Roger Stone Video Deposition in Corsi/Klayman Defamation Suits, Day 1 (Part 3 of 3)
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Back on record at 3.30.
Mr. Stone, a few minutes ago you called me a bitch.
No, I said you were acting like a bitch.
What is a bitch, according to you?
What's the point of that?
I'm not going to answer that.
I know what he meant.
I'm not going to answer the question, so ask a serious question.
Mr. Clayman, ask a question.
You sit there, make a text on me, and when I respond, you don't like it.
Well, I'm entitled to know what you meant by bitch.
Acting like a bitch.
Come on.
What is a bitch?
Stop. You don't know?
Stop. You're unfamiliar with the term?
Is that someone who's gay?
Stop. No, it is not.
Stop. It is not a slur of any kind.
Asparaging gay people?
No, it most certainly is not.
Mr. Klayman, you're a lawyer, sir.
Ask your next question.
Do you have a serious question?
Ask your next question.
He called me then.
Is that really what you think it means?
Come on, ask your next question.
I'm asking him what he asked.
I'm not going to answer the question, so ask me a serious question regarding your lawsuit.
And I'll answer it.
Now, this is an email.
Did you find it?
The one that you sent to Cardillo in 8-18, 2009?
Yes, I did.
2009? 2019.
Yes. And at 5.24 p.m., correct?
Appears to be correct.
And you're forwarding a transcript from Elite Transcripts.
Correct. The same transcription service you're here on today with, correct?
Correct. And the transcript relates to a lawsuit, Larry Klayman versus Roger Stone.
Yes. This lawsuit doesn't have anything to do with Newsmax, does it?
No, I don't think it does.
You sent a transcript of statements that your counsel, Mr. Buchel, made to Judge Michael Robinson, correct, in that lawsuit?
It's been a long time since I read this document, but if you say so.
So you're publishing this transcript to Cardillo of Newsmax?
Publishing. Publishing would not be incorrect.
You're providing it.
Transmitting it.
You're providing it.
Yes. It's a public document, is it not?
Transcript, Mr. Buchel, disparages me in front of Michael Robinson, correct?
That's your opinion.
I think he quoted a judicial decision.
I'm not sure that that's disparagement.
Well, let's go through it.
Now, he says here,
Where are you?
on the second page.
Going down to where Mr. Buchel is talking.
You got a line number?
Yeah. Judicial notice of the published opinions, of court opinions, warrants dismissal of Mr. Klayman's defamation lawsuit.
Mr. Stone is not the first person to question Mr. Klayman's abilities as an attorney.
The United States Court of Appeals for the Ninth Circuit noted how the district court found quite relevant, numerous and relevant, numerous other court findings that he, Mr. Klayman, is unfit to practice based on his inappropriate and ethical behavior.
You see that?
Yes, I do.
Now, you didn't read any of these so-called other opinions, did you, before you sent this to Cardillo?
No, because I have a high regard for Mr. Bushell and his record for accuracy.
You're aware that I've never been found to be unfit to practice law, correct?
You mean you haven't been disbarred?
I just asked the question.
You're aware that I've never been declared unfit to practice law?
Is that the same thing?
I'm asking you the question.
I know that there are charges pending against you in the District of Columbia, yeah.
I read that.
And you're aware that I have no disciplinary record in the District of Columbia at this time, correct?
Yet. Okay.
And you are aware that I've never been found unfit to practice law generally, correct?
No, I don't know that.
I do know that there are some decisions here that would tend to question your judgment, specifically...
Claimant's record demonstrates more than occasional lapse of judgment.
It evinces a total disregard for the judicial process.
I'm not asking you, I'm talking about this question here.
So what in effect you're saying is that I have been found to be unfit to practice law generally by various courts.
I didn't say that.
Where do I say that?
So that's your lawyer who said that?
Yes, I believe he did.
So he defamed you on behalf of yourself?
No, he's responsible for what he says.
If you want to bring against the action, go ahead, you'll lose there too.
