klayman v judicial watch flsd 1:13-cv-20610 #89_3

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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 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‖


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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 ―World’s 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 Watch’s 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 Watch’s 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 Attorney’s 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 can’t 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: I’m 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 World’s 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

state’s primary and general election for 2012.

24. Judicial Watch routinely represents individuals and interests with the same legal needs as

those I represent.

25. Ruffley’s 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


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shrinks from his standards of ethics and morality. He’s 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.


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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 Plaintiff’s opposition, notwithstanding Taitz’s 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 Defendant’s 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.


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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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42 0 13 Comments

Meet Larry Klayman: Man Behind the NSALawsuitDec. 19, 2013

By ALEX LAZAR

214Like 109 Share

Name: Larry Klayman

Age: 62

Occupation: Founder of Freedom Watch and Judicial Watch as well as a World New Dailycolumnist

Claim to fame: As the former head of Judicial Watch, Klayman may be best known for filingnumerous lawsuits against the Clinton Administration during the 1990s – especially while theMonica Lewinsky scandal was unfolding. In 1998, Newsweek wrote an article that claimed Klaymanhad once sued his mother - information that he says was given to the magazine by the Clintonadministration. Klayman, a big proponent of the Tea Party and its ideals, has in the past questionedPresident Obama's assertions that he was born in the United States. Now, however, Klayman isback in the public eye as the man who challenged in court the legality of the NSA's authority tokeep and store the metadata of American citizens – and won.

ABC News spoke with Klayman about the recent NSA ruling and his other famous lawsuits. Theinterview 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 theirgovernment. This is the biggest violation of constitutional rights in American history. It has morethan a chilling effect on free speech. We're very gratified that this judge did the courageous thingand stuck his neck out and in my view he's an American hero. I think it will go to the SupremeCourt and I'm confident that we'll win. You can't have the metadata of over 300 million Americansand say that's a difficult issue to decide. Metadata is even more intrusive than listening to content insome 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 monitoring…to make sure that this isnot happening, will not happen again. We didn't challenge the constitutionality of the Patriot Act orthe Foreign Intelligence Surveillance Act…we intend to raise that with the court. I believe those actsare 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 didnot have two American citizen parents by his own admission. Just for the same reason that Rubiois out and Cruz is out and John McCain – people thought that he didn't qualify for that reasoneither. See that's why the Republicans don't want to challenge it…and no judge wants to touch it sofar."

ABC News: Please tell me about the claim out there that you once sued your mother

Klayman: "My grandmother was dying, and my mother…had dementia. My stepfather had undueinfluence on her and took all my grandmom's money and put a do not resuscitate order on hercharts. I had to bring lawsuits to get the do not resuscitate order off her charts and to get hermoney back so she could afford to be in a nursing home because her insurance had lapsedbecause my mother…she was with dementia, hadn't followed what was going on. It was essentiallya case against my stepfather – not against my mother, but I had to…name my mother becauselegally 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 theshow…DeeDee Myers in the White House, Lawrence O'Donnell – now with MSNBC, and PatCaddell who's a former Carter pollster. I was flattered by it even though they poked fun at mebecause 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'readvocating protests and peaceful nonviolence, civil disobedience, to try to get the government tobecome responsive to the American people. If Gandhi could do it in India, we could do it here. Iwill not be deterred by attacks from the left or anyplace else, that actually emboldens me more todo what I think needs to be done."

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13 comments

Join the discussion…

Best Community Login Share

• Reply •

Sojourner56 • 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'stalk about more important issues . . . how about your mother . . . ya, that's it . . . yourmother.

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 thequestion on his constitutional eligibility?

And why has the (inferior) Supreme court refused to hear cases over him?

Reply

ajudicator1776 • 18 days ago

Keep up the good fight, Mr. Klayman! You have my support as well that of milliions ofAmericans. The lawlessness of the Obama regime is unprecedented. It has reachedcritical-mass. Nixon lied about a third-rate burglarly. Obama lied about the needlessslaughter of four Americans in Benghazi, about "If you like your insurance plan, you cankeep it. Period.", and about his "proof positive" of a Hawaiian birth by his April 27, 2011release of his bogus LFBC. As a nation, we are WAY beyond the point of appointing aspecial prosecutor and beginning impeachment proceedings.

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• Reply • 2 1

• Reply •

King Darius • 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 tobe 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/viewersabout the difference between natural born citizen and citizen at birth.

2 1

• Reply •

rtk25301 • 18 days ago King Darius

You have my attention. What exactly is the difference between "by birth anAmerican 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'sfather was never a US citizen. Cruz , Rubio , Jindal all ineligible to be pres.

2 1

• Reply •

MaryMitch • 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 beingfed to WH handlers....

• Reply •

MaryMitch • 18 days ago

ha ha ha ha... what an idiot

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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 Information

Fil ing Date Side Type Description Image10/09/2013 D1 $$ PAYMENT ON ACCOUNT MADE ON BEHALF OF LUCK/STEPHANIE/ANN IN THE

AMOUNT OF $37.0008/08/2013 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 449.25PAID AMOUNT 412.25 AMOUNT DUE 37 NOTE: ANY ADDITIONAL COURT COSTWILL 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 ISTREATED AS A MOTION TO WITHDRAW APPEAL AND IS GRANTED. DISMISSALOF APPEALS AE WITH PREJUDICE. O.S.J. NOTICE ISSUED

03/15/2013 P1 CA APPELLANT'S 9A RECORD TRANSMITTED TO THE COURT OF APPEALSCONSISTING OF THE TRANSCRIPT OF THE DOCKET, JOURNAL ENTRIES ANDTHE 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 FILEDON FEBRUARY 15, 2013 ARE DISMISSED AS MOOT. COURT COSTS ADJUGEDAGAINST PTLF. AND DEFT. EQUALLY. O.S.J. NOTICE ISSUED

03/08/2013 D4 OT D4 JENNIFER L MALENSEK, GUARDIAN AD LITEM AND COUNSEL FOR MINORCHILDREN NOTICE OF DISMISSAL (W). JENNIFER L MALENSEK 0069646

02/20/2013 P JE CA FROM THE SUPREME COURT OF OHIO UPON CONSIDERATION OF THEJURISDICTIONAL MEMORANDA FILED IN THIS CASE THE COURT DECLINES TOACCEPT JURISDICTION OF THE APPEAL PURSUANT TO S. CT. PRAC.R. 7.08(B)(4). (CUYAHOGA COUNTY COURT OF APPEALS; NO. 97074) NOTICE ISSUEDO.S.J. NOTICE ISSUED

02/15/2013 P1 MO P1 LARRY ELLIOT KLAYMAN MOTION TO ORDER GRANTED PRIOR MOTION TOTERMINATE BY DEFAULT, AND IF NECCESSARY, RENEWED MOTION TOQUASH, AND MOTION TO DISMISS GUARDIAN AD LITEM'S MOTION TO SHOWCAUSE ..... PRO SE 9999999

02/07/2013 P1 CA -------------------- NOTICE OF APPEAL -------------------- CA NO. 99517 NOTICE OFAPPEAL FILED BY THE PLTF. APPELLANT W/A 9A PRAECIPE AND DOCKETINGSTATEMENT ON THE REGULAR CALENDAR. COPIES MAILED.

01/31/2013 P1 SR CERTIFIED MAIL RECEIPT NO. 20613735 RETURNED 01/31/2013 FAILURE OFSERVICE ON DEFENDANT KLAYMAN/LARRY ELLIOT/ - UNCLAIMED NOTICEMAILED TO DEFENDANT(S) ATTORNEY

01/24/2013 N/A JE THIS MATTER HAS BEEN RESET BEFORE MAGISTRATE EILEEN T. GERITY ONFEB. 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) SENT01/23/2013 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 TOSHOW CAUSE FOR FAILURE TO PAY GAL FEES

01/23/2013 N/A SR HEARING SCHEDULED, NOTICE(S) SENT


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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 CONTINUANCEON 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 ANYCONTEMPT MOTION, #340012 IS HEREBY DISMISSED AS MOOT..PETITIONERTO PAY THE COSTS OF THESE PROCEEDINGS.. O.S.J. NOTICE ISSUED

12/24/2012 N/A SR HEARING SCHEDULED, NOTICE(S) SENT12/24/2012 N/A SR HEARING SCHEDULED, NOTICE(S) SENT12/24/2012 N/A SR HEARING SCHEDULED, NOTICE(S) SENT12/24/2012 N/A SR HEARING SCHEDULED, NOTICE(S) SENT12/21/2012 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 TOSHOW CAUSE FOR FAILURE TO PAY GAL FEES MO.# 340012 FILED ON09/06/2012 MOTION TO DISMISS

12/21/2012 D1 $$ PAYMENT ON ACCOUNT MADE ON BEHALF OF LUCK/STEPHANIE/ANN IN THEAMOUNT OF $64.25

12/18/2012 P1 SR MOTION(20613735) SENT BY CERTIFIED MAIL. TO: LARRY ELLIOT KLAYMAN2020 PENNSYLVANIA AVE NW STE 345 WASHINGTON, DC 20006-0000

12/17/2012 D4 MO D4 JENNIFER L MALENSEK, GUARDIAN AD LITEM AND COUNSEL FOR MINORCHILDREN GUARDIAN AD LITEM'S MOTION TO SHOW CAUSE...... JENNIFER LMALENSEK 0069646

12/17/2012 P1 SR INSTRUCTION FOR SERVICE ON GUARDIAN AS LITEM'S MOTION TO SHOWCAUSE VIA CERTIFIED MAIL TO LARRY ELLIOT KLAYMAN. FILED.

10/18/2012 P1 OT P1 LARRY ELLIOT KLAYMAN NOTICE OF INTENT TO FILE APPEAL ANDPETITION FOR WRIT OF MANDAMUS. PRO SE 9999999

10/16/2012 P JE CAMOTIN BY APPELLANT TO SET ASIDE JUDGMENT ENTRY OF OCT 3, 2012AND GRANT EN BANC REVIEW IS DENIED. NOTICE ISSUED O.S.J. NOTICEISSUED

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'SAPPLICATION FOR EN BANC REHEARING AS UNTIMELY. APPELLANT NOWARGUES THE APPLICATION WAS A TIMELY REQUEST FOR EN BANCCONSIDERATION OF THE PANEL'S SEPT. 5,2012 DECISION DENYING HISMOTION FO R RECONSIDERATION . THE APPLICATION REQUESTED EN BANCCONSIDERATION OF THE JULY 26, 2012 PANEL DECISION, NOT THE SEPT.5,2012 RULING. THEREFORE, THE APPLICATION WAS UNTIMELY. NOTICEISSUED. O.S.J. NOTICE ISSUED

09/21/2012 N/A JE *****C/A***** COA NOS. 97074 AND 97075...APPLICATION BY APPELLANT FOREN BANC REHEARING FILED 09/14/12 WAS NOT TIMELY FILED WITHIN TWNDAYS AFTER THE CLERK MAILED THE JUDGMENT TO THE PARTIES ANDMADE A NOTE OF THE MAILING ON THE DOCKET. ACCORDINGLY, THEAPPLICATION IS DISMISSED AS UNTIMELY.. O.S.J. NOTICE ISSUED

09/06/2012 P1 MO P1 LARRY ELLIOT KLAYMAN MOTION TO DISMISS AND/OR DENY ANYCONTEMPT MOTION PRO SE 9999999

08/29/2012 P1 SR MOTION(19987825) SENT BY REGULAR MAIL SERVICE. TO: LARRY ELLIOTKLAYMAN 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 PLTFTO DISMISS AND/OR DENY CONTEMPT MOTION AND TO OBJECT TO AND TOQUASH SUBPOENAS TO PRODUCE DOCUMENTS IS HEREBY DENIED ASMOOT. 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 ATTORNEYFEES VIA ORDINARY MAIL TO LARRY ELLIOT KLAYMAN. FILED.

08/27/2012 P JE THE COURT DOES HEREBY DISMISS RESPONDENT'S MOTION TO SHOWCAUSE (NONCOMPLIANCE WITH JUDGMENT ENTRY) RESPONDENT MOTIONTO INCLUDE INTEREST AT STATUTORY RATES IS DISMISSED AS MOOT.RESPONDENTS MOTION FOR ATTORNEY FEES IS DISMISSED SUE SPONTE. ITIS FURTHER ORDER ADJUDGED AND DECREED THAT PETITIONER'S MOTIONTO DISMISS AND OR DENY CONTEMPT MOTION IS DISMISSED ANDPETITIONER'S MOTION TO QUASH SUBPOENAS AS TO PRODUCEDOCUMENTS IS SUSTAINED AS MOOT. THE COURT DOES DISMISS THEENTIRETY OF PETITIONER'S MOTION N AS IT IS AN EXACT DUPLICATE OF THEMOTIONS ASSIGNED 339098 AND 339099 SUPRA. RESPONDENT TO PAY THECOSTS OF THESE PROCEEDINGS. O.S.J. NOTICE ISSUED

08/24/2012 D1 MO D1 STEPHANIE ANN LUCK MOTION FOR EXTENSION OF TIME TO RESPOND TOMOTION OF PLTF TO DISMISS AND/OR DENY CONTEMPTMOTION AND TOOBJECT 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 ONBEHALF 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 CONTEMPTMOTION ......W...... PRO SE 9999999

08/20/2012 P1 SR MOTION(19913516) SENT BY EXPRESS MAIL. TO: LARRY ELLIOT KLAYMAN2020 PENNSYLVANIA AVE NW STE 345 WASHINGTON, DC 20006-0000

08/20/2012 P1 MO PLTF, LARRY KLAYMAN, PRO SE MTN TO DISMISS AND / OR DENYCONTEMPT MTN AND TO OBJECT TO AND TO QUASH SUBPOENA TOPRODUCE DOCUMENTS PRO SE (9999999)

08/14/2012 P1 SR MOTION(19886964) SENT BY EXPRESS MAIL. TO: LARRY ELLIOT KLAYMAN2020 PENNSYLVANIA AVE NW STE 345 WASHINGTON, DC 20006-0000

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 INCLUDEINTEREST AT STATUTORY RATES; AND MOTION FOR ATTORNEY FEES VIA USEXPRESS MAIL TO LARRY ELLIOT KLAYMAN. FILED.

08/13/2012 P1 SR INSTRUCTION FOR SERVICE ON MOTION TO SHOW CAUSE (PETITIONERSVIOLATION OF JUDGMENT ENTRY OF JUNE 22, 2011), MOTION TO INCLUDEINTEREST AT STATUTORY RATES; AND MOTION FOR ATTORNEY FEES VIAEXPRESS MAIL TO LARRY ELLIOT KLAYMAN. FILED.

08/10/2012 D1 CS CLERK FEE POSTAGE FOR EXPRESS MAIL08/08/2012 P1 SR MOTION(19835666) SENT BY EXPRESS MAIL. TO: LARRY ELLIOT KLAYMAN

2020 PENNSYLVANIA AVE NW STE 345 WASHINGTON, DC 20006-000008/07/2012 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 PAID08/07/2012 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. .08/07/2012 P1 SR INSTRUCTION FOR SERVICE ON MOTION TO SHOW CAUSE (PETITIONERS

VIOLATION OF JUDGMENT ENTRY OF JUNE 22, 2011); MOTION TO INCLUDEINTEREST AT STATUTORY RATES; AND MOTION FOR ATTORNEY FEES VIAEXPRESS MAIL TO LARRY ELLIOT KLAYMAN. FILED.

07/30/2012 P JE ****CA**** JUDGMENT: AFFIRMED. O.S.J. NOTICE ISSUED05/11/2012 N/A SH CUYAHOGA COUNTY SHERIFF DEPT DISPOSITION: SUBJECTED APPEAR IN


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COURT. CAPIAS RETURNED UNEXECUTED. SERVICE FEE $6.0005/03/2012 N/A JE PLTF, LARRY ELLIOT KLAYMAN HAVING APPEARED, THE DOMESTIC

RELATIONS CAPIAS IS RELEASED. COURT COSTS ADJUDGED AGAINSTLARRY 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 ITSENTIRETY. NO TIMELY OBJECTIONS WERE FILED AND THEREFORE PARTIESARE FOUND TO HAVE WAIVED THEIR RIGHT TO ANY FURTHER HEARINGTHEREON. THE GAL'S MOTION FO RFEES #310671, IS GRANTED. PLTF SHALLPAY TO THE GAL THE SUM OF $18,487.50 AS AND FOR GAL FEES..DEFTSHALL PAY $1,000.00 FOR WHICH JUDGMENT IS RENDERED AND EXECUTIONSHALL ISSUE. COSTS ADJUDGED AGAINST PLTF O.S.J. NOTICE ISSUED

04/20/2012 P JE AGREED JUDGMENT ENTRY REGARDING CHILD SUPPORT ARREARAGE ANDWITHDRAWAL OF CAPIAS. O. S. J. NOTICE ISSUED

04/19/2012 P1 MO P1 LARRY ELLIOT KLAYMAN JOINT MOTION TO VACATE CAPIAS... ROGER LKLEINMAN 0022272

04/12/2012 N/A JE ********C/A********** MOTION BY APPELLANT TO SUPPLEMENT THE RECORD ISDENIED. NOTICE ISSUED. O.S.J. NOTICE ISSUED

03/06/2012 N/A JE **********C/A*********** MOTION BY APPELLEE FOR LEAVE TO SUBMITSUPPLEMENTAL 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 ATTEMPTEDWITHDRAWAL TO MOTION TO SUPPLEMENT IS DENIED AS MOOT. THIS COURTGRANTED THE MOTION TO WITHDRAW SUPPLEMENTAL SUPPORT ANDORDERED THAT THE MOTION AND OPPOSITION TO BE STRICKEN FROM THERECORD. NOTICE ISSUED. O.S.J. NOTICE ISSUED

03/01/2012 N/A JE APPELLEE'S NOTICE OF WITHDRAWAL OF MOTION FOR LEAVE TO SUBMITSUPP. SUPPORT IS GRANTED. THE MOTION FILED FEBRUARY 8, 2012 ANDTHE OPPOSITION FILED FEBRUARY 2,1 2012 ARE STRICKEN FROM THERECORD. O.S.J. NOTICE ISSUED

02/23/2012 P JE FOR GOOD CAUSE SHOW, PURSUANT TO APPELLATE RULE 9(E) THERECORD SHALL BE SUPPLEMENTED WITH THE FULL TRANSCRIPT OF THEPROCEEDINS BEFORE MAGISTRATE LAWRENCE L LOEB. THIS COURT IS OFTHE UNDERSTANDING THAT THE FULL TRANSCRIPT WAS FILED WITH THECOURT 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 VOLUMES02/07/2012 P1 MO P1 LARRY ELLIOT KLAYMAN MOTION TO SUPPLEMENT THE RECORD....W......

ROGER L KLEINMAN 002227210/13/2011 P JE ORDER FOR CAPIAS - PETITIONER CASH BOND $5,000.00 IN THE EVENT

PETITIONER POSTS SAID BOND AND IS RELEASED. SAID PERSON SHALLAPPEAR IN ROOM 187 AT 9:00 AM ON THE COURTS NEXT SCHEDULEDBUSINESS 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 ADJUDGEDAGAINST LARRY ELLIOT KLAYMAN O.S.J. NOTICE ISSUED

09/21/2011 N/A JE *******C/A******** MOTION BY APPELLANT TO EXTEND TIME TO FILE THERECORD 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 PENDINGAPPEAL 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 APPEALSCONSISTING OF THE TRANSCRIPT OF THE DOCKET, JOURNAL ENTRIES ANDTHE ORIGINAL PAPERS ON CA NO. 97075.

08/18/2011 P1 CA APPELLANT'S 9B RECORD TRANSMITTED TO THE COURT OF APPEALSCONSISTING OF THE TRANSCRIPT OF THE DOCKET, JOURNAL ENTRIES ANDTHE ORIGINAL PAPERS ON CA NO. 97074.

08/15/2011 N/A AF AFFIDAVIT OF STEPHANIE DELUCA FILED08/04/2011 P JE PLTF'S MOTION TO STAY EXECUTION IS DENIED. O.S.J. NOTICE ISSUED08/01/2011 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 OFAPPEALS ON CA NO. 97074 & 97075. 2 BOXES OF EXHIBITS.

07/29/2011 P1 MO P1 LARRY ELLIOT KLAYMAN MOTION FOR STAY OF EXECUTION PENDINGAPPEAL ROGER L KLEINMAN 0022272

07/21/2011 P1 CA -------------------- NOTICE OF APPEAL -------------------- CA NO. 97075 NOTICE OFAPPEAL FILED BY THE PLTF. APPELLANT W/A 9B PRAECIPE AND DOCKETINGSTATEMENT ON THE REGULAR CALENDAR. COPIES MAILED.

07/21/2011 P1 CA -------------------- NOTICE OF APPEAL -------------------- CA NO. 97074 NOTICE OFAPPEAL FILED BY THE PLTF. APPELLANT W/A 9B PRAECIPE AND DOCKETINGSTATEMENT ON THE REGULAR CALENDAR. COPIES MAILED.

07/13/2011 N/A CS COURT COST ASSESSED LARRY ELLIOT KLAYMAN BILL AMOUNT 3632.8 PAIDAMOUNT 206 AMOUNT DUE 3426.8 NOTE: ANY ADDITIONAL COURT COST WILLBE BILLED AT A LATER DATE

06/24/2011 N/A JE THE COURT ADOPTS THE MAGISTRATE'S DECISION FILED 07/02/2010 IN ITSENTIRETY. OBJECTIONS WERE FILED TO MAGISTRATES DECISION PURSUANTTO RULE 53. AFTER CONSIDERATION; SAID OBJECTIONS ARE HEREBYOVERRULED AND THE DECISION OF THE MAGISTRATE HEREBY ADOPTED.PETITIONER'S MOTION TO WITHDRAW CAPIA ( #291722) IS DISMISSED W/OPREJ. 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 ISIN CONTEMPT OF COURT FOR FAILING TO COMPLY W/ THIS COURT'S ORDEROF AUG. 28, 2007. COSTS PETITIONER, LARRY E. KLAYMAN. O.S.J. NOTICEISSUED

06/22/2011 P JE THE COURT ADOPTS THE MAGISTRATE'S DECISION FILED JUNE 9, 2010 IS ITSENTIRETY. IT IS HEREBY ORDERED: AFTER CONSIDERING THE MAGISTRATE'SDECISION FILED JUNE 9, 2010, PLEADINGS, EXHIBITS, AND COMPLETETRANSCRIPT, PETITIONER'S HEREBY OVERRULED AND THE DECISION OF THEMAGISTRATE ADOPTED WITHOUT MODIFICATION ... COSTS ADJUDGEDAGAINST THE PLTF ... O.S.J. NOTICE ISSUED

06/13/2011 P JE PLTF'S MOTION FOR LEAVE TO FILE REPLY BRIEF IN SUPPORT OFOBJECTIONS #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 INSUPPORT OF OBJECTIONS ROGER L KLEINMAN 0022272

05/23/2011 D1 OT D1 STEPHANIE ANN LUCK RESPONSE TO SUPPLEMENTAL OBJECTIONS TOMAG'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 ISSUED05/05/2011 P JE RESPONDENT'S MOTION FOR TIME EXTENSION IS GRANTED. RESPONSES

SHALL BE DUE BY MAY 12 2011.... O.S.J. NOTICE ISSUED05/03/2011 D1 MO D1 STEPHANIE ANN LUCK MOTION FOR EXTENSION OF TIME FOR

RESPONDENT TO RESPOND TO PETITIONER'S SUPPLEMNTAL OBJECTIONSREQUEST FOR ORAL ARGUMENT FILED ON APRIL 22,2011 "W" SUZANNE M


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1/8/14 Larry Klayman - The One Man TEA Party | Red County

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Larry Klayman - The One Man TEA Party 8371reads

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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 governmentare corrupt to the core then you need to read Larry's book, WHORES: Why and How I Came to Fight the Estab lishment. (/web/20120419054811/http://www.amazon.com/WHORES-Why-Came-Fight-

Establishment/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 behindthe scenes get his book. I just finished reading WHORES (/web/20120419054811/http://www.amazon.com/WHORES-Why-Came-Fight-Establishment/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. Ifound 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, BillMcCollum 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.judicialwatch.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 thatLarry, 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 thecourt 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.worldnetdaily.com/index.php?fa=PAGE.view&pageId=184165) , dozens of pro-life organizations are already asking the Senate to investigate Kagan's 1997 amendment to anAmerican 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 Courtas 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-images/Kagan-Ethics-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-Fight-Establishment/dp/0979201225) and make it a point to learn more about thegreat 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 - agrass roots revolution to save the Republic.

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Comments

Time for TRUE leaders... (/w eb/20120419054811/http://w w w .redcounty.com/content/larry-klayman-one-man-tea-party#comment-52359)

Submi tted 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.

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Sweep the bums out- when? (/w eb/20120419054811/http://w w w .redcounty.com/content/larry-klayman-one-man-tea-party#comment-70459)

Submi tted by George M i 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 partycandidates

CITIZEN'S GRAND JURY (/w eb/20120419054811/http://w w w .redcounty.com/content/larry-klayman-one-man-tea-party#comment-53534)

Submi tted 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, itis time the People did. Save America !!!! Pray for America !!!!! GOD BLESS AMERICA !!!!!!

Highly recommend this book... (/w eb/20120419054811/http://w w w .redcounty.com/content/larry-klayman-one-man-tea-party#comment-55113)

Submi tted by M ar 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, Whoresand give it to all my fr iends to read about a true patriot. Larry will always fight for what is r ight.

Remember the Bastille (/w eb/20120419054811/http://w w w .redcounty.com/content/larry-klayman-one-man-tea-party#comment-59950)

Submi tted by Anonymous (not ver i f i ed) on Sat, 2011-01-15 21:50.

Remember the Bastille (/web/20120419054811/http://www.wnd.com/index.php?fa=PAGE.view&pageId=251053) : http://www.wnd.com/index.php?fa=PAGE.view&pageId=251053(/web/20120419054811/http://www.wnd.com/index.php?fa=PAGE.view&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=5iPM3TGcef4&feature=player_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 abully when I read one.

Remember the Bastille (/w eb/20120419054811/http://w w w .redcounty.com/content/larry-klayman-one-man-tea-party#comment-59972)

Submi tted by Lar ry 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 civilunrest. 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 likelihoodfor 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 ofPresident 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 (/w eb/20120419054811/http://w w w .redcounty.com/content/larry-klayman-one-man-tea-party#comment-65051)

Submi tted by Anonymous (not ver i f i ed) on M on, 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!


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Related Articles

Thanks for your efforts and books and for taking on FB Larry! You're a real hero!

Comic relief (/w eb/20120419054811/http://w w w .redcounty.com/content/larry-klayman-one-man-tea-party#comment-68031)

Submi tted by smtoth (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://americanloons.blogspot.com/2011/05/213-larry-klayman.html)

He does provide comic relief with his frivolous lawsuits.

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Attachment F


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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 1/2

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By Jennifer Harper - The Washington Times Tuesday, December 17, 2013

There’s still a fire in his belly and multiple causes in his heart. Lawyer and longtime conservative legalgadfly Larry Klayman(/topics/larry-klayman/) , the man behind the first successful lawsuit against theNational Security Agency(/topics/national-security-agency/) ’s mass surveillance programs, remainsready 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 thisweek 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 ofAmericans.

