30
A I'm not sure what title or banner it was
19
13:22:33
under, but --
20
13:22:33
Q Right. You came to me, you said Larry, you
21
13:22:36
know, you have a really good reputation. I'd like
22
13:22:38
to work with you at Judicial Watch?
631

Merrill LAD
Page 10
1
13:22:40
A Those are your words, not mine.
2
13:22:42
Q What are you saying?
3
13:22:44
A I approached you and said that I thought I
4
13:22:47
had a skill set that would be valuable to Judicial
5
13:22:49
Watch.
6
13:22:49
Q What was that?
7
13:22:50
A I had a background in investigative work.
8
13:22:52
I was a good writer and put those two together, I
9
13:22:55
thought it was a good match.
10
13:22:56
Q And you told me that you were impressed
11
13:22:58
with the work of Judicial Watch?
12
13:22:59
A Yes.
13
13:23:03
Q Okay. And that you were impressed with my
14
13:23:05
work in particular?
15
13:23:06
A I don't know that that's true.
16
13:23:08
Q You knew that I was the head of Judicial
17
13:23:10
Watch at the time?
18
13:23:10
A That's correct.
19
13:23:11
Q You knew that I was a founder of Judicial
20
13:23:13
Watch at that time?
21
13:23:13
A I didn't know that, no.
22
13:23:15
Q Okay. What ensued after that, after you
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Merrill LAD
Page 11
1
13:23:21
approached me?
2
13:23:24
A We had a conversation. You said to call
3
13:23:27
back to the office, that the next business day,
4
13:23:30
whatever that was, within a couple days, and I did,
5
13:23:36
and then you asked me to come in for an interview.
6
13:23:39
Q Okay. And I hired you?
7
13:23:41
A Correct.
8
13:23:41
Q And what did I hire you as?
9
13:23:43
A An investigator.
10
13:23:45
Q Okay. Did there come a point in time when
11
13:23:49
your position changed at Judicial Watch from that
12
13:23:52
point to today? Strike that.
13
13:23:54
You're still employed by Judicial Watch,
14
13:23:56
correct?
15
13:23:57
A Yes, I am.
16
13:23:57
Q Did there come a point in time when your
17
13:24:00
position changed in any way at Judicial Watch from
18
13:24:02
the time I hired you to today?
19
13:24:03
A Yes. In --
20
13:24:06
Q When was that?
21
13:24:07
A In -- I guess it was September or October
22
13:24:10
of 2003 I became a director of the corporation.
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13:24:16
Q Were you there with -- were you a director
2
13:24:19
with other directors?
3
13:24:19
A Yes.
4
13:24:20
Q Who were the other directors?
5
13:24:21
A Tom Fitton and Paul Orfanedes.
6
13:24:29
Q And as part of your duties and
7
13:24:31
responsibilities as a director at Judicial Watch, do
8
13:24:33
you have regular directors' meetings?
9
13:24:40
A We have meetings, yes. I don't know what
10
13:24:42
regular means, but we have meetings, yes.
11
13:24:44
Q Do you call meetings in a formal way or are
12
13:24:49
they done informally?
13
13:24:50
A We do it in accordance with our bylaws.
14
13:24:53
Q Is there a notice that goes out for those
15
13:24:54
meetings?
16
13:24:55
A In one form or another, yes.
17
13:24:57
Q What do you mean in one form or another?
18
13:24:59
A It's -- we agree that we're going to have a
19
13:25:01
meeting on a particular date and time and we have a
20
13:25:04
meeting.
21
13:25:04
Q Is it a formal meeting, over lunch, or how
22
13:25:07
is that done? There's only three directors.
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1
13:25:10
A It depends.
2
13:25:11
Q Did there come -- does the Board of
3
13:25:14
Directors keep minutes of the meetings?
4
13:25:18
A Yes, I know that we have meetings -- or
5
13:25:21
have minutes from meetings, sure.
6
13:25:22
Q You keep a corporate book?
7
13:25:23
A I don't know. I'm not the secretary.
8
13:25:26
Q Who's the secretary?
9
13:25:27
A Paul Orfanedes.
10
13:25:30
Q Did there come a point in time when the
11
13:25:34
directors had a meeting concerning statements which
12
13:25:36
had been published by Dr. Orly Taitz concerning me,
13
13:25:40
Larry Klayman?
14
13:25:42
A I don't recall any meeting.
15
13:25:45
Q Do you remember any discussion about any
16
13:25:46
comments that were attributed to Constance Ruffley
17
13:25:51
about me, Larry Klayman, among the Board of
18
13:25:59
Directors?
19
13:25:59
A I think when you sued us we probably
20
13:26:02
noticed that you had filed a lawsuit against us.
21
13:26:03
Q With regard to comments made allegedly by
22
13:26:06
Constance Ruffley to Orly Taitz?
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13:26:10
A Whatever your claims were.
2
13:26:18
Q Prior to my having sued you -- sued
3
13:26:22
Judicial Watch over that, you were sued personally
4
13:26:24
in that case initially, correct, along with the
5
13:26:27
other directors and Constance Ruffley; you're aware
6
13:26:30
of that?
7
13:26:44
A Yes.
8
13:26:44
Q Okay. Prior to your getting the court
9
13:26:47
papers -- you got the court papers, I take it? You
10
13:26:52
were served with the complaint?
11
13:26:53
A Okay.
12
13:26:53
Q Correct?
13
13:26:55
A Yes, I was served.
14
13:26:56
Q Okay. Prior to that, had you had any
15
13:26:58
discussion with Paul Orfanedes or -- about what I
16
13:27:03
was alleging in the complaint?
17
13:27:04
A Not that I recall.
18
13:27:06
Q Any discussion with Tom Fitton about what I
19
13:27:09
was alleging in the complaint?
20
13:27:09
A Not that I recall.
21
13:27:18
Q What is it that you are aware that I'm
22
13:27:20
alleging in that complaint?
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13:27:32
A My understanding is that you are upset or
2
13:27:37
feel that you've been harmed in some way about what
3
13:27:46
a lawyer named Taitz published or put on a web site
4
13:27:50
or said.
5
13:27:56
Q And what is -- what is your understanding
6
13:27:58
of what she put on the web site about me?
7
13:28:00
A I don't know. I never read it.
8
13:28:01
Q You never read the complaint?
9
13:28:03
A I never read what Taitz put on a web site
10
13:28:06
or published or whatever.
11
13:28:07
Q Did you read the complaint you were served
12
13:28:09
with when I served you?
13
13:28:11
A I'm sure I did when I first saw it.
14
13:28:14
Q And what do you remember about my
15
13:28:15
allegations?
16
13:28:26
A Something about whether you did or didn't
17
13:28:28
pay child support.
18
13:28:29
Q Are you aware that, according to Orly
19
13:28:33
Taitz, that Connie Ruffley said that I'd been
20
13:28:36
convicted of the crime of not paying child support?
21
13:28:39
A I have no idea what you're talking about.
22
13:28:40
Q And that this information should be shared
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13:28:43
with donors?
2
13:28:44
A No, I have no idea what you're talking
3
13:28:46
about.
4
13:28:49
Q Are you aware that I had brought lawsuits
5
13:28:53
in Florida and elsewhere challenging the eligibility
6
13:28:58
of President Obama to be President --
7
13:29:00
A No.
8
13:29:00
Q -- based on his citizenship?
9
13:29:02
A No.
10
13:29:05
Q Had you ever heard of Orly Taitz at the
11
13:29:10
point you were served with the complaint?
12
13:29:12
A I probably had some awareness of her, but I
13
13:29:15
don't -- I mean, I wasn't -- I didn't have any great
14
13:29:17
knowledge other than the name being in the news
15
13:29:19
occasionally.
16
13:29:19
Q What -- what did you understand her to be
17
13:29:22
doing professionally?
18
13:29:32
A That she was a lawyer who filed lawsuits
19
13:29:35
generally in sort of the birther movement or that
20
13:29:39
issue about the eligibility of the President based
21
13:29:43
on his place of birth or the validity of his
22
13:29:46
certificate or something like that.
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1
13:29:49
Q So I take it at the time you were served
2
13:29:51
with the complaint in this case you were not aware
3
13:29:54
that I had brought lawsuits challenging the
4
13:29:55
President's eligibility?
5
13:29:56
A I had no idea what you were doing.
6
13:29:59
Q I'll show you what has been marked as
7
13:30:01
Exhibit 2 to this deposition.
8
13:30:18
Excuse me. This purports to be a copy of
9
13:30:33
an internet posting of Orly Taitz on her web site,
10
13:30:37
World's Leading Obama Eligibility Challenge Web
11
13:30:40
Site, Exhibit 2.
12
13:30:41
Do you see that?
13
13:30:42
A Yeah, it's in front of me.
14
13:30:43
Q Had you ever heard of World's Leading Obama
15
13:30:47
Eligibility Challenge Web Site?
16
13:30:48
A No.
17
13:30:48
Q Have you ever heard of it?
18
13:30:49
A No. This is --
19
13:30:50
Q Have you ever seen this document before?
20
13:30:51
A I have not.
21
13:30:52
Q Turn to the second page. Where it says, My
22
13:30:52
yesterday's presentation to CCIR and update on
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13:30:52
article2superPAC - Larry Klayman $25,000 fundraising
2
13:31:12
for non-existent law suit affair." Have you ever
3
13:31:13
heard of the Article II Super PAC?
4
13:31:14
A No.
5
13:31:15
Q Reading down, posted February 23rd, 2012 it
6
13:31:20
states, Article2superpac $25,000 solicitation for
7
13:31:20
Larry Klayman, Screen shot $25,000 solicitation for
8
13:31:33
Larry Klayman lawsuits, February 10, 2012."
9
13:31:33
Yesterday -- this is Dr. Orly Taitz writing -- I
10
13:31:38
gave a 2-hour presentation of my platform as a
11
13:31:41
candidate for the U.S. Senate. The presentation was
12
13:31:43
given to some 100 California voters in the Women's
13
13:31:46
club of Garden Grove. I was told that a
14
13:31:49
representative of the Judicial Watch drove for over
15
13:31:51
an hour from San Marino to hear me speak and talk to
16
13:31:54
me. I got a very warm reception. After my
17
13:31:58
presentation people stood up and applauded. This
18
13:32:01
member of the Judicial Watch approached me and gave
19
13:32:03
me her card. Her name is Constance Ruffley and she
20
13:32:06
is the office administrator for the Judicial Watch
21
13:32:08
in the western regional headquarters at 2540
22
13:32:11
Huntington Drive, San Marino. She told me that she
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1
13:32:16
used to work for the FBI and that she worked for the
2
13:32:19
Judicial Watch for many years. She actually
3
13:32:20
initiated the discussion about Larry Klayman and
4
13:32:22
told me that she heard that he's involved in birther
5
13:32:26
cases. I told her that this group Article II Super
6
13:32:29
PAC was soliciting money, that they sent an e-mail
7
13:32:32
and posted on their site an advertisement on
8
13:32:34
February 10 asking for $25,000 claiming that they
9
13:32:37
need to raise $25,000 in 96 hours as the cases in
10
13:32:41
Florida and California need to be filed within a
11
13:32:43
week. I told her that it was a hard sell. They
12
13:32:49
wrote it is now or never saying finally Clinton's
13
13:32:52
team met their match dissing 4 years of my tireless
14
13:32:56
work in the process, and in the end nothing was
15
13:32:58
filed by Larry Klayman. It is not clear what
16
13:33:00
happened to all of the money that was raised, who
17
13:33:02
got it.
18
13:33:04
Then it states in the next paragraph,
19
13:33:07
Ms. Ruffley actually advised me that Larry Klayman
20
13:33:09
is not licensed in California. She told me that he
21
13:33:12
no longer work with the Judicial Watch and that
22
13:33:15
donors should know about litigation in Ohio where he
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1
13:33:18
was convicted just recently of not paying a large
2
13:33:20
amount in child support. She provided a lot of
3
13:33:23
other information. I will publish only what is a
4
13:33:25
public record. I'm not publishing anything that is
5
13:33:28
not a public record.
6
13:33:29
Does this refresh your recollection as to
7
13:33:31
whether or not you have ever known or been advised
8
13:33:38
that Connie Ruffley, Constance Ruffley, stated to
9
13:33:42
Orly Taitz, which was then published on Orly Taitz's
10
13:33:47
web site that I was convicted of a crime?
11
13:33:49
12
13:33:50
If you can answer.
13
13:33:51
THE WITNESS: I don't understand the
14
13:33:52
question.
15
13:33:53
BY MR. KLAYMAN:
16
13:33:53
Q Does this refresh your memory as to whether
17
13:33:56
or not you've known before today that Constance
18
13:33:58
Ruffley allegedly said that I, Larry Klayman, was
19
13:34:00
convicted of a crime?
20
13:34:02
A I think that's what you put in your
21
13:34:04
complaint.
22
13:34:06
Q But you didn't know it was in the complaint
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1
13:34:08
a few minutes ago when I testified (sic) to you.
2
13:34:12
A I said when you gave me the complaint
3
13:34:13
that's when I became aware of what you're -- what
4
13:34:16
you're suing, what you're claiming.
5
13:34:17
Q Okay. Before that you were not aware what
6
13:34:19
I just read to you?
7
13:34:21
8
13:34:22
THE WITNESS: I don't agree. I told you
9
13:34:23
that when you gave me -- when the complaint was
10
13:34:26
served, I read it and I learned what you were upset
11
13:34:29
about.
12
13:34:29
BY MR. KLAYMAN:
13
13:34:29
Q Okay. As a member of the Board of
14
13:34:32
Directors of Judicial Watch, would you have wanted
15
13:34:35
to been -- would you have wanted to be advised that
16
13:34:37
Connie Ruffley purportedly said these things about
17
13:34:40
me that were then published on a web site, the
18
13:34:45
Leading Eligibility web site?
19
13:34:46
MR. KRESS: Objection.
20
13:34:47
THE WITNESS: I don't know that any of this
21
13:34:48
is even true.
22
13:34:49
BY MR. KLAYMAN:
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1
13:34:49
Q Would you have wanted to be informed as a
2
13:34:51
member of the Board of Directors?
3
13:34:54
A It's a hypothetical that I'm just -- I
4
13:34:57
mean, this is make believe. I don't know what your
5
13:34:59
question's about.
6
13:34:59
Q Is my complaint make believe?
7
13:35:03
A I don't understand it necessarily, but --
8
13:35:07
Q If this was said, is that make believe?
9
13:35:10
10
13:35:11
You can answer.
11
13:35:14
THE WITNESS: I don't know. I don't know
12
13:35:15
if any of this is true.
13
13:35:16
BY MR. KLAYMAN:
14
13:35:17
Q What are your duties and responsibilities
15
13:35:18
as a member of the Board of Directors of Judicial
16
13:35:20
Watch?
17
13:35:20
A I have a fiduciary obligation to make sure
18
13:35:22
that the organization is run properly in accordance
19
13:35:25
with the laws of the United States and District of
20
13:35:26
Columbia and to the care and welfare of the
21
13:35:29
organization and its employees.
22
13:35:31
Q If an employee made a statement that was
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1
13:35:33
defamatory of someone in public, that would be
2
13:35:37
something, as a member of the board, you'd want to
3
13:35:39
know about?
4
13:35:40
A All sorts of people have their personal
5
13:35:42
opinions about all sorts of topics. I have no idea
6
13:35:45
what people say or don't say anywhere whether
7
13:35:47
they're in public or they're in private. I don't
8
13:35:49
know.
9
13:35:49
Q Calls for a yes or no. Yes or no?
10
13:35:51
MR. KRESS: I object to the form.
11
13:35:52
12
13:35:53
question.
13
13:35:54
BY MR. KLAYMAN:
14
13:35:54
Q If an employee of Judicial Watch made a
15
13:35:56
statement in public that someone such as myself,
16
13:36:01
Larry Klayman, had committed a crime and that person
17
13:36:07
was claiming it was defamatory, wouldn't you want to
18
13:36:10
know about it as a member of the board?
19
13:36:11
20
13:36:12
THE WITNESS: I don't know what in public
21
13:36:14
means.
22
13:36:15
BY MR. KLAYMAN:
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1
13:36:15
Q Published on a web site. Yes or no?
2
13:36:18
A You just changed your question on me. I
3
13:36:21
don't know what you're talking about. Please --
4
13:36:22
Q You have no idea what I'm talking about?
5
13:36:24
A Please rephrase the question. It's a
6
13:36:26
moving target. You just keep moving the language
7
13:36:30
around.
8
13:36:30
Q All right. Let's -- let's see if you can
9
13:36:31
understand this. You're highly educated. First
10
13:36:34
question, your duties at Judicial Watch are, as you
11
13:36:36
just testified, to protect Judicial Watch from legal
12
13:36:39
liability, correct --
13
13:36:40
14
13:36:41
BY MR. KLAYMAN:
15
13:36:41
Q -- as a director?
16
13:36:42
17
13:36:44
THE WITNESS: Generally speaking, yes.
18
13:36:46
BY MR. KLAYMAN:
19
13:36:46
Q Okay. Now, if an employee of Judicial
20
13:36:50
Watch makes a statement which is alleged to defame
21
13:36:53
someone, as a director you'd want to know about
22
13:36:56
that, correct?
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1
13:36:58
A People are entitled to their personal
2
13:37:00
opinion.
3
13:37:00
Q Yes or no, would you want to know about it
4
13:37:02
or not?
5
13:37:04
6
13:37:07
THE WITNESS: People are entitled to their
7
13:37:08
personal opinions.
8
13:37:09
BY MR. KLAYMAN:
9
13:37:09
Q Yes or no?
10
13:37:09
MR. KRESS: He's answering the question.
11
13:37:11
MR. KLAYMAN: He's not answering it.
12
13:37:12
THE WITNESS: People are entitled to their
13
13:37:14
personal opinions.
14
13:37:14
BY MR. KLAYMAN:
15
13:37:15
Q It has nothing to do with whether you'd
16
13:37:17
want to know. Yes or now?
17
13:37:19
18
13:37:21
opinions.
19
13:37:22
Q Yes or no?
20
13:37:23
21
13:37:26
opinions.
22
13:37:26
Q So what is this? The Board of Directors --
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1
13:37:26
the three Board of Directors are like hear no evil,
2
13:37:30
see no evil, do no evil, is that -- that the modus
3
13:37:34
operandi of the Board of Directors?
4
13:37:36
5
13:37:37
BY MR. KLAYMAN:
6
13:37:37
Q Like three monkeys?
7
13:37:40
8
13:37:40
BY MR. KLAYMAN:
9
13:37:40
Q Is that what you're saying?
10
13:37:42
11
13:37:43
BY MR. KLAYMAN:
12
13:37:43
Q Yes or no?
13
13:37:44
MR. KRESS: Yes or no to a question are
14
13:37:46
they monkeys?
15
13:37:47
THE WITNESS: What's your question?
16
13:37:47
BY MR. KLAYMAN:
17
13:37:49
Q That -- that the Board of Directors makes a
18
13:37:50
makes an effort not to know what employees do
19
13:37:52
because they don't want to be involved?
20
13:37:57
A What's the question? I don't know what it
21
13:37:59
is.
22
13:37:59
Q Is that -- is that the way the Board of
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1
13:38:01
Directors of Judicial Watch operated in about
2
13:38:02
February 23rd, 2012?
3
13:38:04
4
13:38:05
THE WITNESS: Is what the way?
5
13:38:05
BY MR. KLAYMAN:
6
13:38:07
Q That if an employee makes some statement
7
13:38:08
that could expose Judicial Watch to liability, you
8
13:38:11
don't want to know about it because everybody's
9
13:38:13
entitled to their opinion?
10
13:38:18
A Individual people are entitled to their
11
13:38:19
personal opinions.
12
13:38:20
Q I'm asking you what the duties and
13
13:38:22
responsibilities of the board are. If some -- let's
14
13:38:27
back up.
15
13:38:28
As a member of the board, you just
16
13:38:30
testified that you would -- you had a fiduciary duty
17
13:38:35
to protect Judicial Watch from legal liability. If
18
13:38:40
some employee does something which is illegal,
19
13:38:45
wouldn't you want to know about it as a member of
20
13:38:47
the board?
21
13:38:47
A If they do something illegal?
22
13:38:50
Q Yeah.
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1
13:38:50
A Certainly.
2
13:38:50
Q Okay. And defamation is not legal, is it?
3
13:38:53
4
13:38:54
BY MR. KLAYMAN:
5
13:38:54
Q If indeed it's defamation?
6
13:38:56
A That's a big if. What a what an individual
7
13:38:59
private person does is not necessarily the position
8
13:39:04
of Judicial Watch. There's all sorts of employees
9
13:39:06
who have all different opinions and ideas. I don't
10
13:39:13
go around, you know, monitoring what every
11
13:39:15
individual person says or believes or thinks.
12
13:39:16
They're entitled to their personal opinion.
13
13:39:18
Q Let's talk about Constance Ruffley.
14
13:39:20
Constance Ruffley, on or about February 23rd, 2012,
15
13:39:24
was the office administrator of Judicial Watch in
16
13:39:26
its San Marino, California office, correct?
17
13:39:28
A Yes.
18
13:39:28
Q And, in fact, during your tenure at
19
13:39:31
Judicial Watch, you've communicated with Constance
20
13:39:33
Ruffley from time to time, correct?
21
13:39:35
A Correct.
22
13:39:35
Q And you've communicated with her about
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13:39:37
legal matters, correct?
2
13:39:40
A No.
3
13:39:41
Q Judicial Watch deals with a lot of legal
4
13:39:44
matters; does it not?
5
13:39:45
A Yes.
6
13:39:46
Q Files Freedom of Information Act requests?
7
13:39:48
A Correct.
8
13:39:49
Q Files lawsuits when they're not responded
9
13:39:51
to in whole or in part, right?
10
13:39:54
A Correct.
11
13:39:54
Q Files lawsuits over guest worker programs
12
13:39:59
with regard to immigration, correct?
13
13:40:03
A Correct.
14
13:40:04
Q Okay. Files ethics complaints against
15
13:40:08
public officials who have alleged to violate the
16
13:40:11
law --
17
13:40:11
A True.
18
13:40:11
Q -- correct? Judicial Watch is in effect
19
13:40:15
like a public-interest law firm; is it not?
20
13:40:22
A In some capacity it may operate that way.
21
13:40:26
Q Yes. So consequently -- and Judicial
22
13:40:28
Watch's mission is to further ethics, correct?
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1
13:40:31
A Correct.
2
13:40:32
Q Judicial Watch's mission is to make sure
3
13:40:33
that others are not acting dishonestly, correct?
4
13:40:38
A Correct.
5
13:40:39
Q So, therefore, if an employee like
6
13:40:41
Constance Ruffley says something about someone that
7
13:40:44
is defamatory, as a member of the board, you would
8
13:40:48
want to know about that, right?
9
13:40:49
10
13:40:54
THE WITNESS: That's a big if.
11
13:40:55
BY MR. KLAYMAN:
12
13:40:57
Q And that gets back to the three monkeys.
13
13:41:00
You'd rather just close your eyes and pretend it
14
13:41:02
never happened, correct?
15
13:41:03
16
13:41:05
THE WITNESS: There's no reason for you to
17
13:41:08
go down this path of being insulting. You've
18
13:41:12
already been admonished in previous litigation.
19
13:41:15
There's no reason for you to go down this path
20
13:41:18
again. I just want to get on the record you've been
21
13:41:22
admonished by a magistrate judge in the last
22
13:41:23
deposition.
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13:41:23
BY MR. KLAYMAN:
2
13:41:24
Q You will answer the question.
3
13:41:25
A You're being abusive, and you --
4
13:41:27
Q I'm not being abusive. I'm not being
5
13:41:27
abusive.
6
13:41:27
A Continue.
7
13:41:29
Q I'm using an analogy.
8
13:41:31
A What's your next question, Mr. Klayman?
9
13:41:31
What's your next question?
10
13:41:33
Q My question is you don't hear anything, you
11
13:41:36
don't want to see anything, and you don't want to do
12
13:41:38
anything when I'm involved, correct?
13
13:41:40
14
13:41:42
THE WITNESS: I have no interest in you
15
13:41:43
whatsoever.
16
13:41:44
BY MR. KLAYMAN:
17
13:41:44
Q Even if an employee does something which is
18
13:41:47
illegal toward me, employee of Judicial Watch, you
19
13:41:49
have no interest?
20
13:41:51
21
13:41:51
THE WITNESS: That's a huge if.
22
13:41:53
BY MR. KLAYMAN:
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13:41:58
Q Was I convicted of a crime of failing to
2
13:42:00
pay child support? Do you have any knowledge, yes
3
13:42:02
or no, to that effect?
4
13:42:04
A I don't know.
5
13:42:04
Q Have you ever made an effort to find out?
6
13:42:07
A No.
7
13:42:09
Q And if Con- -- even after you were sued you
8
13:42:11
made no effort?
9
13:42:12
A Excuse me?
10
13:42:13
Q Even after you were sued by me you've made
11
13:42:15
no effort?
12
13:42:16
A No.
13
13:42:16
Q Because you don't care?
14
13:42:19
A I'm not concerned with you, Mr. Klayman.
15
13:42:22
Q Are you concerned with Judicial Watch?
16
13:42:23
A Absolutely, yes.
17
13:42:24
Q Okay. And if Judicial Watch is being sued
18
13:42:28
over an alleged defamatory statement, you want to
19
13:42:31
get all the facts, as a member of the Board of
20
13:42:33
Directors, correct?
21
13:42:36
A I rely on our counsel. This is our
22
13:42:43
eleventh year of litigation with you, Mr. Klayman,
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1
13:42:48
our eighth or ninth lawsuit. So the fact that
2
13:42:50
you're suing us again on something you've made up or
3
13:42:53
you have some, you know, claim about -- there's no
4
13:42:57
telling what you'll say.
5
13:42:58
Q You don't like me, do you?
6
13:43:00
A I don't have any feeling at all towards
7
13:43:02
you.
8
13:43:09
Q Do you have a feeling towards Judicial
9
13:43:11
Watch?
10
13:43:11
A Yes.
11
13:43:18
Q Did you ever discuss these allegations that
12
13:43:20
I committed a crime with Connie Ruffley?
13
13:43:23
A No.
14
13:43:23
Q Do you know of anyone at Judicial Watch who
15
13:43:26
has?
16
13:43:30
A No. I haven't been party to anything like
17
13:43:33
that.
18
13:43:33
Q As a member of the Board of Directors, do
19
13:43:38
you feel there was an obligation of the other two
20
13:43:39
directors to advise you what was going on between
21
13:43:42
Larry Klayman, Connie Ruffley, and Judicial Watch?
22
13:43:45
A I don't understand the question.
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1
13:43:47
Q As a member of the board --
2
13:43:49
A Yes.
3
13:43:49
Q -- do you believe that you should be fully
4
13:43:51
informed of allegations against Judicial Watch that
5
13:43:57
had violated the law?
6
13:44:00
A Please restate the question.
7
13:44:01
Q As a member of the Board of Directors of
8
13:44:03
Judicial Watch, do you believe that you should be
9
13:44:05
fully informed of any allegations that are made
10
13:44:08
against Judicial Watch that have violated the law?
11
13:44:11
A Certainly.
12
13:44:17
Q So by not informing you of these
13
13:44:20
allegations, the other two directors breached their
14
13:44:22
duty towards you as another member of the board,
15
13:44:25
correct?
16
13:44:25
A I don't even understand your question.
17
13:44:29
Q I'll rephrase it. Let me show you what's
18
13:44:36
been marked as Exhibit 3. On the first page of this
19
13:45:01
composite exhibit is a letter of March 5th, 2012
20
13:45:04
addressed to me from Richard Driscoll of Driscoll &
21
13:45:11
Seltzer, copy to Paul Orfanedes.
22
13:45:13
Have you ever seen this letter before?
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1
13:45:17
A I believe so.
2
13:45:17
Q When?
3
13:45:21
A Probably sometime around the date of the
4
13:45:22
letter. I can't tell you exactly when.
5
13:45:26
Q And in this letter I'm making an allegation
6
13:45:28
that Constance Ruffley said something that was
7
13:45:34
defamatory about me that was put on the internet?
8
13:45:35
A No. This letter is from Mr. Driscoll
9
13:45:38
telling you that you've produced no evidence to
10
13:45:41
support your outrageous allegations.
11
13:45:43
Q Okay. And what did you understand
12
13:45:45
Mr. Driscoll to be talking about when you saw it on
13
13:45:48
or about March 5th, 2012?
14
13:45:50
A That you had some sort of claim you were
15
13:45:52
making, some sort of allegations that were
16
13:45:54
unsupported and were outrageous.
17
13:45:56
Q How did you come about seeing this letter
18
13:45:58
on March 5th, 2012?
19
13:46:00
A I don't know that it was that date.
20
13:46:02
Sometime around then.
21
13:46:02
Q Yeah, how did -- how did it come to your
22
13:46:04
attention?
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1
13:46:13
A Because you had sent some sort of
2
13:46:14
threatening e-mail or communication and Mr. Driscoll
3
13:46:17
responded to you. Mr. Driscoll is our counsel, and
4
13:46:19
he kept us informed of what was going on.
5
13:46:21
Q And you saw the threatening e-mail?
6
13:46:24
A I don't recall it per se. I don't know
7
13:46:26
exactly what it says, but I'm -- I'm kind of
8
13:46:31
familiar --
9
13:46:32
Q Take your opportunity and read --
10
13:46:33
A Like I said, this is our eleventh year of
11
13:46:38
litigation or eighth or ninth lawsuit from you, so
12
13:46:42
threatening e-mails from you are somewhat common.
13
13:46:45
Q If they're so common, how come they haven't
14
13:46:48
been produced in this litigation?
15
13:46:49
A I don't know.
16
13:46:50
Q Were they destroyed like -- like other
17
13:46:51
things were destroyed?
18
13:46:52
19
13:46:53
BY MR. KLAYMAN:
20
13:46:53
Q You're aware that I asked for any
21
13:46:54
communications that concern me with Judicial Watch?
22
13:46:57
You're aware of that, in this litigation?
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1
13:46:59
MR. KRESS: And I objected as counsel.
2
13:47:00
BY MR. KLAYMAN:
3
13:47:00
Q Well, are you aware of that Mr. Farrell?
4
13:47:03
A Excuse me?
5
13:47:04
Q Are you aware that I've requested e-mails
6
13:47:06
or any documentation that referred to me in this
7
13:47:11
litigation I've requested be produced by Judicial
8
13:47:15
Watch?
9
13:47:15
MR. KRESS: Object to the form.
10
13:47:18
THE WITNESS: I know that you've asked for
11
13:47:20
all sorts of things, but our counsel's responded to
12
13:47:23
you.
13
13:47:24
BY MR. KLAYMAN:
14
13:47:24
Q Are you aware that I asked for e-mail and
15
13:47:27
other communications?
16
13:47:28
A I'm certain you asked for all sorts of
17
13:47:30
things, the details of which I'm not 100 percent
18
13:47:34
familiar with, but your -- your requests are usually
19
13:47:37
very broad and sweeping.
20
13:47:40
Q Oh, so you do keep abreast of legal
21
13:47:43
matters, correct?
22
13:47:46
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1
13:47:47
Q So you do keep abreast of legal matters if
2
13:47:50
you're looking at my requests, right?
3
13:47:51
A I just finished telling you I was informed
4
13:47:54
by our counsel of your usual string of threatening
5
13:47:58
e-mails and I responded to you.
6
13:47:58
Q So when you testified before that you knew
7
13:48:01
of nothing since the complaint you lied, correct?
8
13:48:03
A No. You're making false and misleading
9
13:48:04
statements.
10
13:48:05
Q Okay. Then why did you testify that way?
11
13:48:07
12
13:48:07
THE WITNESS: I didn't testify that way.
13
13:48:08
BY MR. KLAYMAN:
14
13:48:09
Q We'll let the record speak for itself.
15
13:48:12
A Absolutely.
16
13:48:12
Q Take an opportunity and review this
17
13:48:19
document. I'm going to ask you questions about it.
18
13:50:32
A Okay.
19
13:50:33
Q You've seen these string of e-mails
20
13:50:37
culminating in the letter from Mr. Driscoll on March
21
13:50:41
5, 2012 before, correct?
22
13:50:43
A I don't know if that's true.
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1
13:50:43
Q Yes or no?
2
13:50:45
A I don't know that that's true.
3
13:50:46
MR. KRESS: If he doesn't know that's --
4
13:50:48
5
13:50:48
BY MR. KLAYMAN:
6
13:50:48
Q Okay. You've seen them before?
7
13:50:50
A I don't know.
8
13:50:50
Q Okay. Well, let's go through them one by
9
13:50:54
one.
10
13:50:54
A Sure.
11
13:50:54
Q Look on the second-to-last page from the
12
13:51:01
end of this composite exhibit, e-mail to Rich
13
13:51:08
Driscoll from Larry Klayman. Rich, I'm being
14
13:51:12
defamed by an employee and agent of Judicial Watch,
15
13:51:16
Connie Ruffley. Please call me to discuss. Thank
16
13:51:18
you, Larry.
17
13:51:19
Have you seen that e-mail before?
18
13:51:20
A I don't know.
19
13:51:21
Q In and around February 23, 2012, which is
20
13:51:24
the date of the e-mail, you were aware that I was
21
13:51:27
making allegations that Connie Ruffley had defamed
22
13:51:30
me, correct?
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1
13:51:30
2
13:51:31
THE WITNESS: I don't know that -- if it
3
13:51:32
was the 23rd, but perhaps sometime shortly
4
13:51:35
afterwards.
5
13:51:35
BY MR. KLAYMAN:
6
13:51:36
Q And you're aware that it concerned Connie
7
13:51:38
Ruffley stating to Orly Taitz that I committed a
8
13:51:41
crime; you were aware of that?
9
13:51:43
A I don't know what Ms. Ruffley did or not
10
13:51:45
say in respect to this e-mail. I have no idea,
11
13:51:48
because you don't say it.
12
13:51:49
Q Did you make any inquiry, what is Klayman
13
13:51:51
talking about, with either the Judicial Watch board
14
13:51:56
or with Richard Driscoll?
15
13:52:00
A I was relying on Mr. Driscoll to handle
16
13:52:03
whatever it was you were claiming.
17
13:52:07
Q So you felt no obligation, as a member of
18
13:52:09
the board, to inquire?
19
13:52:10
A No. I had very competent legal counsel
20
13:52:13
addressing another one of your claims.
21
13:52:20
Q If indeed I was defamed, would there be an
22
13:52:25
obligation of Judicial Watch, as a member of the
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1
13:52:29
board, to correct it?
2
13:52:30
3
13:52:33
THE WITNESS: I mean, that's a
4
13:52:35
hypothetical, if indeed you were. I have no idea.
5
13:52:37
BY MR. KLAYMAN:
6
13:52:37
Q Well, what I'm saying is, if I'm correct
7
13:52:39
here in what I'm writing to Mr. Driscoll that I was
8
13:52:42
defamed, wouldn't you want to know the specifics if
9
13:52:47
Judicial Watch could correct it?
10
13:52:48
11
13:52:52
THE WITNESS: I don't know what's going on
12
13:52:54
inside your head, so I can't -- I can't make an
13
13:52:56
answer based upon what you may or may not think may
14
13:52:59
or may not be defamatory. I don't know.
15
13:53:02
BY MR. KLAYMAN:
16
13:53:02
Q I'm talking about from the perspective of
17
13:53:04
Judicial Watch. Mr. Driscoll can't make a decision
18
13:53:06
to correct it, can he? He's just outside counsel,
19
13:53:12
correct?
20
13:53:13
A Mr. Driscoll was our legal counsel, that's
21
13:53:15
correct.
22
13:53:15
Q And he can't make a decision to take any
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1
13:53:18
action on behalf of Judicial Watch unless the Board
2
13:53:21
approves, correct?
3
13:53:22
4
13:53:24
THE WITNESS: We consult with him and take
5
13:53:25
his legal advice, like anybody would. You always
6
13:53:30
consult with your attorneys on matters like this.
7
13:53:32
BY MR. KLAYMAN:
8
13:53:32
Q And then Judicial Watch would make the
9
13:53:33
decision whether to correct the defamation -- the
10
13:53:35
alleged defamation or not?
11
13:53:37
A Well, these are your --
12
13:53:41
Q Calls for yes or no.
13
13:53:42
MR. KRESS: You can answer the question.
14
13:53:46
THE WITNESS: You get to ask the question.
15
13:53:47
I get to answer it. You may not like the answer,
16
13:53:49
but that's your problem.
17
13:53:50
BY MR. KLAYMAN:
18
13:53:50
Q You know what, Mr. --
19
13:53:52
MR. KRESS: You can answer. Let him
20
13:53:53
answer.
21
13:53:53
BY MR. KLAYMAN:
22
13:53:53
Q You have to answer the question yes or no.
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1
13:53:55
It's a yes-or-no question.
2
13:53:57
MR. KRESS: Nobody has to answer yes or no
3
13:53:59
if they don't want to.
4
13:54:01
5
13:54:01
question.
6
13:54:01
BY MR. KLAYMAN:
7
13:54:01
Q What is it you don't understand?
8
13:54:01
A I don't understand your question. Please
9
13:54:01
restate it.
10
13:54:01
Q You don't have a clue?
11
13:54:03
MR. KRESS: What is the question? Why
12
13:54:03
don't we --
13
13:54:03
BY MR. KLAYMAN:
14
13:54:04
Q The question is, only Judicial Watch's
15
13:54:07
Board can correct a defamatory statement. Mr.
16
13:54:11
Driscoll, as outside lawyer, doesn't have that
17
13:54:13
power, correct?
18
13:54:14
A What defamatory statement?
19
13:54:14
20
13:54:14
BY MR. KLAYMAN:
21
13:54:15
Q If there was one.
22
13:54:15
A I don't know if there was one.
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Page 44
1
13:54:16
Q Well, if you don't know what was said, you
2
13:54:18
don't know, correct?
3
13:54:19
4
13:54:19
BY MR. KLAYMAN:
5
13:54:20
Q Correct?
6
13:54:21
MR. KRESS: You can answer if you can.
7
13:54:23
8
13:54:23
BY MR. KLAYMAN:
9
13:54:24
Q And you didn't really want to know, did
10
13:54:25
you?
11
13:54:26
12
13:54:28
THE WITNESS: I don't even know what you're
13
13:54:29
talking about. What's the subject of your question?
14
13:54:29
BY MR. KLAYMAN:
15
13:54:33
Q You didn't want to know, did you?
16
13:54:35
A Didn't want to know what.
17
13:54:36
Q You didn't want to know what Connie Ruffley
18
13:54:39
said about me?
19
13:54:39
A Please restate your question.
20
13:54:41
Q You didn't want to know what Connie Ruffley
21
13:54:43
told Orly Taitz about me?
22
13:54:45
A I don't know that Connie Ruffley said
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Page 45
1
13:54:47
anything about you.
2
13:54:47
Q Because you never inquired, correct?
3
13:54:49
A I don't even understand your question.
4
13:55:02
Q Connie Ruffley -- strike that.
5
13:55:07
The reason you didn't want to know what she
6
13:55:10
purportedly said about me is because it was about
7
13:55:13
me, Larry Klayman, correct?
8
13:55:16
9
13:55:17
Q Because you didn't --
10
13:55:19
A Can you ask a basic interrogative instead
11
13:55:23
of test- -- providing testimony and then saying
12
13:55:24
right or correct?
13
13:55:26
Q Are you a lawyer, Mr. Farrell?
14
13:55:27
A No. Thank goodness I'm not.
15
13:55:29
Q Right. So don't tell me how to phrase a
16
13:55:33
question. You just answer the question. That's
17
13:55:33
your duty.
18
13:55:34
A Poor layman. I just don't understand these
19
13:55:37
complex legal proceedings.
20
13:55:37
MR. KRESS: All right, let's get a
21
13:55:37
question before him --
22
13:55:39
BY MR. KLAYMAN:
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1
13:55:39
Q Your refusal to answer these questions is
2
13:55:43
not an affront towards me, it's an affront towards
3
13:55:43
the court.
4
13:55:43
MR. KRESS: He's not refusing --
5
13:55:44
A I'm not refusing anything. I'm fully
6
13:55:46
cooperative. I'm not refusing anything. I don't
7
13:55:48
understand your questions.
8
13:55:48
Q Tell me what you don't understand?
9
13:55:50
MR. KRESS: He's trying to.
10
13:55:51
THE WITNESS: Yeah, you have a problem with
11
13:55:53
basic interrogatives. Stick with those, it might
12
13:55:57
help you out. Last time we had a magistrate judge
13
13:55:59
come into the room three times to help you form
14
13:56:02
questions. Unfortunately, we don't have that this
15
13:56:04
time.
16
13:56:05
BY MR. KLAYMAN:
17
13:56:05
Q So you are a lawyer?
18
13:56:05
A No, not at all.
19
13:56:07
Q No? But you know better, know better than
20
13:56:09
the court?
21
13:56:10
22
13:56:11
BY MR. KLAYMAN:
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1
13:56:11
Q As far as you're concerned, you don't have
2
13:56:12
to answer questions. You'll make -- you'll make the
3
13:56:14
rules yourself?
4
13:56:16
A That is false.
5
13:56:16
MR. KRESS: Let's just -- let's just get
6
13:56:18
questions before him which he will answer.
7
13:56:18
THE WITNESS: False and misleading
8
13:56:18
statement from Mr. Klayman.
9
13:56:18
BY MR. KLAYMAN:
10
13:56:19
Q And you'll pretend that you don't
11
13:56:22
understand a question when you don't want to answer
12
13:56:24
it.
13
13:56:25
A That's a false and misleading statement by
14
13:56:27
Mr. Klayman.
15
13:56:27
MR. KRESS: Let's stop for a second. Let's
16
13:56:27
just get some questions before him and let him
17
13:56:31
answer. Let's not get this back-and-forth
18
13:56:31
arguments.
19
13:56:31
MR. KLAYMAN: Do you want to take him out
20
13:56:33
of the room and instruct him that right now he's
21
13:56:35
violating court process.
22
13:56:36
MR. KRESS: He's not violating any court
631