In fact, you urged me to sue you, didn't you, when you made those comments?
You dared me to sue you.
So you can lose again?
Yeah, why not?
Go ahead, Luz again.
What relevance is there as to what courts ruled about me in a defamation lawsuit against you?
Because I don't think you can be defended.
I think the courts have said worse things about you than I've ever said.
You're aware that Justice Scalia issued an opinion where he said that the defense of being libel-proof is virtually nonexistent?
No, I'm not an attorney.
I'm unfamiliar with that.
I don't know what to be
true either.
Then Mr. Buchel says, turn to the next page,
Since the filing of this lawsuit, Judge Michael Robinson, after nine years, the D.C. Bar has recommended that the D.C. Court of Appeals suspend Mr. Klayman for, among other reasons, sexually harassing a client.
We filed the recommended order, and it is 183 pages.
In fact, I have never been recommended for suspension by the D.C. Bar for sexually harassing a client, correct?
I couldn't tell you.
I don't know.
It's not quoting me.
And in fact, all that's pending is a recommendation by a hearing committee, not the D.C. Bar Board of Professional Responsibility, correct?
Check in the form.
But when you testify, you can clear that up.
I don't need your comment, Mr. Buchel.
I don't understand what you're doing here.
I'll tell you what I'm doing, and I'll get to it, and you don't need to know right now.
I'm asking the questions.
You're the one who produced this on behalf of Mr. Stone.
Now, you're aware that I've never been accused of sexually harassing a client.
You're asking me that?
Yes. Do you have any evidence of that?
I do not, but I also don't know that it's not true.
I have heard it, I must say.
You're aware that sitting on that hearing committee was someone by the name of Michael Tiger who was an avowed communist fired by Justice William Brennan.
It's not funny.
No, I'm not aware of that.
I'm not aware of that.
Why don't you ask questions like who was on the committee?
These are leading, assuming facts.
You can ask your questions.
Have fun.
Believe me, we will.
At the end, have fun.
Believe me, we will.
Have fun.
We'll need three or four days.
I look forward to having you there.
Yeah, me too.
If you're not in prison at that time.
If you're not disbarred by that.
All right, I'm sorry.
Keep going.
I like my odds better than yours.
Keep going.
Well, pray for a pardon.
Keep going
But if you say there was a communist on the board, I'm happy to believe you.
Neither one of us likes communists.
I said the hearing committee.
Oh, the hearing committee.
Pardon me.
Word didn't make any recommendation.
Then your counsel gets into my divorce proceedings and custody proceedings, correct?
It's been a long time since I read this, so I don't recall.
Do you want to point to a line number?
Yeah. The Eleventh Circuit Court of Appeals, our federal line number.
Like zero, zero, zero, a section, then a line number.
Yes. I'm just going to refer generally to it.
Your lawyer can cross-examine if he wishes, but this is a transcript that discusses my custody fight with my former wife over my children, correct?
Unless I can see that section, I couldn't tell you.
Yes, look at lines 1 through 25 below the third set of statements.
Start from the beginning.
There's a page number, and then there are line numbers.
You didn't put page numbers on it.
That's what I'm pointing out.
Here's a page number.
Alright, page 7. And then the line number.
Where it says 7. Oh, I see.
That's a page.
I got it.
Alright. Number, page 7, what line number?
1 through 25. Okay.
So, this transcript contains argument by your counsel, Mr. Buschel, which states that I have been found unfit to practice law,
makes certain statements about court rulings regarding my children and me, about Judicial Watch, in a lawsuit that does not concern Newsmax, correct?
Correct. Yet you sent this to Cardillo of Newsmax to disparage me with Cardillo and to harm my relationship with John Cardillo, correct?
No, incorrect.
I don't know why I sent it to him.
He sent this vindictively to try to harm me.
Boy, you are sensitive.
I don't recall why I sent it.
But I do think it's probably accurate.
If you want to bring an action against Mr. Bushell, you're welcome to do so.
I think you'll lose that, too.