It was the first major setback for the federal government in court after the sensational revelations byformer 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/) andObama 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 forhis grandmother — his own mother.

Journalist Geraldo Rivera(/topics/geraldo-rivera/) once called him a legal wild man, and BillClinton(/topics/bill-clinton/) strategist James Carville(/topics/james-carville/) referred to him as “a littletwerp.” An opposing lawyer described him as snide and argumentative, and a Midwestern newspaperclaimed 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 ona bedrock of principle.

“I think this attitude is something you’re born with. I don’t like when people lie to me. It gets under myskin,” 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 takeoffense. That’s what keeps me going.”

After Mr. Snowden(/topics/edward-snowden/) ’s leaks this year concerning vast government collectionprograms of Americans’ phone records and metadata, Mr. Klayman(/topics/larry-klayman/) filed suitJune 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 theveteran lawyer and activist, ruling that the clandestine agency(/topics/national-security-agency/) ’scollection of citizen phone calls likely violated the Fourth Amendment. Although the administrationstrongly rejected the ruling and the judge stayed his own decision in the face of a near-certainappeal, 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 hiswillingness 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 ownmother 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 nation’s 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 undercontrol and to be watched by the courts in a way that is transparent to the public. And I want people toknow what is at stake here. We’ve learned that every American is under surveillance and manybelieve that there will be retaliation against them. It’s like a police state worse than anything GeorgeOrwell 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 ifthere are genuine links to terrorism,” Mr. Klayman(/topics/larry-klayman/) said. “Still, I want the courts tostep 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 arespilled, 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 shouldn’t havecollaborated with Russia. But he forced the NSA(/topics/national-security-agency/) to admit to what theywere doing,” he said.


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Attachment G


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THANK GOD FOR LARRY KLAYMANPublished: 11/25/1998 at 1:00 AM

JOSEPH FARAH (HTTP://WWW.WND.COM/AUTHOR/JFARAH/) About | Email (mailto:[email protected]) |Archive (http://www.wnd.com/author/jfarah/?archive=true)

Follow 8,703 follow ers Receive author alerts Subscribe to feed (http://www.wnd.com/author/jfarah/feed)

0

Fact: The biggest donor to Bill Clinton’s 1992 presidential campaign — bigger than the teachers union or anypolitical action committee — was the Riady family, long suspected of being Chinese intelligence agents.

Fact: The Riadys had been sponsors of Clinton’s political campaigns since the 1970s when he first ran for attorneygeneral in the state of Arkansas.

Fact: The largest individual donor to the 1996 Clinton re-election effort was Bernard Schwartz, chairman and chiefexecutive officer of the Loral Corp. One of Loral’s biggest business partners and investors is the government ofChina 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 inclean-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 PresidentClinton, 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 influencethe 1996 U.S. elections, yet Clinton did nothing — he didn’t expel the Chinese ambassador, he didn’t invoke tradesanctions, he didn’t even harshly rebuke Beijing.

On and on it goes. From the sweetheart treatment of the COSCO shipping company to the “back channels” of WhiteHouse access provided by John Huang, the China-gate scandal remains, without doubt, a cover-up of historicproportions. 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 herdecision not to name an independent counsel to investigate Vice President Al Gore’s involvement with illegal campaignfund-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 officialcriminal 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-gatescandal. Named as defendants in the shareholder derivative, civil conspiracy and RICO action are Loral Chairman andCEO Bernard Schwartz, Clinton, first lady Hillary Clinton, Gore, Huang, the DNC, the Democratic Senatorial CampaignCommittee, the Democratic Congressional Campaign Committee and others.

As corrupt as Reno’s 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 campaigncontributions from China and the possibility of bribes and influence peddling, has shown little indication his probe isgoing anywhere fast.

(http://www.wnd.com/1998/11/1257/print/)


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It’s time to step up and take your best shot, Mr. Cox. Do it now, while there’s still a chance America can recover from thenational-security damage done by this administration. If you’re not prepared to tell us what you found and add to the listof impeachment counts, step aside and let Larry Klayman do the job.

Likewise, Ken Starr, if you’re all through with Filegate and have decided to exonerate the president of wrongdoing, whynot let Larry Klayman have a shot at interviewing those witnesses you overlooked and examining the evidence youdetermined to be insufficient.

* * *

When it comes to justice in America, it’s not easy maintaining your faith in the system anymore. But that’s why thisThanksgiving season, I’m grateful for the courageous and determined work of Larry Klayman and a few other gutsy,independent, relentless freedom fighters. It’s amazing the impact committed individuals can make when they put theirmind to it.

I thank God there are still a few heroes left. Likewise, I thank God for Jerome Zeifman, the former Watergate chiefcounsel, who, unlike Sam Dash, maintains one simple standard for impeachable offenses — one not colored by whichpolitical 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 throughcyberspace 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 there’s nothing to be thankful for?

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Attachment H


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LARRY KLAYMAN, MY HEROPublished: 11/03/1999 at 1:00 AM



3

People sometimes ask me who my heroes are. After all, I’d behard-pressed to name any contemporary politicians I trust or look to forleadership and courage.

There is such a man. He’s not a politician. He is an activist. But heis one who has integrity — enough to prevent him from blind loyalty toparty or ideology and keep him focused on principle.

His name is Larry Klayman and he founded the organization known asJudicial Watch. (http://www.judicialwatch.org)

Some people have asked me if Larry is crazy, if he’s a zealot, or ifhe has all of his oars in the water. If you don’t know Larry personally,it might be easy to confuse him with a loose cannon. That’s because heis fearless and relentless in the pursuit of justice. That’s a rarecommodity today in America. It wasn’t always like that. There were othermen like Larry early in American history. Their names were Washington,Jefferson, Madison and Henry. They don’t make ‘em like that any more. Atleast not many. Larry is an exception.

So, why am I telling you all about my friend and my attorney, LarryKlayman?

A couple of reasons. I believe that in the next several weeks youwill see an intensification of the establishment political attacks onhim. I’m not sure what form they will take. They might be physicalattacks. They might be character assaults. All I can tell you is LarryKlayman is a dangerous man if you are a corrupt politician. And thiscountry is a breeding ground of corrupt politicians.

The Democratic National Committee is investigating Larry the way theyonce investigated me — running the Lexis-Nexis searches, collectingdossiers and preparing a muckraking report for “journalists” eager to dothe bidding of partisan hatchet wielders.

Just know this: No matter what you hear, no matter what you read, nomatter 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 isLarry Klayman is an American hero.

I don’t make that statement lightly. I don’t make that statementfrequently. But I make it without any reservations about Larry Klayman.

One thing about these Clintonistas: When you expose them, they comeafter you. There’s nothing subtle about the way this administration goesafter its enemies.



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Klayman’s been a target before, and he will be a target again. Iremember when they came after him the last time with an orchestratedsmear campaign in the media.

You can bet the White House’s team of “private investigators” (theywere called “plumbers” in another disgraced administration) dug up the“dirt.”

Just a week or so ago, Clinton himself referenced Larry Klayman byname as a source of irritation so great it forced him to rethink hisillegal deal to purchase a home with a loan that could only becharacterized as a bribe from a major political contributor.

Why are they coming after Larry now? Because, in many ways, Larry andJudicial Watch represent the only game in town. The independent counselis gone. The Justice Department is thoroughly corrupt. The Congress ishopelessly compromised and fearful. The media, by and large, are sittingthis one out.

Everyone is just waiting for Clinton’s term to expire — except LarryKlayman.

And he’s got some important cases on his plate. He’s in the thick ofexposing virtually every major scandal involving the White House — andsome most people have never even heard about. He’ll be taking somecritical depositions in the coming weeks. And the Clinton forces arepreparing, as James Carville would say, ” for war.”

Don’t worry about Larry Klayman backing down in the face of suchpressures. They will only serve to embolden him. Larry Klayman will dowhat is right — no matter who is involved. Klayman is a guy who nevershrinks from his standards of ethics and morality. He’s a man who looksto no one but God for guidance and direction. He’s just the kind ofperson we need in times like this.

Which is why I am also pleased to tell you the next piece of news: Iam happy to report that Judicial Watch’s Larry Klayman will be joiningWorldNetDaily as a regular weekly columnist next week. I am honored thathe would choose this forum to share his keen insights with the Americanpublic. Look for his column each Tuesday.

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Attachment I


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LARRY KLAYMAN FOR U.S. SENATEPublished: 08/26/2004 at 1:00 AM



1

People sometimes ask me who my heroes are. After all, I’d be hard-pressed to name any contemporary politicians I trustor look to for leadership and courage.

There is such a man. He’s 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 andkeep him focused on principle.

Some people have asked me if Larry is crazy, if he’s a zealot, or if he has all of his oars in the water. If you don’t knowLarry personally, it might be easy to confuse him with a loose cannon. That’s because he is fearless and relentless inthe pursuit of justice. That’s a rare commodity today in America. It wasn’t always like that. There were other men likeLarry early in American history. Their names were Washington, Jefferson, Madison and Henry. They don’t make ‘em likethat any more. At least not many. Larry is an exception.

That’s why I am doing something very unusual for me today – I am formally and personally endorsing Larry Klayman inhis uphill bid for the U.S. Senate. The primary election is next Tuesday and you still have a chance to send him acontribution (http://www.klaymansenate.com) or at least hold him up in your prayers in the next few days.

Why do I think it’s so important to elect Larry Klayman to the U.S. Senate?

Because Larry Klayman is an anti-establishment candidate. He is in nobody’s pocket. He’s a man of character andprinciple. 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 theU.S. Senate. We all have an opportunity to make a real difference, a real impact on American government by getting himelected.

Larry Klayman is not running for the U.S. Senate because he wants to participate in a debating society. He’s runningbecause he wants to get America back on track with its constitutional form of government. One of the cornerstones ofhis 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 that’s my friend Larry Klayman. He doesn’t listen to polls. He listens to his heart and his mind. And he listens to theConstitution and the law of the land.

Larry Klayman is an American hero. I don’t make that statement lightly. I don’t make that statement frequently. But Imake it without any reservations about Larry Klayman.

Don’t 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 guywho never shrinks from his standards of ethics and morality. He’s a man who looks to no one but God for guidance anddirection. He’s just the kind of person we need in times like this.



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That’s why I am standing behind Larry Klayman for the U.S. Senate.

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Rembrandt Q. Eins tein • 3 months ago

"To be honest with you, I never thought I would see the day that Larry Klayman was actually a seriouscandidate for the U.S. Senate."

You still haven't.


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Attachment J


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In The Matter of:

LARRY E. KLAYMAN

vs.

JUDICIAL WATCH, INC.

___________________________________________________

PAUL ORFANEDES, ESQUIRE

January 27, 2014

___________________________________________________


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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


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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


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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


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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


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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


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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 09:22:06No. 1 in the deposition of Paul Orfanedes in the

4 09:22:10matter of Larry E. Klayman versus Judicial Watch,

5 09:22:12Incorporated in the United States District Court for

6 09:22:16the Southern District of Florida, Case No.

7 09:22:2213-20610-CIV.

8 09:22:22 Today's date is January 27th, 2014. The

9 09:22:26time on the video monitor is 9:22 a.m. and the video

10 09:22:31operator -- excuse me -- the video operator today is

11 09:22:33Akim Graham. This video deposition is taking place

12 09:22:37at 1325 G Street, Northwest in Washington, D.C.

13 09:22:39 Counsel, please voice identify yourselves

14 09:22:44and state whom you represent.

15 09:22:45 MR. KLAYMAN: I'm Larry Klayman. I am

16 09:22:47counsel for the plaintiff pro se.

17 09:22:49 MR. KRESS: Douglas Kress, counsel for

18 09:22:53Judicial Watch, Inc.

19 09:22:54 THE VIDEOGRAPHER: The court reporter today

20 09:22:55is Joan Cain of Merrill LAD. Would the reporter

21 09:22:57please swear in the witness.

22 09:22:57 PAUL ORFANEDES


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Page 7

1 09:22:57having been duly sworn, was examined and did testify

2 09:23:07as follows:

3 09:23:08 EXAMINATION BY COUNSEL FOR PLAINTIFF PRO SE

4 09:23:08BY 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 09:23:14law school?

9 09:23:16 A 1990.

10 09:23:17 Q Okay. You've been a lawyer continuously

11 09:23:20since then?

12 09:23:21 A Mm-hmm.

13 09:23:21 Q Can you list for us just briefly your

14 09:23:23professional background, where you've worked?

15 09:23:31 A Certainly. I started off working -- I was

16 09:23:35a law clerk -- do you want -- does that include --

17 09:23:41 Q Everything you've done in your legal

18 09:23:42capacity.

19 09:23:43 A I was a law clerk for a guy named Steve

20 09:23:47Trattner while I was in law school. I don't

21 09:23:50remember for how long. It was primarily trademark

22 09:23:54work. I worked at a law clinic while I was at AU.


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Page 8

1 09:24:02We did a variety of different types of work. I was

2 09:24:04a law clerk at a law firm called Connerton Ray &

3 09:24:09Simon here in Washington. They hired me as an

4 09:24:13attorney 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 09:24:25and then I went to work at Klayman & Associates,

10 09:24:28your firm, I believe it was September 1992. At some

11 09:24:31point I became an employee of Judicial Watch. I

12 09:24:35don't remember when. There was some overlap in my

13 09:24:39capacity as an attorney for Klayman & Associates and

14 09:24:42an attorney for Judicial Watch. At some point I

15 09:24:44became a full-time attorney with Judicial Watch and

16 09:24:47I've been there ever since.

17 09:24:48 Q I left Judicial Watch on September 19,

18 09:24:522003. 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 09:24:56for about 11 years?

22 09:24:57 A Yes.


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Page 9

1 09:24:58 Q Okay. And during the time that you worked

2 09:25:01with 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 09:25:12long working with me then?

6 09:25:13 A It was an interesting opportunity. I

7 09:25:16enjoyed the work. I had a lot of freedom to do a

8 09:25:19lot of work that I liked.

9 09:25:21 THE VIDEOGRAPHER: Excuse me. I'm getting

10 09:25:22a little bit of interference maybe from someone's

11 09:25:25phone.

12 09:25:25 MR. KRESS: Could be mine.


14 09:25:28 Q During that time period we tried some cases

15 09:25:31together, 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 09:25:48dispute, Lanham Act claim; Washington, D.C.;

22 09:25:54Seattle. I don't remember other places, maybe


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Merrill LAD

Page 10

1 09:25:57California.

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 09:26:08cases 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 09:26:21terms of what we were doing, particularly with

11 09:26:23regard 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 09:26:38very 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 09:26:45why did you stay with Judicial Watch?

20 09:26:47 A I said I enjoyed the work. I enjoyed some

21 09:26:49of the people. I had a lot of freedom. It was a

22 09:26:52decent -- it was a good choice for me.


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Page 11

1 09:26:54 Q So you'll continue to work with people you

2 09:26:56don'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 09:27:05you didn't think was reputable if you enjoyed that

6 09:27:08work that he was doing and you were doing?

7 09:27:09 A Oh, I think it depends on the

8 09:27:11circumstances.

9 09:27:15 Q Would you work with a law firm that you

10 09:27:17thought is unethical?

11 09:27:20 A No.

12 09:27:21 Q Would you work with a public interest group

13 09:27:24that you thought was unethical?

14 09:27:25 A No.

15 09:27:27 Q And you're still working for Judicial

16 09:27:29Watch, 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 09:27:37secretary. I'm the corporate treasurer. I'm the

21 09:27:40director of litigation, the head of the legal

22 09:27:43department, the chief lawyer for the organization,


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Page 12

1 09:27:47and I'm a member of the Board of Directors.

2 09:27:50 Q Who else is -- is on the Board of

3 09:27:53Directors?

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 09:27:59the Board of Directors since I left Judicial Watch

7 09:28:01in 2003?

8 09:28:02 A No.

9 09:28:04 Q And what is Chris Farrell's position with

10 09:28:06Judicial Watch?

11 09:28:07 A Well, I had just said he's on the Board of

12 09:28:10Directors and he is the head of the research and

13 09:28:12investigations 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 09:28:18president 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 09:28:26yourself. There was never an official position, I

22 09:28:29believe, under the bylaws that was called chairman.


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Page 13

1 09:28:32 Q Did you ever refute the fact that I was

2 09:28:34chairman when I was working with you?

3 09:28:36 A Well, like I said, it was a title that you

4 09:28:38used. I don't think it was -- I don't believe that

5 09:28:41there was an official position called chairman as

6 09:28:46set forth in the bylaws of the organization.

7 09:28:49 Q So the three people that you just

8 09:28:51mentioned, yourself, Chris Farrell, Tom Fitton,

9 09:28:54you're the ones that make the decisions at Judicial

10 09:28:56Watch, 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 09:29:03make lots of decisions. We --

15 09:29:07 Q I'm talking about in terms of the

16 09:29:08governance 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 09:29:18the issue that we're here today about, okay, the

20 09:29:21publication in Orly Taitz's web site, World's

21 09:29:30Leading Obama Eligibility Challenge Web Site.

22 09:29:31You're aware of that web site?


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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 09:29:39something -- my recollection is you sent us

5 09:29:42something complaining about a comment that was

6 09:29:44posted 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 09:29:50the court reporter to mark as Plaintiff's Exhibit 1.

9 09:29:53 (Plaintiff's Deposition Exhibit 1 was

10 09:29:53marked for identification and was attached to the

11 09:30:21deposition transcript.)

12 09:30:21 MR. KRESS: Can we go off the record for

13 09:30:23one second?

14 09:30:23 THE VIDEOGRAPHER: Going off the record.

15 09:30:25The time is 9:30 a.m.

16 09:30:30 (Recess.)

17 09:31:13 THE VIDEOGRAPHER: Back on the record. The

18 09:31:15time is 9:31 a.m.


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?


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Page 15

1 09:31:32 A It was after you had sent us whatever

2 09:31:38communication you sent us complaining about a

3 09:31:40posting 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 09:31:56be attorney-client privilege or attorney work

11 09:31:59product.

12 09:31:59 Q The fact that you had a discussion would

13 09:32:04not 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 09:32:08of that discussion you could perhaps --

17 09:32:09 A Okay. Yes. You're right about that. If I

18 09:32:11did have a discussion, and I don't recall any

19 09:32:13specific discussions with Mr. Farrell or Mr. Fitton,

20 09:32:16those discussions would have been privileged or

21 09:32:17subject to attorney work product.

22 09:32:20 Q You had no discussions because you were


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Page 16

1 09:32:22really not really concerned what Ms. Ruffley had

2 09:32:26said about me, correct?

3 09:32:27 A I don't know what Ms. Ruffley said, if

4 09:32:28anything, 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 09:32:35said, and I'm reading from it. I'm looking at the

9 09:32:38second page. "My yesterday's presentation to CCIR

10 09:32:41and update on article2superPAC - Larry Klayman

11 09:32:47$25,000 fundraising for non-existent law suit

12 09:32:51affair."

13 09:32:52 A I'm sorry. I don't know what -- I don't

14 09:32:54seem 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 09:32:57That is not what this document says.

18 09:33:00 MR. KLAYMAN: Okay. Yeah, mark that as

19 09:33:07Exhibit 2.





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1 09:33:18 THE WITNESS: Okay.


3 09:33:20 Q Do you see where I read, "My yesterday's

4 09:33:20presentation to CCIR and update on article2superPAC

5 09:33:20- Larry Klayman $25,000 fundraising for non-existent

6 09:33:32law 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 09:34:01states, Article2superpac $25,000 solicitation for

12 09:34:01Larry Klayman, Screen shot $25,000 solicitation for

13 09:34:01Larry Klayman lawsuits, February 10, 2012.

14 09:34:16 Yesterday I gave a 2-hour presentation on

15 09:34:19my platform as a candidate for the U.S. Senate. The

16 09:34:22presentation was given to some 100 California voters

17 09:34:24in the Women's club of Garden Grove. I was told

18 09:34:27that a representative of the Judicial Watch drove

19 09:34:30for over an hour from San Marino to hear me speak

20 09:34:34and talk to me. I got a very warm reception. After

21 09:34:37my presentation people stood up and applauded.

22 09:34:40 The member of the Judicial Watch approached


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1 09:34:42me and gave me her card. Her name is Constance

2 09:34:46Ruffley and she is an office administrator for the

3 09:34:49Judicial Watch in their Western Regional

4 09:34:51Headquarters at 2540 Huntington drive, San Marino.

5 09:34:55She told me that she used to work for the FBI and

6 09:34:58that she worked for the Judicial Watch for many

7 09:35:00years. She actually initiated the discussion about

8 09:35:02Larry Klayman and told me that she had heard that he

9 09:35:04is involved in birther cases.

10 09:35:07 I told her that this group,

11 09:35:08article2superpac, was soliciting money and they sent

12 09:35:11an e-mail and posted on their site an advertisement

13 09:35:14on February 10th asking for $25,000, claiming that

14 09:35:18they need to raise $25,000 in 96 hours, as the cases

15 09:35:22in Florida and California need to be filed within a

16 09:35:25week. I told her that it was a hard sell, they

17 09:35:28wrote -- they wrote it is now or never, saying

18 09:35:33finally Obama's team met their match, dissing 4

19 09:35:39years of my tireless work in the process, and in the

20 09:35:42end nothing was filed by Larry Klayman. It is not

21 09:35:44clear what happened to all the money that was

22 09:35:47raised, who got it.


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1 09:35:49 Ms. Ruffley actually advised me that Larry

2 09:35:51Klayman is not licensed in California. She told me

3 09:35:54that he no longer works with the Judicial Watch and

4 09:35:56that donors should know about the litigation in Ohio

5 09:35:59where he was convicted just recently of not paying a

6 09:36:02large amount in child support. She provided a lot

7 09:36:05of other information. I will publish only what is

8 09:36:08in the public record. I am not publishing anything

9 09:36:11that 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 09:36:18reviewed at the time that you've just referenced,

14 09:36:21correct?

15 09:36:21 A I believe I did review it.

16 09:36:23 Q Okay. And when you reviewed it, you

17 09:36:25discussed it with Mr. Fitton, correct?

18 09:36:29 A I'm not getting into the substance of any

19 09:36:31discussion I had with --

20 09:36:31 Q I'm asking whether you had a discussion

21 09:36:33with Mr. Fitton.

22 09:36:34 A You tried to characterize the discussion.


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1 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 09:36:40a discussion is not covered by attorney-client

5 09:36:42privilege.

6 09:36:44 A I've acknowledged that I had a

7 09:36:46discussion -- well, I don't remember what my -- I

8 09:36:50don't believe I have a specific recollection of a

9 09:36:51discussion with Mr. Fitton about this article.

10 09:36:54 Q During the Clinton years, the Clinton

11 09:36:57people used to claim they had no specific

12 09:37:01recollection. 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 09:37:04me?


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 09:37:11phrase, "I have no specific recollection"? What

21 09:37:13does no specific recollection mean? You have a

22 09:37:21recollection but you can't remember now; is that


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1 09:37:23what it means?

2 09:37:23 A I don't recall any specific recollection

3 09:37:25with Mr. Fitton about this posting.

4 09:37:26 Q What -- if you don't have a specific

5 09:37:29recollection, tell me your general recollection.

6 09:37:31 A I have a general recollection -- I -- I

7 09:37:34don't even recall -- I'm saying I may have had a

8 09:37:37discussion with him about it. I don't recall if I

9 09:37:40had a discussion with him about it.

10 09:37:42 Q You didn't think this was very important,

11 09:37:44did 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 09:37:59Ruffley told Orly Taitz that I was convicted of a

15 09:38:03crime?

16 09:38:03 MR. KRESS: Objection to form. You can

17 09:38:04answer.

18 09:38:05 THE WITNESS: I don't know that Connie

19 09:38:06Ruffley made any such statement to Orly Taitz.


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 09:38:15hypotheticals.

2 09:38:16 Q Well, you -- that's permissible under the

3 09:38:17rules of evidence. Now, if someone makes a

4 09:38:19statement that a lawyer committed a crime, that's

5 09:38:22significant; is it not?

6 09:38:23 MR. KRESS: Objection to form.

7 09:38:25 THE WITNESS: Not necessarily.


9 09:38:25 Q No? You're aware that lawyers can lose

10 09:38:28their bar license if they're convicted of a crime,

11 09:38:30correct?

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 09:38:36is a felony; is it not?

17 09:38:37 A I don't know. I'm not a -- I'm not

18 09:38:39familiar with Ohio law, but it would seem to be a

19 09:38:42substantial offense.

20 09:38:43 Q So, therefore, it was a significant

21 09:38:45statement?



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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 09:38:55this statement as alleged.


5 09:38:56 Q Have you ever talked to Connie Ruffley

6 09:38:58about it?

7 09:39:00 A I don't recall if I had a specific

8 09:39:02conversation with her at the time that you had sent

9 09:39:06this note complaining about the posting.

10 09:39:10 Q Did you have a general conversation with

11 09:39:12her?

12 09:39:12 A I don't recall. I might have, but I don't

13 09:39:15recall.

14 09:39:15 Q You realize you're under oath,

15 09:39:17Mr. Orfanedes? You think that's funny?

16 09:39:22 A I think your attempt to intimidate people

17 09:39:26is amateurish.

18 09:39:28 Q No, I'm not attempting to intimidate you.

19 09:39:31I just asked for a straight answer. Will you give

20 09:39:34me 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 09:39:38you? Please define it.

2 09:39:41 A I don't recall any particular details of a

3 09:39:44conversation I may have had with Connie about this

4 09:39:48posting. 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 09:39:54don't recall.

8 09:39:54 Q You and Orfanedes and Farrell got on a

9 09:39:58conference 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 09:40:05got on an a conference call?

13 09:40:07 A No. I would remember that. I don't

14 09:40:08remember 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 09:40:12about this posting. I communicate with her fairly

18 09:40:14regularly.

19 09:40:15 Q You haven't searched your computer for

20 09:40:17e-mails to Connie Ruffley in around this time

21 09:40:19period, 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 09:40:29this time?

5 09:40:29 A Not about this issue -- and actually not

6 09:40:33generally. I tend not to save stuff on my computer,

7 09:40:36but I did look, and there was nothing there.

8 09:40:39 Q Well, you realize that you can recall

9 09:40:42e-mails on a hard drive, correct? Did you ask

10 09:40:45anybody 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 09:40:54after you read this at Judicial Watch? I'm not

14 09:40:58trying to be provocative, but when you give me

15 09:41:01answers that -- like the Clinton people gave me --

16 09:41:04gave us at the time, then obviously it raises

17 09:41:06questions as to whether you're telling me

18 09:41:09everything. So tell me what you know happened after

19 09:41:11you read this at Judicial Watch.



22 09:41:15 THE WITNESS: What I recall doing is


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1 09:41:16sending it to our lawyer, your letter, your

2 09:41:19communication complaining about the posting. I

3 09:41:22think I sent it to our attorney, and I believe he

4 09:41:24wrote a response back to you.


6 09:41:28 Q What -- this was brought -- this posting

7 09:41:31was brought to the attention of Mr. Fitton; was it

8 09:41:34not?

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 09:41:43don't -- is your question -- was it directed only to

13 09:41:46Mr. Fitton or was it directed to Mr. Farrell and

14 09:41:48Mr. 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 09:41:53don't really remember the communication itself.