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1
13:56:38
process.
2
13:56:38
MR. KLAYMAN: We'll see.
3
13:56:39
THE WITNESS: Basic interrogatives, please.
4
13:56:41
BY MR. KLAYMAN:
5
13:56:41
Q You know, it's -- and that gets back to the
6
13:56:42
question hear no evil, see no evil, do no evil.
7
13:56:46
That's not to be sarcastic or anything, that's a way
8
13:56:51
of doing business for you, isn't it Mr. Farrell?
9
13:56:53
A That's a false and misleading statement on
10
13:56:55
your part, Mr. Klayman.
11
13:56:56
Q Tell me why.
12
13:56:57
A First of all, I didn't find a question in
13
13:56:59
that remark. Where's the question?
14
13:57:01
Q What is it about my question as to whether
15
13:57:04
or not you had a duty, as a member of the board, to
16
13:57:06
find out what Connie Ruffley said? What's confusing
17
13:57:09
about that?
18
13:57:12
A Because I don't know that what you're
19
13:57:16
saying is true.
20
13:57:18
Q And if you never inquire, you'll never be
21
13:57:21
able to find out, will you?
22
13:57:22
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1
13:57:23
THE WITNESS: I don't know what that
2
13:57:24
question -- is there a question in there?
3
13:57:24
BY MR. KLAYMAN:
4
13:57:26
Q We'll let the record speak for itself. Has
5
13:57:31
anyone advised you that you're under oath?
6
13:57:34
A I just took an oath a few minutes ago.
7
13:57:36
Q That means to tell the whole truth, not
8
13:57:38
just what you want to tell?
9
13:57:39
A Absolutely.
10
13:57:42
Q You're aware of the penalty for not telling
11
13:57:45
the truth?
12
13:57:46
A Absolutely.
13
13:57:46
Q In and around the time of these -- this
14
13:57:58
string of e-mails, did you see the publication that
15
13:58:00
Orly Taitz had made that I read to you in her
16
13:58:03
eligibility web site?
17
13:58:05
A No.
18
13:58:05
Q Did you ask to see it?
19
13:58:06
A Didn't know it existed.
20
13:58:11
Q Did you ask to see what the basis of the
21
13:58:13
defamation was -- alleged defamation?
22
13:58:21
A I don't remember.
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1
13:58:35
Q If someone accused you of committing a
2
13:58:37
crime, you'd want to know about that, wouldn't you?
3
13:58:39
A Certainly.
4
13:58:40
Q Okay. And if someone had said that Chris
5
13:58:44
Farrell committed a crime, why don't we send that
6
13:58:46
information to Judicial Watch's donors, you would
7
13:58:48
want to know about that, right?
8
13:58:54
A Who's the person saying it?
9
13:58:56
Q Anyone.
10
13:58:57
A I don't know.
11
13:58:57
Q Say it was somebody in some position of
12
13:59:02
prominence accused you of committing a crime and
13
13:59:05
then telling the person that was told that to go
14
13:59:10
send that to your donors, you'd want to know about
15
13:59:13
that, correct?
16
13:59:14
A I don't know.
17
13:59:16
Q That wouldn't concern you?
18
13:59:18
A It's a very vague hypothetical, so I don't
19
13:59:20
know -- I can't answer competently.
20
13:59:23
Q What's -- what's vague about your being
21
13:59:24
accused of a crime and then sending it to donors?
22
13:59:29
What's vague about that?
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1
13:59:30
A You don't say who the person is who's
2
13:59:38
making the statement. There's a lot of open-ended
3
13:59:40
loose hypothetical language in there that I'm not
4
13:59:42
going to make a definitive statement about.
5
13:59:44
Q Are you aware that at the time that this
6
13:59:51
correspondence was being sent to Mr. Driscoll I was
7
13:59:54
asking Mr. Driscoll to help resolve the situation to
8
14:00:00
mitigate any damage by clearing up what was said by
9
14:00:03
Constance Ruffley?
10
14:00:03
A What's your question?
11
14:00:04
Q Are you aware that I was reaching out to
12
14:00:06
Mr. Driscoll to try to mitigate the damage to me by
13
14:00:11
clearing up what was said?
14
14:00:13
A I certainly saw Mr. Driscoll's letter back
15
14:00:15
to you.
16
14:00:19
Q And did you have any discussion with anyone
17
14:00:21
about that letter when you saw it in or about March
18
14:00:27
6th, 2012?
19
14:00:39
A I probably spoke -- when I saw the letter,
20
14:00:42
I probably spoke with -- I don't think I spoke with
21
14:00:45
Mr. Driscoll at that point. I think I read the
22
14:00:48
letter from him. And I probably spoke with the two
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Page 52
1
14:00:57
other directors, Tom Fitton and Paul Orfanedes when
2
14:01:01
I received the letter that we'd received this.
3
14:01:04
Q And what did you talk about? What was
4
14:01:06
discussed?
5
14:01:07
A That Mr. Driscoll had answered unsupported
6
14:01:15
outrageous allegations by you concerning -- let's
7
14:01:24
see -- some sort of a conspiracy to defame and
8
14:01:27
disparage, some claim you'd made. I'm just reading
9
14:01:31
from Mr. Driscoll's letter.
10
14:01:32
Q Do you know whether Constance Ruffley has
11
14:01:39
ever been -- whether any director -- strike that.
12
14:01:42
Do you know whether any director of
13
14:01:44
Judicial Watch has ever talked to Constance Ruffley
14
14:01:46
about what I claim was said to Orly Taitz about my
15
14:01:49
committing a crime and then giving that information
16
14:01:51
to donors?
17
14:01:53
A Please restate your question.
18
14:01:55
Q Do you know whether anyone at Judicial
19
14:01:56
Watch has ever talked to Mrs. Ruffley about my
20
14:01:59
allegations that Orly Taitz published a statement
21
14:02:03
that Ruffley made that I committed a crime and that
22
14:02:06
should be given to donors?
631

Merrill LAD
Page 53
1
14:02:08
A That's a long question. The way you've
2
14:02:13
phrased it, I don't know.
3
14:02:15
MR. KLAYMAN: Will you read it back,
4
14:02:17
please.
5
14:02:17
6
14:02:39
requested.)
7
14:02:39
THE WITNESS: Probably Mr. Orfanedes.
8
14:02:41
BY MR. KLAYMAN:
9
14:02:41
Q But you don't know?
10
14:02:43
A I wasn't, you know, personally involved. I
11
14:02:47
have no firsthand knowledge, but I believe
12
14:02:49
Mr. Orfanedes would have spoken to her.
13
14:02:50
Q Did you know -- did Mr. Orfanedes inform
14
14:02:54
you what was discussed between them?
15
14:02:57
A Just the subject generally. I have no idea
16
14:03:00
about specifics of what was discussed.
17
14:03:01
Q You didn't ask?
18
14:03:05
A I don't recall.
19
14:03:30
Q What kind of computer do you have? I -- I
20
14:03:33
take it you have a computer at your desk at Judicial
21
14:03:35
Watch?
22
14:03:35
A Correct.
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Page 54
1
14:03:36
Q How long have you had that computer?
2
14:03:38
A I have no idea.
3
14:03:40
Q Many years?
4
14:03:43
A I don't know what many is. A few years.
5
14:03:45
Q Dating back prior to February 23rd, 2012?
6
14:03:53
A Yes.
7
14:03:55
Q Have you searched your computer for any
8
14:03:57
communications that concern me, Larry Klayman, Orly
9
14:04:01
Taitz, and Constance Ruffley?
10
14:04:03
A Yes.
11
14:04:03
Q When did you do that?
12
14:04:08
A Probably a few weeks ago.
13
14:04:12
Q What did you find?
14
14:04:13
A Nothing.
15
14:04:15
Q Did you -- do you delete from your e-mails
16
14:04:20
and other communications routinely?
17
14:04:23
A Somewhat routinely, yeah.
18
14:04:32
Q Do you use Outlook?
19
14:04:34
A Yes.
20
14:04:37
Q Is there a central server at Judicial Watch
21
14:04:39
that would keep e-mail communications from everyone?
22
14:04:42
A I don't know.
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Page 55
1
14:04:43
Q You're aware that Mr. Fitton keeps most
2
14:04:47
e-mail communications; he doesn't delete?
3
14:04:49
A I have no idea. You'll have to ask him.
4
14:04:51
Q Do you have a laptop?
5
14:04:52
A No.
6
14:04:53
Q Do you have a cell phone?
7
14:04:54
A Yes.
8
14:04:56
Q What kind of cell phone do you have?
9
14:04:58
A An iPhone.
10
14:05:00
Q Is it paid for by Judicial Watch?
11
14:05:02
A No.
12
14:05:03
Q Do they pay for the service?
13
14:05:05
A No.
14
14:05:05
Q What service do you use?
15
14:05:07
A Verizon.
16
14:05:11
Q Do you sometimes send e-mails off of
17
14:05:13
those -- off of that cell phone?
18
14:05:14
A Yes.
19
14:05:16
Q And you've been sending e-mails well prior
20
14:05:19
to February 23rd, 2012?
21
14:05:21
A Say that question again.
22
14:05:22
Q You've been sending e-mails off of your
631

Merrill LAD
Page 56
1
14:05:25
phone before February 12th -- February 23rd, 2012?
2
14:05:29
A Yes.
3
14:05:29
Q Okay. And you're continuing to do that?
4
14:05:32
A To send e-mails from my phone, is that the
5
14:05:35
question?
6
14:05:35
Q Yeah.
7
14:05:36
A Yes, I send e-mails from my phone.
8
14:05:38
Q Did you check your cell phone for any
9
14:05:40
e-mails that concern Larry Klayman, Constance
10
14:05:44
Ruffley, and/or Orly Taitz?
11
14:05:47
A Yes.
12
14:05:47
Q What'd you find?
13
14:05:48
A Nothing.
14
14:05:51
Q What kind of cell phone does Thomas Fitton
15
14:05:54
have?
16
14:05:54
A I have no idea.
17
14:05:55
Q What kind of computer do you have at your
18
14:05:57
desk? What's -- what brand?
19
14:06:04
A I don't know.
20
14:06:07
Q How many years have you had it?
21
14:06:08
A Years. I don't know how many.
22
14:06:12
Q And in all those years, you don't know what
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Merrill LAD
Page 57
1
14:06:14
kind of computer you have?
2
14:06:15
A No. I turn it on. I do my work.
3
14:06:18
Q You're an investigator, Mr. Farrell, aren't
4
14:06:21
you?
5
14:06:21
A Yes, I am.
6
14:06:22
Q Your job is to deal with detail, correct?
7
14:06:26
A It depends.
8
14:06:27
Q And to be discerning, correct?
9
14:06:31
A Is there a question?
10
14:06:32
Q Yeah. And you don't know what kind of
11
14:06:35
computer you have?
12
14:06:35
A No. I said no.
13
14:06:41
Q Do you know if Constance Ruffley was
14
14:06:45
disciplined at all over the allegations that were
15
14:06:48
contained in my complaint?
16
14:06:51
A No.
17
14:06:51
Q Do you know whether she was given advice to
18
14:06:54
be careful about making statements about Larry
19
14:06:57
Klayman?
20
14:06:57
A No.
21
14:07:11
Q I show you what's been marked as
22
14:07:13
Plaintiffs' Exhibit 9.
631

Merrill LAD
Page 58
1
14:07:19
MR. KLAYMAN: Do you have a copy of that,
2
14:07:21
Doug?
3
14:07:22
MR. KRESS: Exhibit 9, I don't think it's
4
14:07:27
here.
5
14:07:27
MR. KLAYMAN: I'll read it.
6
14:07:28
BY MR. KLAYMAN:
7
14:07:29
Q Let me just show it to you, if I can hand
8
14:07:31
it over to you. I'm talking about an e-mail which
9
14:07:39
is Judicial Watch Bates No. 505 from Connie Ruffley
10
14:07:44
to Tom Fitton, Christopher Farrell, Steve Anderson,
11
14:07:48
Susan Prytherch, concerning Orly Taitz posting a
12
14:07:52
Judicial Watch invite to speak on her web site.
13
14:07:52
A Okay.
14
14:08:17
Q Showing you this page, have you ever seen
15
14:08:18
that e-mail from Connie Ruffley before?
16
14:08:35
A I don't recall seeing it.
17
14:08:36
Q Are you aware of the subject matter of it,
18
14:08:39
that Orly Taitz was apparently invited to an event
19
14:08:43
that she thought was being sponsored by Judicial
20
14:08:46
Watch but instead it was being sponsored by UROC,
21
14:08:49
U-r-o-c?
22
14:08:54
A I see this e-mail in front of me, but I
631

Merrill LAD
Page 59
1
14:08:56
have no recollection of it.
2
14:08:56
Q Do you have any recollection of the issue
3
14:08:58
coming up?
4
14:08:59
A Only after you sued this -- no, I guess
5
14:09:01
only after this, the threatening e-mails and the
6
14:09:04
response from Mr. Driscoll, that's when I would
7
14:09:07
have --
8
14:09:07
Q You were aware about this UROC issue after
9
14:09:12
that? This does not concern me. It concerns UROC.
10
14:09:18
A I don't know. I guess I don't recall
11
14:09:21
seeing this.
12
14:09:21
Q Do you know -- do you recall being advised
13
14:09:25
of the situation with Taitz believing that she was
14
14:09:30
invited to an event by Judicial Watch and Judicial
15
14:09:34
Watch telling Connie Ruffley that this needs to be
16
14:09:37
corrected on any posting?
17
14:09:39
A I don't know what Taitz believed, but I see
18
14:09:42
this e-mail and it says PJO, so it's Paul Orfanedes
19
14:09:49
asking that it be made clear that it's her UROC
20
14:09:53
event and not Judicial Watch.
21
14:09:54
Q Were you aware of that at the time, in and
22
14:09:56
around August 28th, 2012?
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Merrill LAD
Page 60
1
14:10:01
A I don't recall. Perhaps, but I don't know.
2
14:10:03
Q The e-mail's addressed to you, among
3
14:10:06
others.
4
14:10:06
A The e-mail's from Paul. It's addressed to
5
14:10:09
Chris Fedeli, not to me. That's why I don't recall
6
14:10:14
seeing it.
7
14:10:31
MR. KLAYMAN: I have no other questions at
8
14:10:32
this time. I'll leave the deposition open to see
9
14:10:34
what, if anything, comes up in the deposition of
10
14:10:38
Mr. Fitton and in subsequent document production.
11
14:10:40
MR. KRESS: We're not agreeing to keep the
12
14:10:41
deposition open, but that can be an issue for later
13
14:10:44
if necessary, and I have no questions, and we'll
14
14:10:47
reserve the right to read.
15
14:10:48
THE VIDEOGRAPHER: Here marks the end of
16
14:10:49
Volume 1, Tape No. 1 in the deposition of
17
14:10:52
Christopher Farrell. Going off the record. The
18
14:10:55
time is 2:10 p.m.
19
14:10:56
(Signature having not been waived, the
20
14:10:56
deposition of Christopher J. Farrell was concluded
21
14:11:48
at 2:10 p.m.)
22
631

Merrill LAD
Page 61
1 * * *
3 I, Christopher J. Farrell, do hereby acknowledge
4 that I have read and examined the foregoing
5 testimony, and the same is a true, correct and
6 complete transcription of the testimony given by me,
7 and any corrections appear on the attached Errata
8 sheet signed by me.
9
10 _________________________ _____________________
12
13
14
15
16
17
18
19
20
21
22
631

Merrill LAD
Page 62
12 hand and affixed my notarial seal this 31st day of
13 January 2014.
14
16 June 14, 2014
17 ____________________________
20
21
22
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Merrill LAD
Page 63
3 RETURN BY: ________________________________________
4 ===================================================
6 ===================================================
7 ____ ____ ___________________________________
8 ____ ____ ___________________________________
9 ____ ____ ___________________________________
10 ____ ____ ___________________________________
11 ____ ____ ___________________________________
12 ____ ____ ___________________________________
13 ____ ____ ___________________________________
14 ____ ____ ___________________________________
15 ____ ____ ___________________________________
16 ____ ____ ___________________________________
17 ____ ____ ___________________________________
18 ____ ____ ___________________________________
19 ____ ____ ___________________________________
20 ____ ____ ___________________________________
21 _______________ ___________________________________
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Merrill LAD
Page 64
3 RETURN BY: _________________________________________
4 ====================================================
6 ====================================================
7 ____ ____ ___________________________________
8 ____ ____ ___________________________________
9 ____ ____ ___________________________________
10 ____ ____ ___________________________________
11 ____ ____ ___________________________________
12 ____ ____ ___________________________________
13 ____ ____ ___________________________________
14 ____ ____ ___________________________________
15 ____ ____ ___________________________________
16 ____ ____ ___________________________________
17 ____ ____ ___________________________________
18 ____ ____ ___________________________________
19 ____ ____ ___________________________________
20 ____ ____ ___________________________________
21 _______________ ___________________________________
631

Merrill LAD
Page 1
A
able
48:21
abreast
37:20 38:1
Absolutely
32:16 38:15 49:9,12
abusive
31:3,4,5
accused
50:1,12,21
acknowledge
61:3
ACKNOWLEDGM...
61:2
Act
29:6
acting
30:3
action
42:1
addressed
34:20 60:2,4
addressing
40:20
administrator
18:20 28:15
admonished
30:18,21
advertisement
19:7
advice
7:19 42:5 57:17
advise
33:20
advised
19:19 20:7 21:15 49:5
59:12
affair
18:2
affixed
62:12
affront
46:2,2
agent
39:14
ago
21:1 49:6 54:12
agree
12:18 21:8
agreeing
60:11
Akim
3:20 5:10
allegation
35:5
allegations
15:15 33:11 34:4,9,13
35:10,15 39:21 52:6
52:20 57:14
alleged
24:20 29:15 32:18
42:10 49:21
allegedly
13:21 20:18
alleging
14:16,19,22
amount
20:2
analogy
31:7
Anderson
58:10
and/or
56:10
answer
20:12 22:10 31:2
41:13 42:13,15,15,19
42:20,22 43:2 44:6
45:16 46:1 47:2,6,11
47:17 50:19
answered
52:5
answering
25:10,11
anybody
42:5
apparently
58:18
appear
61:7
applauded
18:17
approach
9:10
approached
9:5 10:3 11:1 18:18
approves
42:2
April
6:8
aren't
57:3
arguments
47:18
Army
6:15,16
Article
18:3 19:5
article2superPAC
18:1,6
asked
11:5 36:20 37:10,14
37:16
asking
19:8 27:12 51:7 59:19
assistance
7:19
Association
9:3
attached
61:7
attention
35:22
ATTORNEY
3:5
attorneys
42:6
attributed
13:16
August
59:22
Avenue
3:7
aware
14:5,21 15:18 16:4
17:2 21:3,5 36:20,22
37:3,5,14 39:20 40:6
40:8 49:10 51:5,11
55:1 58:17 59:8,21
awareness
16:12
B
B
4:6
back
11:3 27:14 30:12 48:5
51:14 53:3 54:5
background
6:10 10:7
back-and-forth
47:17
banner
9:18
based
16:8,20 41:13
basic
45:10 46:11 48:3
basis
49:20
Bates
58:9
Beach
3:16
begins
5:2
behalf
3:3,11 42:1
believe
22:4,6,8 34:3,8 35:1
53:11
believed
59:17
believes
28:11
believing
59:13
better
46:19,19
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big
28:6 30:10
birth
16:21
birther
16:19 19:4
board
13:2,17 21:13 22:2,15
23:2,18 25:22 26:1,3
26:17,22 27:13,15,20
30:7 32:19 33:18
34:1,7,14 40:13,18
41:1 42:1 43:15
48:15
book
13:6
born
6:7
brand
56:18
breached
34:13
briefly
6:9
broad
37:19
Bronx
6:13
brought
16:4 17:3
business
11:3 48:8
bylaws
12:13
C
C
3:1 4:1 5:1 64:1
Cain
1:22 2:10 5:20 62:2
California
18:12 19:10,20 28:16
call
11:2 12:11 39:15
called
7:4
Calls
23:9 42:12
candidate
18:11
can't
8:7 35:4 41:12,12,17
41:22 50:19
capacity
29:20
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18:19
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22:20 32:13
careful
57:18
case
1:5 5:6 14:4 17:2 62:9
cases
19:5,9
Catholic
8:22 9:1,2
CCIR
17:22
cell
55:6,8,17 56:8,14
central
54:20
certain
37:16
certainly
28:1 34:11 50:3 51:14
certificate
16:22 62:1
certify
62:4
Challenge
17:10,15
challenging
16:5 17:3
Chaminade
6:11
changed
11:11,17 24:2
charity
8:22 9:1
check
56:8
chiefly
6:18
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15:17,20 20:2 32:2
Chris
50:4 60:5
Christopher
1:11 2:1 4:3 5:3,22 6:6
58:10 60:17,20 61:3
circumstance
9:9
citizenship
16:8
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33:3 35:14 52:8,14
claiming
19:8 21:4 23:17 40:16
claims
14:1 40:20
classified
7:21
clear
19:15 59:19
clearance
7:10
clearing
51:8,13
Clinton's
19:12
close
30:13
club
18:13
clue
43:10
college
6:10
Columbia
2:12 22:20 62:19
come
6:20 8:3 9:4 11:5,10
11:16 13:2,10 35:17
35:21 36:13 46:13
comes
60:9
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59:3
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13:16,21
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62:15
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23:16 33:12 40:7 50:5
52:21
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50:1,12 52:15
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36:12,13
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28:19,22
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36:2
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36:21 37:15 54:8,16
54:21 55:2
competent
40:19
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50:19
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14:10,16,19,22 15:8
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20:21,22 21:2,9 22:6
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complaints
29:14
complete
61:6
complex
45:19
composite
34:19 39:12
computer
53:19,20 54:1,7 56:17
57:1,11
Con
32:7
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concern
36:21 50:17 54:8 56:9
59:9
concerned
32:14,15 40:6 47:1
concerning
13:11,12 52:6 58:11
concerns
59:9
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60:20
conference
9:11
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48:16
Connie
15:19 20:8 21:16
33:12,21 39:15,21
40:6 44:17,20,22
45:4 48:16 58:9,15
59:15
consequently
29:21
conspiracy
52:7
Constance
13:16,22 14:5 18:19
20:8,17 28:13,14,19
30:6 35:6 51:9 52:10
52:13 54:9 56:9
57:13
consult
42:4,6
contained
57:15
Continue
31:6
continuing
56:3
contract
8:12
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7:9 8:15
conversation
11:2
convicted
15:20 20:1,10,19 32:1
cooperative
46:6
copy
17:8 34:21 58:1
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13:6
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11:22
correct
9:14 10:18 11:7,14
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28:16,20,21 29:1,7
29:10,12,13,18,22
30:1,3,4,14 31:12
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59:16
CORRECTION
63:5 64:5
corrections
61:7
correspondence
51:6
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5:13,15,17 6:3 32:21
36:3 37:1 38:4 40:19
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37:11
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6:19
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11:4
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1:1 2:11 5:6,19 14:8,9
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62:2
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15:20 20:10,19 23:16
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38:20
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7:20
D
D
5:1 64:1
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51:8,12
date
5:8 12:19 35:3,19
39:20 61:11 63:22
64:22
Dating
54:5
day
11:3 62:12
days
11:4
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57:6
deals
29:3
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41:17,22 42:9
defamation
28:2,5 42:9,10 49:21
49:21
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23:1,17 30:7 32:18
35:7 41:14 43:15,18
defame
24:20 52:7
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39:14,21 40:21 41:8
Defendant
1:8 3:11
defense
7:9,20 8:14
definitive
51:4
delete
54:15 55:2
Department
7:20
depends
13:1 57:7
DEPONENT
61:2
deposition
1:11 2:1 5:3,11 17:7
30:22 60:8,9,12,16
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53:20 56:18
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36:16,17
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57:6
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37:17
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10:21 15:16 16:13
20:22 38:12 44:9,15
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48:12 49:19 53:17
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28:9
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3:21
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62:7
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11:22 12:1,7 24:15,21
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directors
12:2,4,8,22 13:3,11,18
14:5 21:14 22:2,15
25:22 26:1,3,17 27:1
32:20 33:18,20 34:7
34:13 52:1
discerning
57:8
disciplined
57:14
discuss
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33:11 39:15
discussed
52:4 53:14,16
discussion
9:12 13:15 14:15,18
19:3 51:16
dishonestly
30:3
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52:8
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19:13
District
1:1,2 2:12 5:5,6 22:19
62:19
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17:19 38:17 60:10
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37:6
doesn't
39:3 43:16 55:2
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8:10 16:17 17:5 48:8
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16:1 19:22 50:6,14,21
52:16,22
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10:15 12:9 13:7,14
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26:19,20 27:8 28:9
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57:10 58:3,16 59:10
59:10,17 60:1,1,5
Doug
5:17 58:2
DOUGLAS
3:12
Dr
13:12 18:9
Driscoll
34:20,20 35:8,12 36:2
36:3 38:20 39:13
40:14,15 41:7,17,20
43:16 51:6,7,12,21
52:5 59:6
Driscoll's
51:14 52:9
Drive
18:22
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18:14
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6:1
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7:17 12:6 22:14 24:10
27:12
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27:16 34:14 45:17
48:15
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1:12 2:7 3:8 5:12 9:13
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1:4 3:1,1 4:1,6 5:1,1,4
63:1,1,1 64:1,1,1,1
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24:9
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6:9
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29:18 32:3
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26:18 32:5,8,11
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33:1 36:11
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40:13
eleventh
32:22 36:10
eligibility
16:5,20 17:4,10,15
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11:13 62:9
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22:22 23:14 24:19
27:6,18 30:5 31:17
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22:21 26:18 28:8
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8:16,18
engineer
7:16
ensued
10:22
entitled
25:1,6,12,17,20 27:9
27:10 28:12
Errata
61:7
ESQUIRE
3:4,12
ethics
29:14,22
Evangelization
9:3
event
9:10 58:18 59:14,20
everybody's
27:8
evidence
35:9
evil
26:1,2,2 48:6,6,6
exactly
8:7 35:4 36:7
EXAMINATION
4:3 6:3
examined
6:1 61:4
Excuse
17:8 32:9 37:4
exhibit
17:7,11 34:18,19
39:12 57:22 58:3
exhibits
4:7
existed
49:19
expires
62:15
expose
27:7
eyes
30:13
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19:6 36:2,5 37:14
39:12,17,20 40:10
54:21 55:2 58:8,15
58:22 59:18
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36:12 37:5 38:5,19
49:14 54:15 55:16,19
55:22 56:4,7,9 59:5
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60:2,4
F
fact
28:18 33:1
facts
32:19
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32:1
Fairfax
7:6
false
38:8 47:4,7,13 48:9
familiar
36:8 37:18
far
47:1
Farrell
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6:7 37:3 45:13 48:8
50:5 57:3 58:10
60:17,20 61:3
FBI
19:1
February
18:5,8 19:8 27:2 28:14
39:19 54:5 55:20
56:1,1
Fedeli
60:5
feel
15:2 33:19
feeling
33:6,8
felt
40:17
fiduciary
22:17 27:16
filed
13:20 16:18 19:10,15
Files
29:6,8,11,14
finally
19:12
financial
62:10
find
32:5 48:12,16,21
54:13 56:12
finished
38:3
firm
7:4,9,20 29:19
first
15:13 24:9 34:18
48:12
firsthand
53:11
Fitton
12:5 14:18 52:1 55:1
56:14 58:10 60:10
Florida
1:2 3:16 5:6 16:5
19:10
follows
6:2
Fordham
6:13
foregoing
61:4 62:3,4
form
12:16,17 20:11 21:7
22:9 23:10,19 24:16
25:5 26:4,7,10 27:3
28:3 30:9,15 31:13
31:20 36:18 37:9
40:1 41:2,10 42:3
44:3,11 46:13,21
48:22
formal
12:11,21
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10:19
Freedom
29:6
front
17:13 58:22
fully
34:3,9 46:5
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18:1
further
29:22
G
G
2:6 5:1,11
Garden
18:13
Gardens
3:16
general
7:22 8:14
generally
16:19 24:17 53:15
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14:8
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18:12 52:22 57:17
61:6 62:5
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52:15
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8:8 28:10 30:17,19
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12:14
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12:18 33:20 36:4
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60:17
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9:21 10:8,9
goodness
45:14
graduated
6:11,12
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3:20 5:10
great
16:13
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9:17 19:5
Grove
18:13
guess
11:21 59:4,10
guest
29:11
H
H
4:6 63:1 64:1
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58:7 62:12
handle
40:15
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19:16 30:14
hard
19:11
harmed
15:2
haven't
33:16 36:13
head
10:16 41:12
headquarters
18:21
hear
18:15 26:1 31:10 48:6
heard
16:10 17:14,17 18:3
19:4
held
2:2
help
46:12,13 51:7
helped
8:11
hereunto
62:11
he's
19:4 25:10,11 41:18
46:4,9 47:20,22
high
6:10,11
highly
24:9
hire
11:8
hired
11:6,18
hour
18:15
hours
19:9
Howard
9:15
huge
31:21
Human
8:2
Huntington
18:22
hypothetical
22:3 41:4 50:18 51:3
I
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idea
15:21 16:2 17:5 23:5
24:4 40:10 41:4
53:15 54:2 55:3
56:16
ideas
28:9
identify
5:13
II
18:3 19:5
illegal
27:18,21 31:18
immigration
29:12
impressed
10:10,13
Incorporated
5:5
individual
27:10 28:6,11
inform
53:13
informally
12:12
information
15:22 20:3 29:6 50:6
52:15
informed
22:1 34:4,9 36:4 38:3
informing
34:12
initially
14:4
initiated
19:3
inquire
40:18 48:20
inquired
45:2
inquiry
40:12
inside
41:12
instruct
47:20
insulting
30:17
intelligence
8:2
interest
31:14,19 62:10
interim
8:16
internet
17:9 35:7
interrogative
45:10
interrogatives
46:11 48:3
interview
11:5
investigative
10:7
investigator
11:9 57:3
invite
58:12
invited
58:18 59:14
involved
8:1 19:4 26:19 31:12
53:10
iPhone
55:9
isn't
48:8
issue
16:20 59:2,8 60:12
it's
12:18 17:13 22:3 24:5
28:5 43:1 46:2 48:5
50:18 58:3 59:18,19
60:4
I'd
9:21 15:19
I'll
17:6 34:17 58:5 60:8
I'm
9:18 13:7 14:21 15:13
20:4 22:3 24:4 27:12
31:4,4,7,12 32:14
35:5 36:7,7 37:16,17
38:17 39:13 41:6,6,7
41:16 45:14 46:5,5,6
51:3 52:8 58:8
I've
37:5,7
J
J
1:11 2:1 3:12 4:3 5:22
60:20 61:3
James
3:21
January
1:13 5:8 7:2 62:13
Joan
1:22 2:10 5:20 62:2
job
1:20 9:5 57:6
Jog
3:15
judge
30:21 46:12
Judicial
1:7 5:4,17 8:17 9:5,22
10:4,11,16,19 11:11
11:13,17 12:7 14:3
18:14,18,20 19:2,21
21:14 22:15 23:14
24:10,11,19 27:1,7
27:17 28:8,15,19
29:3,18,21 30:2
31:18 32:15,17 33:8
33:14,21 34:4,8,10
36:21 37:7 39:14
40:13,22 41:9,17
42:1,8 43:14 50:6
52:13,18 53:20 54:20
55:10 58:9,12,19
59:14,14,20 63:2
64:2
June
62:16
K
KAHLE
3:13
keep
13:3,6 24:6 37:20 38:1
54:21 60:11
keeps
55:1
kept
36:4
kind
36:7 53:19 55:8 56:14
56:17 57:1,10
Klayman
1:4 3:4,5 4:4 5:4,15,15
6:4 13:13,17 18:1,7,8
19:3,15,19 20:15,18
21:12,22 22:13 23:13
23:16,22 24:14,18
25:8,11,14 26:5,8,11
26:16 27:5 28:4
30:11 31:1,8,16,22
32:14,22 33:21 36:19
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39:13 40:5,12 41:5
41:15 42:7,17,21
43:6,13,20 44:4,8,14
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48:10 49:3 53:3,8
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64:2
knew
10:16,19 38:6
know
9:21 10:15,21 12:9
13:4,7 15:7 19:22
20:22 21:20 22:4,11
22:11 23:3,8,18,20
24:3,21 25:3,16
26:18,20 27:8,19
28:10 30:8 32:4 33:3
33:14 35:19 36:6,15
37:10 38:22 39:2,3,4
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39:7,18 40:2,9 41:8
41:11,14 42:18 43:22
44:1,2,7,9,12,15,16
44:17,20,22 45:5
46:19,19 48:5,18
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50:16,19 52:10,12,18
53:2,9,10,13 54:4,22
56:19,21,22 57:10,13
57:17 59:10,12,17
60:1
knowledge
16:14 32:2 53:11
known
20:7,17
Kress
3:12,13 5:17,17 20:11
21:7,19 22:9 23:10
23:19 24:13,16 25:5
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43:2,11,19 44:3,6,11
45:20 46:4,9,21 47:5
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60:11
L
LAD
2:4 5:20
language
24:6 51:3
laptop
55:4
large
20:1
Larry
1:4 3:4,5 5:4,15 9:20
13:13,17 18:1,7,8
19:3,15,19 20:18
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law
3:5 18:2 29:16,19 34:5
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laws
22:19
lawsuit
13:20 33:1 36:11
lawsuits
16:4,18 17:3 18:8 29:8
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15:3 16:18 43:16
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layman
45:18
Leading
17:10,14 21:18
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21:10
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60:8
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24:11 27:17 28:2 29:1
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34:19,22 35:4,5,8,17
38:20 51:14,17,19,22
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24:8,8 27:13 28:13
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24:12 27:7,17
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19:20
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38:7
LINE
63:5 64:5
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19:22 30:18 32:22
36:11,14,22 37:7
located
7:5
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9:12
locations
6:18
long
53:1 54:1
longer
19:21
Look
39:11
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38:2
loose
51:3
lot
20:2 29:3 51:2
lunch
12:21
M
magistrate
30:21 46:12
making
35:5,15 38:8 39:21
51:2 57:18
manager
8:21
March
34:19 35:13,18 38:20
51:17
Marino
18:15,22 28:16
marked
4:7 17:6 34:18 57:21
marks
60:15
match
10:9 19:13
matter
5:4 58:17
matters
7:22 29:1,4 37:21 38:1
42:6
may
9:8 29:20 41:13,13,13
41:14 42:15
mean
12:17 16:13 22:4 41:3
means
12:10 23:21 49:7
meeting
12:19,20,21 13:11,14
meetings
12:8,9,10,11,15 13:3,4
13:5
member
18:18 21:13 22:2,15
23:2,18 27:15,19
30:7 32:19 33:18
34:1,7,14 40:17,22
48:15
memory
20:16
Merrill
2:4 5:20
met
19:13
military
6:21
mine
10:1
Mineola
6:12
minutes
13:3,5 21:1 49:6
misleading
38:8 47:7,13 48:9
mission
29:22 30:2
mitigate
51:8,12
modus
26:2
Monday
1:13
money
19:6,16
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monitor
5:9
monitoring
28:10
monkeys
26:6,14 30:12
movement
16:19
moving
24:6,6
N
N
3:1 4:1,1 5:1 64:1,1
name
6:5,6 7:12 16:14 18:19
named
15:3
National
9:2
necessarily
22:7 28:7
necessary
60:13
need
19:9,10
needs
59:15
neither
62:8
never
15:7,8,9 19:12 30:14
45:2 48:20,20
New
6:12,13
news
16:14
ninth
33:1 36:11
non-existent
18:2
North
3:15
Northwest
2:6 3:7 5:12
notarial
62:12
Notary
2:11 62:18
notice
2:10 12:14
noticed
13:20
number
7:21
O
O
4:1 5:1 64:1
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49:5,6
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16:6 17:10,14
object
23:10 37:9
objected
37:1
Objection
20:11 21:7,19 22:9
23:19 24:13,16 25:5
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22:17 33:19 40:17,22
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37:20
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51:2
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29:20
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27:1
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25:2 27:9 28:12
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23:5 25:7,13,18,21
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13:12,22 15:18 16:10
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15:17 32:2 55:12
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15:20 20:1
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penalty
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recall
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63:3 64:3
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61:8
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SHORTHAND
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18:7
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17:6 34:17 57:21 58:7
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58:14
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60:19 61:11 63:22
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that's
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15:2 20:17 28:19,22
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35:9 37:10 38:19
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18:1,6,7 19:8,9
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2:7
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19:9
631

Attachment L
631
In The Matter of:

LARRY E. KLAYMAN
v.
___________________________________________________
THOMAS J. FITTON
January 29, 2014
___________________________________________________

631
THOMAS J. FITTON - 1/29/2014

Merrill - Washington D.C.
Page 1
------------------------x
LARRY E. KLAYMAN, )
Defendant. )
------------------------x
VIDEOTAPED DEPOSITION OF THOMAS J. FITTON
Washington, D.C.
Wednesday, January 29, 2014
9:05 a.m.
Job No.: 2-244103
Pages 1 - 147
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Page 2
1 Videotaped Deposition of THOMAS J. FITTON,
2 held at the offices of:
3
4 MERRILL LAD
5 Suite 200
8 (202) 861-3410
9
13
14
15
16
17
18
19
20
21
22
631

Page 3
2
6 Suite 345
9 Telephone: (310) 595-0800
10
14 Suite 100
17 Telephone: (561) 694-0070
18
19
20 ALSO PRESENT:
22 Dina James
631

Page 4
1 C O N T E N T S
2
3 EXAMINATION OF THOMAS J. FITTON PAGE
4 By Mr. Klayman 8
5
6
7 CERTIFIED QUESTIONS PAGE LINE
8 137 10
9
10 QUESTIONS NOT ANSWERED
11 PAGE LINE PAGE LINE PAGE LINE PAGE LINE
12 50 2 50 11 137 12 139 18
13
14 E X H I B I T S
15 (No exhibits were marked.)
16
17
18
19
20
21
22
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Page 5
1 P R O C E E D I N G S
2 (The following proceedings were held
3 off the video record:)
4 MR. KLAYMAN: Just let the record reflect
5 that we had served -- Larry Klayman, plaintiff -- a
6 subpoena on Orly Taitz requiring her appearance for
7 deposition tomorrow in California. Mr. Douglas
8 Kress, counsel for the defendant, Judicial Watch,
9 had asked that we reschedule that deposition to the
10 afternoon; however, that issue is now moot because
11 Ms. Taitz refuses to appear for the deposition at
12 any time.
13 And we filed a motion for Order to Show
14 Cause, and we will be litigating that, and therefore
15 the issue of her appearing in the afternoon tomorrow
16 or whatever is in front of the court. So we're
17 taking off calendar a potential hearing that we were
18 going to have by telephone with the magistrate
19 Simonton for 11:30.
20 MR. KRESS: And I agree with most of that.
21 My -- my objection was to the notice, that 6 days
22 was insufficient no matter what. I mentioned the
631