The point I'm making here is that there was no reason to send this to Cardillo because he was not involved in your lawsuit other than to try to defame me.
That's not defamation, first of all.
Second, because it's all true.
Truth is in absolute defense, as you know.
So where's the defamation?
Mr. Mushell is a very cautious lawyer, to say the least.
What research have you yourself done to confirm that it's true?
If he says it's true, I would believe him.
He's a very sound attorney.
Why would I believe when you say it's not true?
based on some of the comments here, I'd be less likely to believe that.
I'm going to go ahead and get some of the comments here.
Is this not a public document?
In fact, you instructed Mr. Buschel to
Disparage me in front of...
I gave him no such destruction.
I gave him no such destruction.
Oh, he did on his own?
He's my attorney.
He can make judgments on my behalf, yes.
Is there something in here that's inaccurate?
Then you should bring an action.
I don't know that there is.
Turn to an email of April 8, 2019.
Where's that?
At 2.27 p.m.
Let me go back on Cardillo.
Why did you send it to Cardillo?
I don't recall.
You don't know why you sent things?
I don't recall.
I don't recall, but it's a public document, so I don't think it's terribly sensitive.
Mr. Cardillo could get it on his own, I guess.
Are you aware that after Newsmax was sued, After you were sued for tortiously interfering with Newsmax.
Do you have a contract with that?
Do they have an obligation to put you on the air?
Do you have some God-given right to be on the air whenever you want to be?
I'm unaware of that.
I'm asking the question.
No, I'll ask the question.
I'll say anything I like there.
I know you will.
Jackass. Come on.
Let's go.
Let me ask a question.
Yeah, I'm waiting.
After you were sued for tortiously interfering, A baseless lawsuit.
Go ahead.
Are you aware that John Cardillo called me and asked me to represent him in legal matters?
I am not aware of that.
And that I declined on the basis of conflict of interest?
Completely unaware of that.
I also don't know that it's true.
Are you aware that he was trying to ingratiate himself with me so I would not...
Why should I believe anything that you say?
Mr. Cardillo has never told me that.
Just because you say something does not mean it's true.
I turn to an email from Colin Kahnbacher, K-A-L-M-B-B-A-C-H-E-R.
Yes. And look above that.
From Media Stone Cold Truth.
Yes. That's your email address as well, is it not?
Correct, yes.
Some reporters who have no other way of getting an email address go there.
Because it's online.
The email from colon K, K-A-L-M-B-A-C-H-E-R.
Yes. It says, Howdy, Mr. Stone.
Any comment on the defamation lawsuit filed today?
This is for law and crime.
Yeah, I definitely would not return a call from them.
Why is that?
Because they're a very left-wing outfit, as you're probably aware.
Turn to their next email.
From Michael Caputo, michaelcaputo at gmail.com.
Sent January 5, 2019 at 3.41 p.m.
Yes. To you at player02 at gmail.com.
Yes. Mueller's target bid to pick judge for suit is rejected.
And it says from Caputo, Larry's fucking nuts, Michael Caputo, with his phone number, correct?
Yes. You got that from Caputo, correct?
Evidently. Okay, what was I fucking nuts about?
I don't know.
I'd have to click on the link.
It's been quite a while.
I assume that you are.
This comes from another attorney who obviously thinks that you're a crazy claimant, so why don't you sue him too?
Paul Kemenhar.
Paul Kemenhar.
You know Paul Kamenor, don't you?
I do.
In fact, he represented your assistant, friend, whatever you want to call him, Andrew Miller, right?
Yes, he did.
And who's Andrew Miller?
A guy who worked for me for a number of years, although not recently.
Was he your houseboy?
No. To say the least.
Was he the guy you claimed posted the nude pictures of yourself?
No, he was not.
Half nude.
Objection of form.
Who's Peter Flaherty?
Peter Flaherty runs some kind of...
I mean, I knew him in the Young Americans for Freedom days.
He runs some kind of public interest.