18 09:41:58 Q Now, as the former -- as the founder -- I

19 09:42:01was 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 09:42:13development and its success.

2 09:42:15 Q Are you claiming to be the founder of


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 09:42:241994, 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 09:42:29besides you and me?

10 09:42:30 A No.

11 09:42:30 Q Okay. So by deduction I was the founder,

12 09:42:36correct?

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 09:42:42organization called Judicial Watch was your idea,

17 09:42:44yes.

18 09:42:44 Q Okay. And I'm the one who authorized

19 09:42:47preparation of Articles of Incorporation and

20 09:42:50incorporation 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 09:42:55Klayman law firm, correct?

2 09:42:57 A That's right.

3 09:42:57 Q You weren't working for Judicial Watch

4 09:42:59then?

5 09:42:59 A I was not an employee of Judicial Watch,

6 09:43:01but I did work for Judicial Watch.

7 09:43:03 Q Right. Okay. So given -- and over the

8 09:43:11next many years up into 2003, September 19th, I

9 09:43:16served as the head of Judicial Watch, correct?

10 09:43:21 A You were the -- you had different titles

11 09:43:23over time. You called yourself chairman. I believe

12 09:43:28after Tom Fitton came in we made him the president.

13 09:43:32 Q And I was the president before that,

14 09:43:34correct?

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 09:43:39Mr. Orfanedes, is that wasn't it of concern to you

18 09:43:42that someone who had founded and run Judicial Watch

19 09:43:46for almost 10 years was being accused of a crime?

20 09:43:55 A I had been aware that there was an arrest

21 09:43:58warrant issued for you in the state of Ohio. I was

22 09:44:02very concerned that that could bear negatively on


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1 09:44:06the organization. I don't remember when I became

2 09:44:09aware of that arrest warrant. So that was of

3 09:44:17concern to me.

4 09:44:17 Q How did you become aware of the arrest

5 09:44:19warrant?


7 09:44:21 Q You and Mr. Fitton and Mr. Farrell made it

8 09:44:23a point of tracking my activities for those 10

9 09:44:27years, 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 09:44:38filed multiple lawsuits against us, had other people

14 09:44:41bring lawsuits against us, filed bar complaints, I

15 09:44:46believe, or had been instrumental in the filing of

16 09:44:48bar complaints against me. So your actions towards

17 09:44:54Judicial Watch and Mr. Fitton and Mr. Farrell and I

18 09:44:59took up a fair amount of our time in the 10 years

19 09:45:01after you left Judicial Watch.

20 09:45:03 Q And as a result of these actions, which you

21 09:45:06testify I took against you, you developed an animus

22 09:45:09toward me, correct?


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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 09:45:21characterize my thinking on that. It's really sort

7 09:45:25of an opinion. I don't know how to characterize it.

8 09:45:29 Q You have to answer. There's no privilege

9 09:45:32here.

10 09:45:33 A I guess I don't know how to answer.

11 09:45:36 Q No specific recollection?


13 09:45:39 THE WITNESS: Well, your question was

14 09:45:40whether I dislike you, I believe --


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 09:45:46recollection about whether I like or dislike you.

19 09:45:48 Q You were concerned that Connie Ruffley

20 09:45:51saying that I have been convicted of a crime could

21 09:45:54reflect negatively on Judicial Watch at the time it

22 09:45:56was made, correct?


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3 09:45:59 THE WITNESS: No, that's not what I was

4 09:46:00saying.


6 09:46:01 Q Didn't really matter?



9 09:46:06 THE WITNESS: I don't even -- I'm not

10 09:46:08really -- I don't really understand where we are.

11 09:46:10Your question is convoluted and I don't understand

12 09:46:13it.


14 09:46:14 Q No, it's very simple. Your concern at the

15 09:46:16time that you read what I just read to you from Orly

16 09:46:21Taitz's web site that the allegation -- or the

17 09:46:23statement of the allegation that I had committed a

18 09:46:24crime and was convicted of it could reflect

19 09:46:27negatively on Judicial Watch?

20 09:46:38 A At some point I became aware that you had

21 09:46:40been indicted in Ohio. I was concerned that that

22 09:46:44could affect negatively on Judicial Watch.


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1 09:46:49 Q You were aware that I was never convicted

2 09:46:51of a crime?

3 09:46:53 A I don't -- I don't know if you've been

4 09:46:55convicted of a crime or not, Larry.

5 09:47:00 Q You've taken the time to review the court

6 09:47:02record in Ohio; have you not?

7 09:47:04 A Oh, subsequent to this, yes, I've looked at

8 09:47:08the court record and I understand that you resolved

9 09:47:11whatever -- you resolved the allegations in the

10 09:47:14indictment.

11 09:47:17 Q All I'm getting at is, at the time that you

12 09:47:20read this, you were concerned that this could

13 09:47:23reflect 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 09:47:41this, I bel- -- you had communicated -- you had sent

19 09:47:43us something saying -- taking issue with this

20 09:47:46posting. My concern was primarily with your

21 09:47:51allegations -- your new allegations against Judicial

22 09:47:54Watch and Ms. Ruffley.


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2 09:48:00 Q And what were those allegations?

3 09:48:02 A I think you were alleging that she had

4 09:48:04defamed you and that Judicial Watch had defamed you.

5 09:48:08 Q And that she was also interfering with my

6 09:48:10business, 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 09:48:20is not licensed in California, she told me that he

11 09:48:23no longer works with the Judicial Watch and that

12 09:48:26donors should know about litigation in Ohio, where

13 09:48:29he was convicted just recently of not paying large

14 09:48:32amount in child support."

15 09:48:35 So Ms. Ruffley was telling Orly Taitz,

16 09:48:38based on what is stated here, please tell donors

17 09:48:41that Larry Klayman's been convicted of a crime,

18 09:48:43correct?


20 09:48:44 THE WITNESS: I don't know what, if

21 09:48:46anything, Ms. Ruffley said to Ms. Taitz.



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1 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 09:49:00that Ms. Ruffley was telling her that donors should

7 09:49:05be informed that Larry Klayman was convicted of a

8 09:49:07crime. That's what it says, right?

9 09:49:13 A That is what Ms. Taitz wrote in her

10 09:49:16posting, yes, that's correct. I think that's

11 09:49:17correct.

12 09:49:17 Q You're aware of the legal ramifications if

13 09:49:20Ms. Ruffley was wrong of telling donors that Larry

14 09:49:24Klayman was convicted of a crime; you were aware of

15 09:49:26that, correct, based on your experience as a lawyer?

16 09:49:38 A I don't know what you mean by the

17 09:49:39ramifications.

18 09:49:41 Q Are people going to want to contri- --

19 09:49:43based on your experience, are people going to want

20 09:49:47to contribute to somebody who's been convicted of a

21 09:49:49crime?

22 09:49:49 A You know, there can be no such thing --


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1 09:49:51sometimes there's no such thing as bad publicity, so

2 09:49:54I don't know what motivates people to donate.

3 09:49:56 Q You think being convicted of a crime is

4 09:49:59good 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 09:50:15concerned about what Orly Taitz had written,

10 09:50:19correct?

11 09:50:19 MR. KRESS: I'm sorry. Did you say were or

12 09:50:22were 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 09:50:28concern was that you were making yet another

17 09:50:30allegation against Judicial Watch.


19 09:50:34 Q How is what Orly Taitz wrote of what Connie

20 09:50:39Ruffley told her an allegation of mine?

21 09:50:40 A Because you were writing to us complaining

22 09:50:45about this posting and saying my -- it was --


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1 09:50:54it's -- to me it was yet another threat that you

2 09:50:57were filing -- you were making against Judicial

3 09:51:00Watch. You've done this repeatedly and consistently

4 09:51:03since 2003.

5 09:51:06 Q Now, you are aware that Connie Ruffley was

6 09:51:16at a meeting with Orly Taitz, as reflected in this

7 09:51:19document, correct?

8 09:51:27 A I'm not -- it's just such a difficult

9 09:51:34question the way you phrased it.

10 09:51:36 Q Phrase it the way you want to phrase it.

11 09:51:38She was at the meeting, correct, you've discerned

12 09:51:42that since you saw this publication?

13 09:51:44 A I was not aware at the time that you sent

14 09:51:46your complaint that Ms. Ruffley had gone to a

15 09:51:48meeting 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 09:51:57respect to this posting that Ms. Ruffley had done

19 09:52:00that, and I believe, in the course of this

20 09:52:04litigation, Ms. Ruffley had said she went to this

21 09:52:07meeting.

22 09:52:08 Q And she went there as a representative of


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1 09:52:10Judicial Watch, correct?

2 09:52:13 A I don't know that. Like I said, I

3 09:52:17didn't -- I was not aware that she had gone to the

4 09:52:19meeting until I heard -- well, until there was this

5 09:52:29posting, this posting that you were complaining

6 09:52:32about.

7 09:52:33 Q You have subsequently, after you saw this

8 09:52:36and I alerted you to it, asked Ms. Ruffley how --

9 09:52:42what capacity she was at the meeting, correct?

10 09:52:44 A That would be subject to an attorney-client

11 09:52:46privilege if any such communication took place.

12 09:52:51 MR. KLAYMAN: Off the record.


14 09:52:53The time is 9:52 a.m.

15 09:52:58 (Discussion off the record.)


17 09:54:41time is 9:54 a.m.


19 09:54:45 Q After you reviewed what I had sent of what

20 09:54:53Ms. Constance Ruffley was claimed to have said by

21 09:54:57Ms. Taitz, you did learn that she was there as a

22 09:55:01representative at that meeting of Judicial Watch,


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1 09:55:04correct?

2 09:55:09 A No.

3 09:55:10 Q You learned that she purported to go in her

4 09:55:15capacity as a representative of Judicial Watch?

5 09:55:17 A I don't know that I learned that, and any

6 09:55:19discussions I had with her about that would be

7 09:55:22subject to an attorney-client privilege.

8 09:55:27 Q Are you disclaiming that she was there as a

9 09:55:28representative of Judicial Watch?

10 09:55:31 A I don't know if we've claimed that or not

11 09:55:34in our litigation.

12 09:55:35 Q I'm asking you. I'm not asking anyone

13 09:55:37else. What are you claiming? You're the head of

14 09:55:43the 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 09:55:47I don't -- I don't know.


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 09:55:51know 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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1 09:55:57she was manning that table with literature about


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 09:56:07not?

6 09:56:08 A I may have discussed it with her, but,

7 09:56:10again, any discussions I have would be subject to

8 09:56:13attorney-client privilege.

9 09:56:14 Q You were concerned that statements were

10 09:56:16being made on behalf of Judicial Watch at that

11 09:56:18meeting, correct?

12 09:56:23 MR. KRESS: Objection, form.



15 09:56:26 Q You were concerned of the statements that

16 09:56:29Ms. Taitz said that Constance Ruffley made to her

17 09:56:32that were made at that meeting and that Ms. Ruffley

18 09:56:38was an employee of Judicial Watch, correct?


20 09:56:41 THE WITNESS: I don't understand your

21 09:56:42question.



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1 09:56:44 Q At the time that -- how long has

2 09:56:49Ms. Ruffley been with Judicial Watch?

3 09:56:50 A I'm trying to remember that. I think maybe

4 09:56:541999, 2000 she started with us.

5 09:56:59 Q And since that time she's been the office

6 09:57:01administrator 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 09:57:07there; is she not?

10 09:57:08 A No.

11 09:57:09 Q Is there anyone else working with her

12 09:57:11currently 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 09:57:21made to Ms. Taitz, what was Ms. -- Mr. Norris's

20 09:57:25position with Judicial Watch in the West Coast

21 09:57:28office?

22 09:57:28 A He's an attorney.


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1 09:57:30 Q And how much time does he put in per

2 09:57:33week --

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 09:57:46Wyoming and he tends to spend most of his time there

7 09:57:50between maybe March and September, and from there he

8 09:57:56works occasionally for Judicial Watch. The other

9 09:58:05parts of the year, I would say late September, early

10 09:58:08October through the end of March, he works 3 days a

11 09:58:12week in the San Marino office.

12 09:58:15 Q In and around February 23rd, 2012, what was

13 09:58:17he doing for Judicial Watch, if anything?

14 09:58:20 A I don't know what he was doing any

15 09:58:22particular day, but if it was February in 2012, then

16 09:58:29my guess is he would be -- he would have been on his

17 09:58:333-day-a-week schedule working in the San Marino

18 09:58:36office.

19 09:58:37 Q Doing what?

20 09:58:37 A Oh, he does a variety of things. He fields

21 09:58:43phone calls. He works with me on litigation.

22 09:58:49People contact us with all kinds of problems and


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1 09:58:52issues and thoughts and ideas. You know, it

2 09:58:58depends, 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 09:59:04correct?

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 09:59:12particularly since he's part time?

10 09:59:13 A No, I wouldn't say he's the manager of the

11 09:59:15office. He's in charge of the office when he's

12 09:59:18there.

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 09:59:33request -- given in light of this testimony,

21 09:59:35telephone records between Ms. Ruffley and

22 09:59:38Mr. Orfanedes. If I could get straight responses, I


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1 09:59:41wouldn't need to do that.

2 09:59:42 MR. KRESS: You can make the request.

3 09:59:44 MR. KLAYMAN: Okay.


5 09:59:58 Q I'm going to show you what I'll ask the

6 10:00:01court reporter to mark as composite Exhibit -- well,

7 10:00:04let'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 10:00:14at?

11 10:00:14 MR. KRESS: Yes.


13 10:00:27 Q Showing you Exhibit 1, Exhibit 1 is the

14 10:00:33subsequent posting on Orly Taitz's web site, World's

15 10:00:41Leading Obama Eligibility Challenge Web Site,

16 10:00:41correct?

17 10:00:41 A That's what it appears to be. I'm not

18 10:00:43familiar 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 10:00:48communication complaining about the posting, that I

22 10:00:52saw this subsequent posting. So my recollection is


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1 10:00:58this had been posted at the time you were

2 10:01:04complaining to us.

3 10:01:09 Q Did you review -- you reviewed the comments

4 10:01:12of these postings -- these two postings, correct,

5 10:01:14Exhibits 1 and 2?

6 10:01:16 A Oh, I don't remember if I reviewed the

7 10:01:18comments. Are there comments?

8 10:01:19 Q Yes.

9 10:01:22 A Oh, okay. I see there are some comments.

10 10:01:26Okay. 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 10:01:42so I'm not going to speculate as to whether I may

18 10:01:45have.

19 10:01:45 Q Basically your whole approach here, this

20 10:01:47was not something that really concerned you very

21 10:01:49much?

22 10:01:49 A It concerned me that you were making yet


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1 10:01:51another threat against the organization. We would

2 10:01:53have to figure out how to address it.

3 10:01:55 Q Well, let's see what you claim are threats.

4 10:02:03I'll show you what I'll ask the court reporter to

5 10:02:04mark as Exhibit 3, composite Exhibit 3.




9 10:02:21 MR. KRESS: Can I look at that first?

10 10:02:24 THE WITNESS: Sure.


12 10:02:35 Q Let's turn --

13 10:02:36 MR. KRESS: Wait. I need a second to

14 10:02:38review this. By the way, I've not seen this before,

15 10:02:40and 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 10:02:48but nonetheless.


22 10:03:50 Q Turn to the second-to-last page, please.


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1 10:03:59Top of the page, an e-mail from Larry Klayman to

2 10:04:[email protected]. 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 10:04:13Judicial Watch in the other litigation that we have,

6 10:04:15correct?

7 10:04:15 A One of the other pieces of litigation, yes.

8 10:04:18I don't know that he's been our lawyer in all of the

9 10:04:20various lawsuits you've brought against us.

10 10:04:22 Q Okay. How many lawsuits have I brought

11 10:04:26against 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 10:04:36and lawsuits against our lawyers?

16 10:04:38 Q I'm not here to answer your question. You

17 10:04:41answer mine.

18 10:04:42 A I'm just trying to understand the scope of

19 10:04:43your question.

20 10:04:43 Q How long have you been a lawyer,

21 10:04:46Mr. Orfanedes?



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1 10:04:46 THE WITNESS: I'm just trying to understand

2 10:04:48the scope of your question.


4 10:04:49 Q How many have I brought personally against

5 10:04:51you?

6 10:04:51 A You brought the lawsuit against Judge

7 10:04:53Kollar- -- you brought the lawsuit pending in front

8 10:04:54of Judge Kollar-Kotelly. You sued us in Florida, I

9 10:05:00believe, over something about you didn't like that

10 10:05:04we referred to you as a former employee. I think

11 10:05:08you --

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 10:05:13the threats and allegations and lawsuits that you've

15 10:05:15brought against us.

16 10:05:16 Q Since you've claimed that there was one,

17 10:05:18please cite what lawsuit you're talking about.

18 10:05:20 A I believe it was a false light invasion of

19 10:05:28privacy case, and it was -- it was stayed for a

20 10:05:30while and the Florida Supreme Court was considering

21 10:05:33whether false light is a recognized concept in

22 10:05:35Florida law. I think it's that one.


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1 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 10:05:40Florida, but I don't recall that one specifically.

4 10:05:42There was a small claims lawsuit that you brought

5 10:05:44against 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 10:05:49continue?

9 10:05:49 MR. KLAYMAN: No. No. That's fine. I

10 10:05:51want to ask him about a question about that.


12 10:05:54 Q That was about getting copies of

13 10:05:57drawings -- of Cortland drawings?

14 10:05:59 A Yeah. We had hearings in small claims

15 10:06:00court, mediation and all that stuff.

16 10:06:00 Q Severance agreement said that you had to

17 10:06:02let 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 10:06:12against 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 10:06:17represented her. You encouraged Peter Paul to file

3 10:06:20a lawsuit against us, and then you represented him

4 10:06:22in that. You brought a lawsuit against our lawyer

5 10:06:25David Barmak in the context of your lawsuit against

6 10:06:28us here in D.C. in front of Judge Kollar-Kotelly.

7 10:06:33You actually sued Judge Kollar-Kotelly. I think

8 10:06:37you've been instrumental in having bar complaints

9 10:06:39filed against me in Maryland, D.C. You've had bar

10 10:06:45complaints filed against Rich Driscoll. I don't

11 10:06:49know.

12 10:06:49 Q As a result of all of that, you hate my

13 10:06:52guts, correct?


15 10:06:54 THE WITNESS: I -- no, I don't hate your

16 10:06:57guts, Larry. I don't hate anyone.


18 10:06:59 Q Okay. You are -- you dislike me?


20 10:07:02 THE WITNESS: I think you're a very

21 10:07:04troubled soul, Larry.



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1 10:07:06 Q Okay. When I left Judicial Watch, did you

2 10:07:10not authorize Barmak to send a letter that I could

3 10:07:14not even refer to myself as founder of Judicial

4 10:07:17Watch?

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 10:07:31letter 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 10:07:43among supporters and in the media raises a question

15 10:07:47about trademark issue.

16 10:07:50 Q In fact, people -- some people are still

17 10:07:53communicating with Judicial Watch thinking that I'm

18 10:07:55still 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 10:08:06about what Connie Ruffley said about Larry Klayman,

22 10:08:09correct, because people still think I'm associated


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1 10:08:14with Judicial Watch?

2 10:08:15 A I don't know what people think. I mean,

3 10:08:17it's --

4 10:08:18 Q I asked you what you think. You're

5 10:08:19concerned?

6 10:08:21 A I am concerned that your being indicted for

7 10:08:28failure to pay child support could reflect

8 10:08:32negatively on Judicial Watch.

9 10:08:34 Q And you would be concerned if someone said,

10 10:08:37even worse, that I was convicted of that, correct?


12 10:08:43 THE WITNESS: I don't know that the concern

13 10:08:44would be any greater or any less.


15 10:08:46 Q There's a difference between indictment and

16 10:08:48conviction; 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 10:08:56conviction is a conviction, a final adjudication.


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1 10:08:59 Q And in this country you're innocent until

2 10:09:01proven guilty?

3 10:09:02 A In the criminal context.

4 10:09:04 Q Yes. Okay. So indictment doesn't mean

5 10:09:07you're guilty of a crime?

6 10:09:08 A An indictment, you know, can be -- you can

7 10:09:13have indictments -- you can indict someone in a

8 10:09:16court of public opinion. Indictment can be a loose

9 10:09:20phrase. It doesn't always have the technical

10 10:09:22meaning that you seem to be imputing to it here.

11 10:09:26 Q Well, you just told me that you were aware

12 10:09:29that I was indicted in the criminal justice system,

13 10:09:32not in the court of public opinion, correct; you

14 10:09:35were 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 10:09:40that.

18 10:09:40 Q No. I was asking you the question in the

19 10:09:43context of being indicted in a criminal context as

20 10:09:45opposed to being convicted in the criminal context.

21 10:09:48There's a difference, correct?

22 10:09:50 A You sort of -- now I'm lost as to where we


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1 10:09:54are with all this back and forth.

2 10:09:54 Q You don't know the difference between being

3 10:09:58indicted in a criminal court as opposed to being

4 10:10:00convicted 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 10:10:06conviction is a final adjudication.

9 10:10:08 Q And for an indictment, you're innocent

10 10:10:11until 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 10:10:17Judicial Watch employee, office administrator, that

14 10:10:21a former head of Judicial Watch was convicted, that

15 10:10:24has a serious affect, potential serious affect on

16 10:10:29Judicial Watch if people still think he's there,

17 10:10:31correct?



20 10:10:33 THE WITNESS: I don't understand the

21 10:10:33question and --



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1 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 10:10:43you. If you have an articulable intelligible

6 10:10:48question --

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 10:10:54that there's confusion some people think --

11 10:10:55supporters think and others that I'm still at


13 10:10:58 A I believe some people are confused about

14 10:11:00that.

15 10:11:00 Q So, therefore, if a statement's being made

16 10:11:02in a web site which goes all over the country and

17 10:11:05internationally that Larry Klayman was convicted of

18 10:11:08a crime, that reflects negatively on Judicial Watch;

19 10:11:11does it not?



22 10:11:15 THE WITNESS: There were multiple things in


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1 10:11:17that, and I don't understand your question, so I

2 10:11:19can't answer it.


4 10:11:20 Q Well, do your best. You don't want to

5 10:11:24answer?

6 10:11:24 A I don't understand your question, Larry.

7 10:11:27It 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 10:11:37understand it.

13 10:11:38 Q I'm going to sit here until you understand

14 10:11:42it. Okay, first question: There are people who

15 10:11:43still believe -- there are people in -- out there

16 10:11:45who follow the activities of Judicial Watch, the

17 10:11:49supporters and others, that Larry Klayman is still

18 10:11:51with Judicial Watch; there's confusion to that,

19 10:11:54correct?

20 10:11:56 A Judicial Watch is in the news. You

21 10:12:02sometimes say that you -- you make -- actually not

22 10:12:04sometimes. 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 10:12:10who contact us who are confused or who might think

3 10:12:15you are with Judicial Watch are supporters of the

4 10:12:16organization. I don't know what their thought

5 10:12:18process 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 10:12:32I don't -- I talked -- there's lots of people in the

11 10:12:39world. You asked me if I talk to some of them.

12 10:12:42It'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 10:12:51called in or written in that said, Larry Klayman's

17 10:12:55still with Judicial Watch or asked if Larry

18 10:12:57Klayman's still with Judicial Watch?

19 10:13:00 A I don't recall talking to anyone about

20 10:13:04that, no, in years.

21 10:13:05 Q You are aware that Mr. Fitton has had those

22 10:13:07discussions 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 10:13:14discussions, correct?

4 10:13:15 A No, I'm not aware that they have those --

5 10:13:18they have had them and I don't -- I don't know that

6 10:13:20they have.

7 10:13:24 MR. KLAYMAN: We'll be requesting

8 10:13:25documentation to this effect. If I can get a

9 10:13:27straight answer, I don't have to do it.

10 10:13:29 MR. KRESS: I think -- I think those are

11 10:13:31very straight answers. You asked him if he knows if

12 10:13:34people have asked Fitton and Farrell those questions

13 10:13:38and he said he doesn't know.

14 10:13:39 MR. KLAYMAN: I'm asking about him too and

15 10:13:41he doesn't know that either, so he claims, but then

16 10:13:45he said he has conversations but he has no

17 10:13:49recollection.


19 10:13:50 Q I don't understand what you're saying,

20 10:13:51Mr. Orfanedes. You want to straighten it out?

21 10:13:53 A I don't understand your questions,

22 10:13:54Mr. Klayman. So if you could ask an intelligible


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1 10:13:58question I'll be happy to answer it.

2 10:13:59 Q Let's try it again. People have called

3 10:14:02into Judicial Watch or written into Judicial Watch

4 10:14:04and asked if Larry Klayman is still there, correct?

5 10:14:06 MR. KRESS: Objection, asked and answered.


7 10:14:09 THE WITNESS: Yes -- well, I don't know. I

8 10:14:12don't know how to characterize -- I have seen people

9 10:14:17inquire of us. I don't know what their thinking is.

10 10:14:24I don't know if they think you're still here or if

11 10:14:27they think you are part of Judicial Watch, meaning I

12 10:14:31don't know if someone who knew you were with

13 10:14:33Judicial Watch and left is now contacting us or if

14 10:14:38someone who wasn't aware of Judicial Watch or you

15 10:14:42learned of Judicial Watch or you and contacted us

16 10:14:46then.


18 10:14:47 Q There have been people that have contacted

19 10:14:48Judicial Watch asking for me, correct, in the 10

20 10:14:52years 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 10:15:03are no longer with the organization.

3 10:15:04 Q Okay. Now, with regard to -- let's go back

4 10:15:16to this letter, top of the second page at the end.

5 10:15:21I'm writing to Mr. Driscoll. Rich, I am being

6 10:15:25defamed by an employee and agent of Judicial Watch,

7 10:15:28Connie Ruffley. Please call me to discuss. Thank

8 10:15:31you, 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 10:15:39threat?

13 10:15:39 A It's in all caps, it's in bold. I mean,

14 10:15:39you used the word "defamed" which is a legal word,

15 10:15:42and you also have to take it in the context of the

16 10:15:44history of the allegations that you've made against

17 10:15:46the 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 10:16:00defamation.

3 10:16:00 Q Right. And is there not -- if in fact

4 10:16:08Ms. Ruffley had defamed me, wouldn't you want to

5 10:16:10correct it?

6 10:16:15 A Oh, Larry, that's a hypothetical question.

7 10:16:17I'm not prepared to get into that. I don't --

8 10:16:20Ms. Ruffley didn't defame you so --

9 10:16:22 Q Say I was convicted of a crime is not

10 10:16:25defamation?

11 10:16:26 A Ms. Ruffley didn't -- I don't know what

12 10:16:28Ms. 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 10:16:35with you.

16 10:16:35 MR. KRESS: I'm going to object to the

17 10:16:36form.


19 10:16:37 Q Let's go to the next one. Richard Driscoll

20 10:16:39to Larry Klayman. I attempted to contact you but it

21 10:16:42went unanswered and the message box was full. Will

22 10:16:45you be in witness interview for remainder of the


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1 10:16:47day, Richard W. Driscoll.

2 10:16:50 Have you ever seen these e-mails before?

3 10:16:53Mr. Driscoll forwarded them to you, didn't he?

4 10:16:56 A You know, I had thought you contacted us,

5 10:16:59but maybe you contacted Rich directly. I don't

6 10:17:01remember. I had thought you contacted us, but maybe

7 10:17:04I'm wrong. I'm sure I became aware of this at some

8 10:17:08point, this allegation, so he must have contacted

9 10:17:10us.