Page 6
1 possibility of the afternoon but then indicated I
2 couldn't do the afternoon either. So -- but, in any
3 event, my understanding is the deposition's
4 cancelled and I'll ask my assistant to have the
5 magistrate take it off the calendar.
6 MR. KLAYMAN: Right, it's cancelled pending
7 the disposition of the motion for Order to Show
8 Cause, and with regard to the deposition, although
9 you did not get the notice until the 24th, we had
10 discussed her deposition before then.
11 MR. KRESS: We had discussed it, but --
12 yeah, we had discussed it, but -- correct. You're
13 correct. We had discussed it, but I did not get
14 notice until the 24th.
15 MR. KLAYMAN: Right, and I'd advised you we
16 were having difficulty serving her, that she was
17 evading service of process at the time, right?
18 MR. KRESS: That is correct. That is
19 correct. I received a notice on the 24th, and I
20 think I got this -- a copy of the subpoena actually
21 for Ms. Taitz on the 27th. All right.
22 MR. KLAYMAN: Let's move on.
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Page 7
1 (The following proceedings were held
2 on the video record:)
3 THE VIDEOGRAPHER: Here marks the beginning
4 of Volume 1, Tape No. 1 in the deposition of Thomas
5 Fitton in the matter of Larry E. Klayman versus
6 Judicial Watch, Incorporated in the United States
7 District Court for the Southern District of Florida,
8 Case No. 13-20610-CIV.
9 Today's date is January 29th, 2014. The
10 time on the video monitor is 9:07 a.m., and the
11 video operator today is Akim Graham. This video
12 deposition is taking place at 1325 G Street,
13 Northwest in Washington, D.C.
14 Counsel, please voice identify yourselves
15 and state whom you represent.
16 MR. KLAYMAN: Larry Klayman, counsel for
17 Larry Klayman pro se.
18 MR. KRESS: Douglas Kress, counsel for
19 Judicial Watch.
20 THE VIDEOGRAPHER: The court reporter today
21 is Joan Cain of Merrill LAD. Would the reporter
22 please swear in the witness.
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Page 8
1 THOMAS J. FITTON
2 having been duly sworn, was examined and did testify
3 as follows:
4 EXAMINATION BY COUNSEL FOR PLAINTIFF PRO SE
5 BY MR. KLAYMAN:
6 Q Please state your name.
7 A Thomas Fitton, F, as in Frank, i-t-t-o-n.
8 Q When were you born?
9 A May 30th, 1968.
10 Q Where did you attend high school?
11 A Clarkstown South in New York.
12 Q Where?
13 A In New York.
14 Q What city in New York?
15 A It was West Nyack, New York.
16 Q And did there come a point in time when you
17 entered college?
18 A Yes.
19 Q And when was that?
20 A 1986.
21 Q And what college was that?
22 A George Washington University in Washington,
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Page 9
1 D.C.
2 Q When, if at all, did you graduate from
3 George Washington?
4 A 2003.
5 Q What was the reason that it took so long to
6 graduate?
7 A I was short credits and it took me a long
8 time to get the required credits to graduate, obtain
9 my degree.
10 Q When did you first meet me?
11 A 1996 maybe. I don't remember. '96 or '97.
12 Q In what context did you meet me?
13 A I was working as a television analyst for
14 Paul Weyrich's National Empowerment Television, and
15 they were covering hearings into campaign
16 fund-raising abuses by the Clinton Administration,
17 and I was presenting commentary on that coverage,
18 and you were a -- you were also presenting a legal
19 commentary, and so that's where we met, at least
20 that's how I remember it.
21 Q Who was I with -- who was I working for at
22 the time when I was doing the commentary,
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Page 10
1 notwithstanding Paul Weyrich's television company?
2 A Well, I presume Weyrich was paying y'all to
3 do that or paying you directly, so I presume it was
4 Judicial Watch at the time.
5 Q I'm the founder of Judicial Watch, correct?
6 A I don't know.
7 Q Who's the founder then if you don't know?
8 A Well, you've told me you're the founder,
9 but I don't have any reason to believe that you're a
10 credible person anymore, so I don't know.
11 Q Are you the founder?
12 A No.
13 Q You are the president of Judicial Watch
14 currently; are you not?
15 A Yes.
16 Q As the president of Judicial Watch, you
17 have access to all of Judicial Watch's records,
18 correct?
19 A No. I don't know what you mean by access.
20 Q You have the ability to search through
21 Judicial Watch's files to determine who's the
22 founder of Judicial Watch, correct; you're the
631

Page 11
1 president?
2 A I -- I don't know what that -- do I have
3 the ability to search through Judicial Watch's files
4 to determine who the founder is? Yes -- no. No, I
5 don't -- I don't even know what that question means.
6 I don't know what founder means.
7 Q You don't know what the word "founder"
8 means?
9 A No, not in the context you're using it.
10 Q Does it mean a person who conceived of the
11 concept of Judicial Watch?
12 A I do not have the ability to search through
13 records to find out, because I'm not aware any
14 records exist, showing who conceived the founding of
15 Judicial Watch.
16 Q You have the Articles of Incorporation of
17 Judicial Watch; do you not?
18 A Yes.
19 Q And they list me as the incorporator,
20 correct?
21 A Yes.
22 Q Okay. They don't list you, right?
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Page 12
1 A That's correct.
2 Q And they don't list anybody else, do they?
3 A I don't know if they list anyone else on
4 those records.
5 Q I conceived of the name "Judicial Watch,"
6 correct?
7 A I don't know. That's what you say.
8 Q I designed the trademark for Judicial
9 Watch; did I not?
11 Q I conceived of the logo for Judicial Watch?
13 Q The offices which were occupied by Judicial
14 Watch in and around the time that I was working for
15 Weyrich, they were my law offices; were they not?
16 A One more time with that question. Repeat
17 it, please.
18 Q The offices of Judicial Watch, in and
19 around the time that Larry Klayman, yours truly, was
20 working with you at Weyrich doing commentary, you
21 visited those offices; did you not?
22 A Yes.
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Page 13
1 Q Okay. And you came to know that those were
2 my law offices, correct?
3 A They were -- yeah, your law firm's offices,
4 yes.
5 Q At 501 School Street, Southwest?
6 A Right.
7 Q Correct?
8 A Yes.
9 Q As part of your activities, you do read the
10 newspaper from time to time, do you?
11 A Yes.
12 Q Okay. And various newspapers over the
13 years have referred to me as the founder of Judicial
14 Watch, correct?
15 A Yes.
16 Q Have you ever sought to correct anyone that
17 wrote stories that said I was the founder to tell
18 them that I'm not?
19 A No.
20 Q At the time -- let's back up to the time
21 that we were working together on Weyrich's TV doing
22 commentary. Did there come a point in time when you
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Page 14
1 began to do some work for Judicial Watch?
2 A Yes.
4 A It was about the beginning of 1998, I
5 think.
6 Q And what were the circumstances of your
7 beginning work with Judicial Watch?
8 A Judicial Watch hired me as -- to provide
9 consulting services.
10 Q You were working as a contractor?
11 A Yes.
12 Q And, at that time, did you sometimes come
13 over to the offices to work?
14 A Yes. I mostly worked out of those offices.
15 Q Did there come a point in time when I
16 offered you a full-time position --
17 A Yes.
18 Q -- at Judicial Watch? And when was that?
19 A A few months after I began in -- in the
20 beginning of 1998. I don't recall the exact date.
21 Q And what position were you offered?
22 A President of Judicial Watch.
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Page 15
1 Q In fact, you were not offered President of
2 Judicial Watch at that time, were you?
3 A I recall I was, but, you know, if you want
4 to present information that I wasn't, I'm happy to
5 listen.
6 Q You were offered the position, in effect,
7 of research assistant, correct?
8 A No.
9 Q Do you have any documentation to show that
10 I offered you the position of President of Judicial
11 Watch at that time?
12 A I don't think so.
13 Q Mr. Fitton, you're not a lawyer, are you?
14 A No.
15 Q At the time that you came to work for
16 Judicial Watch, you had provided a resume to me,
17 correct?
18 A I don't believe so, no.
19 Q At the time that you came to work for
20 Judicial Watch, you told me that you were a graduate
21 of George Washington University, correct?
22 A No, I did not.
631

Page 16
1 Q Are you saying that I don't have a resume
2 from you that says that you graduated from George
3 Washington?
4 A I don't know what you have.
5 Q In fact, you were not graduate -- a
6 graduate of George Washington at the time you came
7 to work for me at Judicial Watch?
8 A No. I had not obtained a degree at the
9 time that I came to work for you Judicial Watch.
10 Q And in fact you did not tell me you did not
11 have a degree?
12 A Okay. This is material that went -- we
13 went over in the other lawsuit, was the subject of
14 much protracted litigation in the other lawsuit
15 where discovery is over. I'm not going to continue
16 to be harassed by this line of questioning.
17 Q Well, you questioned my credibility, did
18 you not, a few minutes ago?
19 A Yes.
20 Q Okay. Are you saying I'm not entitled to
21 test your credibility?
22 MR. KRESS: Objection to the form.
631

Page 17
1 That's -- I don't know how he can answer that.
2 THE WITNESS: I don't know how to answer a
3 question like that.
4 BY MR. KLAYMAN:
5 Q Calls for yes or no.
6 MR. KRESS: It also could be I don't know,
7 which I think is what he answered.
8 THE WITNESS: That's a legal issue. I
9 don't know.
10 BY MR. KLAYMAN:
11 Q Now, you've recently authored a book called
12 Corruption Chronicles; have you not?
13 A Yes.
14 Q When did that book -- when did you conceive
15 of the concept of writing the book?
16 A Again, Mr. Klayman has threatened
17 litigation over that book. For him to engage in
18 discovery to help him with litigation -- other --
19 another round of meritless litigation is improper.
20 Q Can I --
21 A You know, the reason I'm sitting here is
22 because Mr. Klayman assured the court he would have
631

Page 18
1 a limited area of inquiry, and Mr. Klayman wants to
2 either relitigate other issues or get into issues he
3 wants to potentially litigate anew or litigate from
4 the beginning. So I'm not going to --
5 Q What's --
6 A -- start talking about a book where he's
7 threatening to litigate us over -- in a separate
8 lawsuit.
9 MR. KLAYMAN: Let's just get -- Mr. Kress,
10 who is the lawyer here?
11 MR. KRESS: Well, let's --
12 MR. KLAYMAN: You know, I'm wondering maybe
13 I've got things reversed here, but it sounds like
14 he's -- he's the lawyer.
15 MR. KRESS: Well, that's -- what is the
16 purpose of -- what's the relevance of --
17 MR. KLAYMAN: Credibility. Credibility.
18 MR. KRESS: Credibility, just because he's
19 writing a book?
20 MR. KLAYMAN: Just a few questions. I'm
21 not even going to dwell on it very long, but I want
22 to ask a couple questions about this --
631

Page 19
1 MR. KRESS: Well, I mean, I --
2 MR. KLAYMAN: -- and I'm not defensive
3 about asking those questions.
4 MR. KRESS: Is there a -- is there a threat
5 of litigation over this book?
6 MR. KLAYMAN: I'm not -- I'm not
7 testifying.
8 MR. KRESS: I think it's -- that could be
9 important to -- well, I think he has a legitimate
10 concern, if -- if there's a threat of litigation and
11 does this involve work product or does this -- is
12 this some other privilege. But why don't you -- if
13 you said you had a limited number of questions,
14 let's not fight over something --
15 MR. KLAYMAN: Yeah, let's just clear this
16 up.
17 BY MR. KLAYMAN:
18 Q Have you and I ever communicated over
19 Corruption Chronicles?
20 A I don't recall if your threats of
21 litigation were directed at me or not personally as
22 opposed --
631

Page 20
1 Q In fact, we've never --
2 A I'm trying to answer your question. I
3 don't remember if you sent me e-mails threatening me
4 over the book, so I don't remember.
5 Q In fact, you've never received a threat
6 from me, have you?
7 A Judicial Watch has.
8 Q Do you have that on paper?
9 A I don't know what I have.
10 Q Do you -- what kind of computer do you
11 have?
12 A A standard Microsoft clone.
13 Q Have you changed computers in the last 5
14 years?
15 A 5 years? I don't think so.
16 Q You have a computer at your desk?
17 A Yes.
18 Q Do you have a laptop?
19 A Yes.
20 Q What kind of laptop do you have?
21 A It's a Microsoft laptop.
22 Q When did you get it?
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Page 21
1 A Last year I think.
2 Q Okay. Now, during the time we worked at
3 Judicial Watch together, it was your practice to
4 keep all e-mails and other communications on your
5 hard drive, correct?
6 A That's where they were stored, yes.
7 Q You don't delete from your hard drive, do
8 you?
9 A Yes, I do.
10 Q You've deleted communications with regard
11 to me from your hard drive?
12 A I don't know if I have or not.
13 Q I'm a big source of what you perceive to be
14 trouble for you, correct?
15 A No.
16 Q No? We're good friends?
17 MR. KRESS: If you can answer, answer.
18 THE WITNESS: No, we're not friendly.
19 BY MR. KLAYMAN:
20 Q No. In fact, we're not friendly, correct?
21 A No.
22 Q In fact, you don't like me very much?
631

Page 22
1 MR. KRESS: Objection to form.
2 BY MR. KLAYMAN:
3 Q Correct?
4 A I don't know how to answer that question.
5 I don't like what you do.
6 Q In fact, you hate me, correct?
7 A No, I don't --
8 MR. KRESS: Objection. That's fine.
9 THE WITNESS: I don't hate you.
10 BY MR. KLAYMAN:
11 Q However, I have from time to time over the
12 years been involved in litigation with you, correct?
13 A I don't know what you mean by with.
14 Q Against you?
15 A Against, yes.
16 Q Okay. Now, as an educated person, as
17 someone who's President of Judicial Watch, in the
18 ordinary course you would therefore keep
19 correspondence with me for legal reasons, correct?
20 A Maybe, maybe not.
21 Q So you don't remember what you've deleted
22 with regard to Larry Klayman?
631

Page 23
1 A I don't recall any testimony that I deleted
2 anything with respect to Larry Klayman.
3 Q You said you don't recall, correct?
4 MR. KRESS: He doesn't recall what?
5 MR. KLAYMAN: Deleting communications with
6 me or other documents that concern me.
7 MR. KRESS: Okay.
8 THE WITNESS: Repeat your last question,
9 because your question was hard to follow.
10 MR. KLAYMAN: Can we read it back, thanks.
11 (The reporter read the record as
12 requested.)
13 THE WITNESS: I don't recall what, if any,
14 documents I've deleted with respect to Larry
15 Klayman.
16 BY MR. KLAYMAN:
17 Q Have you used your laptop in a personal --
18 in a business capacity in the last 5 years?
19 A My laptop?
20 Q Yeah.
21 A Yes.
22 Q Have you deleted documents off that laptop?
631

Page 24
1 A I don't know.
2 Q During the time that we worked together at
3 Judicial Watch, we developed a very good reputation
4 for fighting government corruption, correct?
5 A Yes.
6 Q And we were in the newspaper and on TV
7 frequently?
8 A Yes. Judicial Watch was, yes.
9 Q And, in fact, I was on TV and in the
10 newspaper on a weekly basis, sometimes more than
11 once, correct?
12 A I don't know if I can testify about the --
13 how many ti- -- whether it was a weekly basis or
14 not.
15 Q We were attributed with helping to uncover
16 a number of scandals with the Clinton Administration
17 in particular, correct?
18 A Yes. Yes.
19 Q Okay. Some of the scandals that we
20 uncovered included the so-called Chinagate scandal,
21 correct?
22 A I think the lang- -- we've used different
631

Page 25
1 language than that.
2 Q Campaign finance scandal, Chinagate
3 scandal?
4 A We were instrumental in helping unraveling
5 certain scandals.
6 Q And, in fact, I was the lead lawyer on that
7 case, correct?
8 A If by case you mean the Commerce Department
9 Freedom of Information Act litigation --
10 Q Yeah.
11 A -- yes, that is correct.
12 Q Okay. And before that there was the case
13 that Judicial Watch brought against the President's
14 legal defense fund -- Clinton's legal defense fund;
15 remember that?
16 A I'm aware of it, but that was before I
17 began my association with Judicial Watch.
18 Q Okay. During the time that you were with
19 Judicial Watch, we -- I also filed suit with regard
20 to the so-called Filegate scandal, where President
21 Clinton and Mrs. Clinton were alleged to have
22 obtained FBI files on about 900 people, adversaries,
631

Page 26
1 correct?
2 A Yes. I think you had filed that lawsuit
3 prior to my arrival, but that lawsuit was active
4 when I joined Judicial Watch.
5 Q And we brought lawsuits with regard to
6 Loral Corporation and with regard to the head of the
7 travel office and all kinds of other things during
8 that time period, correct?
9 A Yes.
10 Q Okay. And it became known that Larry
11 Klayman was the lawyer who was primarily bringing
12 these lawsuits in the public domain?
13 A Yes.
14 Q Okay. And, in fact, in one lawsuit, the
15 Filegate lawsuit, Judge Royce Lamberth made a ruling
16 with regard to Kathleen Willey, a woman who alleged
17 that the President had harassed her in the Oval
18 Office, that the release of her Privacy Act file
19 constituted a criminal violation of the Privacy Act;
20 you remember that?
21 A I don't know if that was the exact nature
22 of his ruling, but he had made, I guess, a ruling
631

Page 27
1 related to a discovery dispute in the Filegate
2 matter, as you describe it, and in ruling in our
3 favor, he found a violation of the Privacy Act by
4 the President, and I think it's fair to argue the
5 First Lady and some others, yes.
6 I don't recall there being a criminal -- I
7 don't -- I guess one could argue that's -- that you
8 can -- you could -- that it's a criminal violation
9 to violate the Privacy Act, but I don't know if the
10 judge said criminal violation or not.
11 Q Well, the ruling was in the context of
12 breaking through the crime fraud exception, was it
13 not, to get testimony from the Clinton
14 Administration, Carville --
15 A I don't remember -- I don't remember
16 specifically --
17 Q -- James Carville?
18 A -- but that sounds like it might be right.
19 But, you know, I guess the record will refl- -- you
20 know, the court record there will tell us what --
21 what actually happened.
22 Q Okay. During the time that we worked
631

Page 28
1 together at Judicial Watch, we were also involved in
2 the 2000 election to determine who, in fact, had won
3 in Florida; do you remember that?
4 A Yes.
5 Q Okay. And I was the lawyer who appeared on
6 behalf of Judicial Watch at the trial of Bush v.
7 Gore in a public interest capacity in Tallahassee;
8 you remember that?
9 A I don't know if you appeared there, but
10 you -- I guess you were allowed observer, status,
11 and the judge said, you know, you want to hang
12 around, you can hang around so, yes.
13 Q And during the time we were at Judicial
14 Watch together -- working together, I filed a
15 lawsuit on behalf of Jose Basulto of Brothers to the
16 Rescue concerning the shoot-down of his brothers
17 when they were flying over the Florida Straits
18 trying to pick up rafters who were fleeing from
19 Castro, right; do you remember that?
20 A That's right. Those men were murdered,
21 right.
22 Q And we obtained a $1.8 million judgment,
631

Page 29
1 approximately, against Cuba for that?
2 A I don't remember the exact figure, but we
3 did obtain a -- a large judgment against Cuba for
4 Jose, yes.
5 Q And you remember that during the time I was
6 at Judicial Watch we represented the family of Elian
7 Gonzalez for a while?
8 A I don't remember that for sure, but I won't
9 dispute that.
10 Q Towards the end of his stay in the United
11 States, we were attempting to have the judge order
12 him to remain in the United States; do you remember
13 that, towards the end?
14 A I do.
15 Q Okay. And I was the lead lawyer in that?
16 A I presume you were, but I -- I don't
17 remember much about that specific litigation.
18 Q Well, I'm the only lawyer in the firm
19 that's a Florida counsel, correct, at Judicial Watch
20 at the time?
21 A I don't -- I don't know.
22 Q Okay. And you remember that I also took a
631

Page 30
1 trip with the victims of Castro, some of the
2 journalists that were imprisoned by him for many
3 years, to Europe to argue for greater European
4 sanctions?
5 A I am not trying to be difficult, but
6 there's a lot in that question that makes it hard to
7 answer one way or --
8 Q You remember I went to Europe with a bunch
9 of Castro's victims, including Castro's daughter,
10 Alina Fernndez, to lobby the parliaments of France,
11 Italy, Netherlands, and other countries and the
12 European Union to increase the sanctions on Castro?
13 A I remember there was a trip, one or more
14 trips to Europe that had victims that -- I recall an
15 elderly man who had been a political prisoner for
16 over, you know, 25, 30 years, or something insane
17 like that. I don't know if this was the same trip.
18 I recall a trip with Alina -- I forget -- Fernndez,
19 is that her last name?
20 Q Fernndez.
21 A I don't remember the sanctions being an
22 issue. I remember, you know, an indictment maybe in
631

Page 31
1 a -- in an international court, a European court
2 being an issue, but I do remember trips related to
3 justice for victims of Castro's regime in Europe.
4 Q Well, there were -- there were two trips,
5 correct? There was one to lobby the European Union
6 and the parliaments of various member countries, and
7 then there was another trip to file a criminal
8 complaint in Belgium against Castro for crimes
9 against humanity; do you remember that?
10 A You're -- you are you're refreshing my
11 recollection that there were two separate trips in
12 that regard, yes.
13 Q Okay. The one with regard to Brussels
14 actually occurred shortly after September 11, 2001;
15 do you remember that?
16 A I don't. I don't remember the dates.
17 Q Does it refresh your recollection that I
18 went with Chris Farrell at the time and the victims?
19 A Yeah, I remember Chris and -- Chris Farrell
20 and Larry Klayman, you, and as I said, the elderly
21 gentleman who was, I guess, a former journalist. I
22 don't know who else was on that trip --
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Page 32
1 Q And --
2 A But I don't remember the specifics of which
3 trip was for what and the timing.
4 Q And there was a bomb threat that occurred
5 on the plane flight from Washington, D.C. over to
6 Brussels; you remember that?
7 A I remember the plane was delayed because of
8 some- something uncertain about security on the
9 plane.
10 Q There was an article in The Washington Post
11 about it subsequently; do you remember that?
12 A Yes. I do remember The Washington Post did
13 a story, yes.
14 Q During the time that we worked together at
15 Judicial Watch, you also remember that we filed a
16 lawsuit concerning the Energy Task Force of Dick
17 Cheney, Vice President Dick Cheney?
18 A Yes.
19 Q And I was the lead attorney on that?
20 A Yes.
21 Q And that case made its all -- made its way
22 all the way to the U.S. Supreme Court; do you
631

Page 33
1 remember that?
2 A Yes. After you left Judicial Watch, it
3 went to the Supreme Court, yes.
4 Q During the time that I was at Judicial
5 Watch and you were there, I was the general counsel,
6 correct?
7 A You did have the title of Chairman General
8 Counsel, yes.
9 Q Now, your book Corruption Chronicles
10 doesn't even mention my existence, does it?
11 A Existence?
12 Q No mention of Larry Klayman in Corruption
13 Chronicles?
14 A I don't believe there is a mention of your
15 name in that book, no.
16 Q And, in fact, you claim credit for
17 everything that I had done at Judicial Watch in that
18 book, correct?
19 MR. KRESS: Objection to the relevancy and
20 to the form of the question. Is there -- what's
21 the --
22 MR. KLAYMAN: It bears on credibility.
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Page 34
1 MR. KRESS: On credibility?
2 MR. KLAYMAN: Yes.
3 MR. KRESS: I don't think it does, but it
4 is discovery. If you're able to answer the
5 question, please do.
6 MR. KLAYMAN: It's not a very tough
7 question. It's not provocative.
8 MR. KRESS: What was the -- What was the --
9 BY MR. KLAYMAN:
10 Q There was no mention of Larry Klayman in
11 the book, is there?
12 MR. KRESS: Is that the question that's
13 before him?
14 MR. KLAYMAN: Yes.
15 MR. KRESS: Okay.
16 THE WITNESS: I already answered that
17 question.
18 BY MR. KLAYMAN:
19 Q And, in fact, when I left Judicial Watch on
20 September 19, 2003, you ordered that all references
21 to me be removed from Judicial Watch's web site,
22 correct?
631

Page 35
1 A This is old. This is, again, you know, new
2 discovery in a case that's already been closed in
3 terms of discovery.
4 MR. KRESS: If it's -- I can object. I
5 don't understand -- I don't see the relevance of it.
6 Hopefully, we don't go much further because I think
7 this is --
8 MR. KLAYMAN: No, we're not going to go
9 much further, and I'm -- I'm allowed to get into
10 this, and, you know, we're being quite gentlemanly
11 how we're getting into it so it's not provocative.
12 If you'd just answer the question, Mr. Fitton, I'd
13 appreciate it.
14 MR. KRESS: Would you read the last
15 question back.
16 THE WITNESS: I don't need you to read the
17 question back. No.
18 BY MR. KLAYMAN:
19 Q Okay. You didn't order removal of my name
20 from the web site, any reference to me?
21 A No.
22 Q But my name was removed from the web site,
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Page 36
1 was it not, any reference to me, anything I had ever
2 done at Judicial Watch?
3 A No.
4 Q Is there any reference to Larry Klayman on
5 the web site today --
6 A I do not know.
7 Q -- on Judicial Watch's web site?
8 A I do not know.
9 Q In fact, after I left Judicial Watch,
10 sometimes people would call in to Judicial Watch
11 thinking I was still there, correct?
12 A This is all either related to the prior
13 litigation or the threats over the book litigation.
14 This is inappropriate.
15 MR. KRESS: I can object.
16 THE WITNESS: I've answered this in
17 previous depositions.
18 BY MR. KLAYMAN:
19 Q We're in a different case now, Mr. Fitton.
20 You're aware of that, right?
21 MR. KRESS: Let's --
22 THE WITNESS: I want to consult with my
631

Page 37
1 lawyer.
2 MR. KRESS: Let's step out for -- let's go
3 off the record for just a second.
4 MR. KLAYMAN: Yeah.
5 THE VIDEOGRAPHER: Going off the record.
6 The time is 9:36 a.m.
7 (Recess.)
8 THE VIDEOGRAPHER: Back on the record. The
9 time is 9:46 a.m.
10 MR. KRESS: We're back on?
11 Just for the record, as you know, there's a
12 lot of litigation between Judicial Watch and Larry
13 Klayman other than this. I think Mr. Fitton's
14 concern and hesitancy is that, you know, concern
15 that this may be directed at other litigation that's
16 pending or even contemplated. So that's the reason
17 for the hesitation here, and we would ask you to try
18 to direct the questions to the issues at -- you
19 know, that are in this litigation.
20 MR. KLAYMAN: I appreciate that, and
21 Mr. Kress and the Judicial Watch's people you --
22 counsel who is a reasonable person that you can talk
631