Conservative public interest loss operation in Washington.
Couldn't tell you the name of it.
Is Paul Kamenar talking to Caputo, or are you here?
It appears to me that he has forwarded this to Flaherty and Caputo.
I don't know the other person.
This is of course prior to any, this is prior to my arrest even or my indictment.
I'm going to click down to an email from Peter Santilli, Pete at PeteSantilli.tv, January 3rd, 2019 at 7:40 p.m., Roger Stone, Player02, Gmail, Subject Claim and Docs, Attachments Claim
and Order ProHack, VICE, V-I-C-E, Ritamandame.
I don't know where that is.
Take your time to find it.
What's the date again?
1-3-2009, January 3rd, 2019.
Yes. This is an email that you received from Pete Santilli, correct?
Yes, here's today.
This is yet another communication from Santilli that you did not disclose earlier.
Did not recall it.
Isn't that what you told Congress?
You didn't recall things?
Objection of form.
What's the point of that question?
And it attaches an order of the United States District Court District of Nevada, correct?
Appears to be, yes.
Dealing with my PROHEC VICE application, correct?
Appears to be, yes.
That sat on the Cliven Bundy prosecution, was one Gloria Navarro?
Yes, I was not a fan of hers.
You're aware that she was recommended to the bench to Barack Obama by Harry Reid?
I didn't know that specifically, but I knew she was a Democrat.
You don't have a very high regard for Harry Reid, do you?
No, nor do I have a high regard for this particular judge and the way that she treated the Bundys.
You're aware that she denied me pro-hagnite entry?
But I don't know why.
You're aware that she denied him?
A speedy trial?
Yes, I did.
You're aware that she threw him into solitary confinement?
Yes, that's why I wanted the president to pardon him.
You're aware that for two and a half years they were incarcerated, the Bundys, along with other defendants?
Yes, I think it was outrageous.
That's why I wanted the president to relieve them.
Do you find it inappropriate that the president would intervene with regard to your sentencing in a criminal case but never take any action on behalf of the Bundys?
I'm not going to discuss that.
I'm not discussing that.
Don't you think that's an outrage?
Now I'm going to discuss
that.
Are you aware that it was the Trump Justice Department that appealed the dismissal of the indictment, even by Judge Navarro?
I was not aware of that.
And that was done by the U.S. Attorney in Nevada?
You were aware of that?
I was not aware of that.
The same people that were accused of prosecutorial misconduct?
I remember when it happened, but I don't remember many of the specifics.
It was disturbing.
But Attorney General Bill Barr is able to recommend a lesser sentence for you, but he takes no action with regard to that appeal.
Remember to comment on that.
It has nothing to do with your lawsuit.
Right. You're free to advocate on behalf of Cliven Bundy even today,
aren't you?
I thought his matter was dismissed.
You are aware that it's up on appeal to the Ninth Circuit?
I was not aware of that.
Next time you talk to the President, put in a good word for Clyman Bundy.
I wish I could.
I think he's a good man.
I think he's been very badly treated.
You could have just called us and told us that.
You didn't have to sue him.
You want to take a break or you got more?
Let's take a little break.
Are you aware that Judge Navarro has issued an order telling Mr. Santilli not to be in contact with you?
I recall being told that.
I have not heard from Mr. Santilli one way or another in a very long time.
Mr. Santilli's the one who told you that, correct?
I think Mr. Santilli's lawyer told Grant Smith that.
I'm sorry.
Are you able to get that, or do you want me to?
Yes, I do.
Okay. On or about January 28, 2019, in a video posted on Peter Santilli's YouTube channel titled,
Major Complaint Filed Against Jerome Corsi's Attorney Larry Klayman, Roger Stone Live with Pete Santilli.
You appeared with Pete Santilli on about January 28, 2019, correct?
I don't recall that specifically, but if you say so.
You weren't dead, were you?
No, I was definitely not dead.
Okay. In that broadcast, Santilli stated, you'll remember this, hopefully, defendant Santilli was effectively...