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 10:17:1823rd at 11:03 a.m. Let's talk after. In the

14 10:17:21meantime, thanks for advising Judicial Watch and

15 10:17:24Ruffley what I informed you about. I will explain

16 10:17:27more when we talk. It's over the Obama citizenship

17 10:17:32issue and Ruffley is out making false statements

18 10:17:35about me and my personal life, et cetera. I have a

19 10:17:35record of what was said and done. Best, Larry

20 10:17:38Klayman.

21 10:17:38 Does that sound provocative, best, Larry

22 10:17:41Klayman?


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1 10:17:41 A "Ruffley is out making false statements

2 10:17:44about me and my personal life," yes, that sounds

3 10:17:48provocative, especially coming from you, someone who

4 10:17:50has sued the organization repeatedly and been

5 10:17:52instrumental in bringing multiple lawsuits against

6 10:17:55the organization.

7 10:17:55 Q Well, you just -- you reviewed what Taitz

8 10:17:56had 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 10:18:05don't know Taitz and I haven't spoken with her.

15 10:18:07 Q I didn't manufacture that document; you're

16 10:18:09aware of that. Okay.

17 10:18:13 And then this is Richard Driscoll coming

18 10:18:18back to me: I have no information regarding your

19 10:18:20assertions and concede nothing. Rich Driscoll,

20 10:18:24right?

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 10:18:34pages.


4 10:18:36 Q No, back of it. It's in reverse. Okay.

5 10:18:44Larry Klayman to Rich Driscoll, "Tied up now. Call

6 10:18:56later."

7 10:18:57 A Oh, that's -- okay. I don't know. I'm

8 10:19:01sort of confused as to how these e-mail chains are

9 10:19:03to be read.

10 10:19:04 Q Look at the last page. It got a little bit

11 10:19:11out of order.

12 10:19:12 A Yeah, Rich's call -- tied up now. Call

13 10:19:15later 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 10:19:22in sequence in terms of time so even if the page is

18 10:19:27out. This is from me to Rich Driscoll. "Didn't

19 10:19:29expect you as their counsel to concede anything.

20 10:19:32But if you want to learn what is at issue call me.

21 10:19:35Hopefully, matters can be resolved appropriately

22 10:19:38without further harm. Best, Larry."


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1 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 10:19:44to your counsel, didn't you?

5 10:19:46 A I don't remember -- I don't remember it

6 10:19:47specifically. The issue came to my attention

7 10:19:49somehow. I had thought that you had e-mailed us,

8 10:19:51but this now makes me think that perhaps you

9 10:19:54e-mailed our lawyer directly.

10 10:19:55 Q Let's just talk about what was said. I'm

11 10:19:58asking, am I not, to resolve things appropriately.

12 10:20:01There's no threat of suit there, is there?

13 10:20:03 A I think when you call up someone's lawyer

14 10:20:06and you send an e-mail to someone's lawyer and you

15 10:20:07say, I'm being defamed and false statements are

16 10:20:09being made against me, there's a threat there.

17 10:20:12 Q You're trying to rectify the situation; are

18 10:20:15you not?

19 10:20:15 A You asked me if I thought this was a threat

20 10:20:17at some point. I said I think it's a threat, and I

21 10:20:19continue 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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1 10:20:232012, from Larry Klayman, myself, to Rich. "Is

2 10:20:31there 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 10:20:36Judicial Watch, Fitton, et al.? This matter is

6 10:20:39serious and much damage has been done through Connie

7 10:20:43Ruffley, Fitton, and others, individually on behalf

8 10:20:46of Judicial Watch. And, this is not the only recent

9 10:20:48instance where I have been defamed and held in a

10 10:20:51false light in the last few months. I will explain

11 10:20:53when we talk. The French have an expression; the

12 10:20:55more things change, the more they remain the same.

13 10:20:55 While the french government just removed

14 10:20:59the word "mademoiselle" from government documents,

15 10:21:02this French proverb still applies -- I'm trying to

16 10:21:05be funny -- particularly when it comes to Fitton and

17 10:21:08company. Let me know. Rather than just filing

18 10:21:09suit, I'm attempting to discuss having your clients

19 10:21:11mitigate the damage and to try to resolve matters if

20 10:21:14we can.

21 10:21:15 You see that, "sincerely, Larry Klayman"?

22 10:21:17 A Yes, I see it.


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1 10:21:18 Q Taken on face value, I'm asking to resolve

2 10:21:21it to mitigate it, that I don't want to file suit,

3 10:21:25correct?

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 10:21:29you're apparently demanding compensation. I think

8 10:21:31that'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 10:21:36lawsuit, and you're talking about -- where do you

12 10:21:38say --

13 10:21:42 Q Tell me where there's demand for

14 10:21:44compensation.

15 10:21:45 A Much damage. The matter is serious and

16 10:21:47much damage has been done. I mean, when lawyers

17 10:21:49talk to each other, they're usually talking about

18 10:21:51money in that regard.

19 10:21:52 Q When you make an allegation of someone's

20 10:21:56convicted of a crime, based on your experience,

21 10:21:59that's libel per se is it not?



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1 10:22:04 THE WITNESS: I object to your form -- the

2 10:22:05form and your characterization. I don't know. No

3 10:22:07one has accused you of being -- Ms. Ruffley has not

4 10:22:11alleged that you were convicted of anything. You

5 10:22:13have alleged that Ms. Ruffley said that to

6 10:22:15Ms. Taitz.


8 10:22:19 Q So you did have a conversation with

9 10:22:22Ms. 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 10:22:32privilege, you can't answer it.

14 10:22:34 MR. KLAYMAN: You can't have it both ways,

15 10:22:36Doug, okay. If it's attorney-client privilege, he

16 10:22:40just 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 10:22:42I don't specifically recall having any discussions

21 10:22:45with Ms. Ruffley about this. I may have discussed

22 10:22:47it with her. You are making an allegation that she


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1 10:22:49said certain things. You wrote threatening e-mails

2 10:22:52to our lawyer. I perceive them as threats. If you

3 10:22:54want to characterize them in some other way, that's

4 10:22:57your prerogative.

5 10:22:58 Given the history between you and Judicial

6 10:23:02Watch and all the various lawsuits and allegations

7 10:23:04and threats and demands and claims and accusations

8 10:23:08you've made against Judicial Watch over the years, I

9 10:23:10considered this another threat.


11 10:23:13 Q Well, is it a threat when Judicial Watch

12 10:23:16had a $15,000 contribution from Louise Benson when I

13 10:23:21was with Judicial Watch to build a building and then

14 10:23:23never built a building and you had to give back her

15 10:23:27money? Was that a threat?


17 10:23:30 THE WITNESS: I don't understand what

18 10:23:31you're talking about, Larry.


20 10:23:33 Q Remember that we raised money -- we were

21 10:23:35raising money shortly before I left to buy the

22 10:23:37building that we were in at 501 School Street,


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1 10:23:40correct?

2 10:23:40 A I remember there was an -- there was a

3 10:23:41building campaign. I remember there was a

4 10:23:43contribution by Ms. Benson. I remember there were

5 10:23:46false allegations you made on behalf of Ms. Benson

6 10:23:49about her contribution and that we returned the

7 10:23:52contribution.

8 10:23:54 Q If they were false, why'd you return the

9 10:23:56contribution?

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 10:24:04under false pretenses, correct?

15 10:24:06 A I was concerned about more of the

16 10:24:07organization's scarce time and resources being

17 10:24:11wasted 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 10:24:17building, and we're not here to litigate that matter

21 10:24:20that'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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1 10:24:28 A Past litigation that has already -- that

2 10:24:29has already been finaled.

3 10:24:30 Q What I'm saying is you were concerned about

4 10:24:32that allegation, that you'd taken money under false

5 10:24:35pretenses, and therefore you gave Louise Benson her

6 10:24:38money back.


8 10:24:39 THE WITNESS: No, I don't believe so at

9 10:24:41all. I believe at the time we had decided to

10 10:24:43make -- give the money back the -- the lawsuit in

11 10:24:44which Ms. Benson had -- made you on behalf of

12 10:24:48Ms. Benson had made the allegations had been over.

13 10:24:51I think it was dismissed or dropped. I don't -- I

14 10:24:53don't remember all the circumstances of it right

15 10:24:56now, but I think that litigation had concluded.


17 10:25:00 Q That's inaccurate but fine. Give me your

18 10:25:02testimony. 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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1 10:25:11was concluded.


3 10:25:11 Q So the use of the word "mitigate damage,"

4 10:25:14is it not true that someone if they commit an act

5 10:25:16which is tortious has a duty to mitigate; you're

6 10:25:21aware of that as a lawyer?


8 10:25:23 THE WITNESS: No. I think the mitigation

9 10:25:25applies to the person bringing the claim.


11 10:25:28 Q Well, if I'm asking you to correct a false

12 10:25:31statement, I am attempting to mitigate; am I not?

13 10:25:34 A I don't know what -- I think you're -- I

14 10:25:36interpreted these e-mails as being yet more threats

15 10:25:38from you, yet more distractions caused by your

16 10:25:43baseless threats.

17 10:25:44 Q About 15 minutes ago you couldn't remember

18 10:25:46whether you saw the e-mails. Now you're saying you

19 10:25:50interpreted 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 10:25:56interpreted." That's past tense, correct? Record


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1 10:26:02will speak for itself.

2 10:26:04 A During the course of our discussion here,

3 10:26:05you asked -- I've read these and I characterized

4 10:26:10them 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 10:26:20backward?

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 10:26:29the very first page. Letter of March 5th, 2012 to

12 10:26:36Larry Klayman by e-mail and first class mail.

13 10:26:41Putative claim for defamation, et cetera. "Dear

14 10:26:45Mr. Klayman: This firm represents Judicial Watch

15 10:26:47relating to the above-referenced matter. Through a

16 10:26:50series of e-mails and again during our conversation

17 10:26:52on Tuesday, February 28, 2012, you advanced vague

18 10:26:55and unsupported allegations that Judicial Watch, its

19 10:26:58President Tom Fitton and an employee are

20 10:27:01participants in a conspiracy to defame and disparage

21 10:27:04you based on the recent indictment handed down in

22 10:27:05Ohio. To date, you have produced no evidence to


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1 10:27:07support these truly outrageous allegations.

2 10:27:10 As I stated to you during our conversation,

3 10:27:12Judicial Watch did not authorize, make, or

4 10:27:14participate in the making of any statements

5 10:27:16regarding your indictment for criminal non-support.

6 10:27:18For this reason, it's not necessary for Judicial

7 10:27:20Watch to take any action to clarify or correct the

8 10:27:23statements of others. Sincerely, Driscoll &

9 10:27:28Seltzer, PLLC, Richard W. Driscoll." Copy to Paul

10 10:27:34Orfanedes?

11 10:27:35 Now, you saw this letter at the time

12 10:27:36Driscoll sent it, correct?

13 10:27:38 A Probably.

14 10:27:38 Q And you approved this letter by Driscoll,

15 10:27:40correct?

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 10:27:43behalf of Judicial Watch and yourself that you

19 10:27:45didn't review and approve?

20 10:27:47 A Oh, it depends. I've worked with Rich for

21 10:27:50quite a while so I trust him. I don't know that I

22 10:27:52approved it.


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1 10:27:53 Q Did you ever tell him that what he wrote

2 10:27:55was 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 10:28:06it had no obligation to correct or clarify or do

6 10:28:10anything with regard to what Connie Ruffley told

7 10:28:13Orly Taitz?


9 10:28:15 THE WITNESS: You keep getting back to this

10 10:28:17what Connie Ruffley told Orly Taitz, and I don't

11 10:28:20know what Connie Ruffley told Orly Taitz and it's

12 10:28:21not been established what Connie Ruffley told Orly

13 10:28:25Taitz. So I object to the way you're trying to put

14 10:28:27words into my mouth. I don't think this -- I think

15 10:28:31this letter speaks for itself. It says, Judicial

16 10:28:33Watch did not authorize, make or participate in

17 10:28:36making of any statements, and therefore it's not

18 10:28:38necessary for Judicial Watch to take any action.


20 10:28:40 Q So you're in fact disassociating yourself

21 10:28:44from Constance Ruffley?

22 10:28:47 A No, not at all.


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1 10:28:53 Q If you're -- you're disassociating yourself

2 10:28:55from what Constance Ruffley said to Orly Taitz,

3 10:28:59yourself meaning Judicial Watch?

4 10:29:01 A Larry, I think the issue in your lawsuit,

5 10:29:03if I can characterize your -- your allegations, is

6 10:29:06you're making an allegation about what Connie told

7 10:29:10Orly. I don't know what Connie told Orly. I wasn't

8 10:29:15there.

9 10:29:15 Q Are you saying that in fact I should go

10 10:29:18back and make a motion with the court that we should

11 10:29:22reinstitute Connie as a defendant, Connie Ruffley?



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 10:29:32Judicial Watch or any of the other directors; are

18 10:29:34you saying that?


20 10:29:37 THE WITNESS: That's not my testimony.


22 10:29:39 Q You're holding Connie Ruffley out to dry?


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2 10:29:42 THE WITNESS: My -- my testimony was I

3 10:29:43don't know what, if anything, Connie said.


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 10:29:51hypotheticals about what somebody might have done if

8 10:29:53they 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 10:30:00Connie Ruffley said, but then again since we don't

13 10:30:02know what she said, you don't have an action against

14 10:30:04Connie Ruffley either. That's your position, isn't

15 10:30:06it?

16 10:30:07 A No.



19 10:30:08 Q Are you taking responsibility for -- is

20 10:30:09Judicial Watch taking responsibility for what Connie

21 10:30:10Ruffley said, whatever she said?



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1 10:30:18 THE WITNESS: I don't -- I don't know how

2 10:30:19to answer that.


4 10:30:20 Q You are aware that Ms. Ruffley submitted an

5 10:30:22affidavit in this case where she said she doesn't

6 10:30:24remember what she said?


8 10:30:27 THE WITNESS: I'm not sure that's -- her

9 10:30:29affidavit says what it says.


11 10:30:32 Q The affidavit doesn't disclaim that she had

12 10:30:34a 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 10:30:41conversation about me, Larry Klayman, with Orly

16 10:30:44Taitz?

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 10:30:48submitted 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 10:30:50Watch?


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1 10:30:50 A Yes.

2 10:30:51 Q And you were at the time that this

3 10:30:52statement was allegedly made, correct, about Larry

4 10:30:54Klayman to Orly Taitz?

5 10:30:56 A Yes.

6 10:30:57 Q Okay. And that's why Mr. Driscoll's

7 10:31:01communicating with you because it's your

8 10:31:03responsibility at Judicial Watch to review legal

9 10:31:05matters and to recommend action?

10 10:31:06 A I believe Mr. Driscoll was communicating

11 10:31:09with 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 10:31:13to?

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 10:31:17chief legal officer, correct?

19 10:31:18 A He's informing me, he's sending me a copy

20 10:31:21of his communication to you.

21 10:31:24 Q Just to make it crystal clear, you approved

22 10:31:27what he said in this letter of March 5, 2012?


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1 10:31:30 A I don't remember if I approved it. I read

2 10:31:31it and I think it's completely accurate.

3 10:31:35 Q So you washed your -- you washed your hands

4 10:31:36of anything that may have been said about me to Orly

5 10:31:39Taitz and being convicted of a crime --




9 10:31:42 Q -- you meaning Judicial Watch and Paul

10 10:31:46Orfanedes?

11 10:31:46 A I don't understand your -- I don't

12 10:31:48understand your question.

13 10:31:48 Q You didn't really care what, if anything,

14 10:31:51Connie Ruffley said to Orly Taitz about Larry

15 10:31:54Klayman?

16 10:31:54 A I read the posting and I didn't think it

17 10:31:57was defamatory.

18 10:31:59 Q In the course of -- how many years have you

19 10:32:01been 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 10:32:17worked on cases involving defamation and First

5 10:32:20Amendment 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 10:32:26of 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 10:32:35accuse someone in a misleading or false way of being

14 10:32:39convicted of a crime?

15 10:32:40 A I wouldn't agree with your definition, and

16 10:32:43I 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 10:32:51when 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 10:32:57when you approved Driscoll's letter.

2 10:33:01 A I've been working -- I've been a lawyer for

3 10:33:0224 years. At the time Rich wrote this letter I said

4 10:33:05I didn't recall approving it.

5 10:33:06 Q Subsequent to him writing the letter and

6 10:33:08sending it to me, you told him to correct it?

7 10:33:11 A No. I think it's exactly right. I think

8 10:33:13it's a completely accurate letter.

9 10:33:15 Q Have you asked Connie Ruffley if she made

10 10:33:19this statement?

11 10:33:19 A That would be subject to attorney-client

12 10:33:21privilege.

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 --


17 10:33:27 Q Have you asked her whether she made the

18 10:33:28statement?

19 10:33:28 MR. KRESS: I'm going -- I'm going to

20 10:33:29object, and it also depends if it's after the

21 10:33:32lawsuit or if it's after -- well, really if it's

22 10:33:36after -- at any point I think it is attorney-client


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1 10:33:39privilege if you're asking him about the substance

2 10:33:40of the communication.

3 10:33:41 THE WITNESS: That's correct.

4 10:33:41 MR. KLAYMAN: I'm not asking about the

5 10:33:42substance. I said, did you ask her she made this

6 10:33:47communication to --

7 10:33:47 THE WITNESS: I think that's a substance

8 10:33:49question.


10 10:33:49 Q Did you have a -- you felt that -- did you

11 10:33:50feel you had an obligation to ask her that question

12 10:33:53when I wrote -- when I raised this issue with

13 10:33:57Richard Driscoll?


15 10:33:59 THE WITNESS: I don't understand that.


17 10:33:59 Q Did you, as the chief legal officer of

18 10:34:01Judicial Watch and Judicial Watch itself, have an

19 10:34:04obligation to do due diligence to see whether or not

20 10:34:06Connie Ruffley had made that statement to Orly

21 10:34:08Taitz?

22 10:34:08 MR. KRESS: I'm also going to object here.


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1 10:34:10I -- I believe if you're asking him how he -- his

2 10:34:13state of mind in responding to what he has perceived

3 10:34:15as a threat, I think that could -- that's work

4 10:34:18product, so I don't think he can answer that.

5 10:34:21 MR. KLAYMAN: No, that's an issue as to

6 10:34:23whether or not there is a -- whether in his mind

7 10:34:26there was a legal obligation to make that inquiry

8 10:34:29and whether in Judicial Watch's venue there was an

9 10:34:35obligation to make that inquiry, not what was said,

10 10:34:40whether there was an obligation to do it, based on

11 10:34:42his 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 10:34:49as an expert. I'm here as a fact witness and you're

15 10:34:51asking about --


17 10:34:52 Q I'm not asking you as an expert. I'm

18 10:34:54asking 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 10:35:00you 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 10:35:06perceive that someone such as me is threatening

5 10:35:11litigation if an alleged defamatory statement is not

6 10:35:16corrected, in the ordinary course as the chief legal

7 10:35:19officer of Judicial Watch, did you not have an

8 10:35:21obligation to make an inquiry to see whether or not

9 10:35:24this alleged statement was made?

10 10:35:26 MR. KRESS: I'm going to object. I think

11 10:35:30you're getting into -- into work product, what his

12 10:35:33duties are in responding to litigation.

13 10:35:38 MR. KLAYMAN: Are you instructing him not

14 10:35:40to answer?

15 10:35:40 MR. KRESS: I believe I am. I mean, are

16 10:35:43you asking him -- especially when you're --

17 10:35:45especially if you're asking him with respect to the

18 10:35:48facts of this case, in particular your claim. I

19 10:35:51suppose it might be different if you're asking him

20 10:35:53in general if he has to -- he responds to

21 10:35:58litigation, but I think when you get into the facts

22 10:36:01of this case, you're getting into his legal thought


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1 10:36:04process as counsel for -- for Judicial Watch, and I

2 10:36:08think that's classic work product privilege.


4 10:36:13 Q Judicial Watch is an organization which

5 10:36:16prides 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 10:36:25correct?

11 10:36:29 A I don't really know what your thinking was.

12 10:36:31I thought the idea was to watch the judiciary when

13 10:36:36the original idea of forming an organization called

14 10:36:42Judicial Watch. I thought that was the first idea.

15 10:36:43Things morphed over time. At some point we began to

16 10:36:47focus more on ethics.

17 10:36:49 Q Okay. Well, if someone makes a statement

18 10:36:52that is not true that someone is convicted of a

19 10:36:57crime, would it not be the ethical thing to do, if

20 10:37:01that statement was made by a Judicial Watch

21 10:37:02employee, to make an inquiry to correct it, see

22 10:37:06whether it should be corrected?


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1 10:37:07 A This is a hypothetical question. It's too

2 10:37:11many 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 10:37:17someone's making a false allegation about someone

7 10:37:18and they're an employee of Judicial Watch, is there

8 10:37:20not an obligation to see whether or not that

9 10:37:22happened to correct it?

10 10:37:23 A I don't know. I'm not -- I'm here as a

11 10:37:24fact witness. If you'd ask me some questions I can

12 10:37:27answer about your allegations in this lawsuit, I'm

13 10:37:29happy to. I don't know what you're doing now. I

14 10:37:33don't know what you've done throughout this

15 10:37:34deposition. Please ask me some intelligible

16 10:37:39questions. I'll try to answer them to the best of

17 10:37:42my ability.

18 10:37:43 Q Mr. Orfanedes, you've appeared as counsel

19 10:37:45in 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 10:37:50not?


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1 10:37:51 A That's debatable.

2 10:37:52 Q You were with me for almost 10 years,

3 10:37:54correct?

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 10:38:12and I worked together, did I ever make a false

9 10:38:16allegation 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 10:38:22remember something. I don't remember the whole

14 10:38:23context 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 10:38:36You used to -- you used to allege that we were

18 10:38:38lovers. No. I don't remember when that was, and

19 10:38:41we'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 10:38:51create animus. I mean, it's what you do, Larry.


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1 10:38:53Some people find that endearing.

2 10:38:53 Q Did I ever make that allegation while I was

3 10:38:55at Judicial Watch?


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 10:39:02when -- while we were nego- -- trying to negotiate

10 10:39:04your severance and figure out, there was -- there

11 10:39:07was what happened in May and we dispute what

12 10:39:09happened in May, and then the negotiations --

13 10:39:12 Q Well, up to that point. Up to that point,

14 10:39:14did I ever say anything negative about you?

15 10:39:17 A Oh, sure. I mean, I'm sure you did. I

16 10:39:19don't know.

17 10:39:19 Q What do you know that I ever said negative

18 10:39:23about you?

19 10:39:23 A We worked together for years. I mean, it's

20 10:39:24just back and forth between two people, 11 years, of

21 10:39:30course you did.

22 10:39:30 Q I might have criticized your work from time


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1 10:39:32to 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 10:39:38when you work together with somebody for 11 years

6 10:39:41there's ups and downs.

7 10:39:42 Q Okay. So if I'd done something really

8 10:39:44terrible, 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 10:40:03lawsuits, correct; that's one of the things it does,

12 10:40:08it files lawsuits?

13 10:40:08 A Mm-hmm.

14 10:40:09 Q And Connie Ruffley, you are aware that she

15 10:40:13is knowledgeable about issues in the law, correct,

16 10:40:16because of her work at Judicial Watch?

17 10:40:20 A She has a limited understanding. She's not

18 10:40:22a lawyer, so she doesn't have all the -- she doesn't

19 10:40:26have a complete understanding. Most lawyers don't

20 10:40:28have a complete understanding, but --

21 10:40:30 Q She's worked with you and Ernie Norris and

22 10:40:33others at Judicial Watch on legal matters?


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1 10:40:40 A She provides admin support, yeah. She'll

2 10:40:44file things at the courthouse. She'll put together

3 10:40:47pleadings and copy pleadings and things like that,

4 10:40:50but I mean, in terms of the substance of the legal

5 10:40:51work, 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 10:41:01anything related to this lawsuit, I think that's

9 10:41:03attorney-client privilege but --

10 10:41:04 MR. KLAYMAN: Discussing is not, Doug, and

11 10:41:06you know that, okay? I'm not getting into the

12 10:41:08substance. Did she ever discuss Orly Taitz with

13 10:41:13you?

14 10:41:13 MR. KRESS: If it's -- well, I'll let him

15 10:41:16answer but I think -- I still think if you're

16 10:41:18talking about the issues in this lawsuit with a

17 10:41:21lawyer then that's attorney-client privilege.


19 10:41:23 Q I'm not asking for the substance, not yet.

20 10:41:25I'm just asking did you ever discuss Orly Taitz with

21 10:41:29Connie Ruffley?

22 10:41:29 A See, now I would say that's a substantive


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1 10:41:32question.

2 10:41:35 MR. KRESS: I think that's a substantive

3 10:41:37question too.

4 10:41:37 THE WITNESS: I cannot wear my lawyer hat

5 10:41:38here, but to answer it, before this, you know,

6 10:41:39however you want to call it -- I call it a threat

7 10:41:41that you sent to our lawyer, before that arose, I

8 10:41:44don't recall ever having discussed Orly Taitz with

9 10:41:47her. I'm not even sure when I became aware of Orly

10 10:41:50Taitz.


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 10:41:58somewhere in -- is it Rancho Santa Margarita? And

15 10:42:02she does a lot of these birther lawsuits -- or she

16 10:42:05did in the past. I don't -- I don't know what she's

17 10:42:08done over the last couple of years.

18 10:42:18 Q You are aware that I brought eligibility --

19 10:42:21lawsuits challenging President Obama's eligibility

20 10:42:26in Florida, correct?

21 10:42:33 A I think I became aware of that in the

22 10:42:34course of this lawsuit.


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1 10:42:36 Q And what do you know about it?

2 10:42:38 A I thought I saw, from reviewing your

3 10:42:42answers to interrogatories the other day, that there

4 10:42:44were three and that they've been dismissed, but

5 10:42:47that's my vague understanding.

6 10:42:54 Q You are aware that Orly Taitz, one of her

7 10:42:59primary areas of interest, is filing lawsuits

8 10:43:01concerning the eligibility of President Obama?

9 10:43:04 A I know she used to do that. I don't know

10 10:43:06what she's doing currently. I don't know that she's

11 10:43:09practicing law currently.

12 10:43:18 Q During the time that I was at Judicial

13 10:43:20Watch, we worked on a case together, did we not,

14 10:43:23where we sued Fidel Castro over the shoot down of --

15 10:43:28 A Yes. Did we sue him personally or did we

16 10:43:31sue Cuba?

17 10:43:31 Q Well, we sued --

18 10:43:33 A I don't remember. There was an issue

19 10:43:35involving Cuba and Brothers to the Rescue.

20 10:43:38 Q Tell us a little bit about that lawsuit

21 10:43:40situation.

22 10:43:41 A I don't remember. That was something that


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1 10:43:43Ed Forez (phonetic) worked on primarily I think, but

2 10:43:47we represented José Basulto, founder of Brothers to

3 10:43:52the Rescue and I don't remember who we sued as

4 10:43:54defendants, but it was Cuban government officials

5 10:43:57and/or the Cuban government. There were also some

6 10:44:01other 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 10:44:10back up before that. We did at Judicial Watch

13 10:44:11obtain a $1.8 million verdict against Cuba, correct?

