1

United States Senate

Select Committee on Ethics

3
4

Monday, January 31, 2011

Washington, D.C.
7
Deposition of:
9

10 a Witness, called for examination pursuant to notice of

11 deposition, on Monday, January 31, 2011, in Room 220 of the

12 Hart Senate Office Building, Washington, D.C., at 3:00 p.m.,

13 before a Notary Public within and for the

14 District of Columbia, when were present on behalf of the

15 respective parties:
16
17
18
19
20
21
22
23
24

25
ePA
26

-SSCE0000736
1 Chief Counsel

2 .1111.111 Counsel

3 Counsel

4 Counsel

5 Counsel

6 United States Senate

7 Select Committee on Ethics

8 220 Hart Senate Office Building

9 Washington, D.C. 20510

10 T 202.11111111

11 F 202.224.7410
12
13

14 Williams & Jensen, PLLC

15 701 8th Street, NW

16 Suite 500

17 Washington, D.C. 20001

18 T202.

19 F 202.659.5249

20 E-mail I I I I I I k wms-jen.com

21 On behalf of the Witness

22
23
24
25
26
2
1 CONTENTS
2 Witness: Examination by:
3 : 6
4
5
6
7 EXHIBITS
8 Deposition Exhibit Marked
1 11
10 2 19
11 3 24
12 4 28
13 5 34
14 6 43
15 7 43
16 8 44
17 9 46
18 10 47
19 11 49
20 12 55
21 13 65
22 14 68
23 15 69
24
25 (Exhibits retained.)
26
3
M-SSCE0000738
1 PROCEEDINGS

2 : The Select Committee on Ethics was

3 established by Senate Resolution 388 in the 2nd Session of

4 the 88th Congress, and has the jurisdiction to investigate

allegations of improper conduct or violations of law or

6 rules, and regulations of the Senate relating to the conduct

7 of members, officers, and employees.

8 Your deposition today has been authorized by the members

9 of the Select Committee on Ethics pursuant to its procedural

10 rules, which I've provided a copy to your counsel along with

11 my card.

12 I'm I'm the Chief Counsel and Staff

13 Director of the Committee.

14 : And gained a lot of gray hair lately.

15 Exactly, right. I'm joined here at the

16 table by who is a counsel to the Committee. Also

17 with the Committee Staff,

18 whom you've just met will also be sitting in

19 today.

20 : Let me get them in order here.

21 (Arranging business cards.) There we go.

22 : I'm going to try to do the bulk of the

23 questioning here today.

24 : Okay.

25 : And we don't want to sandbag you with

26
4
SS0E0000739
1 questions, but sometimes the counsel may need to help remind

2 me of things.

3 : Okay.

4 All of the Staff, for that matter, have

5 been authorized by the Chair and the Vice Chair of the

6 Committee to conduct the questioning today, but I'm going to

7 try to do most of it myself.

This deposition is part of a preliminary inquiry being
conducted by the Committee on matters within its

10 jurisdiction with respect to allegations of or information

11 about possible misconduct by Senator John Ensign.

12 After your deposition is concluded here today, a

13 transcript will be prepared of our questions and your

14 responses; that's considered a committee confidential

15 matter, it's going to be locked into a safe and will never

16 leave the committee confines.

17 The transcript will, however, pursuant to the procedural

18 rules, you're entitled to the opportunity to review that

19 transcript, you or your counsel, to come and review it to

20 make sure there aren't any transcription errors. If there

21 are any errors of fact in the deposition, we'll have to have

22 that amended through a sworn declaration. The transcripts

23 are usually available within a couple of days; we'll be

24 happy to arrange a time for you to come by and look at it.

25 Finally, if at any time during the deposition today you

26
5
MEISSCE0000740
6

1 need to take a break or confer with confidentially, we

2 have a room set aside, available for that purpose.

3 And at this point I'd ask the court reporter to

4 administer the oath, and we can get started.

5 Thereupon,
6
a Witness, called for examination by counsel for the Senate

Ethics Committee, after having been first duly sworn, was

examined and testified as follows:

10

if you would be so kind to put

11

your appearance on the record.

12

13

I'm a partner at Williams and

14

Jensen, licensed in the District of Columbia.

15

To kind of get us warmed up, 'm going to

16

start with just some general questions here, sir, just to

17 kind of get us going.

18 THE WITNESS: Okay.

19 EXAMINATION

20 BY

21 Q
How long have you known Senator Ensign?

22 A I met him in late 1994.

23

24 A

25 Q
That's right.
26
M-SSCE0000741
1

2 A
3

4
Q
And did that relationship change or evolve over

5 time?

A Well, it's had some rocky times here lately, I

can tell you that.

Sure, okay.
9
10

11 A
12

13
Q
Do you remember about when that was?

14 A I don't recall, no.

15
Q
Do you think it could have been around 2006?

16 To the extent you know, sir.

17 A It could have been.

18
Q
Could have been, okay.
19
20

21 A
22

23 A
24
25
26
7
-SS0E0000742
1
2 A No.
3 Q
Okay. Did you ever have occasion to have any
4 discussions

about legislative issues or

5 policy issues?
6

A No.
7

I'm going to move ahead to the beginning of 2008,

8 I think is the relevant time frame to proceed here.
9
10
11
8
12
13 A I may have. I don't recall. 111111 11111
14
15
Q
I see.
16
17

A No.
18
19
20 A That year?
21 Q That year.
22 A No.
23 Q
24
25
26
IMSSCE0000743
1 A Yes.