Stated at 1:36 in the broadcast, YouTube video, that I, Larry Klayman, was ousted by the group which he founded, Judicial Watch, because of a sexual harassment complaint.
That's exactly the statement that you published about me on Infowars, correct?
Maybe he heard it, too.
But you were on that broadcast with him.
Which proves what?
So you discussed that with him, correct?
You told him I was ousted from Judicial Watch because of a sexual harassment complaint.
I don't think that's proof, but that has been alleged, as I'm sure you know.
It's not like it's a big secret.
People have said that.
What people?
People. Who?
People. People?
People on other planets?
People. People in politics.
Pluto, in our galaxy.
Venus, who knows?
Venus? Venus.
But you can't remember who said that?
Not specifically, no.
In fact, it was Fitton who said that, correct?
I think you referred to that earlier.
Yeah. Didn't they get a judgment against you?
So he told you about that too?
No. My counsel told me about that.
Okay. He also told you it's on appeal?
Yeah. That doesn't mean anything.
Okay. Well, you...
You may need to take an appeal.
And then...
Then on February 21st, 2019, Deborah Jordan published on Santilli's Facebook page.
Larry Klayman is cooperating with Mueller.
You're aware of that, aren't you?
No, actually I'm not.
And that's exactly what you broadcast that Jerry Corsi and I were doing, cooperating with Mueller against you, correct?
Well, this did get quite a bit of press.
As you recall, Mr. Corsi went out and did a press tour in which he claimed that he had created some memo as a...
As a cover story, I suspect that that was suggested to him because it just wasn't true.
I'm sorry, I didn't understand what you said.
You want to read it back to him?
Sure. Yeah.
It's not comprehensible.
It's entirely comprehensible.
Hang on one second.
That's not exactly what you broadcasted to Jerry Corsi.
And Corsi, they were doing...
No, that is exactly what you...
Not exactly.
No, I know.
I'm just reading the notes.
Just give me one second.
That is exactly what you broadcasted, right?
Yeah. Yeah, that's exactly what you broadcasted.
Okay, good.
Okay, I misheard it.
That's okay.
To Jerry Corsi, and you were doing...
And you were cooperating with Mueller to get...
I mean, you were cooperating with Mueller to get, you went out and did a press term, which he created some memo as a cover story.
I suspect that was suggested to him because it just, it wasn't true.
Yeah, so in other words, you criticized me earlier for doing media to defend myself, but your client went out and did the same thing.
He portrayed a number of falsehoods in those interviews, which is certainly reason to believe that somebody had suggested this falsehood to him, since it is chronologically impossible.
For him to have created a memo as a cover story because there was nothing to cover.
So you're confirming that you had...
No, I'm not confirming that at all.
...published that Corsi and I were cooperating with Mueller against you.
No, I'm not saying that at all.
I think you accused me of that earlier.
What I'm saying is it's entirely possible that this woman learned it from some other public source.
It was becoming pretty apparent based on Corsi's comments.
But you've met Dober Jordan, correct?
I don't recall meeting her.
And you were on the show with Santilli, correct?
I have been on the show with Santilli.
I don't recall meeting Deborah.
And she's his co-host, correct?
I believe she is, but I don't recall ever meeting her.
I'll show you what I asked the court reporter to mark as Exhibit 5. This is Defendant Roger Stone's response to request for production.
consists of two pages.
This was filed with the court by your counsel, Robert Buschel.
Yes. You didn't see this before Mr. Buschel prepared it and filed it, did you?
I don't recall seeing it, but I've seen a lot of legal documents in the last year.
Do you have any zip drives of documents you've retained over the years?
Do you still have those?
No. Do you have any assistance at the time this was prepared?
Strike that.
At the time, documents were reviewed by your counsel to produce in this lawsuit?
No. Do you have any assistants working with you?
No. Did anyone in your family help you?
No. Do you have anybody working for you at this time?
No. Do you have any consulting contracts at this time?
Yes. Who are they with?