14 10:44:16 A Right. That Brothers to the Rescue

15 10:44:18lawsuit, whoever the defendants were, we got a

16 10:44:20default judgment. It was -- I don't remember the

17 10:44:23exact amount. It was something over a million

18 10:44:25dollars.

19 10:44:27 Q And it was for the shoot down of José

20 10:44:31Basulto's brothers by Castro's Air Force, correct?

21 10:44:34 A Well, it was from that whole incident

22 10:44:36involving the Cuban Air Force chasing the Brothers


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1 10:44:40to the Rescue. José Basulto was chased and fired

2 10:44:44at, I believe. He wasn't shot down, his comrades

3 10:44:49were shot down and I think they were killed during

4 10:44:52that incident.

5 10:44:52 Q And our victory in that case obviously was

6 10:44:55popular in the Cuban community, correct?

7 10:44:56 A I don't know. I know José Basulto was very

8 10:45:01grateful for our work.

9 10:45:02 Q And it was very popular in the Miami

10 10:45:05community --

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 10:45:10Miami?

16 10:45:11 A I'm aware it's changing over time. I know

17 10:45:14that Cuba -- or I know that whole south Florida area

18 10:45:18has a mix of all sorts of people from all kinds of

19 10:45:20different areas.

20 10:45:21 Q You're aware that while I was at Judicial

21 10:45:22Watch, shortly before I left, that we took a -- that

22 10:45:25I took a trip to Europe with victims of Castro?


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1 10:45:30 A Yes, I remember your --

2 10:45:32 Q And we appeared in front of the French

3 10:45:35parliament 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 10:45:42stronger actions against Castro for persecuting

7 10:45:45dissidents and reporters?

8 10:45:46 A I think that's right. I wasn't along, but

9 10:45:48I did.

10 10:45:48 Q And that was very popular in the Cuban

11 10:45:51community 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 10:45:56a trip with other victims of Castro to Belgium to

15 10:45:59file a criminal complaint against Castro there in

16 10:46:03its 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 10:46:09too; 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 10:46:17Watch, I brought a lawsuit on behalf of a victim of


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1 10:46:23Hugo 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 10:46:32thought there was something 9/11 related that

6 10:46:36Judicial Watch filed involving Venezuela. I

7 10:46:41don't -- I don't remember the details of it.

8 10:46:50 Q And you are aware that during the time I

9 10:46:52was at Judicial Watch that we intervened and

10 10:46:58participated in the case Gore v. Bush over the 2000

11 10:47:03elections in Florida?

12 10:47:08 A Oh, I know we did lots of public records

13 10:47:11requests, and we had some litigation pending in

14 10:47:12different county Circuit Courts in Florida trying to

15 10:47:16get access to the ballots, and I remember that you

16 10:47:18went up and you watched the proceedings in

17 10:47:21Tallahassee.

18 10:47:23 Q You are aware that the judge allowed me to

19 10:47:25participate in the public interest on behalf of


21 10:47:28 A I don't remember what capacity. I know you

22 10:47:32were there. I don't know what, if anything, the


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1 10:47:34judge said.

2 10:47:34 Q That's a very famous case, isn't it, Gore

3 10:47:38v. Bush, decided a Presidential election?

4 10:47:40 A I guess. I remember the judge telling you

5 10:47:42to sit down once because you were on -- you would

6 10:47:45always -- you'd always walk in front of the camera

7 10:47:47so you could be wherever the camera would be. You

8 10:47:53would be in front of the camera, and the judge told

9 10:47:55you to sit down --

10 10:47:56 Q You're aware we invited that judge and gave

11 10:47:58him an award after the event?

12 10:47:59 A Yes, that's right.

13 10:47:59 Q We went on a cruise --


15 10:48:02 Q -- when we no longer had litigation with

16 10:48:05him?

17 10:48:05 A I don't remember that. I remember the

18 10:48:07award, but I don't remember the cruise.

19 10:48:08 Q You're aware that I became friends with

20 10:48:10that 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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1 10:48:13wife on a cruise?

2 10:48:14 A No. I remember the award. I don't

3 10:48:16remember the cruise.

4 10:48:18 Q You remember the hearing that we had with

5 10:48:20that judge, Judge Sanders Sauls where I asked him to

6 10:48:24intervene and he said, Mr. Klayman I don't know of

7 10:48:27any right to intervene, but I'll grant you a right

8 10:48:30to hang around. Remember that?

9 10:48:31 A Oh, I remember -- I remember that language.

10 10:48:33I don't -- you know, I don't remember the event, but

11 10:48:35I recall the you have a right to hang around, and I

12 10:48:39don't know where that -- I guess -- if you say it

13 10:48:41came from Judge Sauls then that's fine.

14 10:48:44 Q And you're aware that he allowed me to

15 10:48:46speak during that trial?

16 10:48:48 A No, I don't remember that he allowed you to

17 10:48:49speak. Like I said, my recollection of the trial

18 10:48:52was you always -- you wanted to be wherever the

19 10:48:54camera was, so you would move around, and at one

20 10:48:56point he said sit down Mr. Klayman, or something to

21 10:48:58that effect.

22 10:48:58 Q Were you aware that I couldn't move around.


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1 10:49:01I 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 10:49:06faced at the jury box, correct?

5 10:49:08 A I don't remember. I just remember that one

6 10:49:11saying.

7 10:49:11 Q Okay. All right. You're aware that

8 10:49:22Judicial Watch and I also represented the family of

9 10:49:24Elian 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 10:49:33matter, 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 10:49:42was trying to do.

17 10:49:42 Q You didn't like what the family was trying

18 10:49:45to 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 10:49:50worked very hard for the family.


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1 10:49:52 Q Conservative community liked what we were

2 10:49:54doing; did it not?

3 10:49:55 A I don't know. I don't remember. And the

4 10:49:57conservative 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 10:50:02community. I think it's a lot of different people

8 10:50:02with a lot of different views.

9 10:50:02 Q People who are upset at Bill Clinton for

10 10:50:06sending Elian back to Cuba?

11 10:50:08 A I remember people upset -- people being

12 10:50:10upset with Janet Reno. I don't remember them being

13 10:50:13upset with Bill Clinton.

14 10:50:15 Q Janet Reno worked for Bill Clinton, did she

15 10:50:19not, 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 10:50:30of Churches, correct, at the time?

21 10:50:31 A I don't remember who he -- he was

22 10:50:39representing the father in some capacity. I don't


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1 10:50:39know who he -- I thought he was Elian Gonzalez's

2 10:50:44father's lawyer.

3 10:50:44 Q And he played a role in having Elian sent

4 10:50:48back to Cuba, did he not? You're aware of that?

5 10:50:50 A He represented the father in whatever court

6 10:50:54proceedings were going on, so --

7 10:50:54 Q The father wanted the child back in Cuba,

8 10:50:56correct?

9 10:50:56 A Yes.

10 10:50:57 Q Gregory Craig later became Clinton's

11 10:51:01impeachment lawyer, correct, remember that -- in the

12 10:51:03White 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 10:51:06classmate of Hillary Clinton at Yale -- Yale Law

16 10:51:10School?

17 10:51:10 A No, I'm not aware. I don't know anything

18 10:51:12about where he went to law school or who he went to

19 10:51:14law school with.

20 10:51:15 Q You're aware after I left Judicial Watch I

21 10:51:17brought a lawsuit against a mosque in Fort

22 10:51:21Lauderdale?


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1 10:51:21 A No, I'm not aware of that.

2 10:51:22 Q Not aware of that? Okay. You're aware

3 10:51:23that 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 10:51:45which came out a year or so ago called Corruption

7 10:51:50Chronicles. 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 10:51:52name in that book, is there?

11 10:51:57 A I don't know. I don't -- I think you --

12 10:51:58you wrote to us complaining about that so I don't

13 10:52:01know. 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 10:52:07us when we mention your name and you threaten us

17 10:52:09when we don't mention your name, so we're kind of --

18 10:52:12it's a catch-22.

19 10:52:13 Q You're aware that you and Fitton and

20 10:52:19Farrell -- Farrell took total credit for what went

21 10:52:21on 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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1 10:52:24and to the relevancy of this book.

2 10:52:27 THE WITNESS: I don't -- I don't think

3 10:52:28that's a fair characterization, but I do get back to

4 10:52:30my law- -- the lawsuit where you sued us because we

5 10:52:34referred to you as a former employee. So, you know,

6 10:52:37I don't know what we're supposed to do with you.

7 10:52:39You sue us if we refer to you. You threaten to sue

8 10:52:44us if we don't refer to you. It's just --


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 10:52:52of 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 10:52:57we're past the issue of my alleged defamation for

19 10:53:00being convicted of a crime, now all of a sudden you

20 10:53:04have a memory of what I did, correct?

21 10:53:06 MR. KRESS: Object -- Objection to the

22 10:53:07form.


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1 10:53:07 THE WITNESS: I don't understand what

2 10:53:07you're talking about.


4 10:53:08 Q Well, before you had no specific

5 10:53:09recollection of things?

6 10:53:10 A Oh, you were -- when you were asking me

7 10:53:12specific questions about certain things involving

8 10:53:14this, I did not -- I do not have specific -- some

9 10:53:17specific recollections.

10 10:53:18 Q The issue of this lawsuit, you have no

11 10:53:20specific recollection?


13 10:53:22 THE WITNESS: What do you mean? I'm here.

14 10:53:24I recall. I'm here. I know there's a lawsuit

15 10:53:26pending.


17 10:53:27 Q You know you're sitting here so you have

18 10:53:28recollection that you're sitting here right now?

19 10:53:30 A I know you sued us in 2013 and we've been

20 10:53:33litigating it ever since, and I know you've given us

21 10:53:35nothing in terms of discovery and I know you've

22 10:53:38waited till the last minute before you want to take


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1 10:53:40any 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?



7 10:53:51 Q You don't remember what went on with

8 10:53:54Ruffley, you don't remember what went on with

9 10:53:56Driscoll, you don't remember anything else, but now

10 10:53:59you remember everything else, correct?


12 10:54:02 THE WITNESS: No, that's not correct. My

13 10:54:05testimony is what it has been. When you've asked me

14 10:54:07specific questions I've tried to answer you. If I

15 10:54:09didn't recall, I didn't recall. If I had a general

16 10:54:11recollection, I told you.


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 10:54:28Watch matters?

22 10:54:29 A No.


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1 10:54:31 Q What kind of computer did you have in and

2 10:54:33around February 23rd, 2012? Is it the same one you

3 10:54:38have 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 10:54:53that stuff.

12 10:54:58 Q It's sitting in front of you on your desk,

13 10:55:00isn't it?

14 10:55:00 A It's a black box. It's -- actually it's

15 10:55:03sitting 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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1 10:55:22don't you?

2 10:55:22 A I do.

3 10:55:24 Q And you're staring at that computer all the

4 10:55:27time, right?

5 10:55:27 A I have nice speakers. I bought myself, but

6 10:55:33I don't remember what brand though of the monitor I

7 10:55:34have.

8 10:55:34 Q What kind of laptop do you have? What's

9 10:55:38the 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 10:55:47computer, where is the old one?

15 10:55:49 A I don't know. Our computer guy swapped it

16 10:55:51out 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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1 10:56:07 Q Farrell's?

2 10:56:09 A I don't know. I don't think so. I think,

3 10:56:16oh, we have a whole process involving computers and

4 10:56:18periodic, you know, reviews. I was having some

5 10:56:20trouble loading some, you know, programs on mine.

6 10:56:22They looked at it. They determined it was sort of

7 10:56:25old and slow and that they would bring in another

8 10:56:27one, and they did.



11 10:56:39The time is 10:56 a.m.

12 10:56:47 (Recess.)

13 11:07:35 THE VIDEOGRAPHER: Back on the record.

14 11:07:39Here marks the beginning of Volume 1, Tape No. 2 in

15 11:07:41the deposition of Paul Orfanedes. The time is 11:07

16 11:07:45a.m.


18 11:07:49 Q In and around February 23rd, 2012, what

19 11:07:51kind of cell phone did you have?

20 11:07:56 A I've got one of these things. I don't know

21 11:08:00if I had it back then (indicating). It's a black

22 11:08:04box, not very technical.


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1 11:08:06 Q Who makes it?

2 11:08:07 A It says Sprint on it. I don't know who

3 11:08:10makes it.

4 11:08:10 Q So you were using -- Judicial Watch was

5 11:08:12using Sprint at that time?

6 11:08:15 A I know I was, I guess. I don't -- I don't

7 11:08:18remember 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 11:08:25correct?

12 11:08:27 A I'm not very -- I'm not -- I don't really

13 11:08:30text 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 11:08:41screens. I tend to use -- you know those little

19 11:08:44screens, I tend to use my computer but it's linked

20 11:08:47up to the computer anyway.

21 11:08:48 Q Are you saying -- are you saying you've

22 11:08:49never sent an e-mail with Sprint service?


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1 11:08:51 A I might have. I don't -- I'm not very good

2 11:08:55at that. I hate those little screens, so I try to

3 11:08:59communicate -- in e-mail I use my Outlook on my

4 11:09:02computer instead, and I'm usually at my desk, so it

5 11:09:04makes more sense to do that anyway.

6 11:09:06 Q Your computer in and around February 23rd

7 11:09:09of 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 11:09:23Outlook has backup system to retain e-mails, does it

11 11:09:25not?

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 11:09:30correct?

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 11:09:34Outlook, correct?

18 11:09:35 A No. If -- if something is significant, I

19 11:09:38will tend to print it out and put it in the -- you

20 11:09:40know, the relevant correspondence file. I don't

21 11:09:48generally save e-mails for anything past, you know,

22 11:09:50a month or 2 months unless, like I've just talked


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1 11:09:54about, I've printed it and put it in a

2 11:09:57correspondence file. That's always been my practice

3 11:10:00because I hate having all that stuff floating around

4 11:10:03in an e-mail account.

5 11:10:04 Q Have you deleted from Outlook since

6 11:10:06February 23rd, 2012?

7 11:10:08 A Oh, probably. I mean, that's my regular

8 11:10:10practice is not to keep stuff in my --

9 11:10:14 Q So you deleted both from -- from the hard

10 11:10:16drive and from Outlook?

11 11:10:18 A I don't know about the hard -- I don't know

12 11:10:20what you mean by the hard drive. I don't know how

13 11:10:22all that stuff works. All I know is I use -- I

14 11:10:26guess it's Outlook. I get e-mail. If something is

15 11:10:29significant, case related, I'll print it out, a lot

16 11:10:33of the stuff otherwise I just delete without

17 11:10:35printing out.

18 11:10:36 Q I'm going to ask you not to delete further

19 11:10:38until we approach the court on getting access to

20 11:10:40your computer and having looked at by a computer

21 11:10:46expert your computers. You're on notice.

22 11:10:49 A Okay. I mean, just those are more Larry


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1 11:10:52Klayman threats.

2 11:10:52 Q Not threats. I'm just asking you not to do

3 11:10:55it so you don't have a misunderstanding.

4 11:10:58 A When you tell someone you're on notice,

5 11:10:59that'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 11:11:05yourselves accordingly letter that you sent with

9 11:11:12Rich. It's just a notice. Okay.

10 11:11:12 Q You've never seen other lawyers use please

11 11:11:16govern yourself accordingly?

12 11:11:18 A Very few. It's usually you, and it usually

13 11:11:22makes 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 11:11:41I 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 11:11:48I?

20 11:11:49 A I think you were instrumental in

21 11:11:51bringing -- in having Mr. Paul bring it.

22 11:11:53 Q But another law firm brought that lawsuit


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1 11:11:55for --

2 11:11:55 A Right, the same law firm that was

3 11:11:57representing you initially in your lawsuit against

4 11:12:00Judicial Watch based in Pennsylvania sued us on

5 11:12:02behalf of Mr. Paul, and then at some point they

6 11:12:06withdrew and then you represented Mr. Paul.

7 11:12:09 Q You're aware at the time that Mr. Paul had

8 11:12:11no money?

9 11:12:14 A Oh, I don't want to get into Mr. Paul and

10 11:12:18his money. I don't --

11 11:12:19 Q You're aware that he was under house

12 11:12:21arrest?

13 11:12:25 A Those are all loose terms, and I don't know

14 11:12:27what the timing you're referring to.

15 11:12:29 Q And did not have means of making money at

16 11:12:34that time, you're aware of that, right?

17 11:12:36 A Which time frame are you talking about? I

18 11:12:40mean, I want to --

19 11:12:40 Q When you claim that I came into the case on

20 11:12:42behalf of Mr. Paul.

21 11:12:44 A I believe at that point he had been

22 11:12:47indicted for stock manipulation, stock fraud issue,


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1 11:12:52and he had been extradited from Brazil and he was --

2 11:12:59one of the conditions for him not being in jail was

3 11:13:01that he was on -- staying in his apartment in North

4 11:13:05Carolina 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 11:13:22get into that because what I'm aware of came from

10 11:13:24Mr. Paul in the context of an attorney-client

11 11:13:27communication or in the context of an

12 11:13:31attorney-client relationship, and I don't think it's

13 11:13:33appropriate for me to have to testify about that.

14 11:13:35 Q Well, you raised it. That's why I'm

15 11:13:37getting into it.

16 11:13:38 A No. I raised the idea that -- that you

17 11:13:39represented Mr. Paul in a lawsuit against Judicial

18 11:13:42Watch and that you were instrumental in causing

19 11:13:44Mr. Paul to raise that lawsuit. I didn't -- I

20 11:13:46didn't raise anything about Mr. Paul's sources of

21 11:13:48income.

22 11:13:49 Q Well, you are aware that Judicial Watch


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1 11:13:51agreed to represent Mr. Paul with regard to his

2 11:13:56possible indictment and then indictment for

3 11:14:00securities and bank fraud and that we promised to

4 11:14:05provide representation for him, correct?

5 11:14:08 MR. KRESS: I'm not aware of the substance

6 11:14:11of these -- what the answers are, but it appears to

7 11:14:15be approaching attorney-client privileged

8 11:14:16information. So I would just caution you that --

9 11:14:20not to reveal attorney-client privilege, if you can.

10 11:14:22 THE WITNESS: I don't -- I'm not -- this is

11 11:14:25all sort of unusual. I don't know how to get into

12 11:14:28this stuff in a way that preserves any

13 11:14:30attorney-client communications.


15 11:14:32 Q Well, you raised it, correct?

16 11:14:34 A No. I raised the idea that you were

17 11:14:36instrumental in causing the former Judicial Watch

18 11:14:38client to file a lawsuit against the organization,

19 11:14:40and 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 11:14:48you to get into --


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1 11:14:49 MR. KLAYMAN: Let me ask the question and

2 11:14:50you'll see why, because he opened the door to this,

3 11:14:53and --

4 11:14:53 THE WITNESS: No, I did not open the door

5 11:14:54to anything.


7 11:14:55 Q You opened the door to this. And in fact,

8 11:14:59Judicial Watch, after I left, abandoned Mr. Paul and

9 11:15:00he had no representation in the criminal proceeding,

10 11:15:02correct?

11 11:15:02 MR. KRESS: I'm going to object. If you

12 11:15:06know, I suppose you can answer -- I'm going to

13 11:15:09object to the use of the word "abandoned."

14 11:15:14 THE WITNESS: Well, it's also completely

15 11:15:15irrelevant to anything having to do with a 2012

16 11:15:19alleged defamatory statement.


18 11:15:22 Q Well then, why did you raise it,

19 11:15:24Mr. Orfanedes?

20 11:15:24 A You were -- I believe the whole thing came

21 11:15:26up in the context of you were asking me how I

22 11:15:32learned of the posting, and I referenced the threat


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1 11:15:34you made to the organization. And then we got into

2 11:15:36what's a threat, and then I was trying to articulate

3 11:15:39that, given the number of lawsuits and actions that

4 11:15:43you had brought and caused to be brought against the

5 11:15:45organization and me and the other directors, when we

6 11:15:51got the kind of correspondence -- when we got this

7 11:15:54correspondence from you about the February 2012

8 11:16:00matter, we interpreted it as yet another threat.

9 11:16:05 And I think you started asking me why it

10 11:16:07was a threat, and I was trying to explain that you

11 11:16:12had made threats against us in the past and filed

12 11:16:16lawsuits 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 11:16:26contacting Mr. Driscoll was a threat, you, Paul

17 11:16:33Orfanedes as the legal officer of Judicial Watch and

18 11:16:35Judicial Watch itself and as an ethics group, had an

19 11:16:40obligation to correct anything that may have been

20 11:16:41defamatory that was in the public record, correct?

21 11:16:44 A You know, I -- I don't know anything about

22 11:16:46that, but I do know I reviewed the postings at some


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1 11:16:49point after you contacted us, and I looked at both

2 11:16:52of them because I believe Ms. Taitz's subsequent

3 11:16:58posting of a few days later was up -- up being put

4 11:17:03on the internet -- I looked at all of this. I

5 11:17:06didn't see that there was anything defamatory. I

6 11:17:08didn't see that there was anything harmful. I

7 11:17:13didn't see that there was any issue, and I

8 11:17:15interpreted all of this as yet another part of your

9 11:17:17ongoing campaign of harassment against Judicial

10 11:17:20Watch.

11 11:17:20 Q Okay, so saying publicly that someone's

12 11:17:23convicted of a crime when he's not, there's nothing

13 11:17:27harmful about that in your opinion, is there?

14 11:17:30 A I looked at the posting -- I don't know

15 11:17:34where the posting is.

16 11:17:35 MR. KRESS: I think -- do you need to see

17 11:17:37them?

18 11:17:37 THE WITNESS: No, but, I mean, the posting

19 11:17:39says what it says. I think the posting also makes

20 11:17:42clear that it contains other statements saying that

21 11:17:47you were only indicted, and then Ms. Taitz posted

22 11:17:51her subsequent, you know, posting 2 days later that


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1 11:17:55says she was wrong. You had only been indicted and

2 11:17:58not convicted of this child support issue.

3 11:18:03 I mean, I looked at all that and I saw no

4 11:18:05issue. And given your history of threats and

5 11:18:09allegations, false allegations against the

6 11:18:13organization and the number of lawsuits that you've

7 11:18:15already filed against the organization, I saw this

8 11:18:18whole matter that you were raising with Rich, you

9 11:18:22were raising with Judicial Watch as just another of

10 11:18:25the pattern of harassment and threats you've been

11 11:18:29making against the organization for 10 years.


13 11:18:37 Q Let's take a look at Exhibit 2. Look at

14 11:19:03the comments on Exhibit 2.

15 11:19:05 MR. KRESS: He doesn't have it in front of

16 11:19:07him.

17 11:19:07 THE WITNESS: I don't have anything in

18 11:19:08front of me.

19 11:19:32 MR. KRESS: Okay.


21 11:19:34 Q Exhibit 2 February 26 -- wait. Excuse me,

22 11:19:39February 23rd.


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1 11:19:41 MR. KRESS: This is the first posting.

2 11:19:43 THE WITNESS: Okay, yeah.


4 11:19:44 Q Look at the comments. Bloodless coup.

5 11:19:47We're talking -- we're looking at page 4 into that

6 11:19:51document. JW 0004. Okay?

7 11:19:54 A Okay.

8 11:19:55 Q Bloodless coup, February 23rd, 2012. "I

9 11:19:58was initially excited about Larry Klayman, and

10 11:20:00helped the news about him to go viral. Now I am

11 11:20:03wondering about him and what his true motives might

12 11:20:05be."

13 11:20:07 You understand that this is not a positive

14 11:20:09remark with regard to me, correct?

15 11:20:12 A I don't know anything about this comment

16 11:20:13other 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 11:20:21anything about it.

20 11:20:21 Q Well, you had an opportunity to review

21 11:20:25this, did you not, at the time?

22 11:20:25 MR. KRESS: I think he --


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1 11:20:29 THE WITNESS: That doesn't have anything to

2 11:20:31do with anything.

3 11:20:31 MR. KRESS: I think his testimony was he

4 11:20:34didn't know if he read the comments.

5 11:20:36 MR. KLAYMAN: Please don't give him

6 11:20:37testimony.

7 11:20:37 THE WITNESS: Well, that -- that was my

8 11:20:38testimony.

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 11:20:45another problem.

12 11:20:45 THE WITNESS: It's bush league threats and

13 11:20:48intimidation. Maybe it worked in Philadelphia or

14 11:20:50wherever -- wherever you practiced back in the day,

15 11:20:52but come on, Larry.


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 11:21:01because --

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 11:21:052003.

3 11:21:05 Q Look at the second one. "I smelled a rat

4 11:21:09from the get-go. Asking for $25,000 for 2 lawsuits

5 11:21:13sounded way out of the ballpark for me, so I did not

6 11:21:17bite. Seemed like attempt to scam money on the

7 11:21:17backs of people wanting to expose Obama, and nothing

8 11:21:22more. Glad Orly stays on top of things like this

9 11:21:27for us. WHERE DOES SHE FIND THE TIME?? Talk about

10 11:21:27multi-tasking, I think Orly is the queen of that as

11 11:21:31well!"

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 11:21:49is 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 11:21:58about the facts of this case, that's fine, but to

21 11:22:01read me statements and ask -- that I have no idea

22 11:22:04what their origin is, I don't know who these people


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1 11:22:09are, there's multiple levels of hearsay here and you

2 11:22:12ask me if that's positive, you know, I don't know.

3 11:22:14It's just -- it's silly. I'm not going to answer

4 11:22:16that.

5 11:22:16 Q Well, it deals with your state of mind and

6 11:22:19wanting 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 11:22:27of mind was. I looked at all this. I saw no issue.

11 11:22:30I figured this was -- I concluded this was yet

12 11:22:32another part of your long campaign of harassment

13 11:22:35against the organization.

14 11:22:51 Q I want you to take a look at Exhibit 1,

15 11:23:03third page. It's JW 00015.

16 11:23:09 MR. KRESS: I think that's -- he doesn't

17 11:23:12have that in front of him, I don't think. He does

18 11:23:21not have that in front of him.


20 11:23:31 Q Let me read it to you, and I'll show it to

21 11:23:33you.



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2 11:23:46The time is 11:23 a.m.

3 11:24:42 (Recess.)


5 11:28:27time is 11:28 a.m.


7 11:28:38 Q Please turn to the third page of this, JW

8 11:28:4115, on Exhibit 1.

9 11:28:43 A Mm-hmm.

10 11:28:44 Q Paragraph 4, posted by Orly Taitz

11 11:28:49presumptively. I'm going to read this to you. "I

12 11:28:53read the first post I made in regards to Mr. Klayman

13 11:28:56and I saw that indeed there was an error. I wrote,

14 11:28:58that Ms. Ruffley stated that Mr. Klayman was just

15 11:29:02recently convicted of non payment of child support.

16 11:29:02The link and the article right under it stated, that

17 11:29:08he was indicted in 2 counts of criminal non-support,

18 11:29:09that he owes $78,861.76 and arrignment (sic) was

19 11:29:13scheduled for February 7, 2012. So, there was an

20 11:29:16error. Mr. Klayman was indicted in the state of

21 11:29:21Ohio on two counts of criminal non-support, but he

22 11:29:23was not convicted yet. I am making this correction.


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1 11:29:26Ms. Ruffley made an error." Ms. Ruffley made an

2 11:29:30error.