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1 to. That's helpful. I'm not here to be
2 provocative. I'm not here to get into collateral
3 stuff, but you've maintained that I'm a public
4 figure and you've maintained I have to show malice
5 or maliciousness, so these issues bear on that, and
6 I don't intend to get far afield on that.
7 MR. KRESS: Okay.
8 MR. KLAYMAN: And I don't intend to get
9 personal or be provocative here. I just want to get
10 answers to the questions.
11 MR. KRESS: Okay. Is there a question
12 pending, or do you want to reask the last question?
13 MR. KLAYMAN: Let's see what the last
14 question was.
16 requested.)
17 MR. KRESS: I object to form.
18 THE WITNESS: Do you want me to restate the
19 question as I recall it, Mr. Klayman?
20 BY MR. KLAYMAN:
21 Q Well, that's the question. She just read
22 it verbatim.
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1 MR. KRESS: I'm going to object to the
2 form, because that alone is confusing to me.
3 BY MR. KLAYMAN:
4 Q This is a separate case from other cases,
5 correct?
6 A I consider it to be all of a piece, but
7 legally it is a separate case.
8 Q Why do you consider it to be all of a
9 piece?
10 A Litigation like the other litigation you
11 have is harassing.
12 Q You didn't write the book Corrupt- --
13 Corruption Chronicles, did you?
14 MR. KRESS: I'll object to the relevancy.
15 BY MR. KLAYMAN:
16 Q It was ghost written, correct?
17 MR. KRESS: How -- I would like a --
18 MR. KLAYMAN: I'm laying a foundation.
19 MR. KRESS: You're laying a foundation, and
20 how would this have any bearing on this case?
21 MR. KLAYMAN: Please let him answer. It's
22 just one question.
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1 MR. KRESS: How does that have any
2 bearing --
3 MR. KLAYMAN: Well, let me give you the
4 next question.
5 MR. KRESS: All right.
6 BY MR. KLAYMAN:
7 Q You instructed the ghost writer, Ben
8 Shapiro, to remove any reference to me from the
9 history of Judicial Watch, correct?
11 THE WITNESS: These questions are at the
12 heart of his threatened litigation. I'm not getting
13 into this issue.
14 BY MR. KLAYMAN:
15 Q You have to answer the question,
16 Mr. Fitton.
17 MR. KRESS: If it is --
18 MR. KLAYMAN: It bears on malice.
19 MR. KRESS: It bears on malice?
21 Rewriting history because you have a malicious
22 intent towards me.
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1 MR. KRESS: Well, could you -- could you
2 ask him if he -- there could be other -- well, I
3 believe there could be other reasons for not
4 including you in the book other than -- other than
5 malice.
6 MR. KLAYMAN: Well, you know, I'm not
7 Lenin, okay.
8 MR. KRESS: You're not what?
9 MR. KLAYMAN: I'm not Lenin, okay? This is
10 not post-Soviet Russia where any reference to
11 Communist leaders for a while was stricken, okay? I
12 am the founder of Judicial Watch. Everybody knows
13 it. No one's ever refuted it. Yet -- and I did a
14 lot at Judicial Watch. It's all over the media, you
15 can find it on Google, yet there's no reference to
16 Larry Klayman. That shows malice.
17 MR. KRESS: It shows malice to omit you
18 from a book?
19 MR. KLAYMAN: To claim credit that you did
20 things that -- that I did.
21 MR. KRESS: Well, if there's a threat of
22 litigation about this -- let's -- let me let me ask
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Page 42
1 you this. Can we move on to another topic and come
2 back to this later?
3 MR. KLAYMAN: Yeah, you think about it.
5 MR. KLAYMAN: Okay? And I don't intend to
6 get far afield here.
7 MR. KRESS: Okay.
8 MR. KLAYMAN: But I'm entitled because
9 you've made that claim that I have to show malice to
10 get into this.
11 MR. KRESS: I think you are a public
12 figure. Are you denying that you're a public
13 figure?
14 MR. KLAYMAN: I'm not going to answer that
15 question.
16 MR. KRESS: Okay.
17 MR. KLAYMAN: I'm not being deposed right
18 now. You can ask me that question later.
20 MR. KLAYMAN: But the point I'm making is
21 that these are limited questions. I do intend to
22 move on.
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1 MR. KRESS: Okay.
2 MR. KLAYMAN: And I'm entitled to the
3 answers to these questions.
4 MR. KRESS: All right. If you could
5 move -- please move on and we'll see.
6 BY MR. KLAYMAN:
7 Q During the time that -- after I left
8 Judicial Watch, you actually had conversations with
9 television networks, such as CNN, and told them not
10 to put me on TV, correct?
11 MR. KRESS: Again, I think we're dealing
12 with other -- we can't use this as a springboard for
13 other litigation. I think that's the -- the concern
14 here.
15 MR. KLAYMAN: That's the point is that, you
16 know, you've made a claim that I have to show
17 maliciousness here despite the fact that the libel
18 that occurred was libel per se. Okay. When you
19 accuse somebody of a crime, that's libel per se of
20 committing a crime. But you've made that claim, so
21 I'm entitled to get into these areas.
22 MR. KRESS: We believe that the law does
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Page 44
1 require you to show malice, but I don't -- if you're
2 threatening other litigation about this, I don't
3 think it's fair to use this deposition as a
4 springboard or a ground for other -- for other
5 litigation.
6 MR. KLAYMAN: I'm here only on this -- on
7 this case.
8 MR. KRESS: Will you stip- -- are you
9 willing to stipulate on the record that none of
10 this -- well, I don't know if you can really do that
11 because you can't unlearn something. I mean, you
12 said you're going to move on and the next question
13 is still on the same topic.
14 MR. KLAYMAN: I'm not dealing with the book
15 anymore. I'm dealing with whether or not he told
16 networks to keep me off the air after I left
17 Judicial Watch.
18 BY MR. KLAYMAN:
19 Q Answer the question, Mr. Fitton.
21 relevancy.
22 THE WITNESS: No.
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1 BY MR. KLAYMAN:
2 Q When did you become a member of Council for
3 National Policy?
4 MR. KRESS: Just a moment, please.
5 BY MR. KLAYMAN:
6 Q You are a member of Council for National
7 Policy, correct?
8 MR. KRESS: What's the -- what's the
9 relevance of this, whether his --
10 MR. KLAYMAN: That's my first question.
11 BY MR. KLAYMAN:
12 Q The second question is, you've disparaged
13 me with members of National Policy, have you not?
14 You've said negative things about me with members of
15 the Council for National Policy?
17 form, to the relevancy.
18 MR. KLAYMAN: I want answers to the
19 questions. I'm entitled. If you want to withdraw
20 your claim that I have to show malice, then we can
21 move on.
22 MR. KRESS: I can't withdraw that, you know
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1 that.
2 MR. KLAYMAN: Okay.
3 MR. KRESS: That he dis- -- your question
4 is did he disparage you to members of --
5 MR. KLAYMAN: You've said negative
6 things -- whether Mr. Fitton said negative things
7 about me to members of Council for National Policy.
8 MR. KRESS: You're not suing Judicial Watch
9 for things that Mr. Fitton said in this lawsuit.
10 MR. KLAYMAN: Yes, but I'm entitled to show
11 that he's -- that he has a malicious intent towards
12 me --
13 MR. KRESS: Well --
14 MR. KLAYMAN: -- and that Judicial Watch
15 does.
16 MR. KRESS: You haven't shown that
17 Mr. Fitton had anything to do with the comment or
18 even knew about the comment that's at issue here.
19 MR. KLAYMAN: That's why I asked the
20 question.
21 MR. KRESS: The comment being the
22 alleged -- the alleged comment from Connie Ruffley.
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1 MR. KLAYMAN: We're getting to that. I'm
2 getting into this right now. Okay? I don't
3 understand why he can't answer the question.
4 MR. KRESS: Because -- I don't know why --
5 I don't understand how it's relevant.
6 MR. KLAYMAN: You're raising the issue,
7 okay, of -- that I have to show maliciousness. So,
8 therefore, I'm allowed to show a pattern of
9 malicious conduct.
10 MR. KRESS: Let's go off the record again
11 for a second, if you don't mind.
14 (Recess.)
16 time is 9:58 a.m.
17 MR. KRESS: To state an objection to the
18 question related to discussions and even membership
19 in Council for National Policy, we believe there is
20 an associational privilege for that organization,
21 and the things that are said there privately are not
22 discoverable and are privileged.
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1 MR. KLAYMAN: Under what basis do you take
2 that position? That allegedly Council for National
3 Policy says that what goes on there is confidential?
4 Just so you know, Mr. Kress, they're not a
5 government organization. They don't have a national
6 security clearance. They don't have any kind of
7 privilege at all one way or the other.
8 So they have no right, even if they sought
9 to assert it, which they wouldn't do, to thwart my
10 questioning in a deposition based on a supposition
11 that what's discussed there is confidential.
12 They're -- they're not an official organ- -- there's
13 no privilege that's recognized in the law for them,
14 and I'm entitled to ask this question, and to not
15 answer the question is to flout court process here.
16 MR. KRESS: I -- I don't believe we're
17 flouting court process. I understand, based on my
18 communications with my clients, that there is an
19 associational privilege and that, therefore, we
20 can't get into that. And I also believe that this
21 question is -- I think we're getting into more --
22 you're being very polite about it, but I think this
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Page 49
1 is -- the intent behind it is -- is to go beyond
2 this case, and it seems to be a harassing scope of
3 discovery. So that's our objection.
4 MR. KLAYMAN: Well, again, for the
5 record -- I'm not going to repeat it because you're
6 an experienced lawyer, and Mr. Orfanedes, who's
7 sitting here is, and Mr. Fitton's been around
8 lawyers for a long time -- is that, you know, I'm
9 entitled to show a pattern of malicious conduct, and
10 that is relevant to this case, and even the way you
11 deal with me in the context of this litigation is
12 relevant to that, not you but them. Okay?
13 So to me I feel like I'm being harassed
14 here because I can't do my job as a lawyer, and it's
15 running up the bill. It's running up time. And
16 these questions clearly are relevant. So you can
17 take your position and instruct him not to answer.
18 We can litigate that in front of a court, but I
19 would hope that that wouldn't be the case because I
20 view that to be harassing towards me.
21 MR. KRESS: All right. What's the question
22 before the witness?
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Page 50
1 BY MR. KLAYMAN:
2 Q The question is, did you tell people -- did
3 you say negative things about me, Larry Klayman, to
4 members of Council for National Policy?
5 MR. KRESS: I'm going to object both to the
6 form, to relevancy, and also on the basis of
7 privilege of that organization, his communications
8 with that organization, and instruct him not to
9 answer.
10 BY MR. KLAYMAN:
11 Q Are you a member of the Council for
12 National Policy?
13 MR. KRESS: Same objection. Instruct him
14 not to answer.
15 BY MR. KLAYMAN:
16 Q When I left Judicial Watch, you instructed
17 Judicial Watch's lawyer, David Barmak, to send me a
18 letter saying I could not make reference to the fact
19 that I was the founder of Judicial Watch, correct?
20 MR. KRESS: I'm going to object. That's --
21 communications with a lawyer, if they did take
22 place, are attorney-client privilege.
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Page 51
1 BY MR. KLAYMAN:
2 Q You are aware that I got a letter that said
3 I couldn't refer that I was the founder of Judicial
4 Watch when I was running for the U.S. Senate,
5 correct, Mr. Fitton?
6 A I don't remember.
7 Q After I left Judicial Watch, you've had
8 communications with my former wife, Stephanie Luck;
9 have you not?
10 A No.
11 Q You've had communications with her lawyers;
12 have you not?
13 A No.
14 Q Judicial Watch has, correct?
15 MR. KRESS: I think you can answer if
16 they're not your lawyers.
17 THE WITNESS: I don't -- I don't -- I'm
18 confused about the instruction here.
19 MR. KRESS: The question is -- is were
20 there communications with the lawyers for Stephanie
21 Luck? I -- I don't know what the --
22 MR. KLAYMAN: Please don't give testimony.
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Page 52
1 MR. KRESS: I don't know what the -- is
2 that the -- is that the question?
3 MR. KLAYMAN: Yes.
4 MR. KRESS. Okay.
5 MR. KLAYMAN: Did he or anyone at Judicial
6 Watch communicate with the lawyers for my former
7 wife Stephanie Luck, whose last name is now DeLuca.
8 MR. KRESS: Is that about any topic?
9 MR. KLAYMAN: About any topic.
10 MR. KRESS: As long as they're not your
11 lawyers, I think you can answer the question, as
12 long as they're not Judicial Watch's lawyers.
13 THE WITNESS: I cannot answer the question
14 based on my attorney's instruction.
15 MR. KLAYMAN: No, he just said -- he said
16 you can answer.
17 MR. KRESS: If they're -- were there --
18 were they your lawyers?
19 THE WITNESS: I'm answering it per his
20 instructions.
21 MR. KRESS: All right. We don't have to go
22 off the record, but just give us a moment. We have
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Page 53
1 to discuss a privilege issue.
4 (Recess.)
6 time is 10:07 a.m.
7 MR. KRESS: I -- I believe we've resolved
8 the issue as to privilege with the last question,
9 and he can answer it.
10 THE WITNESS: Judicial Watch attorneys have
11 communicated with Stephanie's attorneys, yes.
12 BY MR. KLAYMAN:
13 Q And which attorneys were they?
14 MR. KRESS: You can answer if you know.
15 THE WITNESS: Judicial Watch attorneys --
16 Richard Driscoll would have. Internally, Jim
17 Peterson would have.
18 BY MR. KLAYMAN:
19 Q Jim Peterson works for Judicial Watch?
20 A Yes. As an attorney, yes.
21 Q What did Jim Peterson discuss with
22 Stephanie Luck's attorneys?
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Page 54
1 MR. KRESS: It's -- I think that that is a
2 question calling for attorney-client privileged
3 information.
4 MR. KLAYMAN: No, it does not, because I'm
5 talking about a communication with a third party.
6 There's no privilege of anything that was said or
7 done in and between Jim Peterson and Stephanie Luck.
8 Jim Peterson's not the lawyer of Stephanie Luck.
9 MR. KRESS: But if Jim Peterson reports to
10 Mr. Fitton something, then it is an attorney-client
11 privileged communication. If he -- if he reports
12 the substance --
13 MR. KLAYMAN: I didn't ask what was
14 reported. I asked what was communicated between Jim
15 Peterson and Stephanie Luck's attorneys.
16 MR. KRESS: That sounds like the same
17 question.
18 MR. KLAYMAN: No. It's to a third party.
19 That's not privileged.
20 MR. KRESS: Well, if -- if he overheard it,
21 if he was present, I would agree with you.
22 MR. KLAYMAN: An internal discussion had
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Page 55
1 nothing to do with Stephanie Luck's attorneys,
2 assuming that the claim would be valid, which it's
3 not, there'd be some argument there, but not a valid
4 argument, but there's absolutely zero argument in a
5 communication with a third party. That's not an
6 attorney-client communication.
7 MR. KRESS: Okay. If -- if he overheard an
8 attorney -- if he overheard a communication with a
9 third party, I would agree with you, but if his
10 attorney is telling him something confidentially,
11 then that is attorney-client privileged, so --
12 MR. KLAYMAN: I asked the question in a
13 neutral way. We haven't gotten that far yet.
14 MR. KRESS: All right. Let's -- can I hear
15 the question again? Maybe I -- maybe I misheard it.
17 requested.)
18 MR. KRESS: I'll object this way. If you
19 can answer that question without revealing
20 confidential communications with Judicial Watch's
21 attorney, please do so; otherwise, I'd instruct --
22 instruct you not to answer.
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Page 56
1 THE WITNESS: I cannot answer, as my lawyer
2 directed.
3 MR. KRESS: If I could help matters, if you
4 just -- I mean, if -- if you ask why they were
5 communicating with Stephanie Luck's lawyers, that
6 might break through everything.
7 BY MR. KLAYMAN:
8 Q How frequently was Mr. Peterson
9 communicating with Stephanie Luck's lawyers? It's
10 not the substance; it's the communication.
11 A Infrequent.
12 Q More than once?
13 A Yes.
14 Q More than twice?
15 A Yes.
16 Q More than three times?
17 A Yes.
18 Q More than five?
19 A I don't know.
20 Q Judicial Watch keeps telephone records;
21 does it not?
22 A No.
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Page 57
1 Q You destroy them?
2 A I'm not aware of telephone records Judicial
3 Watch keeps.
4 Q What service provider for landlines has
5 Judicial Watch used in the last decade, if you know?
6 A I don't -- I don't recall specifically.
7 Q Was it AT&T?
8 A I said I don't recall specifically.
9 Q Well, what does specifically mean? You
10 recall, but --
11 A I mean, there are lots --
12 Q -- you just told want to tell me?
13 A There are lots of telephone companies.
14 Your question is vague in a way that I can't answer
15 it, as I discussed.
16 Q Who signs the checks to make the payments
17 to the telephone providers?
18 A I sign checks to telephone providers, and
19 Paul Orfanedes can also sign checks to the telephone
20 providers.
21 Q So what -- what telephone companies have
22 you signed checks to pay for their services?
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Page 58
1 A Verizon, Sprint, another company, I think
2 it's -- I'm not sure if they provide telephone
3 services, but it's XO Communications.
4 Q What cell phone company does Mr. Peterson
5 use -- has he used at Judicial Watch?
6 A I do not know.
7 Q What cell phone provider do you use?
8 A Sprint.
9 Q Have you used that for the last 10 years?
10 A The last 10 years? No.
11 Q What was the subject matter of
12 Mr. Peterson's communication with my former wife?
13 MR. KRESS: If you can answer without
14 revealing attorney-client communications, please do;
15 otherwise -- and if you can do it in the broad sense
16 without, you know, revealing communications, please
17 do so.
18 THE WITNESS: Litigation.
19 BY MR. KLAYMAN:
20 Q Whose litigation, hers or yours, meaning
21 Judicial Watch?
22 MR. KRESS: I think you can answer that.
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Page 59
1 THE WITNESS: It would -- I don't know
2 specifically.
3 BY MR. KLAYMAN:
4 Q What do -- what do you mean, don't know
5 specifically?
6 A It could have been either. I don't know.
7 Q Do you remember during the Clinton years
8 they always used to say, I have no specific
9 recollection, and you would object to that and I
10 would object to that? You would then object to me
11 and I would then object? You don't want to do the
12 same thing, do you?
14 THE WITNESS: My general impression is it
15 relates to litigation.
16 BY MR. KLAYMAN:
17 Q You were -- Judicial Watch was interested
18 in my litigation with Stephanie Luck, correct?
19 A Am I supposed to answer?
20 MR. KRESS: I think you can. Again, with
21 all of these, if you have a concern about
22 attorney-client privileged information --
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Page 60
1 THE WITNESS: This to me is all
2 attorney-client, so I do have a concern about it.
3 BY MR. KLAYMAN:
4 Q Wait a sec. This to you is all
5 attorney-client. You're not a lawyer, are you,
6 Mr. Fitton?
7 MR. KRESS: Wait. Wait. Let's not argue
8 with him about it. Let me resolve this.
9 THE WITNESS: I'm communicating with my
10 attorney.
11 MR. KRESS: Again, if -- I believe the
12 question is were you concerned -- was Judicial Watch
13 conc- -- interested in Mr. Klayman's litigation with
14 his ex-wife. If you can answer that without
15 revealing attorney-client privileged information,
16 please do so.
17 THE WITNESS: I cannot, based on your
18 instruction.
20 BY MR. KLAYMAN:
21 Q Did Ms. Luck's attorneys provide documents
22 to Judicial Watch?
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Page 61
1 A I don't know.
2 Q You've never seen any documents that
3 they've provided -- they may have provided to
4 Judicial Watch?
5 A I don't know.
6 Q Have you instructed anyone to obtain any
7 other -- strike that.
8 Have you or anyone at Judicial Watch,
9 including Mr. Peterson, had contact with anyone else
10 that I was married to?
11 MR. KRESS: Again, I mean, I don't know if
12 this is getting in -- I'm going to object to the
13 relevancy, but, again, if we're looking for
14 attorney-client privileged information or if it is
15 attorney-client privileged information, I would
16 instruct you not to answer. If you can answer based
17 on something other than communications with your
18 client -- or with your attorney, please do.
19 THE WITNESS: As per my -- per my
20 attorney's instruction, I cannot answer.
21 BY MR. KLAYMAN:
22 Q You have to give an answer first. You just
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Page 62
1 can't say per instruction, because he didn't make
2 any presumption one way or the other, your attorney.
3 He gave you an instruction to answer the question
4 based on not -- based on whether or not there was an
5 attorney-client communication. You have to answer
6 that question.
7 MR. KRESS: All right. Let's go off the
8 record again for a second.
11 (Recess.)
13 time is 10:21 a.m.
15 requested.)
16 MR. KRESS: And I -- it's -- again, it's --
17 I'm going to object. It's an overly -- it's also a
18 broad question -- and instruct the witness that if
19 he can only answer the question based on
20 attorney-client privileged information,
21 communications with his lawyers, then not to answer,
22 but if he can answer the question based upon
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Page 63
1 something he knows outside of communications with
2 his lawyers, then he can answer the question.
3 BY MR. KLAYMAN:
4 Q Did you have any communications -- did you
5 or anyone at Judicial Watch communicate with someone
6 by the name of Diana Yazbeck?
7 A Not that I'm aware of.
8 Q Or Diana Klayman?
9 A Not that I'm aware of.
10 Q Did you have any communications with
11 someone by the name of Cesira D'aniello?
12 A I don't know who that is, so the answer is
13 no. Not that I'm aware of. I don't know who that
14 person is.
15 Q But you know who the others are?
16 A Who's the others?
17 Q Stephanie Luck and Diana Yazbeck.
18 A I don't know what that is. I don't know
19 what you mean. I don't know what do you know who
20 they are is.
21 Q Diana Yazbeck?
22 MR. KRESS: What's the question now?
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Page 64
1 MR. KLAYMAN: Diana Yazbeck, Y-a-z-b-e-c-k.
2 MR. KRESS: Does he know who she is?
3 MR. KLAYMAN: Yeah.
4 THE WITNESS: I'm aware she is either your
5 wife or your former wife.
6 BY MR. KLAYMAN:
7 Q How did you find that out?
8 MR. KRESS: Again, if it's -- can we have
9 an agreement that you're not seeking information
10 that he obtained from his lawyers?
11 MR. KLAYMAN: No. No. There's no --
12 there's no privilege here.
13 MR. KRESS: Okay. If you can answer it by
14 means other than -- if you -- answer it by means
15 other than communications with your lawyer, you can
16 answer. If you have some other knowledge of who
17 Diana Yazbeck is --
18 MR. KLAYMAN: I'm -- I'll put this on the
19 record. I'll maintain that these communications
20 were done with malicious intent. That's why I'm
21 getting into this. Okay.
22 BY MR. KLAYMAN:
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Page 65
1 Q Go on.
2 A Per my lawyer's instructions, I can't
3 answer.
4 Q Okay. During the time that you and I
5 worked together at Judicial Watch, Judicial Watch
6 hired someone for the San -- for the San Marino
7 office by the name of Constance Ruffley, correct?
8 A We hired Connie Ruffley during -- during
9 your tenure at Judicial Watch, yes. I don't recall
10 if there was a San Marino office at that time when
11 she was hired or we got it after she was hired.
12 Q In fact, I hired her on behalf of Judicial
13 Watch, correct?
15 Q In fact, I had the authority to hire; you
16 did not?
17 A That's not true, as far as I know.
18 Q Okay. Who is Constance Ruffley -- well,
19 strike that.
20 Constance Ruffley, in the last -- let's
21 just say the last 5 years, has been the office
22 administrator for Judicial Watch in San Marino,
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Page 66
1 California, correct?
2 A Yes.
3 Q And, in fact, she manages that office,
4 correct?
5 A She's the administrative assistant in that
6 office.
7 Q And she manages that office?
8 A Manages as in a supervisory capacity? I'm
9 not quite sure what your question is.
10 Q Yeah, orders supplies, fields telephone
11 calls, deals with logistics, correct?
13 THE WITNESS: Yes.
14 BY MR. KLAYMAN:
15 Q In fact, she's the only one in that office
16 that does that, correct?
17 MR. KRESS: Is the question manages or is
18 the question orders supplies and et cetera? I'm
19 confused by the question.
20 MR. KLAYMAN: Can you read back the
21 question. It's a clear question.
22 THE WITNESS: I can answer it if you'd
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Page 67
1 like.
2 BY MR. KLAYMAN:
3 Q Okay, go ahead.
4 A She's the only administrative employee in
5 that office.
6 Q In fact, the only other person that has
7 worked out of that office is Ernie Norris in the
8 last few years, correct?
9 A Yeah -- no.
10 Q Who has worked out of that office in the
11 last 2 years?
12 A Your question is broad, so that's why I'm
13 saying no.
14 Q Who has done work by or on behalf of
15 Judicial Watch, related to that office, in the last
16 2 years that's in California?
17 A Well, Mr. Orfanedes uses that office when
18 he's conducting business at Judicial -- for Judicial
19 Watch in California in addition to Mr. Norris and
20 Ms. Ruffley.
21 Q And Mr. Norris has been retired for the
22 last 2 years, correct?
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Page 68
1 A No.
2 Q He spends most of his time in Wyoming?
3 A I don't know where he spends most of his
4 time.
5 Q Does he get a regular salary from Judicial
6 Watch?
7 A Yes.
8 Q And -- but he is not in the office most of
9 the time, correct?
10 A I don't know.
11 Q Have you travelled to that office in the
12 last 2 years?
13 A No.
14 Q And in the last 2 years, you were the
15 president of Judicial Watch?
16 A Yes.
17 Q How many times has Mr. Orfanedes been in
18 that office in the last 2 years?
19 A I do not know.
20 Q You're not aware when he goes out of the
21 office, Mr. Orfanedes?
22 A I sometimes am aware when he leaves the
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Page 69
1 office.
2 Q You would know if he went to California,
3 though, wouldn't you?
4 A Generally, I'm aware when he's in
5 California, yes.
6 Q So approximately how many times has he been
7 in California the last 2 years, if -- if at all?
8 A I don't have any way of approximating that.
9 It's been -- it's been -- Mr. Orfanedes has been in
10 California several times over the last 2 years.
11 Q On what? Doing what?
12 MR. KRESS: If you know. You have to --
13 THE WITNESS: I don't know if it's privi-
14 -- you know --
15 MR. KRESS: If you can, you know, answer it
16 without discloses privileges, if you can say
17 generally what he was doing.
18 THE WITNESS: Conducting Judicial Watch
19 business.
20 BY MR. KLAYMAN:
21 Q Which business was he conducting?
22 A Litigation.
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1 Q In which litigation? That's a matter of
2 public record.
3 A There was litigation, I believe, related to
4 proceedings in Los Angeles about Special Order 7.
5 There may have been other litigation, but that's the
6 litigation that's been at least front and center
7 over the last 2 years in terms of our work in
8 California.
9 Q Mr. Orfanedes does not play a role in
10 managing that office, does he?
11 A He helps supervise Mrs. Ruffley -- or
12 Ms. Ruffley.
13 Q In what respect?
14 A Well, presumably, when Mr. -- I would -- I
15 would -- in the ordinary course, if he were in the
16 office, he would direct her activities and direct
17 her activities with respect to litigation as it
18 relates to the litigation I discussed earlier.
19 Q But not with regard to the administration
20 of that office, only with regard to litigation,
21 correct?
22 A Not correct.
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1 Q How's that not correct?
2 A There are administrative matters
3 Mr. Orfanedes has been involved in at the California
4 office.
5 Q Okay. What administrative matters?
6 A Oh, I recall computer issues and copying
7 issues, but beyond that I don't have much to offer.
8 Q What specifically with regard to computers
9 and copying?
10 A I don't know. Computers breaking down or
11 getting new copiers or fax machines, just general
12 equipment issues.
13 Q You are aware that there came a point in
14 time when Connie Ruffley went to a meeting that was
15 organized by an individual named Orly Taitz,
16 T-a-i-t-z, which is the subject of this litigation,
17 correct?
19 You can answer.
21 BY MR. KLAYMAN:
22 Q Okay. And Ms. Ruffley went as a
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1 representative of Judicial Watch, correct?
2 A I don't know what she was doing there.
3 Q You have no idea?
4 A No.
5 Q You're the president. You have no idea?
6 A No.
7 Q Are you claiming that she didn't go as a
8 representative of Judicial Watch?
9 A I'm claiming I do not know what she was
10 doing at the meeting.
11 Q Now, I've alleged in this lawsuit that she
12 made defamatory statements at that meeting, correct?
13 You're aware of that?
14 A I'm not quite sure if your lawsuit alleges
15 that directly, but, you know, I'm alleged (sic) that
16 there's an allegation of defamatory statements made
17 by Ms. Ruffley about you.
18 Q Is it your position, as president of
19 Judicial Watch, that Constance Ruffley is
20 responsible for those alleged defamatory statements
21 and not Judicial Watch?
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1 If you can answer, you can answer.
2 THE WITNESS: That's a privilege issue.
3 MR. KRESS: Can I hear the question again,
4 please?
6 requested.)
7 MR. KRESS: I'm going to object. Again, if
8 it's -- we're not dealing with any -- you're not to
9 reveal any discussions with me, but if you have an
10 answer -- if you understand the question and can
11 answer, please do.
12 THE WITNESS: I'm not aware that any
13 defamatory statements were made, so I can't answer
14 as to the responsibility if things didn't happen.
15 MR. KLAYMAN: Doesn't answer the question,
16 Mr. Kress.
17 MR. KRESS: I think it answered the
18 question.
19 MR. KLAYMAN: It didn't answer any
20 question. What was the question again, if you can
21 read it to Mr. Fitton.
22 BY MR. KLAYMAN:
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1 Q Listen to it carefully, Mr. Fitton.
2 THE WITNESS: Oh, you're not reposing it,
3 you're reading it back?
4 BY MR. KLAYMAN:
5 Q She's reading it back so you can hear it.
6 A To clarify, I was waiting for your --
7 Q I want you to hear it. As an intelligent
8 person, I'm sure you'll be able to figure out that
9 you didn't answer the question.
10 MR. KLAYMAN: Please read the question.
12 requested.)
13 MR. KRESS: I'll note the same objection to
14 the form.
15 THE WITNESS: I stand by my original
16 answer.
17 BY MR. KLAYMAN:
18 Q Let's -- let's say this. Let's ask it this
19 way. Whatever was said at that meeting that
20 Constance Ruffley went to with Orly Taitz, her
21 statements were not by and on behalf of Judicial
22 Watch? Anything she said there would not have been
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1 on behalf of Judicial Watch, is that your position?
3 THE WITNESS: I don't know.
4 BY MR. KLAYMAN:
5 Q Turn your attention to Exhibit 2. It was
6 marked yesterday, Plaintiff's Exhibit 2.
7 A I don't have it --
8 MR. KRESS: I'm going to pull it for you.
9 This is it.
10 THE WITNESS: (Indicating)?
11 MR. KRESS: That's it. I doesn't have a
12 sticker.
13 THE WITNESS: Okay.
14 BY MR. KLAYMAN:
15 Q It's a document which is styled Dr. Orly
16 Taitz, Esquire, doctor and esquire, Defend Our
17 Freedoms Foundation, Santa Margarita Parkway, Rancho
18 Santa Margarita, at the top, World's Leading Obama
19 Eligibility Challenge Web Site. You're aware that
20 Orly Taitz has a web site, World's Leading Obama
21 Eligibility Challenge Web Site, correct?
22 A I'm generally aware she has a web site.
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1 Q You're aware that she's been active in
2 issues involving President Obama's eligibility to be
3 President?
4 A Yes.
5 Q Okay. And you were aware of that before
6 February 23rd, 2012, correct?
7 A I don't know.
8 Q In fact, you were approached by someone by
9 the name of George Miller to bring an eligibility
10 lawsuit challenging the eligibility of the
11 President, were you not, you meaning Judicial Watch?
12 MR. KRESS: As a client?
14 MR. KRESS: Hold on. Okay.
15 BY MR. KLAYMAN:
16 Q Regardless whether it's George Miller or
17 anybody else, there have been individuals and/or
18 groups that have asked Judicial Watch to bring
19 eligibility lawsuits, correct, in the last 5 years
20 that Obama's been President?
21 A Yes.
22 Q And who were they?
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1 A I don't know specifically who's asked. I
2 do recall Orly Taitz asking us to get involved at
3 one point.
4 Q You talked to her?
5 A Yes.
7 A It was last year at CPAC.
8 Q And what did she ask you to do
9 specifically?
10 THE WITNESS: I don't know if there's any
11 privilege issue.
12 MR. KRESS: I don't think -- she's not a
13 client at that point?
14 Okay. I think you can answer.
15 THE WITNESS: Was she seeking legal
16 assistance? I don't know.
17 MR. KRESS: Let's try not -- let's wait one
18 second.
19 THE WITNESS: I'm happy to ans- -- I'm just
20 concerned about any --
21 MR. KRESS: If there's a privilege issue.
22 Let me just talk to Paul for one second.
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1 Okay. I think you can answer the question.
2 THE WITNESS: So I'm sorry. I don't
3 remember the specific pending question.
4 BY MR. KLAYMAN:
5 Q What did she want Judicial Watch to do?
6 A Provide assistance in eligibil- -- her
7 lawsuits -- I'm not quite sure. I don't remember
8 specifically what she was asking, but my impression
9 from the -- my impression based on my memory of the
10 discussion was she was complaining about her
11 inability to get legal assistance for her
12 litigation.
13 Q Has anyone else approached Judicial Watch
14 to participate in eligibility lawsuits or challenges
15 to President Obama?
16 A Well, we received inquiries from members of
17 the public asking us to either litigate or
18 investigate that issue. I'm not aware of -- I'm not
19 saying that it didn't happen. I'm not aware
20 specifically of any, like, request to conduct a
21 specific lawsuit or to engage in litigation as -- as
22 I think you're suggesting.
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1 Q Turn to the second page of Exhibit 2,
2 wherein it reads, "My yesterday's presentation to
3 CCIR and update on article2superPAC-Larry Klayman
4 $25,000 fundraising for non-existant law suit
5 affair."
6 A I don't see where you're reading from.
7 MR. KRESS: The heading (indicating).
8 BY MR. KLAYMAN:
9 Q "Article2superPAC $25,000 solicitation for
10 Larry Klayman." Reading down -- I'm going to ask
11 you questions about this.
12 A Should I read it or do you want to --
13 Q Yeah, why don't you read it first, just
14 read the first page.
15 MR. KRESS: To himself?
16 BY MR. KLAYMAN:
17 Q Yeah, he can read it to himself. It'll
18 make it faster.
19 A I'll read it briefly.
20 Okay. I've read the first page.
21 Q Okay. Look at the third paragraph down --
22 excuse me.
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1 A The second you mean?
2 Q The second.
3 A Yes.
4 Q Yesterday I gave a 2-hour presentation my
5 platform as a candidate for the U.S. Senate. The
6 presentation was given to some 100 California voters
7 in the Women's Club of Garden Grove. I was told the
8 representative of Judicial Watch drove from over an
9 hour to San Marino to hear me speak and talk to me.
10 I got a very warm reception. After my presentation
11 people stood up and applauded.
12 This member of Judicial Watch approached me
13 and gave me her card. Her name is Constance Ruffley
14 and she is an office administrator for the Judicial
15 Watch in their Western Regional Headquarters at 2540
16 Huntington Drive, San Marino. She told me that she
17 used to work for the FBI and that she worked for the
18 Judicial Watch for many years. She actually
19 initiated the discussion about Larry Klayman and
20 told me that she had heard that she is involved in
21 birther cases.
22 I told her that his group Article II Super
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1 PAC sent an e-mail advertisement on February 10th,
2 asking for $25,000 claiming that they need to raise
3 $25,000 in 96 hours as the cases in California and
4 Florida need to be filed within a week. I told her
5 that it was a hard sell. They wrote, it is now or
6 never, saying finally Obama team met their match,
7 dissing 4 years of my tireless work in the process
8 and in the end nothing was filed by Larry Klayman.
9 It is not clear what happened to all of the money
10 who raised, who got it.
11 Third paragraph, Ms. Ruffley actually
12 advised me that Mr. Klayman is not licensed in
13 California. She told me that he no longer works for
14 the Judicial Watch and that donors should know about
15 litigation in Ohio where he was convicted just
16 recently of not paying large amount in child
17 support. She provided a lot of other information.
18 I will publish only what is in the -- what is of
19 public record. I'm not publishing anything that is
20 not in public record.
21 A number of individuals sent me this
22 information. Larry Klayman, 60, of Los Angeles,
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1 California, was indicted on two counts of criminal
2 nonsupport. He owes $78,861.76 for his two children
3 ages 11 and 14. Two hearings were held in Domestic
4 Relations Court between 2009 and 2010. The last
5 voluntary payment was made on August 30, 2011 in the
6 amount of $1,014.26. Arraignment is scheduled for
7 February 7, 2012.
8 Let's turn to that third paragraph,
9 "Ms. Ruffley actually advised me that Larry Klayman
10 is not licensed in California." Were you aware that
11 Ms. Ruffley told Ms. Taitz that I'm not licensed in
12 California at the time?
13 A I'm not aware whether or not that happened.
14 Q Have you seen this document before --
15 A I've --
16 Q -- Exhibit 2?
17 A I've reviewed this news article before.
18 Q This thing that I just read to you?
19 A This news article.
20 Q When -- when did you first see it?
22 Q A while ago, right?
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1 A I don't know what that means.
2 Q You saw it in and around the time that I
3 notified Richard Driscoll that I had been allegedly
4 defamed, correct?
5 A When did you do that?
6 Q I show you what's been marked as Exhibit 3.
7 It's a composite exhibit. Does that refresh your
8 recollection? Take an opportunity and look at it.
9 A I don't remember this, but I mean -- I
10 guess it would have been around the first half of
11 2012. That would be my best guess at the time.
12 Q And it -- it would have been around the
13 time that Driscoll wrote this letter of March 5th,
14 2012 to me?
15 A Maybe.
16 Q Now --
17 A I have a generally -- I've been generally
18 aware of the article probably around that time.
19 I think I dropped the microphone. One
20 moment. Excuse me.
21 Q You are aware that I've never been
22 convicted of any crime, correct?
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1 A I'm not aware of any conviction.
2 Q So when Ms. Ruffley said to Orly Taitz that
3 I was convicted recently of not paying a large
4 amount of child support, that's a false statement,
5 correct?
7 THE WITNESS: I'm not aware what
8 Ms. Ruffley told Ms. Taitz.
9 BY MR. KLAYMAN:
10 Q Well, you just testified that in and around
11 March 5th, 2012 you became aware of Exhibit 2 and
12 you reviewed Exhibit 2 and you saw what Taitz had
13 written that Orly -- that Ms. Ruffley had told her,
14 right?
16 MR. KLAYMAN: I'm just laying the
17 foundation.
18 THE WITNESS: I'm sorry, Larry. Can you
19 ask again.
20 BY MR. KLAYMAN:
21 Q You reviewed this document in around March
22 5th, Exhibit 2, you just testified to that.
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1 MR. KRESS: Objection to form. I don't --
2 I don't mean to be difficult, but I don't think he
3 said --
4 MR. KLAYMAN: All right. I'll go on what
5 was testified to.
6 BY MR. KLAYMAN:
7 Q When you saw what Ruffley -- when you saw
8 what Taitz said Ruffley said to her about my being
9 convicted of a crime, did you contact Ruffley and
10 tell her -- and find out what -- what had happened,
11 whether in fact Taitz was telling the truth?
12 A I don't recall any communications with
13 Ms. Ruffley about this issue at that time.
14 Q Ever?
15 A No.
16 Q There have never been communications on
17 this issue between Judicial Watch and Ruffley?
19 THE WITNESS: That's a different question.
20 BY MR. KLAYMAN:
21 Q All right. Answer that question.
22 A I don't know if it's a privileged issue or
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1 not.
2 MR. KRESS: I'm going to object. If --
3 again, if you can answer without revealing
4 communications with your attorneys, please do. If
5 you can -- if the answer would require you to reveal
6 communications with your attorneys, then do not
7 answer.
8 THE WITNESS: I really don't remember about
9 communications between Judicial Watch and
10 Ms. Ruffley about this issue outside of privileged
11 communications.
12 BY MR. KLAYMAN:
13 Q Well, communications about this issue would
14 not be privileged. I'm not asking you the substance
15 of them yet. I'm asking you whether there were --
16 there was contact between Judicial Watch and Ruffley
17 over what Taitz says Ruffley told her about my being
18 convicted of a crime.
19 MR. KRESS: Can we get a time frame?
20 MR. KLAYMAN: Ever.
21 MR. KRESS: Ever? I think that brings into
22 it the attorney-client privilege. If you're talking
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1 about --
2 MR. KLAYMAN: Let's say up to the point of
3 the suit in this case being filed.
4 MR. KRESS: Thank you.
5 THE WITNESS: I'm not aware of
6 communications between Judicial -- I'm not saying
7 they did not take place, but I don't recall any
8 communications between Ruffley and Judicial Watch,
9 that I can testify to, about this issue around that
10 time.
11 BY MR. KLAYMAN:
12 Q Did anyone at Judicial Watch, you or anyone
13 else, ever tell Ruffley to correct this purported
14 statement that I committed a crime?
15 A I'm not aware -- I don't remember if that
16 happened or not.
17 Q As the president, you would have been
18 informed of that, correct?
19 A Maybe.
20 Q This was an issue of potential liability,
21 so it would have concerned you, correct?
22 MR. KRESS: Objection, form.
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1 You can answer.
2 THE WITNESS: I didn't see it as an issue
3 of liability.
4 BY MR. KLAYMAN:
5 Q Was this issue discussed with the Board of
6 Directors, meaning with Mr. Orfanedes and also
7 Mr. Farrell and you?
8 MR. KRESS: Before the lawsuit was filed?
9 MR. KLAYMAN: Before the lawsuit was filed.
10 MR. KRESS: Thank you.
11 THE WITNESS: I have --
12 MR. KRESS: I will object to the extent if
13 there are communications with Mr. Orfanedes as
14 counsel.
15 THE WITNESS: I have no memory of anything
16 about this article beyond the impression that there
17 was a controversy and that Connie said that she did
18 not say what Orly Taitz attributed to her. That's
19 what -- that's my memory of what happened. That's
20 my memory at least prelitigation.
21 BY MR. KLAYMAN:
22 Q So there was communication between you and
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1 Constance Ruffley, meaning you Tom Fitton, Judicial
2 Watch, and Ruffley over this statement that I just
3 read to you?
5 THE WITNESS: No, that was not my
6 testimony.
7 BY MR. KLAYMAN:
8 Q So, therefore, any such communication would
9 have had to occur after the litigation?
11 THE WITNESS: I do not recall how I gained
12 that information about -- or where that memory comes
13 from, whether it was from a privileged communication
14 or -- or anything else.
15 BY MR. KLAYMAN:
16 Q You are aware that Ms. Ruffley has sworn --
17 sworn to an affidavit in this case where she says
18 she doesn't remember whether she made that statement
19 or not?
21 THE WITNESS: I don't remember her saying
22 that, but I don't deny that she said it.
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1 BY MR. KLAYMAN:
2 Q So that affidavit that she signed would be
3 false if in fact she told you she didn't make the
4 statement, correct?
7 BY MR. KLAYMAN:
8 Q You are aware that I had asked your lawyer,
9 Richard Driscoll -- let's turn back to Exhibit 3 --
10 to correct that statement, and let's turn to the
11 second-to-last page of Exhibit 3 wherein I send an
12 e-mail on February 23rd, 2012 at 10:24 a.m. ?
13 A One second.
14 MR. KRESS: He's not there.
15 THE WITNESS: I'm getting there. Hold on.
16 This is Exhibit 3?
17 MR. KRESS: That's it.
18 THE WITNESS: Okay. I'm on --
19 BY MR. KLAYMAN:
20 Q I'm being defamed by -- Rich, I am being
21 defamed by an employee and agent of Judicial Watch,
22 Connie Ruffley. Please call me to discuss. Thank
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1 you, Larry, and I gave him my phone number.
2 You've seen that before, haven't you, this
3 e-mail, before today?
4 A I don't remember seeing any of this, no.
5 Q And there's a string e-mail here,
6 Mr. Driscoll's coming back at 11 a.m. on the same
7 day, I attempted to contact you, but it went
8 unanswered and the message box was full. Will be in
9 witness interview for remainder of the day.
10 Then at 11:03 a.m. I wrote back to
11 Driscoll, let's talk later. In the meantime, thanks
12 for advising Judicial Watch and Ruffley what I
13 informed you about. I will explain more when we
14 talk. It's over the Obama citizenship issue and
15 Ruffley is out making false statements about me and
16 my personal life, et cetera. I have a record of
17 what was said. Best, Larry.
18 In and around that time period, February
19 23rd, you were contacted by Driscoll, correct?
21 Q And then Driscoll writes back at 12:54 p.m.
22 on February 23rd, "I have no information regarding
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1 your assertions and concede nothing, Richard
2 Driscoll."
3 Does that refresh your recollection as to
4 whether you talked to Driscoll about this?
5 MR. KRESS: Again, whether you talked to
6 him is not privileged, and I think that might -- I
7 think he's at this point just looking for whether
8 you talked to him, which is not privileged.
9 THE WITNESS: I've testified previously
10 about the nature of my recollection about this
11 issue, and I don't remember communications with my
12 attorney about this issue or these e-mail
13 communications that you're showing me here or this
14 letter.
15 BY MR. KLAYMAN:
16 Q Let's turn to --
17 A And they're not refreshing my recollection.
18 Q Flip it over two pages going in reverse.
19 Friday, February 24th, 2012, at 10:24 a.m.,
20 "Rich" -- do you see that?
21 A Yes.
22 Q -- "is there a time today when you are free
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1 to speak? Have you communicated with your clients,
2 Judicial Watch, Fitton, et al.? This matter is
3 serious and much damage has been done through Connie
4 Ruffley, Fitton, and others, individually and on
5 behalf of Judicial Watch. And, this is not the only
6 recent instance where I have been defamed and held
7 in a false light in the last few months. I will
8 explain when we talk."
9 And then I don't need to read the next
10 paragraph, but "Let me know. Rather than just
11 filing suit, I am attempting to discuss having your
12 clients mitigate the damage and to try to resolve
13 matters if we can. Sincerely, Larry Klayman."
15 whether you discussed with Mr. Driscoll my request
16 to have Judicial Watch mitigate the damage?
17 A I have a vague recollection of the weird
18 paragraph you wrote, but I don't remember beyond
19 anything what we're talking about.
20 Q You just remember something about French
21 and mademoiselle?
22 A Yeah, it's something weird, so.
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1 Q But you don't remember anything dealing
2 with potential liability for Judicial Watch?
3 A As there is no liability for Judicial
4 Watch, nor do I -- nor do I see any currently, it's
5 not surprising I don't have any memory of it.
6 Q Let's look at Mr. Driscoll's letter.
7 A First page?
8 Q "Dear Mr. Klayman" -- this is March 5th --
9 "this firm represents Judicial Watch, Inc. relating
10 to the above-referenced matter. Through a series of
11 e-mails and again during our conversation" -- I
12 speak French -- "on Tuesday, February 28th, 2012 you
13 advanced vague and unsupported allegations that
14 Judicial Watch , it's President Tom Fitton and an
15 employee are participants in a conspiracy to defame
16 and disparage you based on the recent indictment
17 handled down in Ohio. To date, you have produced no
18 evidence to support these truly outrageous
19 allegations. As I stated to during our
20 conversation, Judicial Watch did not authorize,
21 make, or participate in making any statements
22 regarding your indictment for criminal nonsupport.
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Page 95
1 For this reason, it's not necessary for Judicial
2 Watch to take any action or clarify or correct the
3 statements of others."
5 your discussions with Rich Driscoll over whether or
6 not Judicial Watch had potential liability here for
7 what Constance Ruffley was -- purportedly said to
8 Orly Taitz?
10 You can answer.
11 THE WITNESS: I dont' -- I still don't
12 recall discussions with Mr. Driscoll about this
13 matter at that time.
14 BY MR. KLAYMAN:
15 Q Last paragraph, what Mr. Driscoll wrote,
16 you take to mean that Connie Ruffley's the one that
17 should have been sued in this case and not Judicial
18 Watch, correct?
20 THE WITNESS: No.
21 BY MR. KLAYMAN:
22 Q Let's go to the second page. Richard --
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1 A We're still on the same exhibit?
2 Q Yeah.
3 Your letter of today makes no sense, and
4 amounts only to posturing. Mrs. Ruffley, on her own
5 and on behalf of Fitton, the board of directors at
6 Judicial Watch and other related clients, published
7 to the world that I have been convicted of a crime
8 and could not enter cases in California, among other
9 false and misleading statements and torts. Given
10 your clients lack of good faith in trying to
11 mitigate their damage and their continuing "state of
12 denial," there is little point in showing our cards,
13 so to speak, to you.
14 We don't need to read that.
15 Please report all of this to the insurance
16 carrier. The so-called Ruffley matter is not the
17 only offending matter that involves Fitton and your
18 other related clients in recent past. Please govern
19 yourself accordingly.
21 your conversations, whether you had conversations
22 over the substance of what Connie Ruffley
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1 purportedly communicated to Orly Taitz with Richard
2 Driscoll?
3 A No.
4 Q Do you know whether or not anyone else at
5 Judicial Watch had such conversations?
6 A No.
7 Q You do know the difference between being
8 indicted and being convicted?
9 A Yes.
10 Q What's the difference?
11 A An indictment is a -- a conviction is a
12 finding by a judge or a jury of criminal conduct.
13 An indictment is a -- is an allegation or a filing
14 by a prosecutor or a court alleging criminal
15 conduct. I guess one is an allegation and one is a
16 finding of, I guess, fact. I don't know.
17 Q And you are aware that in the United States
18 people who are indicted are innocent until proven
19 guilty?
20 A I'm aware that's a legal principle.
21 Q So you're saying that if you're indicted by
22 the government, that means you're guilty?
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1 A I recall Alan Dershowitz once saying, and I
2 was intrigued by it, that if we're indicting
3 innocent people all the time, we've got a real
4 problem, so it's fair for most people to conclude
5 that people who are indicted probably are guilty,
6 and if they're -- if we're, as I said, indicting
7 regular innocent people all the time, then we've got
8 a real problem.
9 Q You have great faith in the American
10 government, don't you?
11 MR. KRESS: Objection to form and
12 relevancy.
13 THE WITNESS: I don't know what you mean by
14 American government.
15 BY MR. KLAYMAN:
16 Q Well, you always believe what the
17 government says, correct?
18 A No.
19 Q Okay. In fact, Judicial Watch, its mission
20 is to promote and investigate unethical conduct in
21 government, correct?
22 A Our mission is to -- not to promote, but to
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1 investigate unethical conduct in government.
2 Q And to prosecute?
3 A Prosecute, we use that word as well, yeah.
4 Q And that was in fact a mission statement
5 that I created when I was at Judicial Watch,
6 correct?
7 A I don't recall you creating the mission
8 statement that -- referencing prosecuting government
9 corruption, but that was a mission statement that
10 was used during your tenure at Judicial Watch.
11 Q So the point being is that the government
12 is not always right, correct?
13 A That is correct.
14 Q And the government doesn't always act
15 ethically, correct?
16 A That is correct.
17 Q And, in fact, particularly during the
18 Clinton years, it acted unethically on a number of
19 occasions, correct?
21 THE WITNESS: I don't know what you mean by
22 government, but government officials act
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1 unethically. They have during the Clinton years,
2 yes.
3 BY MR. KLAYMAN:
4 Q And, in fact, during the Clinton years, you
5 may recall that sometimes people that should have
6 been indicted weren't indicted because they were
7 close to the Clintons?
8 A I -- I drew those conclusions.
9 Q Or the Clintons themselves, you had the
10 conclusion that they should have been indicted for
11 crimes, correct?
12 A Yes.
13 Q And you still have that opinion?
14 A Oh, yes.
15 Q Okay. And there were people who were
16 indicted, such as Nolanda Hill, Ron Brown's
17 girlfriend, that were probably indicted for
18 political reasons, correct?
19 A Yes, that's true.
20 Q So the government frequently perverts the
21 concept of who they indict, correct?
22 MR. KRESS: Objection. Objection to form.
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1 You can answer.
2 THE WITNESS: I don't -- I don't know if
3 frequently is the right word to use, but that can
4 happen in my -- in my opinion, that can happen.
5 BY MR. KLAYMAN:
6 Q So, consequently, the fact that I was
7 indicted doesn't mean that I was guilty of any
8 crime, correct?
10 You can answer.
11 THE WITNESS: Based on my understanding,
12 you probably were guilty of the crimes alleged in
13 the indictment or the crime alleged.
14 BY MR. KLAYMAN:
15 Q And how did you gain that understanding?
16 A Just a review of the indictment.
17 Q Who gave you the indictment?
19 Q That contradicts your earlier testimony,
20 doesn't it?
22 THE WITNESS: No.
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1 BY MR. KLAYMAN:
2 Q You got that through communications with
3 Stephanie Luck or her lawyers?
4 A I said I don't know. I don't remember.
5 Q You just slipped, didn't you, Mr. Fitton?
6 MR. KRESS: Objection, form. This is --
7 this is -- this is no -- there's no purpose to this.
8 This is not an appropriate line of questioning.
9 MR. KLAYMAN: I'm testing credibility.
10 MR. KRESS: I think you're arguing with
11 him.
12 MR. KLAYMAN: Two inconsistent statements.
13 MR. KRESS: The record will reflect whether
14 they're inconsistent or not.
15 MR. KLAYMAN: You're right, it will.
16 BY MR. KLAYMAN:
17 Q And you communicated with Stephanie Luck
18 because you wanted to harm me, correct?
20 THE WITNESS: I have not communicated with
21 Stephanie Luck.
22 BY MR. KLAYMAN:
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1 Q What -- what business is it of you whether
2 or not I pay child support for my children?
3 A I think that's a privilege issue.
4 Q It's not a privilege issue.
5 MR. KRESS: Is it -- you're asking him what
6 business is it of him personally?
7 MR. KLAYMAN: In any respect.
8 MR. KRESS: Him personally or Judicial
9 Watch?
10 MR. KLAYMAN: In any respect. Let's take
11 personally first.
12 MR. KRESS: All right. I don't think
13 that's -- I think you can answer that, if you're
14 able to, if you have any personal interest in his
15 child support issues.
16 THE WITNESS: You've personally accused me
17 of misconduct, so I guess there would be a
18 personal -- I didn't really have a personal issue --
19 well, I didn't have a personal issue as it relates
20 to your misconduct in your Ohio litigation.
21 BY MR. KLAYMAN:
22 Q So you wanted to try to dig up dirt on me
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1 because I accused you of misconduct; that's what
2 you're saying, correct?
4 And, again, if this deals with any
5 attorney-client privileged information or work
6 product in other litigation -- all right. I think
7 we -- I need to step out for a second. Actually,
8 could we take a break for just, like, 5 minutes?
11 (Recess.)
12 THE VIDEOGRAPHER: Back on the record.
13 Here marks the beginning of Volume 1, Tape No. 2 in
14 the deposition of Thomas Fitton. The time is 11:12
15 a.m.
16 BY MR. KLAYMAN:
17 Q Mr. Fitton, have you ever been indicted for
18 an alleged crime?
20 THE WITNESS: No.
21 BY MR. KLAYMAN:
22 Q So, therefore, you've never been convicted
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1 of a crime, correct?
2 A No.
3 Q If someone accused you of being indicted
4 and convicted of a crime, you would want to correct
5 that in the public record, wouldn't you?
6 A It depends on the source.
7 Q If someone accused you of being convicted
8 of a crime and that was on an internet site that's
9 widely viewed, that could harm your reputation,
10 correct?
12 THE WITNESS: Maybe.
13 BY MR. KLAYMAN:
14 Q It could harm your activities, your
15 effectiveness in your activities, correct?
17 THE WITNESS: Maybe.
18 BY MR. KLAYMAN:
19 Q That's a serious matter, isn't it, if
20 someone was to accuse you of committing a crime?
21 That would be serious in your mind, wouldn't it?
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1 THE WITNESS: Depends on the source.
2 BY MR. KLAYMAN:
3 Q Suppose it was a lawyer who was involved in
4 eligibility lawsuits?
5 A You know, that's nonsensical, that
6 question. Suppose what was a lawyer?
7 Q Let's back up. Suppose -- Judicial Watch
8 is widely liked in the conservative community,
9 correct?
10 A I mean, that's a question I can't testify
11 to under oath. That's crazy.
12 Q Based on your experience. You're
13 president.
14 A Again, I don't understand the question.
15 Q Judicial Watch --
16 A I can't testify -- you're asking -- you're
17 asking me to testify under oath about the popularity
18 of Judicial Watch in an ill-defined community. I
19 have no idea what you mean or how any normal person
20 could testify to that.
21 Q Judicial Watch has lots of supporters among
22 conservatives, correct?
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1 A Again, this is a waste of time.
2 MR. KRESS: If you're able to answer the
3 question, answer it. If it's --
4 THE WITNESS: I can't answer the question.
5 MR. KRESS: Okay.
6 BY MR. KLAYMAN:
7 Q Judicial Watch has a conservative
8 orientation; does it not?
9 A Yes.
10 Q If Judicial Watch was to make a statement
11 that was published to the conservative community
12 that I committed a crime, based on your experience,
13 that could do a lot of damage, couldn't it?
15 THE WITNESS: I have no idea.
16 BY MR. KLAYMAN:
17 Q It would do some damage, correct?
18 A I have no idea.
19 Q So it would be the same as saying Larry
20 Klayman just won an NSA lawsuit, it's no different
21 in saying that as saying Larry Klayman is also
22 convicted of a crime?
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2 BY MR. KLAYMAN:
3 Q Based on your experience?
4 A I don't -- I don't understand your
5 question.
6 Q What I'm saying is, is that you wouldn't
7 want someone to publish -- strike that.
8 You wouldn't want Judicial Watch to make a
9 statement that you committed a crime, as president
10 of Judicial Watch, and put that on a web site, would
11 you?
12 A This is just -- this is nonsensical. I
13 don't even -- I don't understand the question. This
14 line of questioning is not -- not possible for me to
15 follow in any way that would allow me to testify to
16 a court.
17 Q Bottom line is, because the statement that
18 was purportedly made by Connie Ruffley to Orly Taitz
19 that then was published on a web site was made about
20 me, you, Thomas Fitton, really didn't care?
21 A I don't understand your question.
22 Q You -- you didn't feel any obligation to
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1 correct it?
2 A I don't understand your question.
3 Q You didn't feel any obligation because you
4 wanted to damage me?
6 THE WITNESS: Again, your question's
7 incomprehensible.
8 BY MR. KLAYMAN:
9 Q And, in fact, you instructed Ruffley to
10 make that statement, didn't you?
12 THE WITNESS: No.
13 BY MR. KLAYMAN:
14 Q But you've never disclaimed responsibility
15 for it, have you?
16 A Whoa. Whoa. I did not instruct Connie
17 Ruffley to make any statement to Orly Taitz as
18 alleged in Exhibit 2 or written about in Exhibit 2.
19 Q Once you learned of that statement, you
20 didn't tell her to correct it, though, did you?
21 A I said I have no memory of the event at the
22 time, other than what I testified to.
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1 Q You just testified that you've seen the
2 indictment from the Cuyahoga County criminal court
3 with regard to me. You did review the public record
4 with regard to what was going on in Cleveland with
5 regard to child support and indictments and such,
6 correct?
7 A I don't understand how I can answer this
8 question without privilege issues popping up.
9 MR. KRESS: He's asking if you read it
10 individually.
11 THE WITNESS: I still don't understand how
12 I can answer this question without privilege issues.
13 MR. KRESS: Did you review it -- I think
14 the act of reading it --
15 MR. KLAYMAN: Please don't give him
16 testimony. Don't give him testimony.
17 MR. KRESS: I'm trying to --
18 THE WITNESS: Okay. My answer is I cannot
19 answer this question without -- my understanding,
20 based on my lawyer's repeated instructions
21 implicating privileges that I don't want to
22 implicate.
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1 BY MR. KLAYMAN:
2 Q Well, I'm not asking you with regard to
3 lawyers. I'm saying did -- you did review the
4 public record of that criminal proceeding, correct,
5 before today?
6 A I don't know what you mean by public
7 record.
8 Q Docket sheet, pleadings.
9 A Yes.
10 Q And when did you review it?
11 A I reviewed it recently because, if I recall
12 correctly, it was part of the Motion for Summary
13 Judgment in our case, and I don't recall when or if
14 I had reviewed it prior to that review.
15 Q What leads you to believe that I should
16 have been convicted --
17 A Based on my --
18 Q -- for nonpayment of child support?
19 A Well, it seemed to me you effectively pled
20 out by paying the alleged moneys and the indictment
21 being removed, so that to me was not technically a
22 plea agreement but certainly looked like an
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1 admission of guilt.
2 Q Where did you learn that?
3 MR. KRESS: Again, objection if the source
4 is your attorney. If there's some other source, you
5 can answer.
6 THE WITNESS: I related -- reviewed it
7 related to the summary judgment proceeding or the
8 summary judgment papers that were filed in this
9 litigation.
10 BY MR. KLAYMAN:
11 Q Well, according to what Ms. Taitz wrote,
12 what was being published about me coming through
13 Ms. Ruffley was based on the public record, correct,
14 what I just read you?
15 A I don't understand. You have to answer
16 (sic) that question again because it's -- I don't
17 have any memory of this article other than that it
18 was an article that was published.
19 Q Yeah, let me read you the part here in
20 Exhibit 2.
21 Ms. Ruffley actually advised me Larry
22 Klayman is not licensed in California and she told
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1 me that he no longer works with the Judicial Watch
2 and that donors should know about litigation in
3 Ohio, where he was convicted just recently of not
4 paying large amount in child support. She provided
5 a lot of other information. I will publish only
6 what is a public record. I'm not publishing
7 anything that is not in public record.
8 So, according to what Ms. Taitz, Ruffley
9 told her that she came to this conclusion from
10 reviewing the public record, correct?
12 You can answer if you -- if you're able.
13 THE WITNESS: I don't understand your
14 question.
15 BY MR. KLAYMAN:
16 Q Well, the public record has never shown a
17 conviction for Larry Klayman for nonpayment of child
18 support, correct?
19 A I don't know. I mean, if you essentially
20 pay the -- the moneys that were result of the
21 indictment and the indictment being removed, that to
22 me is effectively an admission of guilt, so
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1 conviction or admission of guilt, I think it's true
2 enough.
3 Q Okay. So -- so you're endorsing what
4 Ruffley told Taitz, that I was convicted?
5 A I don't know what --
7 THE WITNESS: I do not know what Ruffley
8 told Taitz other than my general impression that she
9 did not say that you were indicted -- or you were
10 convicted.
11 BY MR. KLAYMAN:
12 Q How did you get that if you never talked to
13 her?
15 THE WITNESS: I testified previously about
16 my impressions.
17 BY MR. KLAYMAN:
18 Q So you're just kind of divining that
19 Ruffley didn't say these things?
21 BY MR. KLAYMAN:
22 Q You're making this up?
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2 THE WITNESS: I've had previous testimony
3 on this. I'm not going over it again.
4 BY MR. KLAYMAN:
5 Q Are you aware that I was divorced from
6 Ms. Luck in Virginia?
7 MR. KRESS: If you're aware through sources
8 other than your lawyers, you can answer.
9 BY MR. KLAYMAN:
10 Q In Fairfax, Virginia?
11 A What is -- what is going on here with this
12 questioning? What is this about?
13 MR. KRESS: I don't -- I don't know if it
14 has any relevancy, but if you know of the loca- --
15 it could lead to -- well --
16 THE WITNESS: This is just -- this is -- I
17 mean, you have time to kill before lunch and is this
18 why we're just asking questions? I don't know the
19 testimony is relevant to this litigation that's
20 outstanding that we ought to be getting to, but
21 evidently we're not because of questions like this.
22 MR. KRESS: With this one, just answer it
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1 if you know the location was Fairfax, Virginia.
2 THE WITNESS: Okay, my concern isn't about
3 my ability to answer questions. My concern is about
4 the questions being harassing and for an improper
5 purpose and just wasting my time and the court's
6 time and further showing the nonmeritorious nature
7 of this litigation. So the question's for an
8 improper purpose that I can answer I still don't
9 want to have to deal with.
10 MR. KRESS: I'll note an objection for the
11 record, but I think this is one -- I think this is
12 one we can answer.
13 THE WITNESS: I'm aware that you were
14 divorced in Virginia.
15 BY MR. KLAYMAN:
16 Q You're aware that, given the fact you've
17 apparently reviewed public record documents, that
18 there's a case called Hartman v. Hartman coming out
19 of family court in Fairfax that says when you're
20 denied your children, that you have a defense to
21 paying child support?
22 MR. KRESS: Objection to form, if you know.
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1 THE WITNESS: I'm not aware of that.
2 BY MR. KLAYMAN:
3 Q So you didn't bother to read that part of
4 the public record?
5 A Didn't bother, I object to that. I don't
6 know what that means.
7 Q Didn't take time to.
9 You can answer.
10 THE WITNESS: I -- I don't have an answer.
11 It's a crazy question.
12 BY MR. KLAYMAN:
13 Q So you didn't bother to find out whether I
14 had a defense to this indictment; you just think I'm
15 guilty?
17 THE WITNESS: Again, you know, this is just
18 an argument. I'm not -- I'm not engaging in an
19 argument in a deposition.
20 THE VIDEOGRAPHER: Excuse me, Mr. Fitton.
21 Could you move your microphone up?
22 THE WITNESS: I'm sorry. It slid down.
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1 This is an argument. I'm not engaging in an
2 argument in a deposition. These are not questions.
3 BY MR. KLAYMAN:
4 Q Is it your position, Mr. Fitton, that you
5 make the Rules of Civil Procedure, that you decide
6 what they are, the rules of evidence?
7 MR. KRESS: Please, let's try to get back
8 on track here. That's -- that's not a viable
9 question.
10 MR. KLAYMAN: Well, that's what he's
11 saying. He's saying I'll do what I want. I'm
12 trying to figure out what his state of mind is here
13 because, you know, it bears on -- on whether these
14 questions should be answered or not. Does he have a
15 legal reason why he's not answering them? He just
16 doesn't like the Rules of Civil Procedure or the
17 rules of evidence?
18 MR. KRESS: I think he's concerned about it
19 being harassing, and --
20 MR. KLAYMAN: This is the heart -- this is
21 the heart of the issue of this case.
22 MR. KRESS: The heart of the issue is
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1 whether he read the case of Hartman v. Hartman?
2 MR. KLAYMAN: No, the issue is whether or
3 not, as you've put it, Judicial Watch, in pleadings
4 whether or not what Ruffley said was substantially
5 true or not, okay, so I'm probing on that --
6 MR. KRESS: Okay.
7 MR. KLAYMAN: -- and these questions are
8 legitimate.
9 MR. KRESS: You're ask- -- what was -- if
10 you could restate the most recent substantive
11 question.
12 MR. KLAYMAN: Can you please read it back.
13 MR. KRESS: Probably the one before whether
14 he understood the civil rules.
16 follows.)
17 "Question: So you didn't bother to find
18 out whether I had a defense to this
19 indictment; you just think I'm guilty?"
21 form.
22 THE WITNESS: The answer's no.
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1 MR. KRESS: Okay.
2 BY MR. KLAYMAN:
3 Q So your position is that if Larry Klayman
4 is alleged to have done it, he must be guilty?
6 THE WITNESS: I don't understand what it
7 is. What do you reference by it?
8 BY MR. KLAYMAN:
9 Q I didn't use the word "it."
10 MR. KRESS: I think you did.
11 BY MR. KLAYMAN:
12 Q My question was, your position is that if
13 Larry Klayman was accused of a crime, he must be
14 guilty? There's no it in that sentence.
15 A That's not my position.
16 Q So, therefore, once you learned that
17 Ms. Ruffley had allegedly made this statement, you
18 should have done a due diligence and found out
19 whether or not she did, and if she did make that
20 statement, you should have had it corrected,
21 correct?
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1 THE WITNESS: As I said, I don't remember
2 what I did. Seems to me that our lawyer speaks for
3 Judicial Watch here and evidences the due diligence
4 that Judicial Watch performed related to your
5 ridiculous assertions here.
6 BY MR. KLAYMAN:
7 Q Have you made any claim to Rich Driscoll's
8 insurance carrier as to whether or not he's
9 committed malpractice by saying that they don't
10 have any -- that Judicial Watch doesn't have any
11 interest in correcting what I said occurred?
13 You can answer.
14 THE WITNESS: I don't understand how to
15 answer that question.
16 BY MR. KLAYMAN:
17 Q Let me make it -- let me make it more
18 simple. I'm break it down. I asked Rich Driscoll
19 to -- to have Judicial Watch correct this statement
20 about me being convicted. You're aware of that?
21 A No.
22 Q The letter I read to you, which was Exhibit
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1 3, and documents related to that, don't relate to my
2 asking to have that alleged false statement
3 corrected?
4 A I don't have any awareness outside of this
5 litigation or this document that you've shown me.
6 Q All right. Let me ask you a simple
7 question.
8 A This is the first time I recall seeing this
9 document.
10 Q Have you -- have you put Rich Driscoll on
11 notice or his carrier that by sending this letter
12 he's been negligent?
13 MR. KRESS: Objection to the form. I think
14 you can answer.
15 THE WITNESS: I don't see how I can answer
16 a question like that.
17 BY MR. KLAYMAN:
18 Q It's whether you put him on notice of
19 potential liability for negligence in not having
20 corrected what I said was said by Ruffley.
21 A I'm not aware of any liability then. I'm
22 not -- wasn't aware of any liability then. I'm not
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1 aware of any liability now, despite this wasteful
2 litigation.
3 Q If Constance Ruffley had made this
4 statement, and let's assume that she made the
5 statement that I was convicted of a crime, as
6 president of Judicial Watch, would you have asked
7 her to have it corrected with Ms. Taitz?
10 BY MR. KLAYMAN:
11 Q It calls for yes or no.
12 A It doesn't call for anything other than my
13 response, which is I don't know.
14 Q Look at the rest of the statement here that
15 Taitz says Ruffley made to her.
16 A This is Exhibit 2 again?
17 Q Yeah. "Ms. Ruffley actually advised me
18 that Larry Klayman is not licensed in California,
19 she told me that he no longer works with the
20 Judicial Watch and that donors should know about
21 litigation in Ohio."
22 Donors should know about litigation in
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1 Ohio? Why should donors know about litigation in
2 Ohio?
4 THE WITNESS: I don't know. I didn't make
5 this statement. I don't know if Connie made this
6 statement, so I don't know what it references.
7 BY MR. KLAYMAN:
8 Q Now, if this was Judicial Watch and someone
9 accused you of a crime that you didn't -- you
10 weren't convicted of, would you want donors to know
11 about it?
12 A I don't know what that means. As I said
13 earlier, it depends on the source.
14 Q Whatever source, would you want donors to
15 hear that you were convicted of a crime, as
16 president of Judicial Watch?
18 THE WITNESS: I don't know how to answer
19 the question other than how I've previously answered
20 it.
21 BY MR. KLAYMAN:
22 Q I show you what has been marked as Exhibit
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1 4, Plaintiff's Exhibit 4.
2 MR. KRESS: Let's keep these in order.
3 BY MR. KLAYMAN:
4 Q Have you ever seen Plaintiff's Exhibit 4?
5 A I think I may have.
6 Q When did you see it?
7 A It may have been around the time of the --
8 I don't know. I don't know when I saw it. I -- I
9 have it. I can't speculate as to when I saw it.
10 Q After the litigation was filed in this
11 case?
12 A I recall seeing it in the time frame around
13 the time I saw this other article, Exhibit 2,
14 perhaps.
15 Q How many times have you talked to
16 Mrs. Taitz?
17 A Other than that one conversation, none.
18 Q Yes. How many times have you exchanged
19 e-mails with Mrs. Taitz?
20 A Never. I'm not aware of any e-mails being
21 exchanged.
22 Q Are you aware of anyone by or on behalf of
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1 Judicial Watch exchanging e-mails with Mrs. Taitz?
2 A I recall that I found an e-mail as it
3 relates to Mrs. Taitz, but I don't remember if that
4 was a communication with her.
5 Q Anything else?
6 A No. Oh, there may have been litigation --
7 Mrs. Taitz I think tried to intervene in Judicial
8 Watch NVRA litigation in Indiana, I think it was --
9 well, in Indiana or Ohio, and we opposed -- I know
10 we opposed her Motion for Intervention. So there
11 may have been communications between Judicial Watch
12 attorneys and Ms. Taitz on that -- on that
13 litigation issue with her intervention in our
14 litigation or her effort -- in an effort to
15 intervene.
16 Q Did you communicate with her in that
17 regard?
18 A No.
19 Q Who did?
20 A I don't know who did.
21 Q Show you what's been marked as Plaintiff's
22 Exhibit 5. Have you ever seen that, this document,
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1 "An Open Letter to Orly Taitz, re: Defamatory
2 Statements," on a web site called The Birther
3 Report?
4 A No, I don't remember this.
5 Q I'll show you what's been marked as
6 Plaintiff's Exhibit 6. It's "When A Paper Terrorist
7 Meets A Paper Terrorist" is the title of it. Have
8 you ever seen that document?
9 A I don't remember seeing this.
10 Q I show you what's been marked as
11 Plaintiff's Exhibit 7, title of it is "An Open
12 Letter to Orly Taitz, re: Defamatory Statements."
13 Have you ever seen this document on Free Republic?
14 A You know, I recall vaguely, like, this kind
15 of article or argument or having seen something like
16 this, but I don't remember specific articles like
17 this.
18 Q Well, look at the comments of this article,
19 okay? As a general rule, people are reacting to
20 what Connie Ruffley said to Orly Taitz, correct, and
21 they're making negative remarks about me?
22 A Which article are you referencing, this
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1 Exhibit 7?
2 Q Exhibit 7.
3 MR. KRESS: What page are you referring to
4 so I --
5 MR. KLAYMAN: All of them.
7 BY MR. KLAYMAN:
8 Q It's dispersed throughout.
9 MR. KRESS: I'm going to object that it
10 probably speaks for itself.
11 MR. KLAYMAN: It does.
12 THE WITNESS: I don't see Connie's
13 statement here.
14 BY MR. KLAYMAN:
15 Q Well, my question is, were you concerned
16 that what Connie said could do damage to Larry
17 Klayman?
18 A No. I don't have any rec- -- I don't have
19 any information about what Connie said other than my
20 general impression, which I've testified to earlier.
21 Q Look at Plaintiff's Exhibit 8. Have you
22 ever seen this document?
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1 A No.
2 Q Again, Free Republic comments about me,
3 Larry Klayman.
4 A No.
5 Q Turn to Exhibit 9 to a page --
6 A Is this the same as the other exhibit?
7 MR. KRESS: It's not.
8 BY MR. KLAYMAN:
9 Q Turn to a page that --
10 A How many pages in?
11 Q -- starts with Bates No. 508 -- strike
12 that -- 505. Do you see the e-mail that was sent
13 from PJO -- that's Paul Orfanedes -- to Connie
14 Ruffley, dated August 28, 2012 at 4:03 p.m., copies
15 to you, Christopher Farrell, Steve Anderson, Susan
16 Prytherch. Subject, "Orly Taitz posting a Judicial
17 Watch invite to speak on her Website. "Connie,
18 we've had a couple of inquiries about this posting.
19 Can you make clear to Ms. Taitz or whomever is
20 responsible for the posting that she was invited by
21 UROC and not 'the Judicial Watch.' The posting also
22 needs to be corrected to avoid any further
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1 confusion. Thanks."
2 Do you see that?
3 A Yes, I see that.
4 Q And then underneath it's Steve Anderson --
5 who is Steve Anderson?
6 A An employee of Judicial Watch.
7 Q And what are his job responsibilities in
8 and around that time period?
9 A Director of development.
10 Q Fund-raising, is that what that means?
11 A Yes.
12 Q It says, "I'm extremely" -- this is
13 apparently an e-mail or a posting by Orly Taitz. "I
14 am extremely proud, I just got a call from the
15 'Judicial Watch' and was asked to be a speaker at
16 their event 'Republicans United' on October 13th in
17 California."
18 What is this about? Explain to me the
19 context of this, these e-mail exchanges?
20 A I don't know what the -- I mean, other than
21 what it says, I don't know what the context is.
22 Q Bottom line here, Judicial Watch was
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1 concerned that Orly Taitz said she was being invited
2 to a political event put on by Judicial Watch,
3 correct?
4 A I don't -- it says what it says. I don't
5 think your question represents the --
6 Q You were copied on it. You discussed this
7 at the time with Connie Ruffley?
8 A I don't have any memory of discussing this
9 with Connie Ruffley.
10 Q Who did you discuss it with?
11 A I don't have any memory of discussing this.
12 Q Do you have any memory of it, period?
13 A I don't know if I do or not. I don't think
14 I do.
15 Q In fact, based on the e-mail between Paul
16 Orfanedes and Connie Ruffley, Judicial Watch was
17 concerned that Ruffley had -- or that Orly Taitz was
18 claiming that Judicial Watch had invited her to a
19 UROC event, correct, and that's being represented on
20 the internet?
22 THE WITNESS: I think the e-mail -- I
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1 can't -- as I don't have any independent
2 recollection of this e-mail or this issue, I cannot
3 address and testify to what Judicial Watch's
4 concerns are beyond the text of the e-mail.
5 BY MR. KLAYMAN:
6 Q In fact, Judicial Watch was concerned about
7 an internet posting on Taitz's web site that could
8 have implicated it in political activity, correct?
9 A I've testified previously as to what my --
10 what I'm able to testify to, so I don't know why
11 you're asking another question based on --
12 Q Well, the point is that when Judicial Watch
13 was involved, you were concerned with what Taitz was
14 posting on her web site, correct, you meaning
15 Judicial Watch?
16 A Referring back to the first answer I gave
17 you on this line of questioning, I don't have any
18 independent recollection of any concerns or this
19 issue, so I can't testify as to what Judicial
20 Watch's alleged concerns were. The text of the
21 e-mail speaks for itself.
22 Q But when Connie Ruffley allegedly makes a
631