Unfortunately, I have a confidentiality agreement, so I can't tell you.
Are you asking him, is he working for anybody?
Is that what you mean by that?
Yes. Oh, okay.
Or with?
Regarding requests for production?
No, with regard to anything.
Oh, okay.
Yeah, I have one client.
And you've sent emails to that client?
Not in the last year.
You've sent texts to that client?
No. Client has nothing to do with any of this, even remotely.
Have you changed your email address in the last year?
Have not.
It remained exactly the same.
Have you changed your phone number in the last year?
I have not.
It remained exactly the same.
Do you have more than one cell phone provider?
No, I have one.
Just 18, too?
Correct. Do you have any iPads or any kinds of tablets?
I have an iPad, but I very rarely use it.
I have a laptop.
I also very rarely use that.
But those were all examined.
Everything there was collected.
Who examined them?
Mr. Smith.
I presume he had professional assistants.
But you're not sure?
I believe that's the case.
He has some IT person that he deals with.
He's not a computer guy.
Did your lawyers go through each individual email communication, or did they just put search terms in?
I couldn't answer the question.
I don't know.
I do know that if you're looking for some evidence that I instructed anybody to do anything, as you've obtained today, you're going to be fruitless because those things just didn't happen.
Neither surrogates nor anybody pertaining to Newsmax.
It's just based on some wild assumption.
It's just nothing to find.
I never told anyone at Newsmax.
Not to have you on.
They wouldn't listen to me if I did.
What makes you think they wouldn't listen to you?
Because I know Chris Ruddy, and he's extraordinarily independent.
I would never even do that, because he would be offended.
It's not my business who's on.
I don't own the network.
But John Cardello is your good friend.
He is my good friend, but I don't think he would listen to me either.
He is my good friend.
Do you have any storage facilities?
Yes. Where are your storage facilities?
In Oakland Park, Florida.
And what's in those storage facilities?
Furniture. Some political memorabilia.
Who has access to those storage facilities?
Mrs. Stone and myself.
Do you have any safety boxes at banks?
No. What banks do you use?
Objection. This financial discovery.
No, it's not financial.
He just told me there are no safety deposit boxes.
I don't have a safety deposit box anywhere.
I have a checking account.
I have two checking accounts, actually.
Do you currently own your residence?
I do not.
Do you own any property outside of this country?
We're not doing financial discovery.
I'm looking for documents now.
So whether he owns it or not is important?
Well, it would have a bearing on whether he has stored things there.
I have stored nothing there.
But there is property you own outside of the country?
I did not say that.
I said no, actually.
I own no property outside the country.
Are there any documents that you've created over the last five years that were in the possession of Paul Manafort?
No. Rick Gates?
No, but I'm not going to go down this road.
I'm looking for documents.
Documents pertaining to your lawsuits, yeah.
There are no such documents.
Do you have any storage facilities in Washington DC?
I do not.
Did you ever?
Never did.
New York, New York City.
Yes, I have still some furniture that I have not been able to afford to move from New York to Florida.
And where's that furniture located?
Somewhere in the Upper West Side.
My wife had to do it because of my travel restrictions.
What's the name of the storage facility?
I do not know.
There are no...
Business records or anything of that sort.
It's all furniture.
What did the FBI take from your home?
We're not getting into that.
I'm looking for property.
I'm not getting into motivations.
What did they take out of your home?
I can subpoena them.
What did they take out of your home?
That was the wrong direction.
Do you remember what?
They took all my electronic devices and they returned them.
When did they return them?
They didn't all come back at once, as I recall, but it didn't take that long.
I presume they imaged them and then they returned them.
Have you or anyone else inspected them to see if anything was removed from those devices?
I don't think anything was removed.
Everything I've looked for has still been there.
On the other hand, it's a huge amount of data, much of it irrelevant, but I rarely erased anything.
It is your practice to delete emails that you don't want to keep, though, correct?
No, actually, I wish that was my practice, but it's not the case.
I think I have over a million emails.