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 11:29:34reading 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 11:29:39questions. Let me finish.

9 11:29:40 A Okay.

10 11:29:40 Q It was also self evident in the February

11 11:29:4323rd, 2012 article, as I posted the link right

12 11:29:46underneath and the link stated, that he was indicted

13 11:29:49and arraignment scheduled. The article was

14 11:29:53published a couple of days ago on February 23 and I

15 11:29:56corrected it to today on February 26, 2012. Are you

16 11:29:58saying that Ms. Ruffley did not make an error?

17 11:30:02 A I'm saying that's what Ms. Taitz seems to

18 11:30:05say here. I remember reading this posting back when

19 11:30:07you read this -- you were complaining to Rich or you

20 11:30:11brought the matter to our attention.

21 11:30:15 Q Are you saying that Ms. Ruffley, when she

22 11:30:17made the purported statement to Ms. Taitz did not


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1 11:30:20make an error?

2 11:30:21 A I don't know what Ms. Ruffley said. All I

3 11:30:31know is that Ms. Taitz posted something claiming

4 11:30:34that 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 11:30:40also said you'd been indicted and that an

8 11:30:42arrangement was scheduled. You could read that

9 11:30:45whole posting as a whole as being ambiguous at best,

10 11:30:53and then Ms. Taitz issued this retraction,

11 11:30:56clarification, acknowledgment that there was an

12 11:30:58error. She attributed the error to Connie, but I

13 11:31:02don't know. I don't know what Connie said. The

14 11:31:04error could have been in Ms. Taitz's perception of

15 11:31:07what Connie said.

16 11:31:10 I don't know what happened. But I read the

17 11:31:12whole posting exchange and I concluded there was

18 11:31:14nothing to it, that it was part of the pattern of

19 11:31:19harassment that you had engaged in against Judicial

20 11:31:22Watch and its officers and directors and employees

21 11:31:24since 2003.

22 11:31:24 Q Did you or Judicial Watch make an effort to


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1 11:31:27find out whether or not Connie Ruffley said that?

2 11:31:30 A I think we went over this. I may have

3 11:31:32spoken with Connie, and anything she told me would

4 11:31:35be subject to attorney-client privilege.

5 11:31:41 Q We're in litigation right now over this

6 11:31:43issue, correct?

7 11:31:44 A Which issue is that?

8 11:31:45 Q Whether or not Connie Ruffley said these

9 11:31:47matters on behalf of Judicial Watch, whether or not

10 11:31:50she said I was convicted of a crime and that

11 11:31:52information should be given to donors?

12 11:31:54 A Oh, there's multiple issues there, so

13 11:31:57you've just comp- -- complicated your own question.

14 11:32:00 Q So it wasn't just a question of she's

15 11:32:02saying that I should be -- excuse me. It just

16 11:32:06wasn't a question of her saying I was convicted,

17 11:32:09Connie Ruffley, of a crime but also that that

18 11:32:11information should be provided to donors, correct?


20 11:32:14 THE WITNESS: I -- I guess I didn't

21 11:32:15understand that that's -- you were making an issue

22 11:32:17of that, but if you're making an issue of that,


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1 11:32:20okay, you're making an issue of that. Whether

2 11:32:22Connie said that, I don't know if she said that or

3 11:32:24not. Like I said, I wasn't there.


5 11:32:28 Q You just said you can't testify to that

6 11:32:30because of attorney-client privilege, but now you

7 11:32:32say you don't know if she said that or not. Which

8 11:32:35is it?

9 11:32:35 A I was not present at the meeting that

10 11:32:37allegedly took place on February -- whenever it

11 11:32:40was -- in Garden Grove, California. I'm not a

12 11:32:44witness to that.

13 11:32:45 Q Let's take Larry Klayman out of the whole

14 11:32:47equation, 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 11:32:54not, 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 11:32:59joke to be accused of someone being accused of a

21 11:33:04crime?

22 11:33:04 A I think your questions today is ridiculous,


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1 11:33:07just 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 11:33:14against Judicial Watch and its officers and

5 11:33:15directors and employees.

6 11:33:16 Q You think putting out into public domain

7 11:33:18that a lawyer's been convicted of a crime when he's

8 11:33:20not is a joke?


10 11:33:22 THE WITNESS: I've answered the question.


12 11:33:25 Q Well, you were laughing. I want to find

13 11:33:28out whether you think that's funny.

14 11:33:29 A I was laughing at your absurd attempts to

15 11:33:32be intimidating.

16 11:33:33 Q I haven't raised my voice once during this

17 11:33:35deposition, 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 11:33:44itself, but I'm asking you the question --


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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 11:33:52Watch; 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 11:33:57Judicial Watch is accusing someone of a crime

9 11:33:59falsely, you have an obligation to investigate that;

10 11:34:01do you not?



13 11:34:04 Q As a director?

14 11:34:05 A No, I'm going to object. I don't -- I

15 11:34:07don't know what all my obligations are within the

16 11:34:09scope of my fiduciary duty if they would include

17 11:34:12something like that, but even if it were, you know,

18 11:34:15that's not the scenario. That's not the facts that

19 11:34:17we're here to talk about today. We're not talking

20 11:34:20about hypothetical cases. We're talking about this

21 11:34:22case in which you claim, based on nothing more than

22 11:34:28a posting that has been -- that itself is ambiguous,


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1 11:34:32that Connie made certain statements to Orly Taitz.

2 11:34:38That'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 11:34:43lawsuit, I'm happy to answer them.

6 11:34:44 Q I'm talking about your fiduciary duty to

7 11:34:47Judicial Watch.

8 11:34:47 A In a hypothetical context, and I'm not

9 11:34:51going to answer that.

10 11:34:52 Q I'm asking you in a specific context. If

11 11:34:54one of Judicial Watch's employees makes a statement

12 11:34:57which is false and it's in the public domain, to

13 11:34:59protect Judicial Watch you have an opportunity to do

14 11:35:01due diligence and find out whether that statement

15 11:35:02was made, correct?

16 11:35:03 A Not necessarily. It depends. There's so

17 11:35:06many circumstances, so many variables that could

18 11:35:09exist in your hypothetical that I can't even answer

19 11:35:11the question.

20 11:35:11 Q The difference is if it's Larry Klayman is

21 11:35:14involved then you're not going to do it, correct?

22 11:35:15 A No. The difference is that that provides


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1 11:35:18additional facts such that a lawyer or a court

2 11:35:22trying to reach a conclusion about a fiduciary

3 11:35:25obligation has more on which it could base a

4 11:35:28conclusion. Number one, that's not the purpose of

5 11:35:31this deposition; number two, that's not the question

6 11:35:33that 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 11:35:42suggest your question is a bad question and you

10 11:35:45should just move on to something that's relevant.

11 11:35:47 Q You are -- you are a member of the Board of

12 11:35:49Directors and you're the chief legal officer of


14 11:35:51 A Mm-hmm.

15 11:35:52 Q Okay. You have a fiduciary obligation to

16 11:35:57Judicial Watch, do you not, to find out whether or

17 11:36:00not Connie Ruffley made that statement about Larry

18 11:36:03Klayman, that he was convicted of a crime and the

19 11:36:05information should be given to donors?



22 11:36:09 Q On behalf of Judicial Watch to protect


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1 11:36:11Judicial Watch, you have that obligation, correct?


3 11:36:14 THE WITNESS: I don't know that I'll say

4 11:36:15that I have that. I don't know that I have a

5 11:36:18fiduciary obligation in those circumstances. I

6 11:36:21don't know, especially when I have something in

7 11:36:24front of me, the postings, that make clear to me

8 11:36:28that it's ambiguous at best what was said, if

9 11:36:34anything.


11 11:36:34 Q Is there anything ambiguous about the

12 11:36:36word "convicted"?

13 11:36:38 A Well, I think what you're ignoring is the

14 11:36:40fact that -- I don't know how many paragraphs below,

15 11:36:47but it is not very many, one -- actually, it's --

16 11:36:57well, I don't know. I would say the second

17 11:37:00paragraph below it, "Larry Klayman was indicted on

18 11:37:02two counts of criminal nonsupport," blah, blah,

19 11:37:06blah. Arraignment is scheduled for February 7th.

20 11:37:10 You know, I don't know. To me that's

21 11:37:12saying you were convicted -- I'm sorry. See, I

22 11:37:15misspoke. It's easy to misspeak as well. It says


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1 11:37:20that you were indicted, and then there's other stuff

2 11:37:26goes further on about a bar complaint against you.

3 11:37:29You know, this is -- raises a host of different --

4 11:37:33there's a number of factual statements about that --

5 11:37:36about you here.

6 11:37:36 Q Has Ms. Ruffley been -- have you

7 11:37:39communicated with her and tell her to be careful in

8 11:37:42the future what she says about individuals?

9 11:37:43 A Any such communications would be governed

10 11:37:45by attorney-client privilege and would be subject to

11 11:37:49a litigation privilege as well.

12 11:37:50 Q Was she disciplined over these alleged

13 11:37:53statements?


15 11:37:54 THE WITNESS: Do I need to answer that?

16 11:37:57That's a personnel matter too. I don't know -- I

17 11:38:03don'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.


21 11:38:10The time is 11:38 a.m.

22 11:38:13 (Recess.)


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2 11:39:45time is 11:39 a.m.

3 11:39:47 (The reporter read the record as

4 11:39:53requested.)

5 11:39:53 THE WITNESS: No.


7 11:39:57 Q Was she criticized over these alleged

8 11:39:59statements?

9 11:39:59 A No.

10 11:40:02 Q Was she cautioned not to make statements

11 11:40:04like that in the future?

12 11:40:14 MR. KRESS: I'm going to -- I think that is

13 11:40:15more getting into attorney-client privilege or work

14 11:40:21product, if that's -- if it's anything in --

15 11:40:23 MR. KLAYMAN: It's the same question. It's

16 11:40:25just a corollary of it.

17 11:40:27 MR. KRESS: Is it -- I don't know if it's

18 11:40:30really a corollary, if you're getting into

19 11:40:32communications that are related to the litigation.

20 11:40:40 If it's related -- because I think there

21 11:40:45were no communications until after there's already

22 11:40:49what we've called a threat of a lawsuit, and so I


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1 11:41:00think -- I think it's work product. You're a lawyer

2 11:41:04too, though.

3 11:41:11 THE WITNESS: Can you read back the

4 11:41:12question.



7 11:41:22 MR. KRESS: I'll continue to object. I

8 11:41:23think it's also -- well, I'll continue to object.

9 11:41:29Do we need to talk about this one too?

10 11:41:31 MR. KLAYMAN: You're not instructing him

11 11:41:32not to answer, though, are you?

12 11:41:34 MR. KRESS: Well, I want to -- I think -- I

13 11:41:38think we may need to confer about it again. I'm

14 11:41:41sorry. 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 11:41:42deposition, but let's go off the record again.


19 11:41:46The time is 11:41 a.m.

20 11:41:49 (Recess.)


22 11:43:22time is 11:43 a.m.


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3 11:43:36 THE WITNESS: My answer would be as

4 11:43:40follows: First of all, you didn't use the word

5 11:43:42"alleged" in your question. I mean, we dispute that

6 11:43:45she made the statement that is attributed to her by

7 11:43:48Ms. Taitz. I don't recall if she was cautioned in

8 11:43:51any manner that you suggest. Generally, I would

9 11:43:57tell employees to be very careful about any

10 11:44:00statements or anything they say about you because

11 11:44:02you have this pattern and history of bringing --

12 11:44:05making threats and bringing lawsuits against the

13 11:44:09organization.


15 11:44:12 Q So all of a sudden, in the context of that

16 11:44:14question, you're willing to testify hypothetically,

17 11:44:18as you put it?

18 11:44:18 A No. I'm trying to answer the question that

19 11:44:21I would generally caution employees about saying

20 11:44:23anything about you in public because you have such a

21 11:44:27history of bringing threats and lawsuits and

22 11:44:31baseless allegations against Judicial Watch and its


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1 11:44:34employees.

2 11:44:35 Q So your testimony is you don't remember

3 11:44:37whether or not you told -- you cautioned her not to

4 11:44:40make statements like the alleged statements in the

5 11:44:42future?

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 11:44:55Ms. 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 11:45:00privilege on conversations you had with Ms. Ruffley?

14 11:45:04 A Well, I'm the -- I'm the chief lawyer for


16 11:45:06 Q So you're claiming that you represent her

17 11:45:09in this case?

18 11:45:13 A I represent Judicial Watch in an in-house

19 11:45:15capacity, yes. She's an employee of Judicial Watch

20 11:45:17so, yes.

21 11:45:17 Q So anything that you discuss with anyone

22 11:45:19because you're a lawyer is -- is subject to


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1 11:45:21attorney-client privilege?

2 11:45:23 A I don't think it's quite -- that's not a

3 11:45:25fair articulation of the privilege, but I think I'm

4 11:45:28invoking the privilege to its full extent.

5 11:45:31 Q So, given the operative facts of this case,

6 11:45:35because you're a lawyer you don't have to discuss

7 11:45:37what went on with Judicial Watch and Connie Ruffley

8 11:45:39and Larry Klayman?



11 11:45:42 Q That's your position?

12 11:45:43 A My position is communications I had with

13 11:45:48Judicial Watch employees about this matter are

14 11:45:50subject to attorney-client privilege because I'm

15 11:45:56chief in-house counsel to Judicial Watch.

16 11:45:57 Q You were the point person, in effect, in

17 11:46:03dealing with this issue with regard to Rich

18 11:46:06Driscoll, Larry Klayman, and Connie Ruffley,

19 11:46:08correct?

20 11:46:08 A I'm the point person within Judicial Watch

21 11:46:10for dealing with all legal matters concerning the

22 11:46:12organization.


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1 11:46:15 Q Did Fitton get into a discussion with

2 11:46:17Driscoll 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 11:46:31correct?

8 11:46:31 A Well, it's my job.

9 11:46:33 Q Okay. So, therefore, we'll never been able

10 11:46:36to find out what went on between Ruffley and you

11 11:46:39with regard to these statements that were made

12 11:46:41concerning Larry Klayman, because no one else can

13 11:46:45testify to it and you're invoking privilege?

14 11:46:49 MR. KRESS: I'm going to object to the

15 11:46:51form.

16 11:46:51 THE WITNESS: Is that a question?


18 11:46:52 Q Yeah.

19 11:46:55 MR. KRESS: I'm not sure what the question

20 11:46:56is.

21 11:46:57 THE WITNESS: I don't know -- I don't know

22 11:46:57if that's a question.


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2 11:46:58 Q You don't have to testify because you're an

3 11:47:00attorney 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 11:47:13do you not believe that Judicial Watch had a duty to

7 11:47:16mitigate any damage to Larry Klayman as a result of

8 11:47:19these alleged statements?


10 11:47:22 THE WITNESS: I think that's a legal

11 11:47:23conclusion, and I would disagree with your legal

12 11:47:26conclusion. I think it's the plaintiff's burden to

13 11:47:28mitigate damage.


15 11:47:29 Q If a plaintiff is defamed, it's his burden

16 11:47:32to mitigate the damage?

17 11:47:34 A Usually. Isn't mitigation something that

18 11:47:36weighs against the plaintiff?

19 11:47:43 Q In a defamation case, is that what you're

20 11:47:44saying?

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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1 11:47:49to do nothing with regard to the alleged statements

2 11:47:51concerning me?


4 11:47:53 THE WITNESS: I object to your question

5 11:47:55too.


7 11:47:58 Q Did you?

8 11:48:00 A Of course I consulted the law. I relied on

9 11:48:02my 22 years of experience at that point because it

10 11:48:06was 2012.

11 11:48:07 Q And what -- what did you determine in

12 11:48:11consulting 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 11:48:27at this time. I'm going to leave the deposition

16 11:48:29open subject to hopefully obtaining documentation.

17 11:48:33Hopefully, Doug, to your consulting with your client

18 11:48:36and reconsidering whether he should be answering

19 11:48:38some of these questions so we don't have to go to

20 11:48:40the court and waste unnecessary time and resource.

21 11:48:42 MR. KRESS: I -- I think that we have

22 11:48:43answered questions other than questions that were


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1 11:48:45protected by attorney-client privilege or work

2 11:48:48product. We've produced the documents we have in

3 11:48:50response to -- and I've stated objections to the

4 11:48:54document requests, and those speak for themselves.

5 11:48:59I don't think I need to restate them. So we can --

6 11:49:03I believe we have fully -- more than fully complied

7 11:49:06with our obligations in responding to documents.

8 11:49:14 And the document requests, in effect,

9 11:49:22came -- they did not give us the 30 days to respond.

10 11:49:26They gave us, I think -- I don't know -- less

11 11:49:28than -- a couple weeks, 2, 3 weeks. So we in good

12 11:49:31faith produced those documents, and I think we

13 11:49:33exceeded our obligations in producing documents to

14 11:49:37you, and for those reasons and the other reasons

15 11:49:43stated in our objections.

16 11:49:44 MR. KLAYMAN: I have a few more questions,

17 11:49:47but the deposition will be left open. I have a few

18 11:49:51more.

19 11:50:02 MR. KRESS: I will object to continuing

20 11:50:03questions. You said you were done, but we'll let

21 11:50:05you continue.

22 11:50:24 MR. KLAYMAN: I'll show you what I'll ask


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1 11:50:25the court reporter to mark as Exhibit 4.





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 11:51:35different from the one we marked before, right?

9 11:51:37This is -- this is her responding to some comments,

10 11:51:41something 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 11:51:48questions; you are.

15 11:51:49 A Oh, I'm just trying to understand the

16 11:51:50context of this.

17 11:51:51 Q I asked you if you ever saw the document

18 11:51:53before.

19 11:51:54 A She seems to be responding -- am I right in

20 11:51:57thinking that she's responding to something you

21 11:51:59wrote her, which I assume given it was you,

22 11:52:02threatened her.


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1 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 11:52:09that.

4 11:52:10 MR. KLAYMAN: By the way, these documents

5 11:52:11were 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 11:52:43same thing as Exhibit 1 in a slightly different

9 11:52:45format but --

10 11:52:46 THE WITNESS: Is it? Oh, okay. Well,

11 11:52:53maybe -- I don't know. I'm confused by the format.

12 11:53:05I remember seeing this paragraph 4 on page 2 of

13 11:53:11Exhibit 4, which I also guess is the same as

14 11:53:16paragraph 4 on page 3 of Exhibit 1. So I don't

15 11:53:24know. I'm just confused by the format.


17 11:53:26 Q Have you seen it before?

18 11:53:28 A I don't know. I remember seeing this

19 11:53:31paragraph 4 in both Exhibit 4 and Exhibit 1. I

20 11:53:37don't remember necessarily seeing these comments.

21 11:53:41Maybe they were there and I didn't focus on them. I

22 11:53:43don't know.


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1 11:53:43 Q Okay. I'll show you what I ask to be

2 11:53:48marked as Exhibit 5, Plaintiff's Exhibit 5.




6 11:54:13 THE WITNESS: Is there a question?


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 11:54:20something you produced to us a few days ago, and I

11 11:54:25believe that's the first time I saw it.

12 11:54:29 MR. KLAYMAN: Ask the court reporter to

13 11:54:31mark this Exhibit 6.






19 11:54:47 A I remember this picture of Obama on the

20 11:54:50tricycle in the production that you made on

21 11:54:53Saturday. Was it Saturday?

22 11:54:54 MR. KRESS: Friday to me. I probably


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1 11:54:56forwarded it to you on Saturday.

2 11:54:57 THE WITNESS: Saturday, so that's when I

3 11:54:59remember seeing it.

4 11:55:00 MR. KLAYMAN: Okay. Ask the following

5 11:55:02exhibit be marked Exhibit 7.






11 11:55:24 A I don't believe so. Maybe it was one of

12 11:55:34the production you had the other day, but I don't --

13 11:55:36I don't remember that one.

14 11:55:37 MR. KLAYMAN: I'll ask that the following

15 11:55:39document be marked as Plaintiff's Exhibit 8.




19 11:56:07 THE WITNESS: Is there a question?



22 11:56:09 A No. I don't remember receiving it in your


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1 11:56:17document production.

2 11:56:20 MR. KLAYMAN: I'll ask that the following

3 11:56:21exhibit be marked as Exhibit 9, Plaintiff's Exhibit

4 11:56:249.





9 11:56:34 Q I'm going to ask you specific questions on

10 11:56:36that. If you'd like, we can make another copy of

11 11:56:38it. It's documents that you provided to us,


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 11:56:49a second.

18 11:57:15 Okay.

19 11:57:25 MR. KLAYMAN: Let's make a copy of this.

20 11:57:35Off the record.


22 11:57:38The time is 11:57 a.m.


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1 11:57:40 (Recess.)


3 12:00:36time is 12 p.m.


5 12:00:52 Q Exhibit 9 is a composite exhibit. The

6 12:00:54first page -- and these documents were produced by

7 12:00:57Judicial Watch in this case. The first page is the

8 12:01:00Driscoll letter, copy to Paul Orfanedes. The second

9 12:01:05page, that's Judicial Watch Exhibit JW 000505, at

10 12:01:10least that's the Bates number, purports to be an

11 12:01:12e-mail from Paul Orfanedes to Connie Ruffley, but

12 12:01:22the letterhead is Tom Fitton. Can you explain to me

13 12:01:26why it's configured that way and what this is?

14 12:01:29 A Yeah, because Tom printed it out. I didn't

15 12:01:31save it so I didn't have it.

16 12:01:32 Q So you forwarded this e-mail from Connie

17 12:01:35Ruffley to Tom Fitton?

18 12:01:37 A No. I responded to -- well, I guess you

19 12:01:41got to follow the chain of command. This is a

20 12:01:45multipage one. Looks like Steve Anderson, who is

21 12:01:48our director of development, sent it to Tom, Chris,

22 12:01:51and me, CC'd to Susan. I responded to Connie and I


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1 12:01:56CC'd it on Tom, Chris, Steve, and Susan. Tom had it

2 12:02:06in his e-mail account or on his computer when we did

3 12:02:10the document production; I didn't. Like I say, I

4 12:02:14don'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 12:02:29about this posting. Can you make clear to Ms. Taitz

9 12:02:32or whomever is responsible for the posting that she

10 12:02:32was invited by UROC and not 'the Judicial Watch.'

11 12:02:36The posting also needs to be corrected to avoid any

12 12:02:39further 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 12:02:48briefly. What's this whole issue?

17 12:02:50 A Oh, it looks like -- well, Connie for quite

18 12:02:52a long time has been -- I don't know what her title

19 12:02:54is with UROC, United Republicans Of California.

20 12:02:59It's a conservative political organization and she

21 12:03:02has some leadership role with that organization.

22 12:03:04She does this outside of Judicial Watch.


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1 12:03:07 I think UROC asked -- I mean, I'm just

2 12:03:11going based on my recollection of my review of these

3 12:03:16documents. I think UROC might have asked Orly to

4 12:03:20come speak at an event, and it sounds like she

5 12:03:23misunderstood that, Orly did, and was saying that

6 12:03:28the request came from Judicial Watch. So people

7 12:03:34apparently were contacting us about Orly Taitz's

8 12:03:37appearance, and we needed to tell Connie to correct

9 12:03:41that because we can't be involved in political

10 12:03:44organizations.

11 12:03:44 Q So it concerned you that Orly Taitz

12 12:03:47believed that Judicial Watch had invited her to a --

13 12:03:51to a political event?

14 12:03:52 A No. It concerned me that it created a

15 12:03:54false appearance that Judicial Watch had invited

16 12:03:57Orly Taitz to speak at some event.

17 12:04:01 Q And this e-mail was kept in the ordinary

18 12:04:05course of Judicial Watch's recordkeeping?

19 12:04:07 A I guess it was. I mean, Tom must have kept

20 12:04:10it; I didn't. So that might be better directed to

21 12:04:13him.

22 12:04:18 Q Was there a concern that Orly Taitz having


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1 12:04:22been involved in an issue involving me, Larry

2 12:04:26Klayman, thought that Judicial Watch was inviting

3 12:04:29her to an event?

4 12:04:29 A I don't know. It does seem to demonstrate

5 12:04:31a pattern of misunderstanding on the part of

6 12:04:34Ms. Taitz, however.

7 12:04:35 Q I'm not asking about Ms. Taitz. We'll get

8 12:04:37to Ms. Taitz. I'm talking about you, Judicial

9 12:04:41Watch. Was there a concern that you didn't want to

10 12:04:43be associated with Ms. Taitz because of what had

11 12:04:45happened with me?

12 12:04:46 A No. The concern was that -- like I just

13 12:04:54tried to articulate, the concern was that this

14 12:04:56political organization, not Judicial Watch, had

15 12:05:01invited Ms. Taitz. Ms. Taitz, you know, I think she

16 12:05:06was a candidate. I don't know. But we try to be

17 12:05:10very careful about making sure we don't -- aren't

18 12:05:14affiliated with political organizations. UROC is a

19 12:05:17political organization.

20 12:05:18 You know, we're very protective of our

21 12:05:22501(c)(3) status that we not become involved in

22 12:05:26electoral issues. UROC is involved in electoral


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1 12:05:30issues. It created a false impression that Judicial

2 12:05:33Watch was sponsoring this candidate speaking, not

3 12:05:37UROC, so we needed that corrected.

4 12:05:38 Q So with regard to a so-called false

5 12:05:40impression that Judicial Watch was inviting Orly

6 12:05:43Taitz to a political event --

7 12:05:43 A Mm-hmm.

8 12:05:46 Q -- at UROC, you found it necessary to

9 12:05:48communicate with Ms. Ruffley and caution her,

10 12:05:52correct?


12 12:05:54 THE WITNESS: I don't think I was

13 12:05:55cautioning her. I think -- this e-mail or this

14 12:06:02e-mail chain seems to show that Ms. Taitz is saying

15 12:06:04she was invited to a Judicial Watch function when it

16 12:06:08was truly a UROC function, and I was asking Connie

17 12:06:11to make sure that that was clarified. This is not a

18 12:06:13cautioning to Connie. This is can you make sure

19 12:06:17this is clarified, sort of. That's exactly what I

20 12:06:20said.


22 12:06:21 Q So with regard to something that concerns


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1 12:06:24Judicial Watch and an appearance of political

2 12:06:27activity, you and Judicial Watch were concerned that

3 12:06:32that not appear on a posting, correct?

4 12:06:38 A I don't know. Like I said, we were very --

5 12:06:40I think this has nothing to do with, you know, the

6 12:06:44convicted versus indicted confusion in Ms. Taitz's

7 12:06:48prior posting. We're very protective of our

8 12:06:53501(c)(3) status. We wanted it to be clear this was

9 12:06:57not a Judicial Watch function she was speaking at.

10 12:06:59This was a UROC function, and we asked Connie to

11 12:07:02clarify that.

12 12:07:03 Q So when Judicial Watch's interests are

13 12:07:05concerned, you will communicate with Ms. Taitz, but

14 12:07:07when Larry Klayman is involved and he's being

15 12:07:10allegedly accused of committing a crime, you have no

16 12:07:13interest in communicating with -- with Ruffley?

17 12:07:15 A Judicial Watch wasn't communicating with

18 12:07:17Orly Taitz.

19 12:07:19 Q But you did find a need to correct this

20 12:07:21posting, correct?