Page 133
1 statement that Larry Klayman committed a crime, you
2 really have no interest?
4 THE WITNESS: I guess my testimony is what
5 it is on that area, so I don't know what else to say
6 about it. We're wasting everyone's time here.
7 BY MR. KLAYMAN:
8 Q And felt no obligation to correct that
9 statement?
11 THE WITNESS: Again --
12 BY MR. KLAYMAN:
13 Q Let's come back to The Corruption
14 Chronicles. We said we'd come back to that. Ben
15 Shapiro ghost writ- -- ghost wrote that book at your
16 direction, correct?
17 MR. KRESS: I'm objecting.
18 THE WITNESS: I'm not answering these
19 questions.
20 BY MR. KLAYMAN:
21 Q Do you know who Ben Shapiro is?
22 THE WITNESS: I'm not answering these
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1 questions. He's threatened litigation on this issue
2 and he's conducting discovery for an improper
3 purpose on litigation he's been threatening with us
4 on it. This is ridiculous and it's wasting
5 everyone's time.
6 MR. KRESS: What's the -- if you could
7 proffer the purpose for this line of questioning.
8 MR. KLAYMAN: The proper purpose -- I mean
9 the purpose is that I was written out of the history
10 of Judicial Watch because that was another method to
11 harm me.
12 MR. KRESS: I think --
13 THE WITNESS: That's a separate lawsuit
14 you're threatening. I'm not testifying about it.
15 MR. KRESS: Well, there's a book. We know
16 the book says whether or not you're there or not.
17 I -- I -- there's been multiple lawsuits and there's
18 still pending threatened lawsuits. I think we're
19 just getting, you know, beyond the scope of --
20 beyond the proper scope of the deposition here.
21 MR. KLAYMAN: Well, I've already stated why
22 it's a relevant question, because it bears on
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Page 135
1 malice. It bears on the animus towards me.
2 MR. KRESS: What -- what are you ultimately
3 looking for? Are you looking for --
4 MR. KLAYMAN: Well, why would any- -- why
5 would -- I don't need to testify here, okay. You
6 can ask me later what this is about if you want, but
7 the point is, is that to purposefully publish a book
8 which seeks to rewrite history, that claims credit
9 for things that I have done, bears on a state of
10 mind, a state of mind of malicious intent towards
11 me, and that's what I'm getting at.
12 MR. KRESS: Why don't you ask him did he
13 have malicious intent in not including you in the
14 book?
15 MR. KLAYMAN: I'll ask him what I want to
16 ask him.
17 MR. KRESS: I'm trying to --
18 MR. KLAYMAN: He won't have a memory for
19 that one. Okay. Let's move on.
20 BY MR. KLAYMAN:
21 Q You're refusing to answer the question. Do
22 you remember Peter Paul?
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1 A I'm not sitting for -- this is -- this is
2 insanity.
3 Q Do you know who Peter Paul is?
4 MR. KRESS: Let's -- let's try to -- are
5 you almost --
6 MR. KLAYMAN: Yeah, I am almost wrapping
7 up.
8 MR. KRESS: Let's try to wrap it up.
9 MR. KLAYMAN: I am trying to wrap it up.
10 THE WITNESS: Now he -- now he's trying to
11 get into questions relating to a pending bar
12 proceeding against him on his ethical misconduct as
13 found by a court, and now he's trying to get
14 testimony for, again, an improper purpose for
15 another proceeding. I'm not doing this.
16 MR. KRESS: What's the -- what's the
17 purpose for the relevancy of Mr. Paul?
18 THE WITNESS: I mean, I'm going to tell the
19 bar you're harassing a witness in a proceeding
20 against you if you want to proceed here. This is
21 ridiculous.
22 BY MR. KLAYMAN:
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Page 137
1 Q So you're going to try to hurt me some
2 more?
3 MR. KRESS: Objection to form. You
4 don't -- your question is does he know Peter Paul?
5 MR. KLAYMAN: Yes. All this and that's
6 what we get.
7 THE WITNESS: I'm not testifying about
8 Peter Paul.
9 MR. KLAYMAN: Certify it.
10 BY MR. KLAYMAN:
11 Q Do you know someone named Sandy Cobas?
12 A Again, there are three charges and three
13 cases before the bar in Washington, D.C., the
14 District of Columbia Bar. He's seeking testimony
15 related to that pending proceeding. I am not
16 testifying about it.
17 Q And, in fact, I have not been sanctioned by
18 the Bar. That matter is pending, correct?
19 MR. KRESS: But I think that's a concern
20 that goes --
21 THE WITNESS: Again, I'm not testifying
22 about -- my testimony is clear on the matter here.
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Page 138
1 I'm not testifying.
2 MR. KRESS: And I would add an objection
3 that, I mean, bar proceedings generally are
4 privileged.
5 MR. KLAYMAN: I'm not asking about a bar
6 proceeding. He raised it.
7 MR. KRESS: Well, if these are -- if the
8 only relevancy is --
9 MR. KLAYMAN: Then he broke -- he broke the
10 confidentiality here and he just violated bar rules.
11 MR. KRESS: He's not a member of the bar,
12 for one thing, but I don't --
13 MR. KLAYMAN: He works for a legal
14 organization.
15 THE WITNESS: Okay. Well, the bar will
16 judge the appropriateness of this line of
17 questioning, I guess.
18 BY MR. KLAYMAN:
19 Q I didn't raise that. I just asked if you
20 knew Peter Paul.
21 MR. KLAYMAN: The fact that he would
22 violate bar rules to make a point, stick it to me, I
631

Page 139
1 mean, is quite irrelevant here.
2 MR. KRESS: No one's trying to stick it to
3 you. We're just trying to get through the
4 deposition here. What -- what do you want to know
5 about Peter Paul if he does know Peter Paul?
6 THE WITNESS: This is litigation -- this is
7 a litigation he's sued us over. This is just a
8 rehash of it and it's pending bar. I'm not talking
9 about it.
11 MR. KRESS: All right. Let's -- what's
12 that?
13 Well, the witness --
14 MR. KLAYMAN: Is he refusing to answer?
15 THE WITNESS: Yes, I'm refusing to answer.
16 BY MR. KLAYMAN:
17 Q Louise Benson --
18 A Again, I'm refusing to answer Louise
19 Benson, so now you've asked three questions on the
20 very three matters before -- pending before the bar
21 in the District of Columbia.
22 Q You just violated --
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Page 140
1 A And I'm not testifying about it, and I
2 consider this to be harassing related -- harassment
3 related to that bar investigation and that pending
4 hearing. And I'm a witness there, and you're just
5 seeking discovery improperly for that separate
6 proceeding and harassing me and trying to intimidate
7 me for participating, potentially, in that
8 proceeding. And I'm going to send a copy of this
9 deposition to the bar to alert them to this
10 misconduct.
11 Q Well, you've just violated bar rules again,
12 haven't you?
13 A And if the bar finds that I have, I will
14 deal with that then.
15 Q Are you engaging in the unauthorized
16 practice of law?
17 MR. KRESS: Objection. This is -- we're
18 getting to the point of harassment where we're
19 either going to have to terminate the deposition
20 or just --
21 MR. KLAYMAN: I didn't ask anything about
22 the bar. I just asked if he knew these people --
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Page 141
1 MR. KRESS: You just asked --
2 MR. KLAYMAN: I just asked if he knew these
3 people, and all I got was, you know, there's bar
4 proceedings pending against you and you've done
5 something wrong. Okay. That's inappropriate, Doug.
6 MR. KRESS: Do you have additional
7 questions?
8 BY MR. KLAYMAN:
9 Q Are you aware that I've filed a lawsuit in
10 Miami against Hugo Chavez on behalf of a Venezuelan?
11 A No. Outside of Judicial Watch?
12 Q Yes, after I left.
13 A No. I don't remember anything like that.
14 Q You are aware that before joining Judicial
15 Watch I had been up for a possible appointment as
16 U.S. Attorney for the Southern District of Florida?
17 A I recall you telling me that, but beyond
18 that I don't know.
19 Q Okay. And then, in fact, Senator Connie
20 Mack, his office asked me if I wanted to be
21 considered to be a judge there?
22 A I don't --
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Page 142
1 Q A federal judge?
2 A I don't remember that, no.
3 Q Okay.
4 A I don't remember you telling me that, or I
5 don't have independent knowledge of that either.
6 MR. KLAYMAN: I have no further questions.
7 I'm going to leave the deposition open in light of
8 the fact that he's refused to answer many questions.
9 We're going to have to get some court rulings on
10 that.
11 MR. KRESS: I understand your position.
12 MR. KLAYMAN: And I just want the record to
13 reflect that throughout this deposition, and it can
14 reflect itself, that I've been extremely respectful
15 to Mr. Fitton. I've not raised my voice. I've
16 simply asked questions and that he is refusing to
17 answer questions on his own even without your
18 instruction, and that creates the necessity of
19 having to go to the court to break the impasse.
20 MR. KRESS: We have a -- we have a record.
21 We have a video record, and if necessary we'll
22 address that.
631

Page 143
2 MR. KRESS: Thank you. We'll reserve the
3 right to read.
4 THE VIDEOGRAPHER: Here marks the end of
5 Volume 1, Tape No. 2 in the deposition of Thomas
6 Fitton. The time is 11:50 a.m.
7 (Signature having not been waived, the
8 deposition of Thomas J. Fitton was concluded at
9 11:50 a.m.)
10
11
12
13
14
15
16
17
18
19
20
21
22
631

Page 144
1 * * *
3 I,Thomas J. Fitton, do hereby acknowledge that I
4 have read and examined the foregoing testimony, and
5 the same is a true, correct and complete
6 transcription of the testimony given by me, and any
7 corrections appear on the attached Errata sheet
8 signed by me.
9
10 _________________________ _____________________
12
13
14
15
16
17
18
19
20
21
22
631

Page 145
12 hand and affixed my notarial seal this 7th day of
13 February 2014.
14
16 June 14, 2014
17 ____________________________
20
21
22
631

Page 146
3 RETURN BY: ________________________________________
4 ===================================================
6 ===================================================
7 ____ ____ ___________________________________
8 ____ ____ ___________________________________
9 ____ ____ ___________________________________
10 ____ ____ ___________________________________
11 ____ ____ ___________________________________
12 ____ ____ ___________________________________
13 ____ ____ ___________________________________
14 ____ ____ ___________________________________
15 ____ ____ ___________________________________
16 ____ ____ ___________________________________
17 ____ ____ ___________________________________
18 ____ ____ ___________________________________
19 ____ ____ ___________________________________
20 ____ ____ ___________________________________
21 _______________ ___________________________________
631

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3 RETURN BY: _________________________________________
4 ====================================================
6 ====================================================
7 ____ ____ ___________________________________
8 ____ ____ ___________________________________
9 ____ ____ ___________________________________
10 ____ ____ ___________________________________
11 ____ ____ ___________________________________
12 ____ ____ ___________________________________
13 ____ ____ ___________________________________
14 ____ ____ ___________________________________
15 ____ ____ ___________________________________
16 ____ ____ ___________________________________
17 ____ ____ ___________________________________
18 ____ ____ ___________________________________
19 ____ ____ ___________________________________
20 ____ ____ ___________________________________
21 _______________ ___________________________________
631