After you were indicted, did it become your practice not to keep emails?
No. Or texts?
No. Were any of the phones that you've used in the last two years either lost or destroyed by you or anyone else?
No. Have you ever used your wife's cell phone to send texts?
No. Anybody else in your family?
No. Other than your own wife and family, who are the closest people to you?
Relevance? Other than my wife and my family.
My lawyer Grant Smith is one of my best friends.
I'd say he's the closest person to me.
Is that how you came in contact with Mr. Buchel?
Actually, no.
We met previously.
Do you have any lawyers other than Mr. Smith and Mr. Buchel and Mr. Rogel at this time that are working for you?
Yes. Who's that?
Seth Ginsberg and David Schoen.
And Tara?
And Tara Kempian.
And where are they located?
Seth Ginsburg is in New York and David Schoen is in Atlanta.
Thank you.
And just a general subject matter, what are they working on?
That would be a term client privilege, would it not?
Sure. A term client privilege objection.
They have access to some of your documents, do they not?
They do not.
You've never given them any documents to review?
No, I have not.
What's the area of practice, Seth Ginsburg?
You can look them both up.
I mean, they're defense lawyers.
I mean, they're white-collar defense lawyers.
They're both pretty accomplished.
I'm sure you won't have any trouble finding their bio.
And Seth Ginsburg is where?
He's in New York City.
And David Schoen's in Atlanta?
Correct. Were they retained after you were convicted?
Yes.
Yes. In the course of their representation going forward with you, you've given them documentation, correct?
I've given them nothing.
They have access to documentation that your lawyers here, Mr. Smith and Mr. Buschel have?
They have access to.
Public documents on PACER, I guess.
You've retained them to file an appeal?
No, not necessarily, but there is, as you know, in the sentencing, there's a process.
You provided documents with regard to that sentencing process to the court and to the Bureau of Prisons?
I'm looking for documents.
There are no documents that pertain to your lawsuits.
But you haven't reviewed them to determine that, have you?
There are no documents that pertain to your lawsuits.
Anything given to the Department of Probation would be under seal.
Well, your criminal prosecution obviously involved Dr. Jerome Corsi, correct?
In principle.
Not necessarily.
He was not called as a witness at my trial.
No, not necessarily.
Are you aware that he was subpoenaed by the government as well?
Not aware of that.
You are aware that your own counsel subpoenaed him?
We certainly thought about calling him, yes.
And what were you going to ask him?
I'm not going to discuss anything pertaining to the federal trial.
And attorney-client privilege.
You didn't call him as a witness because he thought he would testify in a manner that would not be helpful to you, correct?
That's your warped opinion.
In fact, you called no witnesses at your trial, correct?
I'm not going to discuss my trial.
Are you satisfied with the legal representation you had at that trial?
I'm not going to discuss my trial.
What's the point of this line of questioning?
You just want to inflame them?
I'm fine.
It's not inflaming him.
I'm fine.
You're not inflaming me.
So ask a question.
I want to know why you went off.
I mean, I want to find out what documents you gave to Ginsburg and shown that...
You have no right to those documents.
Well, anything that's relevant or may lead to relevant evidence, I do.
They're not relevant.
They're not relevant.
Try subpoenaing them.
See how that works out.
They're privileged, and you know that.
So stop.
It's nothing to do with you or your various civil actions.
Are you a member of any organizations here in South Florida?
Organizations such as?
Any political groups of the Republican Party?
No. You've appeared and you've spoken at Republican Party events.
Yes, I have.
I speak for the party whenever they ask, or for the various Trump groups whenever they ask, and I do so for free.
And who has arranged for those speeches?
They usually contact me directly.
What are the names of persons?
Relevance. Who?
I don't recall.
You may have spoken to them about these various matters.
But I didn't.
If you have some evidence that I did, say their name.
You say their name.
No, I'm asking you.
No, I'm asking you.
Just give me the names of the people that invited you to speak.
Did you just say to fuck me?