21 12:07:23 A We asked Connie to make clear, like I said,

22 12:07:27to Ms. Taitz or whoever is responsible that she's


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1 12:07:30being invited by UROC, not by Judicial Watch.

2 12:07:32 Q But Judicial Watch and yourself made no

3 12:07:35effort to have the posting corrected with regard to

4 12:07:37Larry Klayman by Ms. Taitz, correct?

5 12:07:39 MR. KRESS: Objection to form. Asked and

6 12:07:41answered.



9 12:07:43 Q That was not of concern to you --



12 12:07:45 Q -- because it involved me and not you?


14 12:07:48 THE WITNESS: I think I've already answered

15 12:07:49that.


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 12:08:01from Constance Ruffley dated January 7, 2013,

21 12:08:05relatively recent, correct -- no. Excuse me -- a

22 12:08:09year 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 12:08:15Farrell, subject: Judge orders eligibility attorney

4 12:08:18to 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 12:08:24Fitton, Orfanedes, and Farrell received from Connie

8 12:08:27Ruffley?

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 12:08:33sister-in-law in parens, and then Connie writes,

12 12:08:38"Klayman is at it again! Read if you're interested.

13 12:08:40The truly disturbing thing, however, is that the

14 12:08:46judge DID refer to a fictitious movie to make his

15 12:08:50ruling!"

16 12:08:50 That's what Connie wrote to you. Is that

17 12:08:53correct?

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 12:08:56or Mr. Farrell?

21 12:08:57 A No, I have no recollection of whatsoever of

22 12:08:59this e-mail.


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1 12:09:00 Q This document was kept in the ordinary

2 12:09:02course of Judicial Watch's recordkeeping?

3 12:09:03 A I don't know. You'd have to ask Mr. Fitton

4 12:09:05that. I think Connie seems to be more concerned

5 12:09:09about what the judge is doing, which was very

6 12:09:12Judicial Watch related.

7 12:09:13 Q I'm not asking you a question,

8 12:09:14Mr. Orfanedes, on this.

9 12:09:17 A Okay.

10 12:09:17 Q I'll get to the question. This document

11 12:09:19was 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 12:09:27computers.

16 12:09:31 Q "Klayman is at it again!" That shows that

17 12:09:33Ms. Ruffley is very concerned about what I'm doing,

18 12:09:35correct?



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 12:09:40take it any way.

2 12:09:45 Q What difference does it make what I'm doing

3 12:09:47to 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.


8 12:09:55 THE WITNESS: I don't know.


10 12:09:56 Q Did you caution Ms. Ruffley stay away from

11 12:09:59Klayman after you saw this e-mail?

12 12:10:01 A I don't -- I don't remember seeing this

13 12:10:02e-mail until just recently, Larry.

14 12:10:04 Q Do you know whether Fitton or Farrell told

15 12:10:07Connie, get off of Klayman. Get on to something

16 12:10:13else?

17 12:10:13 A Number one, I don't think she's on Klayman;

18 12:10:15and number 2, no, I don't believe they did.

19 12:10:19 Q Because you don't care that she's somehow

20 12:10:21preoccupied with me?


22 12:10:23 THE WITNESS: I don't think she's


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1 12:10:25preoccupied with you. I mean, it could be --


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 12:10:31work you were doing here. I don't know. I have no

6 12:10:32idea, Larry. I don't know what this e-mail is, like

7 12:10:35I said.

8 12:10:35 Q Okay.

9 12:10:37 A Did the judge -- I mean, is this something

10 12:10:38about a judge in your case and did you really refer

11 12:10:41to a movie in making his decision?

12 12:10:45 MR. KLAYMAN: We'll leave the deposition

13 12:10:47open.

14 12:10:48 THE WITNESS: I object to that. You've had

15 12:10:51ample opportunity to ask me all kinds of questions

16 12:10:53and 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 12:10:57best of my ability.

20 12:10:58 MR. KRESS: We're not agreeing to anything,

21 12:10:59but the deposition's over and we'll reserve the

22 12:11:01right to read.


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1 12:11:05 THE VIDEOGRAPHER: Here marks the end of

2 12:11:06Volume 1, Tape No. 2 in the deposition of Paul

3 12:11:09Orfanedes. Going off the record. The time is 12:11

4 12:11:12p.m.

5 12:11:13 (Signature having not been waived, the

6 12:11:13deposition of Paul Joseph Orfanedes, Esquire was

7 12:12:19concluded at 12:11 p.m.)

8

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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

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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

abandoned116:8,13

ability86:17 159:19

able140:9

above-referenced72:15

absurd129:14

access96:15 111:19

account111:4 150:2

accurate79:2 81:8

accusations68:7

accuse80:13

accused28:19 67:3 128:20,20

154:15

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acknowledge161:4

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acknowledgment126:11 161:2

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action60:1 73:7 74:18 76:13

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activities29:8 55:16

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additional132:1

address45:2

adjudication51:22 53:8

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administrative42:5

administrator18:2 40:6 53:13

advanced72:17

advertisement18:12

advised19:1 33:9

advising61:14

affair16:12 17:6

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affidavit77:5,9,11,18

affiliated152:18

affixed162:12

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125:14 146:10

155:22 156:1

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Attachment K


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In The Matter of:

LARRY E. KLAYMAN

vs.


___________________________________________________

CHRISTOPHER J. FARRELL

January 27, 2014

___________________________________________________


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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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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

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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


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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

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21

22


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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 13:18:12No. 1 in the deposition of Christopher Farrell in

4 13:18:16the matter of Larry E. Klayman versus Judicial

5 13:18:19Watch, Incorporated in the United States District

6 13:18:21Court for the Southern District of Florida, Case No.

7 13:18:2813-20610-CIV.

8 13:18:28 Today's date is January 27th, 2014. The

9 13:18:33time on the video monitor is 1:18 p.m., and the

10 13:18:37video operator today is Akim Graham. This video

11 13:18:40deposition is taking place at 1325 G Street,

12 13:18:45Northwest in Washington, D.C.

13 13:18:45 Counsel, please voice identify yourselves

14 13:18:47and state whom you represent.

15 13:18:49 MR. KLAYMAN: Larry Klayman, counsel for

16 13:18:51plaintiff pro se.

17 13:18:52 MR. KRESS: Doug Kress counsel for Judicial

18 13:18:55Watch, Inc.

19 13:18:56 THE VIDEOGRAPHER: The court reporter today

20 13:18:57is Joan Cain of Merrill LAD. Would the reporter

21 13:18:59please swear in the witness.

22 13:18:59 CHRISTOPHER J. FARRELL


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1 13:18:59having been duly sworn, was examined and did testify

2 13:19:10as follows:

3 13:19:10 EXAMINATION BY COUNSEL FOR PLAINTIFF PRO SE


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 13:19:22background, just high school and college.

11 13:19:24 A I graduated from Chaminade High School in

12 13:19:28Mineola, New York in 1979. Then I graduated from

13 13:19:32Fordham 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 13:19:43variety of locations around the world, but chiefly

19 13:19:46as a counterintelligence officer.

20 13:19:48 Q And did there come a point in time when you

21 13:19:51left the military?

22 13:19:52 A Yes.


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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 13:20:07Virginia.

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 13:20:24with Synectics?

16 13:20:26 A My title was systems engineer.

17 13:20:30 Q And what were your duties and

18 13:20:31responsibilities?

19 13:20:31 A I provided advice and assistance to

20 13:20:34Department of Defense customers of the firm on a

21 13:20:39number of classified projects.

22 13:20:43 Q What were the general subject matters


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1 13:20:44involved?

2 13:20:46 A Human intelligence.

3 13:20:48 Q Did there come a point in time when you

4 13:20:50left Synectics?

5 13:20:53 A Yes.


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 13:21:15contract proposals.

13 13:21:16 Q With regard to?

14 13:21:17 A The same general world of defense

15 13:21:19contracting.

16 13:21:23 Q Did you have any interim employment between

17 13:21:27you working for yourself and later for Judicial

18 13:21:28Watch, 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 13:21:37Catholic charity.


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1 13:21:39 Q Which Catholic charity?

2 13:21:41 A The Paulist National Catholic

3 13:21:46Evangelization Association.

4 13:21:47 Q Did there come a point in time when you

5 13:21:49approached me for a job at Judicial Watch?

6 13:21:51 A Yes.


8 13:21:56 A I would say May of 1999.

9 13:22:06 Q And under what circumstance did you

10 13:22:07approach me? Was it an event or whatever?

11 13:22:10 A It was some sort of a conference or a panel

12 13:22:14discussion. 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 13:22:33under, but --

20 13:22:33 Q Right. You came to me, you said Larry, you

21 13:22:36know, you have a really good reputation. I'd like

22 13:22:38to work with you at Judicial Watch?


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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 13:22:47had a skill set that would be valuable to Judicial

5 13:22:49Watch.

6 13:22:49 Q What was that?

7 13:22:50 A I had a background in investigative work.

8 13:22:52I was a good writer and put those two together, I

9 13:22:55thought it was a good match.

10 13:22:56 Q And you told me that you were impressed

11 13:22:58with 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 13:23:05work 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 13:23:10Watch 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 13:23:13Watch 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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1 13:23:21approached me?

2 13:23:24 A We had a conversation. You said to call

3 13:23:27back to the office, that the next business day,

4 13:23:30whatever that was, within a couple days, and I did,

5 13:23:36and 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 13:23:49your position changed at Judicial Watch from that

12 13:23:52point to today? Strike that.

13 13:23:54 You're still employed by Judicial Watch,

14 13:23:56correct?

15 13:23:57 A Yes, I am.

16 13:23:57 Q Did there come a point in time when your

17 13:24:00position changed in any way at Judicial Watch from

18 13:24:02the time I hired you to today?

19 13:24:03 A Yes. In --


21 13:24:07 A In -- I guess it was September or October

22 13:24:10of 2003 I became a director of the corporation.


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1 13:24:16 Q Were you there with -- were you a director

2 13:24:19with 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 13:24:31responsibilities as a director at Judicial Watch, do

8 13:24:33you have regular directors' meetings?

9 13:24:40 A We have meetings, yes. I don't know what

10 13:24:42regular means, but we have meetings, yes.

11 13:24:44 Q Do you call meetings in a formal way or are

12 13:24:49they 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 13:24:54meetings?

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 13:25:01meeting on a particular date and time and we have a

20 13:25:04meeting.

21 13:25:04 Q Is it a formal meeting, over lunch, or how

22 13:25:07is 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 13:25:14Directors keep minutes of the meetings?

4 13:25:18 A Yes, I know that we have meetings -- or

5 13:25:21have 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 13:25:34directors had a meeting concerning statements which

12 13:25:36had been published by Dr. Orly Taitz concerning me,

13 13:25:40Larry 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 13:25:46comments that were attributed to Constance Ruffley

17 13:25:51about me, Larry Klayman, among the Board of

18 13:25:59Directors?

19 13:25:59 A I think when you sued us we probably

20 13:26:02noticed that you had filed a lawsuit against us.

21 13:26:03 Q With regard to comments made allegedly by

22 13:26:06Constance Ruffley to Orly Taitz?


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1 13:26:10 A Whatever your claims were.

2 13:26:18 Q Prior to my having sued you -- sued

3 13:26:22Judicial Watch over that, you were sued personally

4 13:26:24in that case initially, correct, along with the

5 13:26:27other directors and Constance Ruffley; you're aware

6 13:26:30of that?

7 13:26:44 A Yes.

8 13:26:44 Q Okay. Prior to your getting the court

9 13:26:47papers -- you got the court papers, I take it? You

10 13:26:52were 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 13:26:58discussion with Paul Orfanedes or -- about what I

16 13:27:03was 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 13:27:09was 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 13:27:20alleging in that complaint?


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1 13:27:32 A My understanding is that you are upset or

2 13:27:37feel that you've been harmed in some way about what

3 13:27:46a lawyer named Taitz published or put on a web site

4 13:27:50or said.

5 13:27:56 Q And what is -- what is your understanding

6 13:27:58of 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 13:28:06or published or whatever.

11 13:28:07 Q Did you read the complaint you were served

12 13:28:09with 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 13:28:15allegations?

16 13:28:26 A Something about whether you did or didn't

17 13:28:28pay child support.

18 13:28:29 Q Are you aware that, according to Orly

19 13:28:33Taitz, that Connie Ruffley said that I'd been

20 13:28:36convicted 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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1 13:28:43with donors?

2 13:28:44 A No, I have no idea what you're talking

3 13:28:46about.

4 13:28:49 Q Are you aware that I had brought lawsuits

5 13:28:53in Florida and elsewhere challenging the eligibility

6 13:28:58of 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 13:29:10point you were served with the complaint?

12 13:29:12 A I probably had some awareness of her, but I

13 13:29:15don't -- I mean, I wasn't -- I didn't have any great

14 13:29:17knowledge other than the name being in the news

15 13:29:19occasionally.

16 13:29:19 Q What -- what did you understand her to be

17 13:29:22doing professionally?

18 13:29:32 A That she was a lawyer who filed lawsuits

19 13:29:35generally in sort of the birther movement or that

20 13:29:39issue about the eligibility of the President based

21 13:29:43on his place of birth or the validity of his

22 13:29:46certificate or something like that.


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1 13:29:49 Q So I take it at the time you were served

2 13:29:51with the complaint in this case you were not aware

3 13:29:54that I had brought lawsuits challenging the

4 13:29:55President'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 13:30:01Exhibit 2 to this deposition.

8 13:30:18 Excuse me. This purports to be a copy of

9 13:30:33an internet posting of Orly Taitz on her web site,

10 13:30:37World's Leading Obama Eligibility Challenge Web

11 13:30:40Site, 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 13:30:47Eligibility 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 13:30:52yesterday's presentation to CCIR and update on


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1 13:30:52article2superPAC - Larry Klayman $25,000 fundraising

2 13:31:12for non-existent law suit affair." Have you ever

3 13:31:13heard 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 13:31:20states, Article2superpac $25,000 solicitation for

7 13:31:20Larry Klayman, Screen shot $25,000 solicitation for

8 13:31:33Larry Klayman lawsuits, February 10, 2012."

9 13:31:33Yesterday -- this is Dr. Orly Taitz writing -- I

10 13:31:38gave a 2-hour presentation of my platform as a

11 13:31:41candidate for the U.S. Senate. The presentation was

12 13:31:43given to some 100 California voters in the Women's

13 13:31:46club of Garden Grove. I was told that a

14 13:31:49representative of the Judicial Watch drove for over

15 13:31:51an hour from San Marino to hear me speak and talk to

16 13:31:54me. I got a very warm reception. After my

17 13:31:58presentation people stood up and applauded. This

18 13:32:01member of the Judicial Watch approached me and gave

19 13:32:03me her card. Her name is Constance Ruffley and she

20 13:32:06is the office administrator for the Judicial Watch

21 13:32:08in the western regional headquarters at 2540

22 13:32:11Huntington Drive, San Marino. She told me that she


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1 13:32:16used to work for the FBI and that she worked for the

2 13:32:19Judicial Watch for many years. She actually

3 13:32:20initiated the discussion about Larry Klayman and

4 13:32:22told me that she heard that he's involved in birther

5 13:32:26cases. I told her that this group Article II Super

6 13:32:29PAC was soliciting money, that they sent an e-mail

7 13:32:32and posted on their site an advertisement on

8 13:32:34February 10 asking for $25,000 claiming that they

9 13:32:37need to raise $25,000 in 96 hours as the cases in

10 13:32:41Florida and California need to be filed within a

11 13:32:43week. I told her that it was a hard sell. They

12 13:32:49wrote it is now or never saying finally Clinton's

13 13:32:52team met their match dissing 4 years of my tireless

14 13:32:56work in the process, and in the end nothing was

15 13:32:58filed by Larry Klayman. It is not clear what

16 13:33:00happened to all of the money that was raised, who

17 13:33:02got it.

18 13:33:04 Then it states in the next paragraph,

19 13:33:07Ms. Ruffley actually advised me that Larry Klayman

20 13:33:09is not licensed in California. She told me that he

21 13:33:12no longer work with the Judicial Watch and that

22 13:33:15donors should know about litigation in Ohio where he


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1 13:33:18was convicted just recently of not paying a large

2 13:33:20amount in child support. She provided a lot of

3 13:33:23other information. I will publish only what is a

4 13:33:25public record. I'm not publishing anything that is

5 13:33:28not a public record.

6 13:33:29 Does this refresh your recollection as to

7 13:33:31whether or not you have ever known or been advised

8 13:33:38that Connie Ruffley, Constance Ruffley, stated to

9 13:33:42Orly Taitz, which was then published on Orly Taitz's

10 13:33:47web site that I was convicted of a crime?


12 13:33:50 If you can answer.

13 13:33:51 THE WITNESS: I don't understand the



16 13:33:53 Q Does this refresh your memory as to whether

17 13:33:56or not you've known before today that Constance

18 13:33:58Ruffley allegedly said that I, Larry Klayman, was

19 13:34:00convicted of a crime?

20 13:34:02 A I think that's what you put in your

21 13:34:04complaint.

22 13:34:06 Q But you didn't know it was in the complaint


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1 13:34:08a few minutes ago when I testified (sic) to you.

2 13:34:12 A I said when you gave me the complaint

3 13:34:13that's when I became aware of what you're -- what

4 13:34:16you're suing, what you're claiming.

5 13:34:17 Q Okay. Before that you were not aware what

6 13:34:19I just read to you?


8 13:34:22 THE WITNESS: I don't agree. I told you

9 13:34:23that when you gave me -- when the complaint was

10 13:34:26served, I read it and I learned what you were upset

11 13:34:29about.


13 13:34:29 Q Okay. As a member of the Board of

14 13:34:32Directors of Judicial Watch, would you have wanted

15 13:34:35to been -- would you have wanted to be advised that

16 13:34:37Connie Ruffley purportedly said these things about

17 13:34:40me that were then published on a web site, the

18 13:34:45Leading 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 13:34:48is even true.



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1 13:34:49 Q Would you have wanted to be informed as a

2 13:34:51member of the Board of Directors?

3 13:34:54 A It's a hypothetical that I'm just -- I

4 13:34:57mean, this is make believe. I don't know what your

5 13:34:59question'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?



11 13:35:14 THE WITNESS: I don't know. I don't know

12 13:35:15if any of this is true.


14 13:35:17 Q What are your duties and responsibilities

15 13:35:18as a member of the Board of Directors of Judicial

16 13:35:20Watch?

17 13:35:20 A I have a fiduciary obligation to make sure

18 13:35:22that the organization is run properly in accordance

19 13:35:25with the laws of the United States and District of

20 13:35:26Columbia and to the care and welfare of the

21 13:35:29organization and its employees.

22 13:35:31 Q If an employee made a statement that was


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1 13:35:33defamatory of someone in public, that would be

2 13:35:37something, as a member of the board, you'd want to

3 13:35:39know about?

4 13:35:40 A All sorts of people have their personal

5 13:35:42opinions about all sorts of topics. I have no idea

6 13:35:45what people say or don't say anywhere whether

7 13:35:47they're in public or they're in private. I don't

8 13:35:49know.

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.




14 13:35:54 Q If an employee of Judicial Watch made a

15 13:35:56statement in public that someone such as myself,

16 13:36:01Larry Klayman, had committed a crime and that person

17 13:36:07was claiming it was defamatory, wouldn't you want to

18 13:36:10know about it as a member of the board?


20 13:36:12 THE WITNESS: I don't know what in public

21 13:36:14means.



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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 13:36:21don'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 13:36:26moving target. You just keep moving the language

7 13:36:30around.

8 13:36:30 Q All right. Let's -- let's see if you can

9 13:36:31understand this. You're highly educated. First

10 13:36:34question, your duties at Judicial Watch are, as you

11 13:36:36just testified, to protect Judicial Watch from legal

12 13:36:39liability, correct --



15 13:36:41 Q -- as a director?


17 13:36:44 THE WITNESS: Generally speaking, yes.


19 13:36:46 Q Okay. Now, if an employee of Judicial

20 13:36:50Watch makes a statement which is alleged to defame

21 13:36:53someone, as a director you'd want to know about

22 13:36:56that, correct?


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1 13:36:58 A People are entitled to their personal

2 13:37:00opinion.

3 13:37:00 Q Yes or no, would you want to know about it

4 13:37:02or not?


6 13:37:07 THE WITNESS: People are entitled to their

7 13:37:08personal opinions.


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



15 13:37:15 Q It has nothing to do with whether you'd

16 13:37:17want to know. Yes or now?


18 13:37:21opinions.

19 13:37:22 Q Yes or no?


21 13:37:26opinions.

22 13:37:26 Q So what is this? The Board of Directors --


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1 13:37:26the three Board of Directors are like hear no evil,

2 13:37:30see no evil, do no evil, is that -- that the modus

3 13:37:34operandi of the Board of Directors?



6 13:37:37 Q Like three monkeys?



9 13:37:40 Q Is that what you're saying?



12 13:37:43 Q Yes or no?

13 13:37:44 MR. KRESS: Yes or no to a question are

14 13:37:46they monkeys?

15 13:37:47 THE WITNESS: What's your question?


17 13:37:49 Q That -- that the Board of Directors makes a

18 13:37:50makes an effort not to know what employees do

19 13:37:52because they don't want to be involved?

20 13:37:57 A What's the question? I don't know what it

21 13:37:59is.

22 13:37:59 Q Is that -- is that the way the Board of


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1 13:38:01Directors of Judicial Watch operated in about

2 13:38:02February 23rd, 2012?


4 13:38:05 THE WITNESS: Is what the way?


6 13:38:07 Q That if an employee makes some statement

7 13:38:08that could expose Judicial Watch to liability, you

8 13:38:11don't want to know about it because everybody's

9 13:38:13entitled to their opinion?

10 13:38:18 A Individual people are entitled to their


12 13:38:20 Q I'm asking you what the duties and

13 13:38:22responsibilities of the board are. If some -- let's

14 13:38:27back up.

15 13:38:28 As a member of the board, you just

16 13:38:30testified that you would -- you had a fiduciary duty

17 13:38:35to protect Judicial Watch from legal liability. If

18 13:38:40some employee does something which is illegal,

19 13:38:45wouldn't you want to know about it as a member of

20 13:38:47the 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?



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 13:38:59private person does is not necessarily the position

8 13:39:04of Judicial Watch. There's all sorts of employees

9 13:39:06who have all different opinions and ideas. I don't

10 13:39:13go around, you know, monitoring what every

11 13:39:15individual person says or believes or thinks.

12 13:39:16They're entitled to their personal opinion.

13 13:39:18 Q Let's talk about Constance Ruffley.

14 13:39:20Constance Ruffley, on or about February 23rd, 2012,

15 13:39:24was the office administrator of Judicial Watch in

16 13:39:26its San Marino, California office, correct?

17 13:39:28 A Yes.

18 13:39:28 Q And, in fact, during your tenure at

19 13:39:31Judicial Watch, you've communicated with Constance

20 13:39:33Ruffley 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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1 13:39:37legal matters, correct?

2 13:39:40 A No.

3 13:39:41 Q Judicial Watch deals with a lot of legal

4 13:39:44matters; 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 13:39:51to in whole or in part, right?

10 13:39:54 A Correct.

11 13:39:54 Q Files lawsuits over guest worker programs

12 13:39:59with regard to immigration, correct?

13 13:40:03 A Correct.

14 13:40:04 Q Okay. Files ethics complaints against

15 13:40:08public officials who have alleged to violate the

16 13:40:11law --

17 13:40:11 A True.

18 13:40:11 Q -- correct? Judicial Watch is in effect

19 13:40:15like 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 13:40:28Watch'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 13:40:33that others are not acting dishonestly, correct?

4 13:40:38 A Correct.

5 13:40:39 Q So, therefore, if an employee like

6 13:40:41Constance Ruffley says something about someone that

7 13:40:44is defamatory, as a member of the board, you would

8 13:40:48want to know about that, right?


10 13:40:54 THE WITNESS: That's a big if.


12 13:40:57 Q And that gets back to the three monkeys.

13 13:41:00You'd rather just close your eyes and pretend it

14 13:41:02never happened, correct?


16 13:41:05 THE WITNESS: There's no reason for you to

17 13:41:08go down this path of being insulting. You've

18 13:41:12already been admonished in previous litigation.

19 13:41:15There's no reason for you to go down this path

20 13:41:18again. I just want to get on the record you've been

21 13:41:22admonished by a magistrate judge in the last

22 13:41:23deposition.


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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 13:41:27abusive.

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 13:41:31What's your next question?

10 13:41:33 Q My question is you don't hear anything, you

11 13:41:36don't want to see anything, and you don't want to do

12 13:41:38anything when I'm involved, correct?


14 13:41:42 THE WITNESS: I have no interest in you

15 13:41:43whatsoever.


17 13:41:44 Q Even if an employee does something which is

18 13:41:47illegal toward me, employee of Judicial Watch, you

19 13:41:49have no interest?


21 13:41:51 THE WITNESS: That's a huge if.



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1 13:41:58 Q Was I convicted of a crime of failing to

2 13:42:00pay child support? Do you have any knowledge, yes

3 13:42:02or 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 13:42:11made 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 13:42:15no 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 13:42:28over an alleged defamatory statement, you want to

19 13:42:31get all the facts, as a member of the Board of

20 13:42:33Directors, correct?

21 13:42:36 A I rely on our counsel. This is our

22 13:42:43eleventh year of litigation with you, Mr. Klayman,


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1 13:42:48our eighth or ninth lawsuit. So the fact that

2 13:42:50you're suing us again on something you've made up or

3 13:42:53you have some, you know, claim about -- there's no

4 13:42:57telling 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 13:43:02you.

8 13:43:09 Q Do you have a feeling towards Judicial

9 13:43:11Watch?

10 13:43:11 A Yes.

11 13:43:18 Q Did you ever discuss these allegations that

12 13:43:20I 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 13:43:26has?

16 13:43:30 A No. I haven't been party to anything like

17 13:43:33that.

18 13:43:33 Q As a member of the Board of Directors, do

19 13:43:38you feel there was an obligation of the other two

20 13:43:39directors to advise you what was going on between

21 13:43:42Larry 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 13:43:51informed of allegations against Judicial Watch that

5 13:43:57had 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 13:44:03Judicial Watch, do you believe that you should be

9 13:44:05fully informed of any allegations that are made

10 13:44:08against Judicial Watch that have violated the law?


12 13:44:17 Q So by not informing you of these

13 13:44:20allegations, the other two directors breached their

14 13:44:22duty towards you as another member of the board,

15 13:44:25correct?

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 13:44:36been marked as Exhibit 3. On the first page of this

19 13:45:01composite exhibit is a letter of March 5th, 2012

20 13:45:04addressed to me from Richard Driscoll of Driscoll &

21 13:45:11Seltzer, 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 13:45:22letter. I can't tell you exactly when.

5 13:45:26 Q And in this letter I'm making an allegation

6 13:45:28that Constance Ruffley said something that was

7 13:45:34defamatory about me that was put on the internet?

8 13:45:35 A No. This letter is from Mr. Driscoll

9 13:45:38telling you that you've produced no evidence to

10 13:45:41support your outrageous allegations.

11 13:45:43 Q Okay. And what did you understand

12 13:45:45Mr. Driscoll to be talking about when you saw it on

13 13:45:48or about March 5th, 2012?

14 13:45:50 A That you had some sort of claim you were

15 13:45:52making, some sort of allegations that were

16 13:45:54unsupported and were outrageous.