Page 1
A
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107:2 113:12 132:10
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94:10
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43:19 105:20
accused
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135:1
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77:19
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4:10 17:7 34:16 36:16
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133:22
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38:10 43:3 45:18
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119:22
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10:10 44:15
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Page 2
apparently
116:17 130:13
appear
5:11 144:7
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28:5,9
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5:15
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80:11
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141:15
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138:16
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55:3,4,4 117:18,19
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32:10 80:22 82:17,19
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79:9
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129:11
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Page 4
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21:4,10 23:5 48:18
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41:11
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106:8,18 107:11
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57:13,21
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10:1 58:1,4
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78:10
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31:8
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144:5
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83:7
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20:10,16 71:6
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20:13 71:8,10
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60:13
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92:1
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17:14
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11:10,14 12:5,11
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11:11 17:15 100:21
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19:10 23:6 37:14,14
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60:12 77:20 87:21
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28:16 32:16
concerns
132:4,18,20
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conclude
98:4
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143:8
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100:10 113:9
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100:8
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47:9 49:9 78:20 97:12
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67:18 69:18,21 134:2
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48:3,11 55:20
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138:10
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130:1
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128:12
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101:6
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106:8 107:7,11
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106:22
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39:6,8 140:2
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141:21
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94:15
Constance
65:7,18,20 72:19
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26:19
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36:22
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61:9 85:9 86:16 91:7
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91:19
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37:16
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9:12 11:9 27:11 49:11
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16:15
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96:11
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14:10
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101:19
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88:17
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94:11,20 125:17
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81:15 83:22 84:3 85:9
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84:1 97:11 113:17
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131:6
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71:11
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129:14
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71:6,9
Corporation
26:6
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6:12,13,18,19 10:5,18
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144:7
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17:12 19:19 24:4 33:9
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6:2 51:3 107:13
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court's
116:5
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coverage
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9:15
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77:7
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106:11 117:11
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99:5
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Defend
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Deleting
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25:8
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105:6 106:1 124:13
DEPONENT
144:2
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42:17
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63:6,8,17,21 64:1,17
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6:16
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103:22
diligence
120:18 121:3
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Dina
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76:6 81:1 82:7 90:12
91:18,22 92:19 94:12
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145:13
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142:1
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Garden
80:7
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Gardens
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generally
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high
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Hill
100:16
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hire
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hired
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history
40:9,21 134:9 135:8
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Hopefully
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140:5
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Incorporation
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132:1,18 142:5
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82:1 97:8,18,21 98:5
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110:5
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Infrequent
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Internally
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105:8 131:20 132:7
intervene
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intervention
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interview
91:9
intimidate
140:6
intrigued
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98:2
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132:3,6,12,15,19
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146:2 147:2
June
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justice
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KAHLE
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lack
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location
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logistics
66:11
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logo
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long
9:5,7 18:21 49:8 52:10
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Meets
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mitigate
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moment
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money
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111:20 113:20
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142:18
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35:16 81:2,4 93:9
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129:22
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45:14 46:5,6 50:3
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122:19
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nonpayment
111:18 113:17
nonsensical
106:5 108:12
nonsupport
82:2 94:22
non-existant
79:4
normal
106:19
Norris
67:7,19,21
North
3:15
Northwest
2:6 3:7 7:13
notarial
145:12
Notary
2:11 145:18
note
74:13 116:10
notice
2:10 5:21 6:9,14,19
122:11,18
notified
83:3
notwithstanding
10:1
NSA
107:20
number
19:13 24:16 81:21
91:1 99:18
NVRA
126:8
Nyack
8:15
O
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4:1 5:1 147:1
oath
106:11,17
Obama
75:18,20 78:15 81:6
91:14
Obama's
76:2,20
object
35:4 36:15 38:17 39:1
39:14 44:20 45:16
50:5,20 55:18 59:9
59:10,10,11 61:12
62:17 73:7 86:2
88:12 117:5 119:20
128:9
objecting
133:17
objection
5:21 16:22 22:1,8
33:19 40:10 47:17
49:3 50:13 59:13
66:12 71:18 72:22
74:13 75:2 84:6,15
85:1,18 87:22 89:4
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100:22,22 101:9,21
102:6,19 104:3,19
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115:1 116:10,22
117:8,16 120:5,22
121:12 122:13 123:8
124:3,17 131:21
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140:17
obligation
108:22 109:3 133:8
observer
28:10
obtain
9:8 29:3 61:6
obtained
16:8 25:22 28:22
64:10
occasions
99:19
occupied
12:13
occur
89:9
occurred
31:14 32:4 43:18
121:11
October
130:16
offending
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96:17
offer
71:7
offered
14:16,21 15:1,6,10
office
26:7,18 65:7,10,21
66:3,6,7,15 67:5,7,10
67:15,17 68:8,11,18
68:21 69:1 70:10,16
70:20 71:4 80:14
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officer
145:2
offices
2:2 12:13,15,18,21
13:2,3 14:13,14
official
48:12
officials
99:22
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71:6 74:2 100:14
126:6
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81:15 94:17 103:20
113:3 123:21 124:1,2
126:9
okay
11:22 13:1,12 16:12
16:20 21:2 22:16
23:7 24:19 25:12,18
26:10,14 27:22 28:5
29:15,22 31:13 34:15
35:19 38:7,11 41:7,9
41:11 42:5,7,16 43:1
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35:1
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41:17
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24:11 56:12 98:1
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41:13 139:2
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127:1,11 142:7
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7:11
opinion
100:13 101:4
opportunity
83:8
opposed
19:22 126:9,10
order
5:13 6:7 29:11 35:19
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34:20
orders
66:10,18
ordinary
22:18 70:15
Orfanedes
49:6 57:19 67:17
68:17,21 69:9 70:9
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48:12
organization
47:20 48:5 50:7,8
138:14
organized
71:15
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107:8
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74:15
Orly
5:6 71:15 74:20 75:15
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88:18 95:8 97:1
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ought
115:20
outcome
145:10
outrageous
94:18
outside
63:1 86:10 122:4
141:11
outstanding
115:20
Oval
26:17
overheard
54:20 55:7,8
overly
62:17
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82:2
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81:1
page
4:3,7,11,11,11,11 79:1
79:14,20 90:11 94:7
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pages
1:21 92:18 129:10
Palm
3:16
paper
20:8 127:6,7
papers
112:8
paragraph
79:21 81:11 82:8
93:10,18 95:15
Parkway
75:17
parliaments
30:10 31:6
part
13:9 111:12 112:19
117:3
participants
94:15
participate
78:14 94:21
participating
140:7
particular
24:17
particularly
99:17
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145:9
party
54:5,18 55:5,9
pattern
47:8 49:9
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9:14 10:1 57:19 77:22
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pay
57:22 103:2 113:20
paying
10:2,3 81:16 84:3
111:20 113:4 116:21
payment
82:5
payments
57:16
pending
6:6 37:16 38:12 78:3
134:18 136:11
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Page 18
137:15,18 139:8,20
140:3 141:4
Pennsylvania
3:7
people
25:22 36:10 37:21
50:2 80:11 97:18
98:3,4,5,7 100:5,15
127:19 140:22 141:3
perceive
21:13
performed
121:4
period
26:8 91:18 130:8
131:12
person
10:10 11:10 22:16
37:22 63:14 67:6
74:8 106:19
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23:17 38:9 91:16
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personally
19:21 103:6,8,11,16
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100:20
Peter
135:22 136:3 137:4,8
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Peterson
53:17,19,21 54:7,9,15
56:8 58:4 61:9
Peterson's
54:8 58:12
phone
58:4,7 91:1
pick
28:18
piece
39:6,9
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129:13
place
7:12 50:22 87:7
plaintiff
1:5 3:3 5:5 8:4
Plaintiff's
75:6 125:1,4 126:21
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plane
32:5,7,9
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80:5
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70:9
plea
111:22
pleadings
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please
7:14,22 8:6 12:17 34:5
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111:19
point
8:16 13:22 14:15
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135:7 138:22 140:18
Policy
45:3,7,13,15 46:7
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polite
48:22
political
30:15 100:18 131:2
132:8
popping
110:8
popularity
106:17
position
14:16,21 15:6,10 48:2
49:17 72:18 75:1
118:4 120:3,12,15
142:11
possibility
6:1
possible
108:14 141:15
Post
32:10,12
posting
129:16,18,20,21
130:13 132:7,14
posturing
96:4
post-Soviet
41:10
potential
5:17 87:20 94:2 95:6
122:19
potentially
18:3 140:7
practice
21:3 140:16
prelitigation
88:20
present
3:20 15:4 54:21
presentation
79:2 80:4,6,10
presenting
9:17,18
president
10:13,16 11:1 14:22
15:1,10 22:17 25:20
26:17 27:4 32:17
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President's
25:13
presumably
70:14
presume
10:2,3 29:16
presumption
62:2
previous
36:17 115:2
previously
92:9 114:15 124:19
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primarily
26:11
principle
97:20
prior
26:3 36:12 111:14
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30:15
Privacy
26:18,19 27:3,9
privately
47:21
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69:13
privilege
19:12 47:20 48:7,13
48:19 50:7,22 53:1,8
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privileged
47:22 54:2,11,19
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privileges
69:16 110:21
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3:3 7:17 8:4
probably
83:18 98:5 100:17
101:12 119:13
128:10
probing
119:5
problem
98:4,8
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Page 19
Procedure
118:5,16
proceed
136:20
proceeding
111:4 112:7 136:12,15
136:19 137:15 138:6
140:6,8
proceedings
5:2 7:1 70:4 138:3
141:4
process
6:17 48:15,17 81:7
produced
94:17
product
19:11 104:6
proffer
134:7
promote
98:20,22
proper
134:8,20
prosecute
99:2,3
prosecuting
99:8
prosecutor
97:14
protracted
16:14
proud
130:14
proven
97:18
provide
14:8 58:2 60:21 78:6
provided
15:16 61:3,3 81:17
113:4
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57:4 58:7
providers
57:17,18,20
provocative
34:7 35:11 38:2,9
Prytherch
129:16
public
2:11 26:12 28:7 38:3
42:11,12 70:2 78:17
81:19,20 105:5 110:3
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publish
81:18 108:7 113:5
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96:6 107:11 108:19
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publishing
81:19 113:6
pull
75:8
purported
87:13
purportedly
95:7 97:1 108:18
purpose
18:16 102:7 116:5,8
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purposefully
135:7
Pursuant
2:10
put
43:10 64:18 108:10
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3:13
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91:21 129:14
Q
question
11:5 12:16 17:3 20:2
22:4 23:8,9 30:6
33:20 34:5,7,12,17
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121:15 122:7,16
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questioned
16:17
questioning
16:16 48:10 102:8
108:14 115:12
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questions
4:7,10 18:20,22 19:3
19:13 37:18 38:10
40:11 42:21 43:3
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109:6 116:7
quite
35:10 66:9 72:14 78:7
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3:1 5:1 146:1,1 147:1
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rafters
28:18
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81:2 138:19
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81:10 138:6 142:15
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47:6
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75:17
reacting
127:19
read
13:9 23:10,11 35:14
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74:3,5 79:6,10 110:14
reads
79:2
real
98:3,8
really
44:10 86:8 103:18
108:20 133:2
reask
38:12
reason
9:5 10:9 17:21 37:16
95:1 118:15 146:5
147:5
reasonable
37:22
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Page 20
reasons
22:19 41:3 100:18
rec
128:18
recall
14:20 15:3 19:20 23:1
23:3,4,13 27:6 30:14
30:18 38:19 57:6,8
57:10 65:9 71:6 77:2
85:12 87:7 89:11
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received
6:19 20:5 78:16
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80:10
Recess
37:7 47:14 53:4 62:11
104:11
recognized
48:13
recollection
31:11,17 59:9 83:8
92:3,10,17 93:14,17
95:4 96:20 132:2,18
record
5:3,4 7:2 23:11 27:19
27:20 37:3,5,8,11
38:15 44:9 47:10,12
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62:12,14 64:19 70:2
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records
10:17 11:13,14 12:4
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reduced
145:7
refer
51:3
reference
35:20 36:1,4 40:8
41:10,15 50:18 120:7
references
34:20 124:6
referencing
99:8 127:22
referred
13:13
referring
128:3 132:16
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27:19
reflect
5:4 102:13 142:13,14
refresh
31:17 83:7 92:3 93:14
95:4 96:20
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31:10 92:17
refused
142:8
refuses
5:11
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135:21 139:14,15,18
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41:13
regard
6:8 21:10 22:22 25:19
26:5,6,16 31:12,13
70:19,20 71:8 110:3
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regarding
91:22 94:22
Regardless
76:16
regime
31:3
Regional
80:15
regular
68:5 98:7
rehash
139:8
relate
122:1
related
27:1 31:2 36:12 47:18
67:15 70:3 96:6,18
112:6,7 121:4 122:1
137:15 140:2,3 145:8
relates
59:15 70:18 103:19
126:3
relating
94:9 136:11
Relations
82:4
release
26:18
relevance
18:16 35:5 45:9
relevancy
33:19 39:14 44:21
45:17 50:6 61:13
98:12 115:14 136:17
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relevant
47:5 49:10,12,16
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18:2
remain
29:12
remainder
91:9
remarks
127:21
remember
9:11,20 20:3,4 22:21
25:15 26:20 27:15,15
28:3,8,19 29:2,5,8,12
29:17,22 30:8,13,21
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34:21 35:22 111:21
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12:16 23:8 49:5
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110:20
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96:15 127:3
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reporter
2:11 7:20,21 23:11
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REPORTER-NOT...
145:1
reports
54:9,11
reposing
74:2
represent
7:15
representative
72:1,8 80:8
represented
29:6 131:19
represents
94:9 131:5
Republic
127:13 129:2
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Republicans
130:16
reputation
24:3 105:9
request
78:20 93:15
requested
23:12 38:16 55:17
62:15 73:6 74:12
require
44:1 86:5
required
9:8
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5:6
reschedule
5:9
Rescue
28:16
research
15:7
reserve
143:2
resolve
60:8 93:12
resolved
53:7
respect
23:2,14 70:13,17
103:7,10
respectful
142:14
response
123:13
responsibilities
130:7
responsibility
73:14 109:14
responsible
72:20 129:20
rest
123:14
restate
38:18 119:10
result
113:20
resume
15:16 16:1
retired
67:21
RETURN
146:3 147:3
reveal
73:9 86:5
revealing
55:19 58:14,16 60:15
86:3
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92:18
reversed
18:13
review
101:16 110:3,13 111:3
111:10,14
reviewed
82:17 84:12,21 111:11
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113:10
rewrite
135:8
Rewriting
40:21
Rich
90:20 92:20 95:5
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Richard
53:16 83:3 90:9 92:1
95:22 97:1
ridiculous
121:5 134:4 136:21
right
6:6,15,17,21 11:22
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Road
3:15
role
70:9
Ron
100:16
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17:19
Royce
26:15
Ruffley
46:22 65:7,8,18,20
67:20 70:11,12 71:14
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95:16
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127:19
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118:5,6,16,17 119:14
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ruling
26:15,22,22 27:2,11
rulings
142:9
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49:15,15 51:4
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41:10
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65:6,6,10,22 80:9,16
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137:17
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30:4,12,21
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137:11
Santa
75:17,18
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83:2 84:12 85:7,7
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16:1,20 50:18 67:13
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24:20 25:2,3,20
scandals
24:16,19 25:5
scheduled
82:6
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8:10 13:5
SCHWED
3:13
scope
49:2 134:19,20
se
3:3 7:17 8:4 43:18,19
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Page 22
seal
145:12
search
10:20 11:3,12
sec
60:4
second
37:3 45:12 47:11 62:8
77:18,22 79:1 80:1,2
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90:11
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35:5 38:13 43:5 79:6
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141:19
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58:15 96:3
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20:3 81:1,21 129:12
sentence
120:14
separate
18:7 31:11 39:4,7
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September
31:14 34:20
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94:10
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93:3 105:19,21
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services
14:9 57:22 58:3
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145:11
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40:8 133:15,21
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111:8 144:7
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66:5,15 67:4 74:5 76:1
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28:16
short
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shortly
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Signature
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1:7 5:19
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Sincerely
93:13
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34:21 35:20,22 36:5,7
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17:21 49:7 136:1
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117:22
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102:5
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79:9
somebody
43:19
sorry
78:2 84:18 117:22
sought
13:16 48:8
sounds
18:13 27:18 54:16
source
21:13 105:6 106:1
112:3,4 124:13,14
sources
115:7
South
8:11
Southern
1:2 7:7 141:16
Southwest
13:5
so-called
24:20 25:20 96:16
speak
80:9 93:1 94:12 96:13
129:17
speaker
130:15
speaks
121:2 128:10 132:21
Special
70:4
specific
29:17 59:8 78:3,21
127:16
specifically
27:16 57:6,8,9 59:2,5
71:8 77:1,9 78:8,20
specifics
32:2
speculate
125:9
spends
68:2,3
springboard
43:12 44:4
Sprint
58:1,8
stand
74:15
standard
20:12
start
18:6
starts
631

Page 23
129:11
state
7:15 8:6 47:17 96:11
118:12 135:9,10
stated
94:19 134:21
statement
84:4 87:14 89:2,18
90:4,10 99:4,8,9
107:10 108:9,17
109:10,17,19 120:17
120:20 121:19 122:2
123:4,5,14 124:5,6
128:13 133:1,9
statements
72:12,16,20 73:13
74:21 91:15 94:21
95:3 96:9 102:12
127:2,12
States
1:1 7:6 29:11,12 97:17
status
28:10
stay
29:10
stenographically
145:6
step
37:2 104:7
Stephanie
51:8,20 52:7 53:22
54:7,8,15 55:1 56:5,9
59:18 63:17 102:3,17
102:21
Stephanie's
53:11
Steve
129:15 130:4,5
stick
138:22 139:2
sticker
75:12
stip
44:8
stipulate
44:9
stood
80:11
stored
21:6
stories
13:17
story
32:13
Straits
28:17
Street
2:6 7:12 13:5
stricken
41:11
strike
61:7 65:19 108:7
129:11
string
91:5
stuff
38:3
styled
75:15
subject
16:13 58:11 71:16
129:16
subpoena
5:6 6:20
subsequently
32:11
substance
54:12 56:10 86:14
96:22
substantially
119:4
substantive
119:10
sued
95:17 139:7
suggesting
78:22
suing
46:8
suit
25:19 79:4 87:3 93:11
Suite
2:5 3:6,14
summary
111:12 112:7,8
Super
80:22
supervise
70:11
supervisory
66:8
supplies
66:10,18
support
81:17 84:4 94:18
103:2,15 110:5
111:18 113:4,18
116:21
supporters
106:21
Suppose
106:3,6,7
supposed
59:19
supposition
48:10
Supreme
32:22 33:3
sure
29:8 58:2 66:9 72:14
74:8 78:7
surprising
94:5
Susan
129:15
swear
7:22
sworn
8:2 89:16,17
T
T
4:1,1,14 146:1,1 147:1
147:1,1
Taitz
5:6,11 6:21 71:15
74:20 75:16,20 77:2
82:11 84:2,8,12 85:8
85:11 86:17 88:18
95:8 97:1 108:18
109:17 112:11 113:8
114:4,8 123:7,15
125:16,19 126:1,3,7
126:12 127:1,12,20
129:16,19 130:13
131:1,17 132:13
Taitz's
132:7
take
6:5 48:1 49:17 50:21
83:8 87:7 95:2,16
103:10 104:8 117:7
taken
145:3,6
talk
37:22 77:22 80:9
91:11,14 93:8
talked
77:4 92:4,5,8 114:12
125:15
talking
18:6 54:5 86:22 93:19
139:8
Tallahassee
28:7
Tape
7:4 104:13 143:5
Task
32:16
team
81:6
technically
111:21
telephone
3:9,17 5:18 56:20 57:2
57:13,17,18,19,21
58:2 66:10
television
9:13,14 10:1 43:9
tell
631

Page 24
13:17 16:10 27:20
50:2 57:12 85:10
87:13 109:20 136:18
telling
55:10 85:11 141:17
142:4
tenure
65:9 99:10
terminate
140:19
terms
35:3 70:7
Terrorist
127:6,7
test
16:21
testified
84:10,22 85:5 92:9
109:22 110:1 114:15
128:20 132:9
testify
8:2 24:12 87:9 106:10
106:16,17,20 108:15
132:3,10,19 135:5
testifying
19:7 134:14 137:7,16
137:21 138:1 140:1
testimony
23:1 27:13 51:22 89:6
101:19 110:16,16
115:2,19 133:4
136:14 137:14,22
144:4,6 145:5,6
testing
102:9
text
132:4,20
Thank
87:4 88:10 90:22
143:2
thanks
23:10 91:11 130:1
that's
9:19,20 12:1,7,10,12
17:1,8 18:15 21:6
22:8 27:7 28:20
29:19 34:12 35:2
37:15,16 38:1,21
43:13,15,19 45:10
46:18,19 48:13 49:3
50:20 54:19 55:5
64:20 65:17 67:12,16
70:1,5,6 73:2 75:11
84:4 85:19 88:18,19
88:19 90:17 97:20
100:19 103:3,13
104:1 105:8,19 106:5
106:10,11 115:19
118:8,8,10 120:15
129:13 131:19
134:13 135:11 137:5
137:19 141:5
there'd
55:3
there's
19:10 30:6 37:11
41:15,21 48:12 54:6
55:4 64:11,12 72:16
77:10,21 91:5 102:7
112:4 116:18 120:14
134:15,17,17 141:3
they're
48:4,12,12 51:16
52:10,12,17 92:17
98:6 102:14 127:21
they've
61:3
thing
59:12 82:18 138:12
things
18:13 26:7 41:20
45:14 46:6,6,9 47:21
50:3 73:14 114:19
135:9
think
6:20 14:5 15:12 17:7
19:8,9 20:15 21:1
24:22 26:2 27:4 34:3
35:6 37:13 42:3,11
43:11,13 44:3 48:21
48:22 51:15 52:11
54:1 58:1,22 59:20
73:17 77:12,14 78:1
78:22 83:19 85:2
86:21 92:6,7 102:10
103:3,12,13 104:6
110:13 114:1 116:11
116:11 117:14
118:18 119:19
120:10 122:13 125:5
126:7,8 131:5,13,22
134:12,18 137:19
thinking
36:11
third
54:5,18 55:5,9 79:21
81:11 82:8
Thomas
1:11 2:1 4:3 7:4 8:1,7
104:14 108:20 143:5
143:8
threat
19:4,10 20:5 32:4
41:21
threatened
17:16 40:12 134:1,18
threatening
18:7 20:3 44:2 134:3
134:14
threats
19:20 36:13
three
56:16 137:12,12
139:19,20
thwart
48:9
ti
24:13
time
5:12 6:17 7:10 8:16
9:8,22 10:4 12:14,16
12:19 13:10,10,20,20
13:22 14:12,15 15:2
15:11,15,19 16:6,9
21:2 22:11,11 24:2
25:18 26:8 27:22
28:13 29:5,20 31:18
32:14 33:4 37:6,9
43:7 47:13,16 49:8
49:15 53:3,6 62:10
62:13 65:4,10 68:2,4
68:9 71:14 82:12
83:2,11,13,18 85:13
86:19 87:10 91:18
92:22 95:13 98:3,7
104:10,14 107:1
109:22 115:17 116:5
116:6 117:7 122:8
125:7,12,13 130:8
131:7 133:6 134:5
143:6
times
56:16 68:17 69:6,10
125:15,18
timing
32:3
tireless
81:7
title
33:7 127:7,11
today
7:11,20 36:5 91:3
92:22 96:3 111:5
Today's
7:9
told
10:8 15:20 43:9 44:15
57:12 80:7,16,20,22
81:4,13 82:11 84:8
84:13 86:17 90:3
112:22 113:9 114:4,8
123:19
Tom
89:1 94:14
tomorrow
5:7,15
top
75:18
topic
42:1 44:13 52:8,9
631

Page 25
torts
96:9
tough
34:6
track
118:8
trademark
12:8
transcript
145:4
transcription
144:6
travel
26:7
travelled
68:11
trial
28:6
tried
126:7
trip
30:1,13,17,18 31:7,22
32:3
trips
30:14 31:2,4,11
trouble
21:14
true
65:17 100:19 114:1
119:5 144:5 145:5
truly
12:19 94:18
truth
85:11
try
37:17 77:17 93:12
103:22 118:7 136:4,8
137:1
trying
20:2 28:18 30:5 96:10
110:17 118:12
135:17 136:9,10,13
139:2,3 140:6
Tuesday
94:12
turn
75:5 79:1 82:8 90:9,10
92:16 129:5,9
TV
13:21 24:6,9 43:10
twice
56:14
two
31:4,11 82:1,2,3 92:18
102:12
typewriting
145:7
T-a-i-t-z
71:16
U
U
147:1
ultimately
135:2
unanswered
91:8
unauthorized
140:15
uncertain
32:8
uncover
24:15
uncovered
24:20
underneath
130:4
understand
35:5 47:3,5 48:17
73:10 106:14 108:4
108:13,21 109:2
110:7,11 112:15
113:13 120:6 121:14
142:11
understanding
6:3 101:11,15 110:19
understood
119:14
unethical
98:20 99:1
unethically
99:18 100:1
Union
30:12 31:5
United
1:1 7:6 29:10,12 97:17
130:16
University
8:22 15:21
unlearn
44:11
unraveling
25:4
unsupported
94:13
update
79:3
UROC
129:21 131:19
use
43:12 44:3 58:5,7 99:3
101:3 120:9
uses
67:17
U.S
32:22 51:4 80:5
141:16
V
v
1:6,22 2:10 28:6
116:18 119:1 145:2
146:2 147:2
vague
57:14 93:17 94:13
vaguely
127:14
valid
55:2,3
various
13:12 31:6
Venezuelan
141:10
verbatim
38:22
Verizon
58:1
versus
7:5
viable
118:8
Vice
32:17
victims
30:1,9,14 31:3,18
video
5:3 7:2,10,11,11
142:21
Videographer
3:21 7:3,20 37:5,8
47:12,15 53:2,5 62:9
62:12 104:9,12
117:20 143:4
Videotaped
1:11 2:1
view
49:20
viewed
105:9
violate
27:9 138:22
violated
138:10 139:22 140:11
violation
26:19 27:3,8,10
Virginia
115:6,10 116:1,14
visited
12:21
voice
7:14 142:15
Volume
7:4 104:13 143:5
voluntary
82:5
voters
80:6
W
wait
631

Page 26
60:4,7,7 77:17
waiting
74:6
waived
143:7
want
15:3 18:21 28:11
36:22 38:9,12,18
45:18,19 57:12 59:11
74:7 78:5 79:12
105:4 108:7,8 110:21
116:9 118:11 124:10
124:14 135:6,15
136:20 139:4 142:12
wanted
102:18 103:22 109:4
141:20
wants
18:1,3
warm
80:10
Washington
1:12 2:7 3:8 7:13 8:22
8:22 9:3 15:21 16:3
16:6 32:5,10,12
137:13
wasn't
15:4 122:22
waste
107:1
wasteful
123:1
wasting
116:5 133:6 134:4
Watch
1:7 5:8 7:6,19 10:4,5
10:13,16,22 11:11,15
11:17 12:5,9,11,14
12:18 13:14 14:1,7,8
14:18,22 15:2,11,16
15:20 16:7,9 20:7
21:3 22:17 24:3,8
25:13,17,19 26:4
28:1,6,14 29:6,19
32:15 33:2,5,17
34:19 36:2,9,10
37:12 40:9 41:12,14
43:8 44:17 46:8,14
50:16,19 51:4,7,14
52:6 53:10,15,19
56:20 57:3,5 58:5,21
59:17 60:12,22 61:4
61:8 63:5 65:5,5,9,13
65:22 67:15,19 68:6
68:15 69:18 72:1,8
72:19,21 74:22 75:1
76:11,18 78:5,13
80:8,12,15,18 81:14
85:17 86:9,16 87:8
87:12 89:2 90:21
91:12 93:2,5,16 94:2
94:4,9,14,20 95:2,6
95:18 96:6 97:5
98:19 99:5,10 103:9
106:7,15,18,21 107:7
107:10 108:8,10
113:1 119:3 121:3,4
121:10,19 123:6,20
124:8,16 126:1,8,11
129:17,21 130:6,15
130:22 131:2,16,18
132:6,12,15 134:10
141:11,15 146:2
147:2
Watch's
10:17,21 11:3 34:21
36:7 37:21 50:17
52:12 55:20 132:3,20
way
30:7 32:21,22 48:7
49:10 55:13,18 57:14
62:2 69:8 74:19
108:15
web
34:21 35:20,22 36:5,7
75:19,20,21,22
108:10,19 127:2
132:7,14
Website
129:17
Wednesday
1:13
week
81:4
weekly
24:10,13
weird
93:17,22
went
16:12,13 30:8 31:18
33:3 69:2 71:14,22
74:20 91:7
weren't
100:6 124:10
West
8:15
Western
80:15
Weyrich
10:2 12:15,20
Weyrich's
9:14 10:1 13:21
we'd
133:14
we'll
43:5 142:21 143:2
we're
5:16 21:16,18,20 35:8
35:10,11 36:19 37:10
43:11 47:1 48:16,21
61:13 73:8 93:19
96:1 98:2,6 115:18
115:21 133:6 134:18
139:3 140:17,18
142:9
we've
20:1 24:22 53:7 98:3,7
129:18
what's
18:5,16 33:20 45:8,8
48:11 49:21 63:22
83:6 97:10 126:21
127:5,10 134:6
136:16,16 139:11
WHEREOF
145:11
Whoa
109:16,16
who's
10:7,21 22:17 49:6
63:16 77:1
widely
105:9 106:8
wife
51:8 52:7 58:12 64:5,5
Willey
26:16
willing
44:9
withdraw
45:19,22
witness
7:22 17:2,8 21:18 22:9
23:8,13 34:16 35:16
36:16,22 38:18 40:11
44:22 49:22 51:17
52:13,19 53:10,15
56:1 58:18 59:1,14
60:1,9,17 61:19
62:18 64:4 66:13,22
69:13,18 71:20 73:2
73:12 74:2,15 75:3
75:10,13 77:10,15,19
78:2 84:7,18 85:19
86:8 87:5 88:2,11,15
89:5,11,21 90:6,15
90:18 91:9 92:9
95:11,20 98:13 99:21
101:2,11,22 102:20
103:16 104:20
105:12,17 106:1
107:4,15 109:6,12
110:11,18 112:6
113:13 114:7,15
115:2,16 116:2,13
117:1,10,17,22
119:22 120:6 121:1
121:14 122:15 123:9
124:4,18 128:6,12
131:22 133:4,11,18
631

Page 27
133:22 134:13
136:10,18,19 137:7
137:21 138:15 139:6
139:13,15 140:4
145:11
woman
26:16
Women's
80:7
won
28:2 107:20
wondering
18:12
won't
29:8 135:18
word
11:7 99:3 101:3 120:9
work
14:1,7,13 15:15,19
16:7,9 19:11 67:14
70:7 80:17 81:7
104:5
worked
14:14 21:2 24:2 27:22
32:14 65:5 67:7,10
80:17
working
9:13,21 12:14,20
13:21 14:10 28:14
works
53:19 81:13 113:1
123:19 138:13
world
96:7
World's
75:18,20
wouldn't
48:9 49:19 69:3 105:5
105:21 108:6,8
wrap
136:8,9
wrapping
136:6
writ
133:15
write
39:12
writer
40:7
writes
91:21
writing
17:15 18:19
written
39:16 84:13 109:18
134:9
wrong
141:5
wrote
13:17 81:5 83:13
91:10 93:18 95:15
112:11 133:15
Wyoming
68:2
X
x
1:3,9 4:14
XO
58:3
Y
Yazbeck
63:6,17,21 64:1,17
yeah
6:12 13:3 19:15 23:20
25:10 31:19 37:4
42:3 64:3 66:10 67:9
79:13,17 93:22 96:2
99:3 112:19 123:17
136:6
year
21:1 77:7
years
13:13 20:14,15 22:12
23:18 30:3,16 58:9
58:10 59:7 65:21
67:8,11,16,22 68:12
68:14,18 69:7,10
70:7 76:19 80:18
81:7 99:18 100:1,4
yesterday
75:6 80:4
yesterday's
79:2
York
8:11,13,14,15
you'd
35:12 66:22
you'll
74:8
you're
6:12 10:8,9,22 11:9
15:13 31:10,10 34:4
36:20 39:19 41:8
42:12 44:1,12 46:8
47:6 48:22 49:5 60:5
64:9 68:20 72:5,13
73:8 74:2,3 75:19
76:1 78:22 79:6
86:22 92:13 97:21,21
97:22 102:10,15
103:5,13 104:2
106:12,16,16 107:2
113:12 114:3,18,22
115:7 116:16,19
119:9 121:20 132:11
134:14,16 135:21
136:19 137:1 140:4
you've
10:8 17:11 20:5 21:10
22:21 38:3,4 42:9
43:16,20 45:12,14
46:5 51:7,11 61:2
91:2 103:16 104:22
109:14 110:1 116:16
119:3 122:5 139:19
140:11 141:4
y'all
10:2
Y-a-z-b-e-c-k
64:1
Z
zero
55:4
$
$1,014.26
82:6
$1.8
28:22
$25,000
79:4,9 81:2,3
$78,861.76
82:2
1
1
1:21 7:4,4 104:13
143:5
10
4:8 58:9,10
10th
81:1
10:03
53:3
10:07
53:6
10:16
62:10
10:21
62:13
10:24
90:12 92:19
100
3:14 80:6
11
4:12 31:14 82:3 91:6
11:03
91:10
11:05
104:10
11:12
104:14
11:30
5:19
11:50
143:6,9
11410
3:15
12
631

Page 28
4:12
12:54
91:21
13th
130:16
13-20610-CIV
7:8
13-20610-CIV-ALT...
1:6
1325
2:6 7:12
137
4:8,12
139
4:12
14
82:3 145:16
147
1:21
18
4:12
19
34:20
1968
8:9
1986
8:20
1996
9:11
1998
14:4,20
2
2
4:12 67:11,16,22
68:12,14,18 69:7,10
70:7 75:5,6 79:1
82:16 84:11,12,22
104:13 109:18,18
112:20 123:16
125:13 143:5
2-hour
80:4
2-244103
1:20
200
2:5
2000
28:2
20005
2:7
20006
3:8
2001
31:14
2003
9:4 34:20
2009
82:4
2010
82:4
2011
82:5
2012
76:6 82:7 83:11,14
84:11 90:12 92:19
94:12 129:14
2014
1:13 7:9 145:13,16
202
2:8
2020
3:7
23rd
76:6 90:12 91:19,22
24th
6:9,14,19 92:19
25
30:16
2540
80:15
27th
6:21
28
129:14
28th
94:12
29
1:13
29th
7:9
3
3
83:6 90:9,11,16 122:1
30
30:16 82:5
30th
8:9
310
3:9
33418
3:16
345
3:6
4
4
81:7 125:1,1,4
4:03
129:14
5
5
20:13,15 23:18 65:21
76:19 104:8 126:22
5th
83:13 84:11,22 94:8
50
4:12,12
501
13:5
505
129:12
508
129:11
561
3:17
595-0800
3:9
6
6
5:21 127:6
60
81:22
694-0070
3:17
7
7
70:4 82:7 127:11
128:1,2
7th
145:12
8
8
4:4 128:21
861-3410
2:8
9
9
129:5
9:05
1:14
9:07
7:10
9:36
37:6
9:46
37:9
9:55
47:13
9:58
47:16
900
25:22
96
9:11 81:3
97
9:11
631

Attachment M
631
1
1 UNITED STATES DISTRICT COURT

2 SOUTHERN DISTRICT OF FLORIDA

3

4 LARRY E. KLAYMAN, )
Plaintiff, )
5 ) Case No. 13-20610-CIV-
) ALTONAGA/SIMONTON
6 v. )
)
7 JUDICIAL WATCH, INC., )
et al., )
8 Defendants. )
)
9 _____________________________)

10

11

12 DEPOSITION OF CONSTANCE S. RUFFLEY

13 FRIDAY, JANUARY 31, 2014

14 9:01 a.m.

15

16 205 South Broadway, Suite 200

17 Los Angeles, California 90012

18

19

20

21

22

23
REPORTED BY:
24 TRACY WILLIAMS,
CSR #10139, RPR, CRR
25 JOB NO. 109385

Coalition of Court Reporters of Los Angeles
205 South Broadway, Suite 200, Los Angeles, CA 90012 | 213.471.2966 | www.ccrola.com
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2
1 APPEARANCES:

2
FOR PLAINTIFF:
3
KLAYMAN LAW FIRM
4 BY: LARRY KLAYMAN, ESQ., PRO SE
(VIA TELEPHONIC CONFERENCE)
5 NAVEED MAHBOOBIAN, ESQ.
MONA FALAH, ESQ.
6 2520 Coral Way
Suite 2027
7 Miami, Florida 33145
(310) 595-0800
8 Leklayman@gmail.com

9

10 FOR DEFENDANT:

11 LAW OFFICES OF SCHWED, KAHLE, KRESS
BY: DOUGLAS J. KRESS, ESQ.
Suite 100
13 Palm Beach Gardens, FL 33418
(561) 694-0070
14 Dkress@schwedpa.com

15

16 Also Present:

17 JUDICIAL WATCH
PAUL J. ORFANEDES, Director of Litigation
18 425 Third Street, SW
Suite 800
19 Washington, DC 20024
(202) 646-5172
20 Porfanedes@judicialWatch.org

21
VIDEOGRAPHER: Elizabeth Collins
22

23

24

25

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3
1 I N D E X

2
WITNESS: CONSTANCE S. RUFFLEY
3
EXAMINATION BY PAGE
4
Mr. Klayman..................................8
5
Mr. Kress...................................74
6
Mr. Klayman.................................76
7

8

9 EXHIBITS

10 EXHIBIT DESCRIPTION PAGE

11 29 Declaration under penalty of
perjury of Constance S. Ruffley 24
12
2 World's Leading Obama Eligibility
13 Challenge Web Site reprint 27

14 9 Driscoll Seltzer document dated
March 5th of 2012, 10 pages 62
15

16

17

18

19

20

21

22

23

24

25

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1 LOS ANGELES, CALIFORNIA;

2 FRIDAY, JANUARY 31, 2014 9:01 A.M.

3
-oOo-
4

5 THE VIDEOGRAPHER: Today is the videotaped

6 deposition of Constance Ruffley taken on January 31st,

7 2014, at the Coalition of Court Reporters of

8 Los Angeles at 205 South Broadway Street, Suite 200,

9 in Los Angeles, California. In the matter of Larry

10 Klayman v. Judicial Watch, et al., Case No.

11 13-20610-CIV-ALTONAGA in the U.S. District Court for

12 the Southern District of Florida.

13 My name is Elizabeth Collins with Coalition

14 of Court Reporters of Los Angeles, located at 205

15 South Broadway, Suite 200, in Los Angeles, California.

16 We are now commencing at 9:01 a.m.

17 Will all present please identify themselves, beginning

18 with the witness.

19 THE WITNESS: Constance Ruffley.

20 MR. KRESS: Douglas Kress, attorney for Judicial

21 Watch and for the witness, as well.

22 MR. ORFANEDES: Paul Orfanedes with Judicial

23 Watch.

24 MS. FALAH: Mona Falah with Larry Klayman.

25 MR. MAHBOOIAN: Naveed Mahboobian for Larry

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1 Klayman.

2 THE VIDEOGRAPHER: And, Mr. Klayman, if you will

3 identify yourself.

4 MR. KLAYMAN: Yes.

5 Larry Klayman, Counsel Pro Se for Larry

6 Klayman.

7 Can you all hear me? Because it's breaking up

8 coming through on our end.

9 MR. KRESS: We can hear you fine.

10 MR. KLAYMAN: Okay. Well, let's see how we do

11 with the witness. I may have to call back on a

12 different phone.

13 THE VIDEOGRAPHER: Okay.

14 Will the court reporter please swear in the

15 witness?

16 THE REPORTER: Will you raise your right hand,

17 please?

18 THE WITNESS: (Complies.)

19

20 CONSTANCE S. RUFFLEY,

21 having been first duly sworn was examined and

22 testified as follows:

23


25 You can proceed.

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1 (No audible response.)

2

3 MS. FALAH: Larry.

4 MR. KLAYMAN: Yes.

5 Who was -- who said "Larry"?

6 MS. FALAH: You can proceed.

7 Did you get --

8 MR. KLAYMAN: Hello.

9 I think we are going to have to call back.

10 MR. KRESS: If that's what you need to do, that's

11 fine.

12 I mean, can you hear me now?

13 MR. KLAYMAN: I can hear you fine. I can't hear

14 the court reporter at all.

15 MR. KRESS: Let's -- let's try and see if it works.

16 MR. KLAYMAN: All right.

17 Let me -- let's -- starting with Ms. Ruffley.

18 We are not communicating really well over the phone.

19 It won't take long.

20 Can you hear me?



23 THE WITNESS: Yes, I can hear you.

24 MR. KLAYMAN: We are going to have to go to

25 another -- we will call in in just a second.

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7
1 MR. KRESS: Okay.


3 Do you want to go off the record, then?

4 MR. KRESS: We will go off the record.

5 THE VIDEOGRAPHER: The time is 9:03 a.m. We are

6 going off the record.

7

8 (At 9:03 a.m., a recess was taken

9 until 9:06 a.m. of the same day.)

10

11 MR. KLAYMAN: Larry Klayman joining the conference

12 again.

13 MR. KRESS: Hi, Larry.


15 MR. KRESS: We are back.

16 Can you hear us now?

17 MR. KLAYMAN: Yeah, hold on.

18 We are seeing if our speaker works. If not,

19 I'm going to call back on the other phone again.

20 Because I think the problem is at your end, frankly.

21

22 (A brief pause in the proceedings.)

23

24 MR. KLAYMAN: Can you hear me?

25 MR. KRESS: Yes.

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1 THE WITNESS: Yes.

2 MR. KLAYMAN: You can?

3 MR. KRESS: Yes, we can hear you.

4 MR. KLAYMAN: Okay. All right.

5 Let's start.

6 MR. KRESS: Wait. The videographer is going to

7 turn the video back on.

8 MR. KLAYMAN: Ms. Ruffley, have you been sworn

9 in?

10 THE VIDEOGRAPHER: Okay. The time is 9:06 a.m.

11 We are now back on the record.

12 MR. KRESS: Larry, the videographer was just

13 speaking. If you could ask your question again.


15

16 EXAMINATION

17 BY MR. KLAYMAN:

18 Q. Ms. Ruffley, have you been sworn in?

19 A. Yes.

20 Q. Okay. Would you please state your name?

21 A. Constance Ruffley.

22 Q. When were you born?

23 A. January 14th, 1944.

24 Q. Where were you born?

25 A. Pasadena, California.

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1 Q. Can you run us briefly through your

2 educational background?

3 A. I graduated from high school in 1961, and I

4 received my B.S./B.M. in 1994.

5 Q. What is an ESBM [sic]?

6 A. It's a Bachelor of Science in Business

7 Management.

8 Q. And where did you receive that degree?

9 A. University of Redlands, California.

10 Q. What did you do after you got that degree?

11 A. The bank I was working for paid for my degree

12 and I continued to work in the bank.

13 Q. Which bank was that?

14 A. Community Bank.

15 Q. Which bank was that?

16 A. Community Bank headquartered in Pasadena,

17 California.

18 MR. KLAYMAN: Can we turn the sound up a bit?

19 You are very faint.

20 MR. KRESS: I don't know if there is --

21 One second, please. Let me see.

22


24

25 MR. KRESS: How does that sound to you now,

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1 Larry?

2 Larry.

3 MR. KLAYMAN: Yes.

4 MR. KRESS: We tried. Let's see how that works.

5 THE VIDEOGRAPHER: Move it closer.

6 THE WITNESS: (Complies.)

7 MR. KLAYMAN: All right.

8 Hold on one second.

9


11


13 MR. KRESS: Hello.

14 MR. KLAYMAN: Yes. Okay. All right.

15 Q. What bank was that, Ms. Ruffley?

16 A. I beg your pardon?

17 Q. What bank did you work for that paid for your

18 education?

19 A. Community Bank headquartered in Pasadena,

20 California.

21 Q. And how long did you stay with the bank?

22 A. Nine years.

23 Q. Who was your immediate supervisor at that

24 bank?

25 A. Richard M. Acu. A-c-u-n-a, with a tilde

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1 over the "n."

2 Q. Is he still there?

3 A. No.

4 Q. And what, if anything, did you do after you

5 left the bank professionally?

6 A. I went to work for Judicial Watch.

7 Q. What was your position at the bank?

8 A. First it was executive secretary, and then

9 legal secretary.

10 Q. What was your duties and responsibilities as

11 legal secretary?

12 A. I helped to write business contracts between

13 the bank and the customers; I did filing for my boss;

14 maintained relationships between --

15 Q. Who was your boss?

16 A. Richard M. Acu.

17 Q. Is he still with the bank?

18 A. No.

19 Q. Where is he located now?

20 A. I'm -- I'm not sure.

21 Q. Have you had any contact with him since he

22 left the bank?

23 A. Yes.

24 Q. When was that?

25 A. The last time was about two years ago.

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1 Q. And what were the circumstances of that

2 contact?

3 A. He was going to be homeless and wanted to know

4 if he could come and live with me and my husband.

5 Q. Do you know someone by the name of Marian

6 Hurley?

7 A. Yes. She's dead.

8 Q. When did she die?

9 A. September 19th of 2009.

10 Q. Was Marian Hurley the person who introduced

11 you to me?

12 A. She introduced -- yes.


14 introduction?

15 A. Mike Pendleton, the director of the San Marino

16 branch of Judicial Watch, was looking for a secretary,

17 and Marian called Mike after he had been there for a

18 month and said, "I know just the person who will be

19 perfect for you. She can write, she can -- has

20 stamina, and she can work all night, if need be."

21 Q. Michael Pendleton was looking for a legal

22 secretary. Correct?

23 A. He was looking for someone to run his office.

24 Q. The office administrator?

25 A. Basically, office administrator.

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1 Q. I didn't hear you. I'm sorry.

2 A. Basically office administrator.

3 Q. Okay. But he also was looking for someone who

4 had legal background. Correct?

5 A. I don't remember that.

6 Q. You do have legal background, as you were a

7 legal secretary for Mr. Acu. Correct?

8 A. Yes.

9 The only reason I was a legal secretary is

10 they had enough executive secretaries, and they were

11 looking to get rid of one of the executive secretaries

12 so they changed my title.

13 Q. Michael Pendleton subsequently left Judicial

14 Watch. Correct?

15 A. Correct.

16 Q. Did you hear my question?

17 A. Yes.

18 Q. Michael Pendleton subsequently left Judicial

19 Watch. Correct?

20 A. Yes.

21 Q. When did he leave Judicial Watch?

22 A. I don't remember exactly.

23 Q. Roughly speaking.

24 A. 2004.

25 Q. About the same time that I left Judicial

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1 Watch. Correct?