I did.
Not answering that question.
It has no relevance.
This is harassment.
Like everything you do.
This is called gathering evidence.
It's called harassment.
What's your next question?
Did the head of the Republican Party of Broward invite you to speak?
No. The head of the Republican Party of Palm Beach?
No. Who is the head of the Republican Party of Broward?
I couldn't tell you.
I've never spoken to them.
Who's the head of the Republican Party of Palm Beach?
Mike? Don't recall his last name.
He is an African-American gentleman.
Mike Barnett.
My bullet.
Is there a group called Trump something with a number?
Trump 45. Who runs that?
It's a board.
a guy named Joe Budd who runs it and a woman named Linda Storch.
I'm not sure how she pronounces it.
They've helped you raise money for your defense, correct?
I think they gave a contribution to my legal defense fund.
They put on a fundraiser, correct?
No, I don't think so.
I think that they took a percentage of their...
They have a monthly meeting, and you have to buy a seat.
So I think they took a percentage of whatever their monthly income was to give to my legal defense fund.
So I think they took a percentage of the income.
Have you been, since you were indicted, invited to Mar-a-Lago?
I have not.
Have you spoken or communicated in any way with any person associated with Mar-a-Lago?
The only one would be Chris Ruddy, who's a member, and we detailed that conversation earlier.
Are you a member of Mar-a-Lago?
I am not.
Well beyond my ability.
What does it cost to be a member?
It's kind of a floating event, but I think it's 50 grand to start.
What do you get for 50 grand?
The ability to pay top dollar for good food and a beach club.
No golf course.
You ever play golf with a president?
No, I'm not a golfer.
Who has put on fundraisers for you for your legal defense?
Relevance? Yeah, objection.
I want to go talk to them.
About what?
About what?
What they know and what you've said about me, of course.
I've said nothing about you, of course.
Why would you assume that?
Just because you're obsessed with me doesn't mean I'm obsessed with you.
Well, apparently you're obsessed enough to...
When you guys are out telling lies about me.
When you guys are out telling lies about me.
Well, you're saying things that are provably false.
To say that I'm retarded, in effect.
Well... Mr. Klayman, come on.
We've been through this.
Who's put on fundraisers for you?
Numerous people.
Some strip clubs have put on fundraisers for you, correct?
Some owners of gentlemen's clubs, yes.
And who are they, and what club?
I could not recall the names, to be honest with you.
There was one in Memphis.
There was one in Richmond.
Why would owners are strip clubs?
Because they believe in free speech.
As related to stripping.
They happen to be conservatives.
It's free expression.
It's perfectly legal.
I mean, look, I'd prefer to be speaking again at the Oxford Political Union, but that was not an option.
So the fallback was a strip club?
You know, I needed to raise money for my legal defense.
I would call it a gentleman's club, however.
Why would you call it a gentleman?
Because that's what they're commonly called.
Do you have any security guards?
I do not.
Have you had any in the last two years?
I have used security when I go to D.C., off-duty, D.C. political.
Who have you used?
Couldn't tell you their names.
What company, if any?
They're private individuals, not in a security company.
They're mostly off-duty policemen trying to pick up money on the side.
African Americans, I know their first names, but I couldn't tell you their last names.
Were they off-duty police officers?
Either former police officers or current police officers, I'm unsure.
Who paid them?
Paid by my legal defense fund.
Who runs that legal defense fund?
Well, runs it.
Who administers to it?
A woman named Nancy Watkins, who is a CPA out of Tampa.
This has all been in the press.
Do you do any direct mail?
Very limited.
Who do you do direct mail with?
Eberly, I believe.
It's been very limited.
Do you draft letters that are sent?
I used to.
They draft them now.
You've kept copies of letters that you drafted?
Not necessarily, but I'm not sure I understand the relevance.
You're not mentioned in any of them, nor is Mr. Corsing, if that's what you want to know.
Okay, we can break down.
We're willing to stay, but we'll resume tomorrow at 9 o'clock.