17 13:45:56 Q How did you come about seeing this letter

18 13:45:58on March 5th, 2012?

19 13:46:00 A I don't know that it was that date.

20 13:46:02Sometime around then.

21 13:46:02 Q Yeah, how did -- how did it come to your

22 13:46:04attention?


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1 13:46:13 A Because you had sent some sort of

2 13:46:14threatening e-mail or communication and Mr. Driscoll

3 13:46:17responded to you. Mr. Driscoll is our counsel, and

4 13:46:19he 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 13:46:26exactly what it says, but I'm -- I'm kind of

8 13:46:31familiar --

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 13:46:38litigation or eighth or ninth lawsuit from you, so

12 13:46:42threatening e-mails from you are somewhat common.

13 13:46:45 Q If they're so common, how come they haven't

14 13:46:48been 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 13:46:51things were destroyed?



20 13:46:53 Q You're aware that I asked for any

21 13:46:54communications that concern me with Judicial Watch?

22 13:46:57You're aware of that, in this litigation?


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1 13:46:59 MR. KRESS: And I objected as counsel.


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 13:47:06or any documentation that referred to me in this

7 13:47:11litigation I've requested be produced by Judicial

8 13:47:15Watch?

9 13:47:15 MR. KRESS: Object to the form.

10 13:47:18 THE WITNESS: I know that you've asked for

11 13:47:20all sorts of things, but our counsel's responded to

12 13:47:23you.


14 13:47:24 Q Are you aware that I asked for e-mail and

15 13:47:27other communications?

16 13:47:28 A I'm certain you asked for all sorts of

17 13:47:30things, the details of which I'm not 100 percent

18 13:47:34familiar with, but your -- your requests are usually

19 13:47:37very broad and sweeping.

20 13:47:40 Q Oh, so you do keep abreast of legal

21 13:47:43matters, correct?



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1 13:47:47 Q So you do keep abreast of legal matters if

2 13:47:50you're looking at my requests, right?

3 13:47:51 A I just finished telling you I was informed

4 13:47:54by our counsel of your usual string of threatening

5 13:47:58e-mails and I responded to you.

6 13:47:58 Q So when you testified before that you knew

7 13:48:01of nothing since the complaint you lied, correct?

8 13:48:03 A No. You're making false and misleading

9 13:48:04statements.

10 13:48:05 Q Okay. Then why did you testify that way?


12 13:48:07 THE WITNESS: I didn't testify that way.


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 13:48:19document. 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 13:50:37culminating in the letter from Mr. Driscoll on March

21 13:50:415, 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 --



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 13:50:54one.

10 13:50:54 A Sure.

11 13:50:54 Q Look on the second-to-last page from the

12 13:51:01end of this composite exhibit, e-mail to Rich

13 13:51:08Driscoll from Larry Klayman. Rich, I'm being

14 13:51:12defamed by an employee and agent of Judicial Watch,

15 13:51:16Connie Ruffley. Please call me to discuss. Thank

16 13:51:18you, 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 13:51:24the date of the e-mail, you were aware that I was

21 13:51:27making allegations that Connie Ruffley had defamed

22 13:51:30me, correct?


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2 13:51:31 THE WITNESS: I don't know that -- if it

3 13:51:32was the 23rd, but perhaps sometime shortly

4 13:51:35afterwards.


6 13:51:36 Q And you're aware that it concerned Connie

7 13:51:38Ruffley stating to Orly Taitz that I committed a

8 13:51:41crime; you were aware of that?

9 13:51:43 A I don't know what Ms. Ruffley did or not

10 13:51:45say in respect to this e-mail. I have no idea,

11 13:51:48because you don't say it.

12 13:51:49 Q Did you make any inquiry, what is Klayman

13 13:51:51talking about, with either the Judicial Watch board

14 13:51:56or with Richard Driscoll?

15 13:52:00 A I was relying on Mr. Driscoll to handle

16 13:52:03whatever it was you were claiming.

17 13:52:07 Q So you felt no obligation, as a member of

18 13:52:09the board, to inquire?

19 13:52:10 A No. I had very competent legal counsel

20 13:52:13addressing another one of your claims.

21 13:52:20 Q If indeed I was defamed, would there be an

22 13:52:25obligation of Judicial Watch, as a member of the


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1 13:52:29board, to correct it?


3 13:52:33 THE WITNESS: I mean, that's a

4 13:52:35hypothetical, if indeed you were. I have no idea.


6 13:52:37 Q Well, what I'm saying is, if I'm correct

7 13:52:39here in what I'm writing to Mr. Driscoll that I was

8 13:52:42defamed, wouldn't you want to know the specifics if

9 13:52:47Judicial Watch could correct it?


11 13:52:52 THE WITNESS: I don't know what's going on

12 13:52:54inside your head, so I can't -- I can't make an

13 13:52:56answer based upon what you may or may not think may

14 13:52:59or may not be defamatory. I don't know.


16 13:53:02 Q I'm talking about from the perspective of

17 13:53:04Judicial Watch. Mr. Driscoll can't make a decision

18 13:53:06to correct it, can he? He's just outside counsel,

19 13:53:12correct?

20 13:53:13 A Mr. Driscoll was our legal counsel, that's

21 13:53:15correct.

22 13:53:15 Q And he can't make a decision to take any


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1 13:53:18action on behalf of Judicial Watch unless the Board

2 13:53:21approves, correct?


4 13:53:24 THE WITNESS: We consult with him and take

5 13:53:25his legal advice, like anybody would. You always

6 13:53:30consult with your attorneys on matters like this.


8 13:53:32 Q And then Judicial Watch would make the

9 13:53:33decision whether to correct the defamation -- the

10 13:53:35alleged 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 13:53:47I get to answer it. You may not like the answer,

16 13:53:49but that's your problem.


18 13:53:50 Q You know what, Mr. --

19 13:53:52 MR. KRESS: You can answer. Let him

20 13:53:53answer.


22 13:53:53 Q You have to answer the question yes or no.


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1 13:53:55It's a yes-or-no question.

2 13:53:57 MR. KRESS: Nobody has to answer yes or no

3 13:53:59if they don't want to.


5 13:54:01question.


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 13:54:01restate it.

10 13:54:01 Q You don't have a clue?

11 13:54:03 MR. KRESS: What is the question? Why

12 13:54:03don't we --


14 13:54:04 Q The question is, only Judicial Watch's

15 13:54:07Board can correct a defamatory statement. Mr.

16 13:54:11Driscoll, as outside lawyer, doesn't have that

17 13:54:13power, correct?

18 13:54:14 A What defamatory statement?



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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1 13:54:16 Q Well, if you don't know what was said, you

2 13:54:18don't know, correct?



5 13:54:20 Q Correct?

6 13:54:21 MR. KRESS: You can answer if you can.



9 13:54:24 Q And you didn't really want to know, did

10 13:54:25you?


12 13:54:28 THE WITNESS: I don't even know what you're

13 13:54:29talking about. What's the subject of your question?


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 13:54:39said 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 13:54:43told Orly Taitz about me?

22 13:54:45 A I don't know that Connie Ruffley said


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1 13:54:47anything 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 13:55:10purportedly said about me is because it was about

7 13:55:13me, Larry Klayman, correct?


9 13:55:17 Q Because you didn't --

10 13:55:19 A Can you ask a basic interrogative instead

11 13:55:23of test- -- providing testimony and then saying

12 13:55:24right 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 13:55:33question. You just answer the question. That's

17 13:55:33your duty.

18 13:55:34 A Poor layman. I just don't understand these

19 13:55:37complex legal proceedings.

20 13:55:37 MR. KRESS: All right, let's get a

21 13:55:37question before him --



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1 13:55:39 Q Your refusal to answer these questions is

2 13:55:43not an affront towards me, it's an affront towards

3 13:55:43the 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 13:55:46cooperative. I'm not refusing anything. I don't

7 13:55:48understand 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 13:55:53basic interrogatives. Stick with those, it might

12 13:55:57help you out. Last time we had a magistrate judge

13 13:55:59come into the room three times to help you form

14 13:56:02questions. Unfortunately, we don't have that this

15 13:56:04time.


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 13:56:09the court?




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1 13:56:11 Q As far as you're concerned, you don't have

2 13:56:12to answer questions. You'll make -- you'll make the

3 13:56:14rules yourself?

4 13:56:16 A That is false.

5 13:56:16 MR. KRESS: Let's just -- let's just get

6 13:56:18questions before him which he will answer.

7 13:56:18 THE WITNESS: False and misleading

8 13:56:18statement from Mr. Klayman.


10 13:56:19 Q And you'll pretend that you don't

11 13:56:22understand a question when you don't want to answer

12 13:56:24it.

13 13:56:25 A That's a false and misleading statement by

14 13:56:27Mr. Klayman.

15 13:56:27 MR. KRESS: Let's stop for a second. Let's

16 13:56:27just get some questions before him and let him

17 13:56:31answer. Let's not get this back-and-forth

18 13:56:31arguments.

19 13:56:31 MR. KLAYMAN: Do you want to take him out

20 13:56:33of the room and instruct him that right now he's

21 13:56:35violating court process.

22 13:56:36 MR. KRESS: He's not violating any court


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1 13:56:38process.

2 13:56:38 MR. KLAYMAN: We'll see.

3 13:56:39 THE WITNESS: Basic interrogatives, please.


5 13:56:41 Q You know, it's -- and that gets back to the

6 13:56:42question hear no evil, see no evil, do no evil.

7 13:56:46That's not to be sarcastic or anything, that's a way

8 13:56:51of doing business for you, isn't it Mr. Farrell?

9 13:56:53 A That's a false and misleading statement on

10 13:56:55your 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 13:56:59that remark. Where's the question?

14 13:57:01 Q What is it about my question as to whether

15 13:57:04or not you had a duty, as a member of the board, to

16 13:57:06find out what Connie Ruffley said? What's confusing

17 13:57:09about that?

18 13:57:12 A Because I don't know that what you're

19 13:57:16saying is true.

20 13:57:18 Q And if you never inquire, you'll never be

21 13:57:21able to find out, will you?



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1 13:57:23 THE WITNESS: I don't know what that

2 13:57:24question -- is there a question in there?


4 13:57:26 Q We'll let the record speak for itself. Has

5 13:57:31anyone 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 13:57:38just what you want to tell?


10 13:57:42 Q You're aware of the penalty for not telling

11 13:57:45the truth?


13 13:57:46 Q In and around the time of these -- this

14 13:57:58string of e-mails, did you see the publication that

15 13:58:00Orly Taitz had made that I read to you in her

16 13:58:03eligibility 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 13:58:13defamation was -- alleged defamation?



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1 13:58:35 Q If someone accused you of committing a

2 13:58:37crime, you'd want to know about that, wouldn't you?


4 13:58:40 Q Okay. And if someone had said that Chris

5 13:58:44Farrell committed a crime, why don't we send that

6 13:58:46information to Judicial Watch's donors, you would

7 13:58:48want 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 13:59:02prominence accused you of committing a crime and

13 13:59:05then telling the person that was told that to go

14 13:59:10send that to your donors, you'd want to know about

15 13:59:13that, 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 13:59:20know -- I can't answer competently.

20 13:59:23 Q What's -- what's vague about your being

21 13:59:24accused of a crime and then sending it to donors?

22 13:59:29What's vague about that?


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1 13:59:30 A You don't say who the person is who's

2 13:59:38making the statement. There's a lot of open-ended

3 13:59:40loose hypothetical language in there that I'm not

4 13:59:42going to make a definitive statement about.

5 13:59:44 Q Are you aware that at the time that this

6 13:59:51correspondence was being sent to Mr. Driscoll I was

7 13:59:54asking Mr. Driscoll to help resolve the situation to

8 14:00:00mitigate any damage by clearing up what was said by

9 14:00:03Constance 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 14:00:06Mr. Driscoll to try to mitigate the damage to me by

13 14:00:11clearing up what was said?

14 14:00:13 A I certainly saw Mr. Driscoll's letter back

15 14:00:15to you.

16 14:00:19 Q And did you have any discussion with anyone

17 14:00:21about that letter when you saw it in or about March

18 14:00:276th, 2012?

19 14:00:39 A I probably spoke -- when I saw the letter,

20 14:00:42I probably spoke with -- I don't think I spoke with

21 14:00:45Mr. Driscoll at that point. I think I read the

22 14:00:48letter from him. And I probably spoke with the two


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1 14:00:57other directors, Tom Fitton and Paul Orfanedes when

2 14:01:01I received the letter that we'd received this.

3 14:01:04 Q And what did you talk about? What was

4 14:01:06discussed?

5 14:01:07 A That Mr. Driscoll had answered unsupported

6 14:01:15outrageous allegations by you concerning -- let's

7 14:01:24see -- some sort of a conspiracy to defame and

8 14:01:27disparage, some claim you'd made. I'm just reading

9 14:01:31from Mr. Driscoll's letter.

10 14:01:32 Q Do you know whether Constance Ruffley has

11 14:01:39ever been -- whether any director -- strike that.

12 14:01:42 Do you know whether any director of

13 14:01:44Judicial Watch has ever talked to Constance Ruffley

14 14:01:46about what I claim was said to Orly Taitz about my

15 14:01:49committing a crime and then giving that information

16 14:01:51to donors?

17 14:01:53 A Please restate your question.

18 14:01:55 Q Do you know whether anyone at Judicial

19 14:01:56Watch has ever talked to Mrs. Ruffley about my

20 14:01:59allegations that Orly Taitz published a statement

21 14:02:03that Ruffley made that I committed a crime and that

22 14:02:06should be given to donors?


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1 14:02:08 A That's a long question. The way you've

2 14:02:13phrased it, I don't know.

3 14:02:15 MR. KLAYMAN: Will you read it back,

4 14:02:17please.



7 14:02:39 THE WITNESS: Probably Mr. Orfanedes.


9 14:02:41 Q But you don't know?

10 14:02:43 A I wasn't, you know, personally involved. I

11 14:02:47have no firsthand knowledge, but I believe

12 14:02:49Mr. Orfanedes would have spoken to her.

13 14:02:50 Q Did you know -- did Mr. Orfanedes inform

14 14:02:54you what was discussed between them?

15 14:02:57 A Just the subject generally. I have no idea

16 14:03:00about 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 14:03:33take it you have a computer at your desk at Judicial

21 14:03:35Watch?

22 14:03:35 A Correct.


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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 14:03:57communications that concern me, Larry Klayman, Orly

9 14:04:01Taitz, 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 14:04:20and 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 14:04:39that would keep e-mail communications from everyone?

22 14:04:42 A I don't know.


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1 14:04:43 Q You're aware that Mr. Fitton keeps most

2 14:04:47e-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 14:05:13those -- 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 14:05:19to 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


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1 14:05:25phone 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 14:05:35question?

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 14:05:40e-mails that concern Larry Klayman, Constance

10 14:05:44Ruffley, 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 14:05:54have?

16 14:05:54 A I have no idea.

17 14:05:55 Q What kind of computer do you have at your

18 14:05:57desk? 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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1 14:06:14kind 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 14:06:21you?

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 14:06:35computer you have?

12 14:06:35 A No. I said no.

13 14:06:41 Q Do you know if Constance Ruffley was

14 14:06:45disciplined at all over the allegations that were

15 14:06:48contained in my complaint?

16 14:06:51 A No.

17 14:06:51 Q Do you know whether she was given advice to

18 14:06:54be careful about making statements about Larry

19 14:06:57Klayman?

20 14:06:57 A No.

21 14:07:11 Q I show you what's been marked as

22 14:07:13Plaintiffs' Exhibit 9.


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1 14:07:19 MR. KLAYMAN: Do you have a copy of that,

2 14:07:21Doug?

3 14:07:22 MR. KRESS: Exhibit 9, I don't think it's

4 14:07:27here.

5 14:07:27 MR. KLAYMAN: I'll read it.


7 14:07:29 Q Let me just show it to you, if I can hand

8 14:07:31it over to you. I'm talking about an e-mail which

9 14:07:39is Judicial Watch Bates No. 505 from Connie Ruffley

10 14:07:44to Tom Fitton, Christopher Farrell, Steve Anderson,

11 14:07:48Susan Prytherch, concerning Orly Taitz posting a

12 14:07:52Judicial 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 14:08:18that 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 14:08:39that Orly Taitz was apparently invited to an event

19 14:08:43that she thought was being sponsored by Judicial

20 14:08:46Watch but instead it was being sponsored by UROC,

21 14:08:49U-r-o-c?

22 14:08:54 A I see this e-mail in front of me, but I


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1 14:08:56have no recollection of it.

2 14:08:56 Q Do you have any recollection of the issue

3 14:08:58coming up?

4 14:08:59 A Only after you sued this -- no, I guess

5 14:09:01only after this, the threatening e-mails and the

6 14:09:04response from Mr. Driscoll, that's when I would

7 14:09:07have --

8 14:09:07 Q You were aware about this UROC issue after

9 14:09:12that? This does not concern me. It concerns UROC.

10 14:09:18 A I don't know. I guess I don't recall

11 14:09:21seeing this.

12 14:09:21 Q Do you know -- do you recall being advised

13 14:09:25of the situation with Taitz believing that she was

14 14:09:30invited to an event by Judicial Watch and Judicial

15 14:09:34Watch telling Connie Ruffley that this needs to be

16 14:09:37corrected on any posting?

17 14:09:39 A I don't know what Taitz believed, but I see

18 14:09:42this e-mail and it says PJO, so it's Paul Orfanedes

19 14:09:49asking that it be made clear that it's her UROC

20 14:09:53event and not Judicial Watch.

21 14:09:54 Q Were you aware of that at the time, in and

22 14:09:56around August 28th, 2012?


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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 14:10:06others.

4 14:10:06 A The e-mail's from Paul. It's addressed to

5 14:10:09Chris Fedeli, not to me. That's why I don't recall

6 14:10:14seeing it.

7 14:10:31 MR. KLAYMAN: I have no other questions at

8 14:10:32this time. I'll leave the deposition open to see

9 14:10:34what, if anything, comes up in the deposition of

10 14:10:38Mr. Fitton and in subsequent document production.

11 14:10:40 MR. KRESS: We're not agreeing to keep the

12 14:10:41deposition open, but that can be an issue for later

13 14:10:44if necessary, and I have no questions, and we'll

14 14:10:47reserve the right to read.

15 14:10:48 THE VIDEOGRAPHER: Here marks the end of

16 14:10:49Volume 1, Tape No. 1 in the deposition of

17 14:10:52Christopher Farrell. Going off the record. The

18 14:10:55time is 2:10 p.m.

19 14:10:56 (Signature having not been waived, the

20 14:10:56deposition of Christopher J. Farrell was concluded

21 14:11:48at 2:10 p.m.)

22


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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 _________________________ _____________________


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12 hand and affixed my notarial seal this 31st day of

13 January 2014.

14


16 June 14, 2014

17 ____________________________



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3 RETURN BY: ________________________________________

4 ===================================================


6 ===================================================

7 ____ ____ ___________________________________

8 ____ ____ ___________________________________

9 ____ ____ ___________________________________

10 ____ ____ ___________________________________

11 ____ ____ ___________________________________

12 ____ ____ ___________________________________

13 ____ ____ ___________________________________

14 ____ ____ ___________________________________

15 ____ ____ ___________________________________

16 ____ ____ ___________________________________

17 ____ ____ ___________________________________

18 ____ ____ ___________________________________

19 ____ ____ ___________________________________

20 ____ ____ ___________________________________

21 _______________ ___________________________________



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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

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Attachment L


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In The Matter of:

LARRY E. KLAYMAN

v.


___________________________________________________

THOMAS J. FITTON

January 29, 2014

___________________________________________________


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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


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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


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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


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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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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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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


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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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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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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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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.


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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.


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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


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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 --


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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 --


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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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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?


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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?


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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?


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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


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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,


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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


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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


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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,


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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


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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 Fernández, 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 -- Fernández,

19 is that her last name?

20 Q Fernández.

21 A I don't remember the sanctions being an

22 issue. I remember, you know, an indictment maybe in


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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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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


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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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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?


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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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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


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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


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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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


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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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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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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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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


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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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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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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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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.


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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


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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

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12 hand and affixed my notarial seal this 7th day of

13 February 2014.

14


16 June 14, 2014

17 ____________________________



20

21

22


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3 RETURN BY: ________________________________________

4 ===================================================


6 ===================================================

7 ____ ____ ___________________________________

8 ____ ____ ___________________________________

9 ____ ____ ___________________________________

10 ____ ____ ___________________________________

11 ____ ____ ___________________________________

12 ____ ____ ___________________________________

13 ____ ____ ___________________________________

14 ____ ____ ___________________________________

15 ____ ____ ___________________________________

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17 ____ ____ ___________________________________

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1 UNITED STATES DISTRICT COURT 2 SOUTHERN DISTRICT OF FLORIDA 3 4 LARRY E. KLAYMAN, ) Plaintiff, )5 ) Case No. 13-20610-CIV- ) ALTONAGA/SIMONTON6 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 Angeles205 South Broadway, Suite 200, Los Angeles, CA 90012 | 213.471.2966 | www.ccrola.com


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1 APPEARANCES: 2 FOR PLAINTIFF:3 KLAYMAN LAW FIRM4 BY: LARRY KLAYMAN, ESQ., PRO SE (VIA TELEPHONIC CONFERENCE)5 NAVEED MAHBOOBIAN, ESQ. MONA FALAH, ESQ.6 2520 Coral Way Suite 20277 Miami, Florida 33145 (310) 595-08008 [email protected] 9

10 FOR DEFENDANT:

11 LAW OFFICES OF SCHWED, KAHLE, KRESS BY: DOUGLAS J. KRESS, ESQ.

12 11410 North Jog Road Suite 100

13 Palm Beach Gardens, FL 33418 (561) 694-0070

14 [email protected]

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 [email protected]

21 VIDEOGRAPHER: Elizabeth Collins

22

23

24

25



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1 I N D E X 2 WITNESS: CONSTANCE S. RUFFLEY3 EXAMINATION BY PAGE4 Mr. Klayman..................................85 Mr. Kress...................................746 Mr. Klayman.................................767 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

24 THE VIDEOGRAPHER: Okay.

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?


22 MR. KLAYMAN: Hello.

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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1 MR. KRESS: Okay. 2 THE VIDEOGRAPHER: 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.

13 Q. And what were the circumstances of that

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. 9 Q. And when was that?

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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1 Q. And when was that? 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.

18 Q. And what were the circumstances of that

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.

16 MR. KRESS: I object to the form.

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 6 (Exhibit 2 was marked 7 for identification.) 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



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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.



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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.



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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? 6 MR. KRESS: Objection to the form. 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



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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?



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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



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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?



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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



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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? 7 MR. KRESS: I object to the form. 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.



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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.



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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.



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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: 7 Q. Why did you give her the information? 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.



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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.



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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.



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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



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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




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1 You can answer it. 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?



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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?



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1 MR. KRESS: Objection. 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.



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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.



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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.



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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.)



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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



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1 not? 2 MR. KRESS: Objection to the form. 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."



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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.



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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.



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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



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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



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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,



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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? 9 MR. KRESS: Objection to the form.

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.



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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.



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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?



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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 8 (Exhibit 9 was marked 9 for identification.)

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? 5 MR. KRESS: Objection to the form. 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?

25 MR. KRESS: Objection.



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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? 7 MR. KRESS: Objection to the form. 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. 8 Q. Do you see that? 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.



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1 Correct? 2 MR. KRESS: I object to the form. 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.



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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



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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



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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. 8 MR. KRESS: All right. 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. 3 MR. KRESS: All right. 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.)

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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

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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

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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:_____________________________________________ 8 Reason for Change:__________________________________ 9 Page No.____________Line No.____________

10 Change:_____________________________________________

11 Reason for 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

Powered by TCPDF (www.tcpdf.org)



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UNITED STATES DISTRICT COURTCENTRAL DISTRICT OF CALIFORNIA

LARRY KLAYMAN

Plaintiff(s),

v.

JUDICIAL WATCH

Defendant(s).

CASE NO:2:14−cv−01602−ABC−AS

CIVIL CASE MANAGEMENTORDER

READ IMMEDIATELY ANDTHOROUGHLY

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 Court’s

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.

\\\

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Case 2:14-cv-01602-ABC-AS Document 4 Filed 03/11/14 Page 1 of 13 Page ID #:17Case 1:13-cv-20610-CMA Document 89-3 Entered on FLSD Docket 03/17/2014 of 631

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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 blue−backed. For security reasons, chambers copies

should be removed from envelopes or folders before being placed in the chambers

drop−box.

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 5−4 for instructions on efiling documents.

b. Local Rule 7−3. The Court strictly enforces Local Rule 7−3, which

requires a pre−filing meeting of counsel to discuss the substance and

potential resolution of non−discovery 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

twenty−eight (28) days before the hearing date designated in the

notice. (Local Rule 6−1.) Opposing papers shall be filed and served

no later than twenty−one (21) days before the hearing date. (Local

Rule 7−9.) 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 7−10.)

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 Court’s limited resources.

6. MOTIONS FOR SUMMARY JUDGMENT

The Court encourages the moving party to provide more than the minimum

twenty−eight (28) days’ notice. The movant must send the Statement of

Uncontroverted Facts and Conclusions of Law, in WordPerfect or MS Word

format, to [email protected].

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 7−19. 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 7−19.1, which, inter alia, requires

the applicant to advise the court in writing of his or her efforts to contact

opposing counsel, and of opposing counsel’s intention to oppose the

application. Counsel must inform the Courtroom Deputy Clerk at

(213) 894−6500 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 16−15.1, every case must attempt Alternative

Dispute Resolution (“ADR). This Court participates in the Court−Directed 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 Court−Directed ADR Program. Counsel must comply with Local Rule

26−1(c), which orders counsel to furnish and discuss with their clients the Notice

to Parties of Court−Directed ADR Program in preparation for the Fed. R. Civ. P.

26(f) conference. Plaintiff’s 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 non−jury 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 16−15.5. If a settlement is reached, the

parties shall report it immediately to this Court as required by Local Rule

16−15.7.

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 twenty−one (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 16−12, or the Court expressly waived pretrial procedures

pursuant to Local Rule 16−11, 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

party’s 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 16−9.) 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 16−2 for items to be discussed.) In addition to

the items listed in Local Rule 16−2, at the FPTC, counsel must

be ready to discuss how to streamline the trial, including, but

not limited to bifurcation, presentation of non−critical 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 16−2 through 16−7.

These documents shall be filed and served not later than

twenty−one (21) days before the FPTC. (Local Rules 16−4

through 16−6.) Also note that Rule 16 contains specific

requirements for the presentation of deposition testimony

(Local Rule 16−2.7) and the disclosure of graphic and

illustrative material (Local Rule 16−3).

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 16−7, 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 3−hole 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

right−hand 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 16−6. 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 16−2 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. Plaintiff’s proposed instructions, to which

Defendant objects; and

iii. Defendant’s 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

[email protected].

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

3−hole 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 16−6. 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 counsel’s 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 re−read 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 Court’s 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

Plaintiff’s counsel or, if Plaintiff is appearing pro se, Defendant’s 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. COURT’S 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 District’s website.¹

Dated: March 11, 2014

Audrey B. CollinsUnited States District Judge

¹ 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 55164−9979 Los Angeles, CA 90012

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