2 A. No, you left before.

3 Q. Well, I left in 2003, at the end of 2003.

4 You recollect that, don't you?

5 A. Yes. September 22nd of 2003.

6 Q. Right.

7 In fact, Mr. Pendleton was fired by Judicial

8 Watch because I had hired him. Correct?

9 A. No.

10 Q. When Mr. Pendleton left, you were the one who

11 was in the office most of the time. Correct?

12 A. Yes.

13 Q. I had hired someone by the name of Ernie

14 Norris.

15 You remember that --

16 A. Yes.

17 Q. -- correct?

18 Ms. Ruffley, do you hear my question?

19 A. Yes.

20 MR. KRESS: Her answer was: "Yes."

21 BY MR. KLAYMAN:

22 Q. I had hired someone by the name of Ernie

23 Norris. Correct?

24 A. Yes. And I responded "Yes."

25 Q. Okay. Well, the phone broke up, apparently.

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1 Ernie Norris at some point retired. Correct?

2 A. Not from Judicial Watch.

3 Q. Well, he started to spend most of his time in

4 Wyoming. Correct?

5 A. No.

6 Q. Where is he now?

7 A. In San Marino.

8 Q. How many times -- let's go back a little bit.

9 From -- during 2013, how frequently was

10 Mr. Norris in the office?

11 A. About six months.

12 Q. How many days per week, if any?

13 A. Three.

14 Q. I didn't hear your response.

15 A. Three.

16 Q. Three days?

17 A. Yes.

18 Q. But he wasn't there every week, was he?

19 A. He wasn't there when he was in Wyoming.

20 Q. And he was in Wyoming quite a bit, was he

21 not?

22 A. Half the year.

23 Q. Mr. Norris is not an office administrator, is

24 he?

25 A. No.

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1 Q. Doesn't manage the office, does he?

2 A. No.

3 Q. When did you first -- do you know someone by

4 the name of Orly Taitz?

5 A. Yes.

6 Q. When did you first come to know of her?

7 A. When she was running for Secretary of State of

8 California.

9 Q. And when was that?

10 A. 2008, 2010. I don't recollect exactly.

11 Q. What were the circumstances of your coming to

12 know her?

13 A. I went to a meeting where she was talking

14 about her qualifications for being Secretary of State,

15 and that's when I met her.

16 Q. And at that time did you have discussion with

17 her?

18 A. Just briefly. Just introducing ourselves.

19 That's it.

20 Q. And what was that date again, Ms. Ruffley?

21 A. It was either 2008 or 2010. It was at the

22 Green Hotel in Pasadena, California.

23 Q. Did you offer to assist her in her campaign to

24 become secretary?

25 A. No.

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1 Q. Did there come a point in time when you had

2 further contact with Ms. Taitz?

3 A. Maybe -- I think the only time -- other time

4 I had contact with her was in -- when I had gone to a

5 meeting of the California Coalition for Immigration

6 Reform where she was running as a potential candidate

7 to run against Barbara Boxer's seat as the senator

8 from California.


10 A. February 22nd of 2012. And there was another

11 candidate --

12 Q. Did you --

13 A. Excuse me?

14 Q. Did you speak with Ms. Taitz at that event?

15 MR. KRESS: I think she was -- she didn't quite

16 finish her last answer.

17 THE WITNESS: I was going to say that the other

18 candidate who was speaking that night was Robert

19 Lauten, L-a-u-t-e-n. And the person who

20 videographed -- took the videotape of that gave me a

21 DVD of the presentation.

22 BY MR. KLAYMAN:

23 Q. Did you have a conversation with Ms. Taitz

24 that day?

25 A. Yes.

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1 Q. And what was discussed?

2 A. I don't exactly remember what we were talking

3 about, but --

4 Q. But generally.

5 A. "How are you doing?" "How is things?"

6 Q. At the point that you first met Ms. Taitz at

7 that meeting, you had followed her activities, had you

8 not?

9 A. No.

10 Q. You tracked her -- you followed her on the

11 website, on the Internet?

12 A. Never.

13 Q. You are aware that she has a Internet site

14 called "The World's Leading Obama Eligibility Challenge

15 Web Site"?

16 A. If that's what its name is. I don't remember.

17 Q. And you, from time to time, look at that

18 website, do you not?

19 A. No.

20 Q. You do not believe that President Obama is

21 eligible to be president, do you?

22 A. I don't believe he's eligible.

23 Q. After that second encounter with Ms. Taitz

24 you've had further encounters with you, have you not?

25 A. Once.

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2 A. I think it was the -- in November of 2012.

3 Q. And what happened then?

4 A. I had invited her to speak at UROC, United

5 Republicans of California, and she came.

6 Q. And why did you invite her to speak there?

7 A. Because of her -- I thought it was the

8 authority on Obama's eligibility.

9 Q. Did she ultimately come and speak?

10 A. Yes.

11 Q. Did she speak?

12 A. Yes.

13 Q. And how long was her speech, approximately?

14 A. Oh, half an hour, 45 minutes.

15 Q. You invited Ms. Taitz because you have a high

16 regard for her. Correct?

17 A. Yes.

18 Q. You have never known her to lie, have you?

19 A. No.

20 Q. At that event, did you offer to help her in

21 any way or at any time after that event in her

22 endeavors with regard to eligibility?

23 A. We passed the hat for her, and that was it.

24 Q. Did you offer to help her in any of her

25 activities?

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1 A. No.

2 Q. You have helped her, though, in her

3 activities, have you not?

4 A. I beg your -- would you please repeat the

5 question?

6 Q. You have helped her in her activities, have

7 you not?

8 A. No, I have not helped her in her activities.

9 Q. Did there come a time after November 2012 when

10 you encountered Ms. Taitz?

11 A. I'm sorry. Would you repeat that again?

12 Q. Did there come a time after November 2012 when

13 you had contact with Ms. Taitz?

14 A. No.

15 Q. But you did have contact with her in February

16 2013, did you not?

17 A. Yes.


19 contact?

20 A. I was there with some Judicial Watch

21 materials, which I've often taken down to the CCIR

22 meetings, the regularly-scheduled ones, which this one

23 was, and -- excuse me -- I was down there --

24 Q. What materials did you take?

25 MR. KRESS: I --

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1 THE WITNESS: I can't hear you.

2 MR. KRESS: If I could just --

3 BY MR. KLAYMAN:

4 Q. What materials of Judicial Watch did you take

5 to that meeting?

6 A. Oh, probably copies of the verdict, several

7 issues of them. And I think we had some Judicial Watch

8 note bags, or something like that. But I -- or

9 calendars. We had some leftover calendars, and so I

10 took them down there to share with the -- the people

11 at CCIR.

12 MR. KRESS: Larry, if I could interject.

13 I believe the date that's been stated was

14 actually incorrect, and I don't want there to be a

15 confusion in the record.

16 There was a mention of February of 2013. I

17 believe from all the records the meeting was February

18 of 2012.

19 MR. KLAYMAN: Oh, thank you. Then I misspoke.

20 MR. KRESS: I think it was actually Ms. Ruff- --

21 well, I'm not sure who misspoke. But I believe --

22 just so the record's clear, I think everyone's talking

23 about February of 2012.

24 BY MR. KLAYMAN:

25 Q. So the meeting that dealt with eligibility --

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1 you had a meeting in November of 2012 and then before

2 that February of 2012 where Ms. Taitz was in

3 attendance, Ms. Ruffley?

4 MR. KRESS: I object to the form.

5 But you can answer if you --

6 THE WITNESS: I've -- she appeared at -- in

7 November at the UROC Convention in 2012. And prior

8 to that, the last time that I had seen her before then

9 was when she was at the CCIR meeting in February 22nd

10 of 2012. And I have not --

11 BY MR. KLAYMAN:

12 Q. At that meeting Ms. Taitz was advocating for

13 her candidacy for the U.S. Senate, was she not?

14 A. Yes.

15 Q. And did she also discuss eligibility issues

16 at that time?

17 A. I don't remember.

18 Q. You offered to help her in her senate bid,

19 did you not?

20 A. I did not.

21 Q. Did you help her in her run for the U.S.

22 Senate in any way as a volunteer --

23 A. No.

24 Q. -- personally?

25 A. No.

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1 Q. You were at that -- the CCIR meeting where

2 she advocated her senate candidacy as a representative

3 of Judicial Watch, were you not?

4 A. Who are you talking about, Orly Taitz being a

5 representative of Judicial Watch or me?

6 Q. I'm saying when you went to that meeting at

7 the CCIR with the women's club --

8 A. Yes.

9 Q. -- you were there as a representative of

10 Judicial Watch. I'm not asking you about Orly Taitz.

11 A. Okay. Yes.

12 Q. I'm going to show you what has been -- what

13 I'll ask the court reporter to mark as Plaintiff's

14 Exhibit 10.

15 A. The court reporter is not producing anything.

16 MR. KRESS: Your assistant is.

17 MR. KLAYMAN: Okay. Well --

18 MR. KRESS: And if -- Larry, if you remember, we

19 did the exhibits consecutively, so there's already an

20 Exhibit 10. I think we are on --


22 MR. KRESS: -- we are on 29, if you don't mind

23 marking it 29.

24 MR. KLAYMAN: Fine. Then we will make it

25 Plaintiff's Exhibit 29.

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1 Naveed, would you please hand that to the

2 court reporter so Ms. Ruffley can have a copy.

3 MR. MAHBOOBIAN: (Complies.)

4

5 (Exhibit 29 was marked

6 for identification.)

7

8 MR. KRESS: She has the exhibit.

9 BY MR. KLAYMAN:

10 Q. Exhibit 29 is a Declaration Under Penalty of

11 Perjury of Constance S. Ruffley, is it not?

12 A. Yes.

13 Q. This is your affidavit that was submitted in

14 the lawsuit that you are here on today; correct?

15 A. Yes.


17 BY MR. KLAYMAN:

18 Q. Klayman v. Judicial Watch.

19 A. (No audible response.)

20 Q. Correct?

21 A. I'm sorry. Would you repeat the question?

22 Q. This is an affidavit which was submitted on

23 your behalf in the lawsuit that you are appearing on

24 today, Klayman vs. Judicial Watch. Correct?


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1 But you can answer.

2 THE WITNESS: It says -- not an affidavit, it says

3 "Declaration of -- under Penalty of Perjury."

4 MR. KLAYMAN: Okay. Let's call it a declaration.

5 Q. Correct?

6 A. Yes.

7 Q. You signed this declaration under oath.

8 Correct?

9 A. Yes.

10 Q. Do you know what it means, "under oath"?


12 Q. Do you know what being under oath means?

13 A. Right. To tell the truth, the whole truth,

14 and nothing but the truth, so help me God.

15 Q. Thank you.

16 All right. Turn your attention to Paragraph

17 3.

18 Well, take a look at Exhibit 29. That is the

19 declaration which was submitted. Right? That's --

20 A. Yes.

21 Q. -- that's accurate?

22 Okay. Turn to Paragraph 5.

23 A. (Witness complies.) All right.

24 Q. Where it states, "It is my understanding that

25 Larry Klayman has sued me, Judicial Watch, Inc., and

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1 other Judicial Watch, Inc. employees alleging that we,

2 on or about February 22nd, 2012, negligently,

3 maliciously and/or willfully published and furthered

4 the publication of a false statement that Plaintiff

5 Klayman had been 'convicted' of a crime for not paying

6 a large amount of child support with regard to his

7 children, on the Internet and elsewhere within this

8 judicial district, Florida, and elsewhere throughout

9 the United States and the world," unquote.

10 Is that a true statement?

11 A. I object to the word "convicted" because I

12 can't remember whether I said "convicted" or, um,

13 "indicted."

14 Q. In fact, you also told Orly Taitz, did you

15 not, whether or not you can remember using the word

16 "convicted" or "indicted," that this information that

17 you were providing to her should be given to Klayman's

18 donors. Correct?

19 A. What about Klayman's donors?

20 Q. You told Ms. Taitz, did you not, whether or

21 not you used the word "convicted" or "indicted," which

22 you say you can't remember --

23 A. Correct.

24 Q. -- the information about Klayman not paying

25 child support in Ohio should be given to donors.

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1 Correct?

2 A. No.

3 Q. All right. I'll turn your attention to what's

4 been marked as Exhibit 2.

5



8

9 BY MR. KLAYMAN:

10 Q. This is the eligibility website of Orly Taitz,

11 a reprint, is it not?

12 A. I'm being handed this by your assistant,

13 Naveed.

14 Q. All right. Take a look at it. Take your

15 time.

16 The question is: This is a reprint of what

17 appeared on Orly Taitz's website on February 23rd,

18 that website called "World's Leading Obama Eligibility

19 Challenge Web Site." Correct?

20 A. That's what it says.

21 MR. KRESS: Okay. Just -- the court reporter is

22 looking confused.

23 We actually have -- we have exhibits --

24 MR. KLAYMAN: I don't care whether the court

25 reporter is confused or not.

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1 MR. KRESS: Well, I --

2 MR. KLAYMAN: Please don't put colloquy in the

3 record now.

4 MR. KRESS: No, no. No. She's --

5 MR. KLAYMAN: Just let me get an answer, and let

6 me move on.

7 MR. KRESS: No, Larry, I'm just trying to clarify

8 something. Your -- because your office is marking this

9 as Exhibit 30. I just want to make sure everyone --

10 MR. KLAYMAN: Oh, no. It's --

11 MR. KRESS: It's already marked as Exhibit 2.

12 MR. KLAYMAN: It's Exhibit 2. Please don't do

13 that.

14 MR. KRESS: Okay. That's -- that's all right.

15 That's it.

16 MR. KLAYMAN: That's all right.

17 MR. KRESS: We don't know what the question is.

18 MR. KLAYMAN: Third paragraph.

19 Q. "Ms. Ruffley actually advised me that Larry

20 Klayman is not licensed in California. She told me

21 that he no longer works with the Judicial Watch and

22 that donors should know about litigation in Ohio, where

23 he was convicted just recently of not paying large

24 amount in child support. She provided a lot of other

25 information. I will publish only what is in the public

631
29
1 record. I'm not publishing anything that is not in the

2 public record."

3 That's an accurate statement of what you told

4 Ms. Taitz. Correct?

5 A. I never said any -- no, it's not correct.

6 Because where it says that "donors should know about

7 litigation in Ohio."

8 Q. It says, "She provided a lot of other

9 information."

10 What other information did you provide to

11 Ms. Taitz?

12 A. The only other information that I provided is

13 that you are not licensed in the State of California.

14 I told her about the issue of the -- the child support.

15 And also there was the issue -- excuse me -- of a

16 lawsuit that was down in Florida.

17 Q. Was that an eligibility lawsuit for Michael

18 Dolz?


20 Q. But it was an eligibility lawsuit. Correct?


22 Q. Well, what was the subject matter of the

23 lawsuit?

24 A. Basically, that you had taken money for a

25 lawsuit and not performed.

631
30
1 Q. You offered information to Ms. Taitz about

2 this, did you not?

3 MR. KRESS: I'm going to object to the form.

4 You can answer.

5 THE WITNESS: I told Ms. Taitz only what could be

6 found on the Internet. I told her nothing else.

7 BY MR. KLAYMAN:

8 Q. You told her what could be found in the public

9 record. Correct?

10 A. Correct.

11 Q. Did you say "Yes"?

12 A. Yes.

13 Q. And the public record would include court

14 files. Correct?

15 A. Well, as I found it on the Internet, it was

16 not in the court files. It was public information.

17 And she had the ability to look up those -- those

18 things on the Internet herself.

19 Q. And you gave her that information -- you

20 volunteered that information. She didn't ask you for

21 it. Correct?

22 A. Yes.

23 Q. And you did that because you were trying to

24 help Ms. Taitz?

25 A. No.

631
31
1 Q. You did that because you were trying to hurt

2 me, Larry Klayman. Correct?

3 A. No.

4 Q. So you just gave the information because it

5 came to your head in some kind of epiphany?


7 You can answer.

8 BY MR. KLAYMAN:

9 Q. Is that the reason?

10 A. No.

11 Q. You did it because you thought it would curry

12 favor with the directors of Judicial Watch, Mr. Fitton

13 and Mr. Orfanedes --

14 A. Absolutely.

15 Q. -- to follow which had been adverse to me.

16 Correct?

17 A. No.

18 Q. Then why did you do it?

19 A. Because she asked me.

20 Q. You just told me you volunteered the

21 information. Which is right, she asked you or you

22 volunteered it?


24 You can answer.

25 THE WITNESS: Would you mind repeating the

631
32
1 question again? Whether I volunteered it, or --

2 BY MR. KLAYMAN:

3 Q. You previously testified in this deposition

4 under oath that you volunteered the information in

5 this case.

6 A. Yes.

7 Q. That's correct, is it not?

8 A. That's because she asked me.

9 Q. What did she ask you?

10 A. She asked me if you were still with Judicial

11 Watch. And I told her no.

12 Q. But she didn't ask you about my children, and

13 she didn't ask you about whether I was licensed in

14 California, did she?

15 A. I did not provide her any information that

16 was not available on the Internet.

17 Q. But the question --

18 A. This was a completely private conversation

19 between the two of us, and it was not to be -- I did

20 not have any expectation of her putting it out there

21 on the web.

22 MR. KLAYMAN: Non responsive. Move to strike.

23 Q. In fact, she didn't ask you about my children,

24 and she didn't ask you about my being licensed in

25 California, did she?

631
33
1 A. No.

2 Q. And, in fact, I had already left Judicial --

3 in 2012, in February 2012, I had been gone from

4 Judicial Watch eight to nine years. Correct?

5 A. Could have been.

6 Q. So you didn't have any -- and you didn't have

7 any contact with me in those years, did you?

8 A. No.

9 Q. So you would have no way of knowing whether I

10 had become licensed in California or not when you said

11 that to Ms. Taitz. Correct?

12 A. I would know whether you were not licensed

13 because I -- anyone can go to the State Bar and look up

14 and plug in a name and see if that person is licensed

15 in California or not.

16 Q. But you hadn't done that before telling

17 Ms. Taitz that I was not licensed in California.

18 Correct?

19 A. Wrong. Because I did look it up, and you were

20 not licensed.

21 Q. When did you look it up? Afterwards? After

22 you had the conversation with Taitz?

23 A. Prior to that.

24 Q. Why did you bother to look it up?

25 A. Because I wanted to see if you had become

631
34
1 licensed at some point.

2 Q. And why was that?

3 A. Just because I wanted to know.

4 Q. Because you didn't want me representing anyone

5 with regard to eligibility, did you?

6 A. No.

7 Q. Because you wanted to try to hurt me.

8 Correct?

9 A. No.

10 Q. Then what business was it of yours?


12 You can answer.

13 THE WITNESS: Would you mind restating the

14 question properly?

15 BY MR. KLAYMAN:

16 Q. What business was it of yours whether I was

17 licensed in California or not?


19 You can answer.

20 THE WITNESS: If I want to look up anyone, I

21 can -- there's nothing that prohibits me from looking

22 up someone's name in the State Bar.

23 BY MR. KLAYMAN:

24 Q. Then I'm asking you why you did it, then.

25 What caused you to do it?

631
35
1 MR. KRESS: Objection to the form. Asked and

2 answered.

3 You can answer it one more time.

4 THE WITNESS: Because I had looked it up several

5 years before, maybe once a year, something like that,

6 and this was just something that happened.

7 BY MR. KLAYMAN:

8 Q. Why bother looking it up if I'm not with

9 Judicial Watch anymore?

10 A. Why not?

11 Q. What caused you to look up any situation with

12 regard to my kids?


14 You can answer.

15 THE WITNESS: It was just one of the things that

16 happened to pop up.

17 BY MR. KLAYMAN:

18 Q. In fact, Ms. Taitz [sic], you were aware that

19 I had been in litigation with Judicial Watch and its

20 directors before you met with Ms. Taitz on

21 February 22nd, 2012. Correct?

22 A. You addressed me as Ms. Taitz.

23 Q. Ms. Ruffley.

24 A. Restate the question, please.

25 Q. In fact, you knew at the time that you met

631
36
1 with Ms. Taitz on February 22nd, 2012 that I, Larry

2 Klayman, had been in various litigations with Judicial

3 Watch and its directors. Correct?

4 A. Yes.

5 Q. And you knew that we were adverse to each

6 other. Correct?


8 You can answer.

9 THE WITNESS: Yes.

10 BY MR. KLAYMAN:

11 Q. And that was the basis for your looking up

12 whether I was licensed in California and in order to

13 be able to get information about my children. Correct?


15 You can answer.

16 THE WITNESS: No.

17 BY MR. KLAYMAN:

18 Q. The Judicial Watch directors asked you to

19 track me, did they not?

20 A. No.

21 Q. You conveyed the information about my not

22 being licensed in California and the information that

23 you claimed pertains to my children to the directors

24 of Judicial Watch, though, didn't you?

25 A. No.

631
37
1 Q. You never talked to them about my being

2 licensed in California?

3 A. No.

4 Q. Or my children?

5 A. No.

6 Q. Why is it, then, that you gave this

7 information to Ms. Taitz?

8 MR. KRESS: I object to the form. Asked and

9 answered.

10 You can answer it one more time.

11 THE WITNESS: Well, I had an expectation of

12 privacy with Ms. Taitz. And, in fact, she said that

13 she was going to call me the next morning, and I've

14 never heard from her since. Well, except for when I

15 invited her to speak at UROC.

16 BY MR. KLAYMAN:

17 Q. And why did you have an expectation of

18 privacy?

19 A. Because the conversation was between she and

20 myself, and there weren't any other people around.

21 Q. But that doesn't answer the question.

22 Why did you give her the information, apart

23 from expectations of privacy?

24 MR. KRESS: I object to the form. Asked and

25 answered.

631
38
1 You can answer.

2 THE WITNESS: I still just had the expectation of

3 privacy that it would be just information between

4 herself and myself. I had no idea that she would have

5 ever put that up there on her website.

6 BY MR. KLAYMAN:

7 Q. Why did you -- why did you give her the

8 information?

9 A. I --

10 Q. I'm not talking about expectations of privacy.

11 Why --

12 A. So that she could --

13 Q. -- did you give her the information?

14 A. So that she could look it up for herself.

15 Q. And why did you want her to look it up for

16 herself?

17 A. To make sure that what I said was correct.

18 Q. Ms. Ruffley, we will stay here for hours.

19 I will get an answer to this question. So you can

20 answer it now. Do you want to go two hours more on it?

21 I will ask it for two hours.

22 MR. KRESS: What question is before her?

23 BY MR. KLAYMAN:

24 Q. Why did you give her the information?

25 MR. KRESS: She just answered that question.

631
39
1 THE WITNESS: So that she -- I gave her the

2 information and told her where she could find it on --

3 excuse me. I didn't tell her where she could find it

4 on the web. But if she did a Google search, she would

5 have been able to find it.

6 BY MR. KLAYMAN:


8 MR. KRESS: Maybe you can ask your question

9 differently. Because --

10 MR. KLAYMAN: No, she understands what I said.

11 She's highly educated. She has a college degree. She

12 was a legal secretary. She understands what I said.

13 I'm asking it the way I want to answer it -- ask it.


15 MR. KRESS: Objection.

16 You can answer.

17 THE WITNESS: So that she could look it up for

18 herself and make sure that the information was correct.

19 I believe in giving correct information, not lies or

20 innuendos or anything else.

21 BY MR. KLAYMAN:


23 A. I just told you --

24 MR. KRESS: We are going to have to --

25 She has answered the question.

631
40
1 MR. KLAYMAN: Oh, you didn't give me the

2 information.

3 Q. So she could look it up. What was the

4 underlying purpose of giving her the information so she

5 could look it up on the Internet?

6 A. So that she would have the correct

7 information.

8 Q. For what reason?

9 MR. KRESS: I don't know how many times she can

10 tell you.

11 BY MR. KLAYMAN:

12 Q. For what reason?

13 MR. KRESS: If you have any different answer, you

14 can give it to him. But --

15 THE WITNESS: I don't have a different answer.

16 You can say that all day long if you want to

17 say "And for what reason," and it's not going to help.

18 BY MR. KLAYMAN:

19 Q. You do not want to answer the question; do

20 you, Ms. Ruffley?


22 Q. You do not want to answer this question, do

23 you?

24 A. I believe I've answered the question three or

25 four times already.

631
41
1 Q. I'm asking you -- the underlying question

2 is --

3 A. You don't -- you are not asking me an

4 underlying question, you are asking me about the same

5 thing --

6 Q. I'm asking information about anything that she

7 could look up on the Internet, why did you do it?

8 I'm not asking about her looking it up on the

9 Internet --

10 MR. KRESS: This is getting --

11 BY MR. KLAYMAN:

12 Q. -- I'm asking about what was the reason that

13 you gave her that information; what was in your mind

14 why you gave it to her.

15 MR. KRESS: Is that a different question, or do

16 you have --

17 THE WITNESS: Is that a different question?

18 MR. KLAYMAN: No, it's the same question. But

19 you can answer it.

20 MR. KRESS: This is getting close to the point of

21 just being harassing. She's been answering the

22 question. You don't like the answer, but that's not

23 her problem.

24 MR. KLAYMAN: That's your problem, not mine.

25 MR. KRESS: Well, we will see about that.

631
42
1 BY MR. KLAYMAN:

2 Q. Answer the question, Ms. Ruffley.

3 MR. KRESS: Are you asking her -- you have asked

4 her if she was intending to harm you. She said no.

5 MR. KLAYMAN: I don't want the testimony. That's

6 inappropriate.

7 MR. KRESS: Well, you --

8 MR. KLAYMAN: I'll phrase it --

9 Will you, Madam Court Reporter, please read my

10 last question back.

11 Thank you.

12

13 (Whereupon, the record was read

14 by the reporter.)

15

16 MR. KLAYMAN: Please answer that.

17 THE WITNESS: Because she asked me about you.

18 BY MR. KLAYMAN:

19 Q. What did she ask you?

20 A. She asked me what I knew about you.

21 Q. Did she say why she asked me [sic] what you

22 knew about me?

23 A. No.

24 Q. The time that you gave Ms. Ruffley that

25 information, you knew that Orly Taitz had an

631
43
1 eligibility website. Correct?

2 A. No.

3 Q. You were very knowledgeable about eligibility

4 issues, though, were you not?

5 A. Probably more than the average person.

6 Q. You are telling me that you would look up

7 whether I was a California lawyer and about my children

8 on your own, but you never looked at Orly Taitz's

9 eligibility website --

10 A. No.

11 Q. -- up to the point --


13 BY MR. KLAYMAN:

14 Q. -- of November 22nd, 2012? Is that what you

15 are saying?


17 You can answer it.

18 THE WITNESS: Would you restate the question,

19 please?

20 MR. KLAYMAN: Please read it back.

21

22 (Whereupon, the record was read

23 by the reporter.)

24


631
44

2 THE WITNESS: No, I never looked up her website.

3 BY MR. KLAYMAN:

4 Q. But you knew she had a website?

5 A. I don't believe I did.

6 Q. Based on your experience in public interest

7 activities and politics, you are aware that nearly all

8 people have websites these days. Correct?

9 A. Yes. A lot of people do. I don't.

10 Q. People that are running for the U.S. Senate

11 have websites. Correct?

12 A. I'm not sure whether all people do or not.

13 I don't know.

14 Q. Well, any credible candidate would have one.

15 Correct?


17 You can answer, if you know.


19 BY MR. KLAYMAN:

20 Q. You are aware that Ms. Taitz is an activist,

21 a conservative activist, in addition to having run for

22 the U.S. Senate. Correct?

23 A. Yes.

24 Q. Conservative activists generally have websites

25 so they can communicate with the public. Correct?

631
45
1 A. I don't know.

2 Q. You didn't tell Ms. Taitz not to publish the

3 information that you gave her on the Internet, did you?

4 A. She said she would call me the next day.

5 Q. You did not tell Ms. Taitz not to publish

6 the information you gave her about me on the Internet,

7 did you?

8 A. No, I did not. Because I had -- I had

9 anticipated that the conversation was just between

10 the two of us, and that was it. And that if she wanted

11 to do any further research, she could do that on her

12 own.

13 And I object to your inserting your children

14 into this. I -- the only reason I mentioned that was

15 because it happened to pop up on one of the searches

16 that I did. And that was about Cuyahoga County,

17 et cetera. And that's where your children came in.

18 But I did not deliver --

19 Q. Before your deposition today, this morning,

20 you met with the lawyer for Judicial Watch in this

21 lawsuit and Mr. Orfanedes its director, one of its

22 directors. Correct?

23 A. Yes.

24 Q. And you discussed your testimony today, did

25 you not?

631
46

2 THE WITNESS: No.

3 BY MR. KLAYMAN:

4 Q. I didn't hear your response.

5 A. No.

6 Q. You didn't discuss anything about your

7 testimony today?

8 MR. KRESS: I'm going to object to the extent you

9 are getting into or very close to the attorney-client

10 privilege.

11 MR. KLAYMAN: No, I'm -- you know, Doug, I'm not

12 getting into that. I'm just identifying whether there

13 was a discussion. I'm not asking for the content.

14 MR. KRESS: Okay. If you want to know whether

15 there's a discussion, you can -- you can inquire.


17 Q. You had a discussion about your testimony

18 today, did you not, earlier before this deposition

19 began with Mr. Kress and Mr. Orfanedes?

20 A. Maybe two minutes.

21 Q. Was your response "two minutes"?

22 A. Yes.

23 Q. Okay. But you had discussions before today

24 with one or both of them. Correct?

25 A. Yes.

631
47
1 Q. And when did you have discussions with him

2 about your testimony?

3 A. Again --

4 MR. KRESS: You can answer, but don't give him

5 any of the substance.

6 THE WITNESS: Yesterday.

7 BY MR. KLAYMAN:

8 Q. How long was your discussion?

9 MR. KRESS: You can answer that.

10 THE WITNESS: Approximately two hours.

11 BY MR. KLAYMAN:

12 Q. The affidavit which has been marked as

13 Exhibit 29, you didn't actually draft it, did you?

14 A. Parts of it, yes.

15 Q. Who presented to you the first draft of it?

16 MR. KRESS: I object --

17 THE WITNESS: I don't remember.

18 MR. KRESS: And I will just object along this line

19 to be careful not to reveal confidential communications

20 with any lawyers.

21 BY MR. KLAYMAN:

22 Q. Was it Mr. Orfanedes who sent it to you?


24 Q. But you do have a computer at Judicial Watch?

25 A. Yes.

631
48
1 Q. And have you deleted any communications

2 concerning this lawsuit from that computer?

3 A. No.

4 Q. Did you check your computer today about --

5 A. No, because I didn't go in the office.

6 Q. -- the various documents that were relevant to

7 this case?

8 A. No.

9 Q. Have you ever checked your computer in that

10 regard?

11 A. No.

12 Q. Have you ever checked your computer in that

13 regard?

14 A. No.

15 Q. I'm going to ask you to check your computer in

16 that regard, Ms. Ruffley. Because there were documents

17 that were requested by me from Judicial Watch, and

18 obviously you are at the eye of the hurricane here.

19 MR. KRESS: Well, when you say "in that regard,"

20 that's a little broad and open-ended.

21 I will -- so, as you know, we've objected to

22 numerous document requests.

23 MR. KLAYMAN: No, I understand. But, obviously,

24 she should have done a search for the documents, so I'm

25 asking that a search be conducted.

631
49
1 THE WITNESS: Well, the search was not conducted

2 because there weren't any documents related to this.

3 MR. KLAYMAN: Well, you just testified --

4 Ms. Ruffley, you are under oath. Okay? So let me ask

5 the questions.

6 THE WITNESS: I remember that I'm under oath.

7 MR. KLAYMAN: I'm not asking for gratuitous PYA

8 responses when I don't have a question pending.

9 MR. KRESS: Please be polite to the witness.

10 MR. KLAYMAN: Excuse me?

11 MR. KRESS: I -- I -- I don't think we need to

12 engage in this.

13 MR. KLAYMAN: Well, I used an acronym. It's not

14 appropriate for her to inject stuff before questions

15 are made.

16 MR. KRESS: Please move on.

17 BY MR. KLAYMAN:

18 Q. You just testified that you hadn't checked

19 your computer. So I'm asking you politely and

20 courteously to check your computer.

21 MR. KRESS: I will confer with Ms. Ruffley, and

22 we will be sure to do that.

23 BY MR. KLAYMAN:

24 Q. Let's turn to Paragraph 7.

25 A. (Witness complies.)

631
50
1 MR. KRESS: This is of the declaration. Correct?

2 MR. KLAYMAN: The affidavit of the 29th.

3 THE WITNESS: Declaration.

4 MR. KLAYMAN: Declaration.

5 Q. "On or about February 22, 2012, I attended the

6 monthly meeting of the California Coalition for

7 Immigration Reform in Garden Grove, California.

8 Orly Taitz was one of the speakers at the meeting.

9 I am familiar with Orly Taitz. Ms. Taitz is a

10 California resident who was, at the time, running on

11 the primary ballot for one of the California seats on

12 the United States Senate.

13 "After the meeting, I was seated at an

14 information table for Judicial Watch, displaying

15 various forms of Judicial Watch literature. Orly Taitz

16 approached me and we discussed a number of issues.

17 We eventually discussed Larry Klayman. The only

18 information that I conveyed to Ms. Taitz about Larry

19 Klayman was information that I had learned from public

20 records, including information related to court

21 proceedings for failure to pay child support."

22 In reference to public records, you were not

23 talking about the Internet, were you?

24 A. Yes, I was talking about the Internet.

25 Q. You were talking about court records, were you

631
51
1 not?


3 THE WITNESS: No.

4 BY MR. KLAYMAN:

5 Q. In fact, you had gone into court records in

6 Cleveland, Ohio with regard to my custody proceeding

7 with my children. Correct?

8 A. No.

9 Q. In fact, you have a tremendous curiosity about

10 me -- don't you, Ms. Ruffley -- at a minimum?

11 A. Morbidly.

12 Q. What do you mean by "morbidly"?

13 A. You are an interesting person. I just wanted

14 to keep abreast of what your dealings were.

15 Q. And that's morbid. Correct?



18 THE WITNESS: Well, I'm sorry. That was probably

19 an offhand word. But, uh, just a curiosity.

20 BY MR. KLAYMAN:

21 Q. You don't usually use offhand words, do you?

22 A. Yes.

23 Q. Paragraph 8, "My expectation was that Orly

24 Taitz would not restate my comments to any other person

25 or entity."

631
52
1 In fact, you didn't know one way or the other

2 whether Orly Taitz would restate your comments --

3 A. I had no --

4 Q. -- to anyone else or the public, did you?

5 A. I had no way of knowing whether she would.

6 And I never gave her permission to restate my comments

7 to any other person or entity.

8 Q. But you never told her not to. Correct?

9 A. I thought that that was understood.

10 Q. You are aware that Orly Taitz communicates

11 with the public on the Internet?

12 A. I do now.

13 Q. And you are aware that she communicates in

14 public by either giving speeches like she gave at the

15 Garden Grove Women's Club --

16 A. She --

17 Q. -- or that she gave earlier at UROC?

18 A. She gave her candidacy for U.S. Senator. And

19 Robert Lauten was there and another candidate who gave

20 his statements for running for Barbara Boxer's seat.

21 Q. So you are aware that Orly Taitz's activities

22 as a U.S. senator candidate requires her to communicate

23 with the public. Correct?

24 A. Well, if that's what you have to do to run,

25 yes.

631
53
1 Q. Let's look at Paragraph 9. "The information

2 that I conveyed to Orly Taitz was gathered through my

3 own independent research. No one from Judicial Watch

4 advised me of this information or instructed me to

5 convey the information to Orly Taitz."

6 A. That's true.

7 Q. And your independent research entailed looking

8 in court records in Cleveland, Ohio about Larry Klayman

9 and his children. Correct?



12 THE WITNESS: No. There's no way that you can get

13 into the -- the court records in any court.

14 BY MR. KLAYMAN:

15 Q. Subsequent to your making these statements

16 that are the subject of this lawsuit to Ms. Taitz,

17 you have researched and learned that I was not

18 convicted of any crime for nonpayment of child support.

19 Correct?

20 A. Convicted, indicted. I don't know.

21 Q. I'm talking about convicted.

22 A. I don't know when I used the word "convicted"

23 or "indicted."

24 Q. I'm not even asking you what word you used at

25 this point. We have already been over that.

631
54
1 You are aware today that I was never convicted

2 of any crime. Correct?

3 A. True. Yes, I am aware that you --

4 Q. How did you learn that?

5 A. Pardon?

6 Q. How did you learn that?

7 A. That you were not convicted of any crime?

8 Q. Correct.

9 A. It's on the Internet.

10 Q. Where on the Internet did you find that?


12 Q. You went into the court records of the

13 Cleveland family court and found out that I was not

14 convicted of any crime. Correct?

15 A. I went onto the Internet and found that.

16 It was not in the court records.

17 Q. You looked in the court records, though,

18 didn't you?

19 A. No.

20 Q. Did you make any effort before you made the

21 statement that I was convicted to determine

22 definitively whether I was convicted or not?


24 But you can answer it.

25 You can answer if you know the -- if you

631
55
1 understand the question and you know the answer.

2 THE WITNESS: I don't know about any convictions.

3 BY MR. KLAYMAN:

4 Q. You have never known about any convictions,

5 have you?

6 A. No.

7 Q. Did you tell anyone at Judicial Watch after

8 you gave this information to Ms. Taitz that you had

9 talked to her about me?

10 A. No.

11 Q. You are aware that I ran for the U.S. Senate

12 in Florida?

13 A. Yes. That's why you left Judicial Watch.

14 Q. You are aware that I've been involved in

15 many lawsuits involving Fidel Castro for the Cuban

16 community in Miami?

17 A. Somewhat, yes.

18 Q. You are aware that I traveled while at

19 Judicial Watch to Europe to lobby on behalf of

20 victims of Castro?

21 A. Yes.

22 Q. You are aware that I was involved while at

23 Judicial Watch with trying to help the Elian Gonzalez

24 family?

25 A. Sure. You brought Donato Dalrymple out, who

631
56
1 was holding Elian Gonzalez when he was -- when Elian

2 was stripped from his arms.

3 Q. In fact, shortly after 9/11 occurred in 2001,

4 I took a trip to Belgium -- you remember, do you not --

5 to have Fidel Castro and others indicted for crimes

6 against humanity?

7 A. Somewhat.

8 Q. And after that happened, we had a -- a

9 judicial international conference in Miami when I

10 returned from Belgium. Correct?

11 A. Yes. I was there.

12 Q. Right.

13 And you were aware that Miami is my home town.

14 Correct?

15 A. I'm not exactly aware of that.

16 Q. You are aware that I lived in Miami many

17 years?

18 A. Yes.

19 Q. You are aware that I began my legal career

20 there?

21 A. Yes.

22 Q. You are aware that the eligibility lawsuits

23 that I brought were in Florida?

24 A. Not really.

25 Q. You -- you had become aware of that, though,

631
57
1 haven't you?

2 A. Not completely.

3 Q. I couldn't hear your response.

4 A. Not completely.

5 Q. But partially?

6 A. Partially.

7 Q. I was the founder of Judicial Watch, was I

8 not?


10 You can answer.


12 BY MR. KLAYMAN:

13 Q. You have a high regard for me, don't you?

14 A. On a personal level, yes.

15 Q. And you're aware that I was always nice to

16 you, wasn't I?

17 A. Always.

18 Q. And I was nice to other people in the San

19 Marino office --

20 THE REPORTER: Pardon me. Repeat that.

21 BY MR. KLAYMAN:

22 Q. -- correct?

23 MR. KRESS: I think he said, "I was nice to other

24 people in the San Marino office."

25 THE WITNESS: Yes. Yes.

631
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1 BY MR. KLAYMAN:

2 Q. And that I would come out there frequently to

3 visit to make sure that the office was running in a

4 productive way?

5 A. That you would come out and visit when you had

6 other things to do. But I don't remember, you know,

7 coming out to make sure that it was being run properly.

8 I remember on a personal level when I was

9 going through the cancer -- it was the chemo and the

10 radiation back in September through May of 2002 that

11 you, as head of Judicial Watch -- that there was a

12 beautiful bouquet from the most expensive florist in

13 town. And it was gorgeous. And it said on the card,

14 "From your friends at Judicial Watch."

15 And two days later, I received a second

16 bouquet from the same expensive florist that said,

17 "From Larry Klayman and your friends at Judicial

18 Watch."

19 Q. I appreciate that, Ms. Ruffley. I wish you

20 well. I want you to know that.

21 A. Thank you. I'm still here.

22 Q. How is your health today? You don't have to

23 tell me, but I hope it's well.

24 A. It's well. Thank you.

25 Q. You don't have to answer that.

631
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1 A. I thought I did.

2 Q. Okay. All right.

3 Is it good?

4 A. Yes. Thank you.

5 Q. I hope so. Okay.

6 Are you aware that I asked after the

7 statements were published by Ms. Taitz, the ones that

8 we are here on today, that I asked Judicial Watch and

9 its lawyers to correct those statements?

10 A. Did -- are you asking whether Mr. Kress and

11 Mr. Orfanedes asked me to correct any statements?

12 Q. No.

13 Are you aware that shortly after the

14 February 22nd, 2012 meeting --

15 A. Right.

16 Q. -- with Ms. Taitz that I asked Judicial Watch

17 to correct those statements?

18 A. I'm not aware of that.

19 Q. Did you have any contact with anyone by the

20 name of Richard Driscoll after February 22nd, 2012?

21 A. That name is completely unfamiliar to me.

22 Q. Did anyone from Judicial Watch after

23 February 22nd, 2012, before this litigation was filed

24 that you are here on today, ask you whether you had

25 made those statements to Ms. Taitz?

631
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1 A. No.

2 Q. Was the answer "No"?

3 A. Correct.

4 Q. Have you ever had discussions with Mr. Fitton

5 about the statements that you are here on today that

6 were published by Ms. Taitz on her website?

7 A. No. The only communications I had with

8 Mr. Fitton are a beautiful Christmas card every

9 Christmas. And that's it.

10 Q. Otherwise, you don't talk to him at all?

11 A. Nuh-uh. Right. I do not speak with him at

12 all.

13 Q. And you have not spoken with him since I left

14 Judicial Watch?

15 A. That's not entirely correct.

16 I have -- as a daughter of the American

17 Revolution, I have gone back to Continental Congress in

18 Washington, D.C. where I was a part of the -- where I

19 was Vice Chairman of the National Resolutions

20 Committee. And, as such, I would have a little time

21 off, and so I would go over to Judicial Watch

22 headquarters and visit.

23 So I would spend maybe five minutes with each

24 person such as, you know, Mr. Orfanedes and Mr. Fitton

25 and Mr. Farrell if they were in the offices. And

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1 Mr. -- but it was just chitchat. I don't -- and that's

2 it. Your name never came up.

3 Q. Did you ever talk to Mr. Orfanedes about the

4 statements that Ms. Taitz published on her eligibility

5 website concerning me?

6 A. No.

7 Q. Did you ever talk to Mr. Farrell about them?

8 A. No.

9 Q. Did you ever talk to anyone at Judicial Watch

10 about the statements that Ms. Taitz published on the

11 website about me?

12 A. No.

13 Q. Did you?

14 A. No, I do not -- did not, have not.

15 Q. If I was not convicted of a crime, are you

16 sorry that this wound up on Ms. Taitz's website?


18 MR. KLAYMAN: I'll withdraw the question.

19 THE WITNESS: Did you say you withdrew the

20 question?

21 MR. KRESS: Right.

22 MR. KLAYMAN: I'll withdraw this question.

23 THE WITNESS: Thank you.

24 BY MR. KLAYMAN:

25 Q. The -- I'll turn your attention to Exhibit 9.

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1 MR. KLAYMAN: If my colleague would put that in

2 front of you or your attorney.

3 THE WITNESS: It's still here.

4 MR. KRESS: No, that's a different one.

5 THE WITNESS: Oh. I'm sorry.

6 MR. KRESS: This one (indicating).

7



10

11 THE WITNESS: Okay. I'm looking at something that

12 says Driscoll Seltzer dated March 5th of 2012. It's

13 addressed to you --

14 MR. KLAYMAN: Right.

15 Q. I want to turn your attention to a document

16 that is labeled "Judicial Watch, Bates No. 000508."


18 Q. Do you see that?

19 A. Okay.

20 Q. That's an e-mail that you sent to Tom Fitton,

21 Paul Orfanedes, and Chris Farrell --

22 A. Right.

23 Q. -- correct?

24 Okay. It says, "From my sister-in-law."

25 A. Right.

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1 Q. And then the subject is, "Judge orders

2 eligibility attorney to stay away."

3 Who is your sister-in-law?

4 A. Carolyn Kwan Sloan.

5 Q. It says, "Klayman is at it again!"

6 Exclamation point.

7 You meant that in a negative way?

8 A. I don't know. Because I don't know what this

9 thing is where it says, "Judge orders eligibility

10 attorney to stay away."

11 Q. Why did you write to the judicial directors,

12 "Klayman is at it again!" exclamation point?

13 A. I don't know. I don't remember.

14 Q. You were trying to curry favor with them,

15 were you not --


17 BY MR. KLAYMAN:

18 Q. -- the Judicial Watch directors?

19 A. No.

20 Q. It says, "Read if you are interested. The

21 truly disturbing thing, however, is that the judge

22 DID," capital DID, "refer to a fictitious movie to make

23 his ruling!!" double exclamation point.

24 A. Right.


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1 A. Yes, I see it.

2 Q. You were disturbed that the judge had made

3 a -- a stupid ruling about something that was a

4 fictitious movie. Right?


6 You can answer.

7 THE WITNESS: Yeah. I mean, when a judge makes a

8 ridiculous ruling, then it affects everyone.

9 BY MR. KLAYMAN:

10 Q. But you would -- you would like Barack Obama

11 to be ruled ineligible by a court of law. Correct?

12 A. I'm sorry. What was that?

13 Q. You would like a court of law to make a ruling

14 that President Barack Hussein Obama isn't eligible to

15 be president.

16 MR. KRESS: I object to the form. And relevancy.

17 You can answer.

18 THE WITNESS: I'm sorry. I --

19 BY MR. KLAYMAN:

20 Q. Correct?

21 A. I'm sorry, Larry.

22 Q. You would like -- you would like the Court to

23 make a ruling that Barack Obama is ineligible to be

24 president. Correct?


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1 You can answer.

2 THE WITNESS: It would be great.

3 BY MR. KLAYMAN:

4 Q. And you were aware at the time that you met

5 Ms. Taitz that she had several lawsuits trying to

6 declare Obama ineligible. Correct?

7 A. Correct.

8 Q. And you were very supportive of her efforts

9 to do that. Correct?

10 A. On a personal level.

11 Q. And you were supportive of her attempts to

12 raise money for those efforts. Correct?

13 A. I was aware of it.

14 Q. You weren't against her raising money for

15 those efforts, were you?

16 A. No.

17 Q. Were you?

18 A. No.

19 Q. So when you gave her the information about my

20 children and me and had given it to the donors, you

21 were trying to help Ms. Taitz. Correct?


23 THE WITNESS: This memo -- this e-mail was dated

24 January 7th of 2013, not 2012.

25 MR. KLAYMAN: I'm not talking about the date.

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1 Q. I'm saying at the time that you gave Ms. Taitz

2 the information --

3 A. Right.

4 Q. -- about me and my children and suggested that

5 it would be given to donors, you were trying to help

6 Ms. Taitz. Correct?


8 THE WITNESS: Objection because I did not tell her

9 to give it to donors.

10 BY MR. KLAYMAN:

11 Q. But you don't remember what you said, do you?



14 THE WITNESS: I do remember what I said on a

15 limited basis.

16 BY MR. KLAYMAN:

17 Q. But you read Ms. Taitz's posting, did you not?

18 A. I didn't read her posting until months later.

19 Q. Having read it months later, did you ever tell

20 her to correct it?

21 A. No.

22 Q. You were aware that giving that information to

23 donors could hurt Larry Klayman. Correct?


25 THE WITNESS: I did not give it to her to hurt --

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1 to have her put it on a website or hurt you.

2 MR. KLAYMAN: Let's back up on this.

3 Q. Turn your attention to -- who is Price Sloan?

4 A. My brother who died last June.

5 Q. Who is it?

6 A. Price --

7 Q. Who is Price Sloan?

8 A. Price Newton -- well, there are two Price

9 Sloans. There's Price William Elmer Sloan, who is my

10 father. And there's Price N. Newton Sloan, who is my

11 brother.

12 My brother died on --

13 Q. On the e-mail that I just -- on the e-mail

14 that I just read to you, which is Judicial Watch

15 Document 508, it says Sloan Price Sloan. Which

16 Price Sloan is that?

17 A. My brother, as my father died on December 14th

18 of 2001.

19 Q. Turn your attention to a document Judicial

20 Watch Bates Number 505. It's part of that same

21 Exhibit 9.



24 A. Okay.

25 Q. Ms. Ruffley, do you see that?

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1 A. Yes, dated August 28th.

2 Q. Yes.

3 There's an e-mail there from Steve Andersen

4 of Judicial Watch to Tom Fitton, Paul Orfanedes, and

5 Chris Farrell. Copy to Susan Prytherch. Subject:

6 "Orly Taitz posting a Judicial Watch invite to speak on

7 her website??"

8 And it states, "I am extremely proud, I just

9 got a call from the 'Judicial Watch,' and was asked to

10 be a speaker at their event, 'Republicans United,' on

11 October 13th in California."

12 That's a posting on Orly Taitz's website, is

13 it not?

14 A. Right.

15 Q. You said "Right"?

16 A. Yes.

17 Q. Now, that's in -- when Andersen sent that to

18 Fitton, Orfanedes, and Farrell, that then generated an

19 e-mail from Paul Orfanedes to you Tuesday, August 28th,

20 2012 at 4:03 p.m., which is above what I just read to

21 you on that page --

22 A. Right.

23 Q. -- Bates Number 505. Correct?

24 A. Correct.

25 Q. And that e-mail says, "Connie: We've had a

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1 couple of inquiries about this posting. Can you make

2 clear to Ms. Taitz or whomever is responsible for the

3 posting that she was invited by UROC and not 'The

4 Judicial Watch.' The posting also needs to be

5 corrected to avoid any further confusion. Thanks.

6 PJO."

7 A. Right.


9 A. Yes.

10 Q. PJO is Paul J. Orfanedes. Correct?

11 A. Correct.

12 Q. The person who is in the room with you today?

13 A. Yes.

14 Q. One of them. Correct?

15 A. (Nods head in the affirmative.)

16 Q. What was this about?

17 Well, strike that.

18 In fact, Mr. Orfanedes was concerned that

19 Ms. Taitz had posted something incorrectly on her

20 website --

21 A. Right.

22 Q. -- as she was being invited by Judicial

23 Watch --

24 A. Well --

25 Q. -- to a Judicial Watch event rather than UROC.

631
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1 Correct?


3 THE WITNESS: Correct.

4 MR. KRESS: But you can answer it. That's fine.

5 THE WITNESS: She had only known me as Judicial

6 Watch. And the fact that -- you know, because that's

7 the way I had introduced myself. And so when I called

8 her on the phone, which was around 8:42 p.m., she was

9 still at her office doing work. And I called her on

10 her cell phone and asked her if she would speak at

11 UROC.

12 And because of Ms. Taitz's heavy accent --

13 well, it's not a heavy accent, but it's an accent.

14 She was just confused about the -- the UROC. I mean,

15 I don't know when this woman ever sleeps. So that's

16 why she said that.

17 But she -- and I said -- and I told her

18 United Republicans of California. She got confused and

19 put in there Republicans United. So I called her and

20 asked her to correct it. And I think she did.

21 BY MR. KLAYMAN:

22 Q. But you never called her, as you testified,

23 to ask her to correct anything she wrote about me,

24 did you?

25 A. No.

631
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1 Q. Ms. --

2 A. Actually --

3 Q. Someone --

4 A. Let --

5 Q. -- at Judicial --

6 A. -- let me --

7 Q. -- Watch --

8 A. Wait a --

9 Q. -- had called --

10 A. -- minute.

11 Q. -- after --

12 A. Let me -- wait a minute. The court reporter

13 is having a little trouble keeping up.

14 Let me restate that last comment. I never --

15 never corrected her on that. I was just, you know,

16 stunned and didn't know that she would actually print a

17 retraction or a correction.

18 Q. Well, regardless of whether you were stunned

19 or not, you didn't feel like you had an obligation to

20 correct her claimed misquotes with you?

21 A. I'm not sure whether --

22 MR. KRESS: I'm going to object to the form.

23 But you can answer it. You can answer it,

24 if you know.

25 THE WITNESS: I really don't know. I didn't feel

631
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1 like I, uh -- I just kind of object to the word

2 "obligation," or whatever it was that you used.

3 BY MR. KLAYMAN:

4 Q. You don't know of anyone at Judicial Watch

5 calling her to ask her to correct the statements with

6 regards to Larry Klayman that are at issue here, do

7 you?

8 A. No.

9 Q. If you were so stunned about what Ms. Taitz

10 had published about your conversation with her --

11 A. Right.

12 Q. -- why you did you invite her to the November

13 conference to speak?


15 THE WITNESS: Well, she really does know from

16 the -- the times that I have seen her speak and

17 everything and from all of the -- I -- this goes back

18 to when I first met her when she was running for

19 Secretary of State, how she had been to visit all of

20 the Secretaries of State and all -- in the union, and

21 I didn't know anyone else who did that.

22 So that's one of the reasons why she was

23 invited to speak --

24 BY MR. KLAYMAN:

25 Q. That impressed you. Right?

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1 A. -- to UROC.

2 I beg your pardon?

3 Q. That I'm pressed you?

4 A. Well, it should impress anyone. She was

5 taking the time to get out there to gather the correct

6 information.

7 Q. So you didn't think it was that important that

8 she allegedly misquoted you, you just wanted her to

9 speak?


11 THE WITNESS: It had nothing to do with what she

12 had put on the website. I just wanted her to speak to

13 the attendees at the UROC Convention and discuss --

14 BY MR. KLAYMAN:

15 Q. You saw her at the UROC Convention, did you

16 not?


18 Q. You saw her at the UROC Convention, did you

19 not?

20 A. Yes.

21 Q. You didn't ask her to correct what she had

22 published on her website about Larry Klayman, did you?

23 A. No.

24 MR. KLAYMAN: I have no further questions.

25 We will leave this deposition open because you

631
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1 need to look for the documents on your computer,

2 Ms. Taitz -- Ms. Ruffley.

3 I just want you to know that I wish you no

4 harm. And I trust that we can get the documents that

5 you haven't looked for yet, and that we can resolve

6 this case appropriately.

7 But thank you for your time.

8 MR. KRESS: I --

9 MR. KLAYMAN: And --

10 MR. KRESS: I do have --

11 MR. KLAYMAN: -- and that concludes the question

12 session.

13 MR. KRESS: I do have a couple questions for her,

14 Mr. Klayman.

15

16 EXAMINATION

17 BY MR. KRESS:

18 Q. First of all, do you know for certain when it

19 was that you first read Orly Taitz's website posting

20 about Mr. Klayman?

21 A. It was probably several months after the --

22 several months after the incident.

23 Q. Was it -- do you know whether --

24 MR. KLAYMAN: Objection. Move to strike.

25 Speculative.

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1 BY MR. KRESS:

2 Q. Do you know whether it was before or after the

3 UROC Convention?

4 A. It would have been before the UROC Convention.

5 Q. Okay. At the -- back in February of 2012,

6 did you understand the difference between the words

7 "convicted" and "indicted"?

8 A. No.

9 Q. When you did the work as a legal secretary,

10 did you do any criminal work?

11 A. Never.

12 Q. Okay. Did you -- at the time that you first

13 read Orly Taitz's website, did you also see that she

14 had made a correction of the statement?

15 A. No, I didn't.

16 MR. KLAYMAN: I didn't hear that.

17 MR. KRESS: I asked if -- if she -- I asked if

18 she recalls -- well, I asked if she saw Orly Taitz's

19 correction, and she said no.

20 MR. KLAYMAN: I didn't hear the question.

21 MR. KRESS: The question was --

22 MR. KLAYMAN: Can you repeat?

23 MR. KRESS: Sure. I'll paraphrase, if that's all

24 right.

25 I asked her if she had seen Orly Taitz's

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1 correction on the website. And she answered no.

2 And those are all of the questions that I

3 have.

4 MR. KLAYMAN: I object to that. That presumes

5 facts not in evidence that there was a correction.

6 MR. KRESS: I have no further questions.

7 MR. KLAYMAN: I have a few more.


9

10 Examination

11 BY MR. KLAYMAN:

12 Q. You have spent a good deal of time working

13 with Ernie Norris, who is former Deputy District

14 Attorney of Los Angeles County --

15 A. Yes.

16 Q. -- at Judicial Watch. Correct?

17 A. Yes.

18 Q. Correct?

19 A. Yes.

20 Q. Ernie is a -- Ernie was a criminal prosecutor

21 for a number of years with the District Attorney's

22 Office of Los Angeles. Correct?

23 A. 32 years. Yes.

24 Q. In fact, he played a role in the prosecution

25 of O.J. Simpson underneath Deputy D.A. Gil Garcetti.

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1 Correct?

2 A. I'm sorry. I didn't hear the first part of

3 the question correctly.

4 Would you mind repeating it, please, Larry?

5 Q. Ernie Norris, as Deputy Assistant District

6 Attorney underneath the District Attorney Gil Garcetti,

7 played a substantial role in the prosecution of O.J.

8 Simpson.

9 You are aware of that?

10 A. No, he did not have anything to do with the

11 O.J. Simpson trial. The O.J. Simpson trial was given

12 to his underling, Marcia Clark, and to Chris Darden.

13 But Ernie did not have --

14 Q. You are aware that -- you have talked about

15 the O.J. Simpson case with Mr. Norris. Correct?

16 A. Oh, off and on.

17 Q. And Mr. Norris was quite -- was quite

18 despondent or upset that O.J. Simpson was not convicted

19 of the crime of murder. Correct?

20 A. I can't speak to his feelings on that or

21 emotions.

22 Q. You are aware that O.J. Simpson was indicted

23 but never convicted for murder. Correct?

24 A. Did you say "Ernie Simpson" or "O.J. Simpson"?

25 I'm sorry.

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1 Q. O.J.

2 A. Yes.

3 Q. Okay.

4 A. I'm aware that he was not convicted.

5 Q. Therefore, you do know the meaning of the word

6 "convicted" as opposed to "indicted." Correct?

7 A. More now. But at the time -- but at the time,

8 I was not aware of a difference between indicted and

9 convicted.

10 Q. So during the time of the O.J. Simpson trial,

11 you thought that O.J. Simpson was convicted because he

12 was indicted?

13 A. No.

14 Q. You are a highly intelligent person; are you

15 not, Ms. Ruffley?

16 A. Thank you. Yes.

17 Q. Newspaper regularly?


19 Q. You do read the newspaper, do you not --

20 A. No.

21 Q. -- regularly?

22 A. No.

23 Q. You watch Fox News, don't you?

24 A. I'm forced to watch it, yes. I hate it.

25 Q. You prefer MSNBC?

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1 A. No, I don't watch anything else except Fox.

2 It's my husband who watches Fox from in the morning

3 until late at night. And I just -- I'm stuck with it.

4 MR. KLAYMAN: I have no further questions at this

5 time.

6 Thank you for your time.

7 MR. KRESS: No further questions.

8 Thank you.

9 THE WITNESS: Thank you.

10 THE VIDEOGRAPHER: Any stipulation?

11 MR. KRESS: We will read -- he will read the

12 transcript.

13 What other stipulations are you looking for?

14 THE REPORTER: Who receives it.

15 MR. KRESS: Who receives it? I would prefer if

16 the transcript would be sent to me for review, if that

17 is acceptable.

18 Mr. Klayman.

19 MR. KLAYMAN: Excuse me.

20 MR. KRESS: In terms of reading the transcript, do

21 you mind if the court reporter just sends the

22 transcript to me for review so that I can send it to

23 Ms. Ruffley for review?

24 MR. KLAYMAN: No, I don't mind. But we want a

25 copy, too --

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1 MR. KRESS: Sure.

2 MR. KLAYMAN: -- contemporaneous.


4 THE VIDEOGRAPHER: This concludes today's

5 videotaped deposition of Constance Ruffley in the

6 matter of Larry Klayman vs. Judicial Watch.

7 We are off the record. The time is

8 10:33 a.m.

9 THE WITNESS: P.M.

10 Oh, it is A.M.

11 MR. KLAYMAN: Thank you.

12 You have also a very courteous counsel. So

13 I'll say that, as well.

14

15 (At 10:33 a.m., the proceedings

16 were concluded.)

17

18

19

20

21

22

23

24

25

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1 STATE OF CALIFORNIA )
)
2 COUNTY OF LOS ANGELES )

3

4 I, Tracy Williams, CSR #10139, Certified

5 Shorthand Reporter, do hereby certify:

6 That prior to being examined, the witness

7 named in the foregoing deposition was by me duly

8 sworn;

9 That said deposition was taken down by me in

10 shorthand at the time and place therein named and

11 thereafter transcribed under my direction;

12 I further certify that I am neither counsel

13 for, nor related to, any party to said proceedings, not

14 in any way interested in the outcome thereof.

15 I declare under penalty of perjury under the

16 law of the State of California that the foregoing is

17 true and correct.

18

19 Dated: February 14, 2014

20

21 _____________________________
Tracy Williams
22 CSR No. 10139, RPR CRR

23

24

25

631
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1 DECLARATION UNDER PENALTY OF PERJURY

2 I, Constance S. Ruffley, do hereby certify under

3 penalty of perjury that I have read the foregoing

4 transcript of my deposition taken January 31, 2014; that I

5 have made such corrections as appear noted on the

6 Deposition Errata Page, attached hereto, signed by

7 me; that my testimony as contained herein, as

8 corrected, is true and correct.

9

10 Dated this ____ day of _____________________,

11 2014, at __________________________________________,

12 California.

13

14

15 ______________________________

16 CONSTANCE S. RUFFLEY

17

18

19

20

21

22

23

24

25

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1 DEPOSITION ERRATA SHEET

2

3 Page No.____________Line No.____________

4 Change:_____________________________________________

5 Reason for Change:__________________________________

6 Page No.____________Line No.____________

7 Change:_____________________________________________


9 Page No.____________Line No.____________

10 Change:_____________________________________________


12 Page No.____________Line No.____________

13 Change:_____________________________________________


15 Page No.____________Line No.____________

16 Change:_____________________________________________


18 Page No.____________Line No.____________

19 Change:_____________________________________________


21 Page No.____________Line No.____________

22 Change:_____________________________________________


24 ____________________ _______________________

25 CONSTANCE S. RUFFLEY Dated

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CENTRAL DISTRICT OF CALIFORNIA
LARRY KLAYMAN
Plaintiff(s),
v.
JUDICIAL WATCH
Defendant(s).
CASE NO:
2:14cv01602ABCAS
CIVIL CASE MANAGEMENT
ORDER
READ IMMEDIATELY AND
THOROUGHLY
This case has been assigned to the calendar of Judge Audrey B. Collins,
Courtroom 680, Roybal Federal Building, 255 East Temple Street, Los Angeles,
CA 90012.
The responsibility for the progress of litigation in federal courts falls not only
upon the Court, but upon the attorneys in the action as well. In order to secure the
just, speedy, and inexpensive determination of every action, Fed. R. Civ. P. 1,
all counsel are ordered to familiarize themselves with the Federal Rules of Civil
Procedure, the Local Rules of the Central District of California, and this Courts
Case Management Order. Note that some of the requirements in this Case
Management Order are more specific than those set out in the Local Rules.
\\\
1
Case 2:14-cv-01602-ABC-AS Document 4 Filed 03/11/14 Page 1 of 13 Page ID #:17 Case 1:13-cv-20610-CMA Document 89-3 Entered on FLSD Docket 03/17/2014 Page 598 of
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1. SERVICE
Plaintiff shall promptly serve the Complaint in accordance with Federal Rule
of Civil Procedure 4, and file proofs of service pursuant to Local Rule 5.3.1.
2. ATTENDANCE AT PROCEEDINGS
The attorney attending any proceeding before this Court must be the attorney
who is primarily responsible for the conduct of the case.
3. MANDATORY CHAMBERS COPIES
ONE copy of any document filed with the Court must be delivered directly
to chambers no later than 12:00 p.m. (noon) of the next court day. Chambers
copies do not need to be bluebacked. For security reasons, chambers copies
should be removed from envelopes or folders before being placed in the chambers
dropbox.
4. FILING MOTIONS
Adherence to the Local Rules is essential to proper chambers preparation of
motions.
a. Electronic filing (efiling). Efiling is mandatory in this District.
See Local Rule 54 for instructions on efiling documents.
b. Local Rule 73. The Court strictly enforces Local Rule 73, which
requires a prefiling meeting of counsel to discuss the substance and
potential resolution of nondiscovery motions. Counsel for the
moving party must inform the Court in the notice of motion of
the date of the conference.
c. Timing and service requirements. If served personally or
electronically, the notice of motion shall be served not later than
twentyeight (28) days before the hearing date designated in the
notice. (Local Rule 61.) Opposing papers shall be filed and served
no later than twentyone (21) days before the hearing date. (Local
Rule 79.) Reply papers, if any, shall be filed and served no later
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than fourteen (14) days before the hearing date. (Local Rule 710.)
d. Oral Argument. If the Court does not require oral argument,
counsel will be so advised during the week before the hearing date.
If the Court requires oral argument, the Court generally provides
a tentative ruling, which the Deputy Courtroom Clerk distributes
before the hearing when counsel check in.
5. MOTIONS TO DISMISS
The Court believes that most motions to dismiss can be avoided by good
faith efforts to meet and confer and, if necessary, by stipulations to amend the
pleadings. As such, the parties should avoid filing motions to dismiss when they
can resolve the issues without imposing on the Courts limited resources.
6. MOTIONS FOR SUMMARY JUDGMENT
The Court encourages the moving party to provide more than the minimum
twentyeight (28) days notice. The movant must send the Statement of
Uncontroverted Facts and Conclusions of Law, in WordPerfect or MS Word
format, to abc_chambers@cacd.uscourts.gov.
7. DISCOVERY
This Court refers all discovery motions and disputes to the Magistrate Judge
assigned to the case (see initials in parentheses following the case number).
Counsel are expected to resolve substantially all discovery problems without the
assistance of the Court. Discovery disputes of a significant nature should be
brought promptly before the Magistrate Judge. The Court requires strict compliance
with Local Rule 37.
8. EX PARTE APPLICATIONS
Ex parte applications are usually decided on the papers and not set for
hearing. Ex parte applications are to be reserved solely for extraordinarily relief
and must comply with Local Rule 719. Counsel are ordered to read and adhere
to Mission Power Enginneering, Co. V. Continental Casualty Co., 883 F. Supp.
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488 (C.D. Cal. 1995) before filing any ex parte application.
The requesting party shall serve the motion by personal delivery, fax,
or other electronic means, at or before the time the application is filed.
Oppositions are due within 24 hours of service. At the time of the application,
the applicant shall comply with Local Rule 719.1, which, inter alia, requires
the applicant to advise the court in writing of his or her efforts to contact
opposing counsel, and of opposing counsels intention to oppose the
application. Counsel must inform the Courtroom Deputy Clerk at
(213) 8946500 if the ex parte application will not be opposed.
Applications that fail to comply with the Local Rules or this Order will not be
considered. The Court may impose sanctions for misuse of the ex parte process.
In re Intermagnetics Am., Inc., 101 B.R. 191 (C.D. Cal. 1989).
9. ALTERNATIVE DISPUTE RESOLUTION (ADR)
As set forth in Local Rule 1615.1, every case must attempt Alternative
Dispute Resolution (ADR). This Court participates in the CourtDirected ADR
Program. Therefore, at the Scheduling Conference, all civil cases will presumptively
be referred either to the Mediation Panel or to a private dispute resolution process.
A settlement conference with a Magistrate Judge is generally not available for cases
within the CourtDirected ADR Program. Counsel must comply with Local Rule
261(c), which orders counsel to furnish and discuss with their clients the Notice
to Parties of CourtDirected ADR Program in preparation for the Fed. R. Civ. P.
26(f) conference. Plaintiffs counsel received this Notice at the time the Complaint
was filed and must serve it on all parties.
10. SETTLEMENT
This Court will not conduct settlement conferences in nonjury cases it is to
In jury cases, this Court will conduct a settlement conference if three conditions
exist:
a. Counsel are satisfied that the fact issues in the case will be
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b. All significant pretrial rulings that this Court must make have
been made; and
c. All counsel desire this Court to conduct the conference,
understanding that if settlement fails, it will try the case.
If all three conditions exist, counsel must submit to this Court a proposed
stipulation requesting a settlement conference date.
Unless otherwise ordered by the judge or magistrate judge conducting a
settlement conference, the parties shall follow the Requirements for ADR
Procedures set forth in Local Rule 1615.5. If a settlement is reached, the
parties shall report it immediately to this Court as required by Local Rule
1615.7.
11. MOTIONS IN LIMINE
Motions in limine on classes of evidence that are appropriate for preliminary
rulings must be noticed for hearing at the Final Pretrial Conference. Motions in
limine must be filed twentyone (21) days before the Final Pretrial Conference.
Oppositions shall be filed seven (7) days later. Replies are not ordinarily filed for
motions in limine. Counsel are strongly advised to be selective about what they file
as the Court will not entertain excessive motions.
12. FINAL PRETRIAL CONFERENCE
Unless this case is exempt from a Final Pretrial Conference (FPTC)
pursuant to Local Rule 1612, or the Court expressly waived pretrial procedures
pursuant to Local Rule 1611, this case will be placed on calendar for a FPTC
pursuant to Federal Rule of Civil Procedure 16(e) and Local Rule 16. The Court
requires strict compliance with Local Rule 16.
a. Lead Trial Counsel. Each party appearing in this action shall
be represented at the FPTC and all pretrial meetings by that
partys lead trial counsel unless excused for good cause.
b. Continuances. The Court will not continue the FPTC merely
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on stipulation of the parties. (Local Rule 169.) Counsel
should plan to do the necessary pretrial work on a schedule
that will ensure its completion well before the FPTC. Failure
to complete discovery is not a ground for a continuance.
c. Conference of Counsel. Counsel must confer in preparation
for the FPTC no later than forty (40) days before the FPTC.
(See Local Rule 162 for items to be discussed.) In addition to
the items listed in Local Rule 162, at the FPTC, counsel must
be ready to discuss how to streamline the trial, including, but
not limited to bifurcation, presentation of noncritical testimony
by deposition, stipulations as to the content of testimony, and
qualification of experts by admitted resumes.
d. Preparation of Required Trial Documents. Carefully
prepared Memoranda of Contentions of Fact and Law
(which may also serve as the trial brief), Witness Lists, and
Joint Exhibit Lists shall be submitted in accordance with the
timing and other provisions of Local Rules 162 through 167.
These documents shall be filed and served not later than
twentyone (21) days before the FPTC. (Local Rules 164
through 166.) Also note that Rule 16 contains specific
requirements for the presentation of deposition testimony
(Local Rule 162.7) and the disclosure of graphic and
illustrative material (Local Rule 163).
e. Proposed Final Pretrial Conference Order (FPTCO).
The Proposed FPTCO shall be lodged with the Clerk
eleven (11) days before the FPTC. As required by Local
Rule 167, the Proposed FPTCO should follow the format
Pretrial Form No. 1. See Local Rules, Appendix A, Pretrial
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Form No. 1.
f. Status Report Re: Settlement. At the time that they lodge
the Proposed FPTCO, the parties must file a Status Report
Re: Settlement, indicating whether they have conducted the
Local Rule 16 ADR Procedure and/or what additional steps
are being taken to achieve settlement.
13. BENCH TRIALS
The following requirements apply to parties preparing for a bench trial.
a. Counsel for each party shall lodge and serve proposed
Findings of Fact and Conclusions of Law at least seven (7)
days before trial.
b. The parties shall be prepared to submit to the Court, and to
exchange among themselves, supplemental findings of fact
and conclusions of law during the course of the trial.
c. Counsel must prepare their exhibits for presentation at trial by
placing them in 3hole binders with tabs down the side showing
the exhibit numbers. These binders are to be prepared in an
original (for the Courtroom Deputy Clerk) and two copies
(for the Judge and the law clerk). The originals shall each be
tagged with the appropriate exhibit tags in the upper or lower
righthand corner of the first page of each exhibit. Each binder
shall include a list of each exhibit it contains. The exhibits must
be numbered in accordance with Local Rule 166. Counsel
shall supply three extra copies of their individual or joint
exhibit lists and witness lists to the Courtroom Deputy Clerk
at trial.
d. Counsel must meet not later than ten (10) days before trial to
stipulate as much as possible to foundation, waiver of the
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best evidence rule, and which exhibits may be received into
evidence at the start of trial. Any exhibits that the parties
have stipulated to admit should be identified on the exhibit
lists.
14. JURY TRIALS
The following requirements apply to parties preparing for a jury trial.
a. Proposed Jury Instructions and Special Verdict Forms.
The parties must jointly submit proposed jury instructions.
Counsel need only submit proposed substantive instructions.
The Court will propound its own general instructions taken
from the current Manual of Model Civil Jury Instructions
(Thompson West) for the Ninth Circuit. The Court prefers
counsel to use the instructions from the Manual of Model
Civil Jury Instructions (Thompson West) for the Ninth
Circuit. Where California law applies and the Ninth Circuit
instructions are inapplicable, the Court expects counsel to
use California Civil Jury Instructions (CACI). If neither
of the above sources is applicable, counsel are directed to use
the instructions from Devitt, Blackmar & Wolff, Federal Jury
Practice and Instructions or California Forms of Jury
Instructions. The parties may also propose a special verdict
form.
b. Meeting of Counsel. Counsel shall exchange proposed jury
instructions and special verdict forms seven (7) days before
the Local Rule 162 meeting of counsel. Counsel shall
exchange any objections to the proposed jury instructions
and special verdict forms within seven (7) days. Counsel
shall meet and confer prior to the FPTC with the goal of
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reaching agreement on a set of joint instructions and one
special verdict form.
c. Filing Joint Proposed Jury Instructions. The parties
shall file their joint proposed jury instructions no later than
three (3) days before the FPTC. Each requested jury
instruction shall be numbered and set forth in full on a separate
page, citing the authority or source of the requested instruction.
The joint jury instructions shall be filed in the following form:
i. The agreed upon instructions;
ii. Plaintiffs proposed instructions, to which
Defendant objects; and
iii. Defendants proposed instructions, to which
Plaintiff objects.
An index shall accompany all jury instructions submitted to
the Court. The index shall indicate the following:
i. The number of the instruction;
ii. A brief title of the instruction;
iii. The source of the instruction and any relevant
case citations; and
iv. The page number of the instruction.
EXAMPLE OF JURY INSTRUCTION INDEX ENTRY
Number Title Source Page
1 Burden of Proof 9th Cir. 1.3 5
In addition to filing the proposed jury instructions and
providing chambers copies, counsel must email their
proposed instructions in WordPerfect or MS Word to
abc_chambers@cacd.uscourts.gov.
d. Filing Objections to Disputed Jury Instructions.
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Objections to disputed instructions shall be filed by the date
of the FPTC. Any and all objections shall first set forth the
proposed instruction in its entirety. The objection shall be
specific and contain citation to authority and/or a concise
argument supporting the view that the instruction is improper.
If applicable, the objecting party shall submit an alternative
instruction on a separate page.
e. Exhibit Lists and Witness Lists. Counsel must prepare
their exhibits for presentation at trial by placing them in
3hole binders with tabs down the side showing the exhibit
numbers.These binders are to be prepared in an original (for
the Courtroom Deputy Clerk) and two copies (for the Judge
and Court Reporter). These shall be delivered to the Courtroom
Deputy Clerk no later than 8:15 a.m. on the first day of trial.
The originals shall each be tagged with the appropriate exhibit
tags in the upper or lower righthand corner of the first page
of each exhibit. Each binder shall include a list of each exhibit
it contains. The exhibits shall be listed and numbered in
numerical order in accordance with Local Rule 166. Counsel
shall supply four clean copies (without PDF headers) of their
individual or joint exhibit lists and witness lists to the
Courtroom Deputy Clerk at the trial.
f. Stipulations. Counsel must meet at least ten (10) days before
trial to stipulate as much as possible to foundation, waiver of
the best evidence rule, and which exhibits may be received
into evidence at the start of trial. Any exhibits that the parties
have stipulated to admit should be identified on the exhibit lists.
In cases involving many exhibits, the Court encourages counsel
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to reach agreement on ways in which testimony about exhibits
can be clarified and streamlined for the jury as it is being
presented. For example, counsel may consider using
enlargements of important exhibits. Counsel should also meet
and confer specifically about stipulating to most exhibits in
such cases. Counsel may not provide exhibits or copies of
the exhibits to the jury during the trial.
g. Conduct of Trial.
i. If counsel need to arrange for the installation of their
own equipment, notify the Courtroom Deputy Clerk
no later than 4:30 p.m. two days before trial to
make the necessary arrangements.
ii. Counsel shall arrive at the Courtroom not later than
8:15 on the first day of trial. Counsel must be on
time as the Court starts promptly.
iii. Trial days are Tuesday through Friday, 8:30 a.m. to
4:30 p.m., with a morning and an afternoon break,
and a lunch recess from approximately 12:00 p.m. to
1:15 p.m. Each day before trial commences, the
Court will give counsel an opportunity to discuss
administrative matters and anticipated procedural or
legal problems outside of the presence of the jury.
Counsel are urged to anticipate matters that may need
discussion or hearing outside of the presence of the
jury and to raise them during this period. The Court
rarely grants counsels requests for sidebars during the
trial of civil cases. During the trial, if there are any
matters you wish to discuss, please inform the
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Courtroom Deputy Clerk.
iv. Please rise when addressing the Court and when the
jury enters or leaves the courtroom.
v. Address all remarks to the Court. Do not directly address
the Courtroom Deputy Clerk, the court reporter, or
opposing counsel. If you wish to speak with opposing
counsel, ask permission to talk to him or her off the
record. All requests to reread questions or answers,
or to have an exhibit placed in front of a witness, shall
shall be addressed to the Court.
vi. Avoid discussing the law or arguing the case in opening
statements.
vii. Do not approach the Courtroom Deputy Clerk or the
witness box without the Courts permission. Please
return to the lectern when your purpose has been
accomplished.
viii. When objecting, state only that you are objecting and
the legal ground of the objection, e.g., hearsay,
irrelevant, etc.
ix. If a witness was on the stand at a recess or adjournment,
have the witness back on the stand and ready to proceed
when Court resumes.
x. When a party has more than one lawyer, only one may
conduct the examination of a given witness and only
that same lawyer may handle objections during the
testimony of that witness.
xi. While court is in session, do not leave the counsel table
to confer with investigators, secretaries, or witnesses
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in the back of the courtroom unless permission is
granted in advance.
xii. Do not run out of witnesses. If you run out of witnesses
and there is more than a brief delay, the Court may
you to have rested.
xiii. The Court attempts to accommodate witnesses who
have scheduling constraints and will, except in
extraordinary circumstances, permit them to testify
out of sequence. Anticipate any such possibility and
discuss it with opposing counsel. If there is an objection,
confer with the Court in advance.
xiv. Do not refer to your client, other litigants, or witnesses
by their first names.
15. NOTICE
Plaintiffs counsel or, if Plaintiff is appearing pro se, Defendants counsel,
shall provide this Order to any parties who first appear after the date of this
Order and to parties who are known to exist but have not yet entered appearances.
16. COURTS WEBSITE
This Case Management Order is available on the Central District of California
website at www.cacd.uscourts.gov under Judges Procedures & Schedules. The
Local Rules and General Orders are also available on the Central Districts website.
Dated: March 11, 2014
Audrey B. Collins
United States District Judge
Local Rules may be purchased from the following
Los Angeles Daily Journal West Group Metropolitan News
915 East First Street 50 West Kellogg Boulevard 210 South Spring Street
Los Angeles, CA 90012 St. Paul, MN 551649979 Los Angeles, CA 90012
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Klayman V Judicial Watch FLSD 1:13-cv-20610 #89 - 3

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1

IN THE UNITED STATES DISTRICT COURT

Case 1:13-cv-20610-CMA Document 89-3 Entered on FLSD Docket 03/17/2014 Page 22 of

1/6/14 Cuyahoga County Clerk of Courts - Case Docket

1/6/14 Cuyahoga County Clerk of Courts - Case Docket

1/6/14 Cuyahoga County Clerk of Courts - Case Docket

1/6/14 Cuyahoga County Clerk of Courts - Case Docket

1/6/14 Cuyahoga County Clerk of Courts - Case Docket

THANK GOD FOR LARRY KLAYMAN

LARRY KLAYMAN, MY HERO

Klaymans been a target before, and he will be a target again. I

Note: Read our discussion guidelines (/discussion-guidelines/) before commenting.

LARRY KLAYMAN FOR U.S. SENATE

Case 1:13-cv-20610-CMA Document 89-3 Entered on FLSD Docket 03/17/2014 Page 47 of

In The Matter of:

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014

PAUL ORFANEDES, ESQUIRE - 1/27/2014