2
Q
Do you recall the dates of that

3 A No.

4
Q
'Do you recall if Senator Ensign

5 were on the 1111111

6 A
7

9 A
10

11
Q
Okay. During the trip did you have any occasion,

12 outside of these meetings, to speak to Senator Ensign

13

14

A Oh, I'm sure I did.

15
16

17 A No

18
Q
No.

19 A No,
20

21
Q
Okay. 11111111111 111111111111111.1IM
22

23 A No.

24 Q
Do you recall who attended
25
26
9
-SSCE0000744
10

A
2
3
4
5
6
7
8

9 A No. There was an argument on where Senator

10 Ensign was sitting, a discussion. That's all, the only

11 thing I recall.

12
Q
Do you remember --

13 A They changed, where Senator Ensign sat.

14 Q
Okay.
15
16

17 A No.
18
19
20

21 A No.

22
Q
Maybe it would be helpful to nail down just the

23 dates of the trip, just so we can make sure the record's

24 clear.

25 A Okay.
26
I-SSCE0000745
1 Q
And we're going to show you some documents. And
2

3 Well mark this as Exhibit 1.

4 (Deposition Exhibitillk was marked for

5 identification.)

6 : I've got itineraries and I've got copies

7 for both of you.

8 And this is document 1098 and the pages that follow.

9 (Document to witness and counsel.)

10
: And I draw your attention to the top of

11 the page. What dates are reflected on the itinerary?

12 THE WITNESS: Oh, that's right.

13

14 BY

15 Q
So you think might have accompanied you on

16 the trip?

17 A Yes.

18 Q
And just so the record is clear, there's a

19 designation, MLA. What does that refer to?

20 A Military Legislative Assistant.

21
22
23

24 A Sometimes, it depends.
25
26
11
111111111-SSCE0000746
1
Q
So it varies.
2 A It varies.
And it's the
4 A Uh-huh, it is.
discretion at that point?
12

5 Q
The IIIIII participants represented here at

6 Senator Ensign, Senator

and Senator

7 Is that accurate, to your recollection?

8 A To my recollection.
9
10

11 A Yes.

12
Q
And the document also reflects the dates of the

13 trip as being from September 7 to the 12th of 2008, is that

14 correct?

15 A That's what it shows.

16
Q
What it shows, okay.

17 You said September, not February.

18 I'm sorry, February. The record should

19 reflect September 7 to 12, February 2008.

20 BY

21
Q
So in terms of kind of the evolution of events

22 here, what -- you returned home from the trip.

23 A Uh-huh (affirmative).

24
Q
What happened next in connection with this

25 matter, to your knowledge and recollection?

26
IIIII.-SSCE0000747
A Probably not sure I know what you're asking.

2
Q
Let me put it this way. According to this, it
looks like the were turned back on February 12th.

4 The following day, the 13th, do you recall receiving a phone

5 call from

6 A No.

7 Q
From

8 A No.
9
10
11

12 A
13
14
15

16 A No, I don't. And I'm sure it was sometime in the

17 winter of that year, but I don't remember the dates.

18 Q
And you don't have a recollection that it was

19 within a day or two after having returned from the

20 A No.

21 Q
Let me ask this question: When did you first

22 learn of Senator Ensign's affair?

23 A
24

25 A
26
13
MIIIIIII-SSCE0000748
1 John's.
2

3 A Uh-huh (affirmative).

4
Q
5

6 A
7

8 A

9 Q

10 A
11
12

13 A Well,

14 Q
Okay. So what did you do next?

15 A
16
17

18 A Uh-huh.
19

20
Q
And what happened next?

21 A Had a meeting.
22

23 A
24

25Q
Perhaps the next day.
26
14
-SSCE0000749
1
2 A I don't. I recall what I said.
3 Q
Okay.
4 A
5
6
7 A
or how did --?
15
9
10
11 A
12
13 A Uh-huh (affirmative).
14
15
16 A
17 Q
I see. So you placed the call to Senator Ensign,
18 you arranged the meeting, please describe for the Committee
19 what happened next.
20 A Brought him into a room with
21
22
23 A Yes.
24 Q
And where was the meeting?
25 A
26
-SSCE0000750
1
2
3
4
Q
So that's
A Right.
Q
If you can kind of just lay out for us, what
happened? Describe what happened.
5 A The first thing John did was to deny it.
6
7 Q And what did he say?
8 A Was remorseful, was emotional, as you would
9 expect;
10
11 Q
Okay. To the extent you can recollect,
12 say to Mr. Ensign at this time?
13 A
14 Q
Okay.
15 A
16
17
18
19
20 Q
Sure. Do you have any recollection of anything
21 might have said at the meeting?
22 A
23
24 Q
Do you know what they talked about?
25 A No, I don't.
26
16
MESSCE0000751
2
3

4 A No.
5
6

7 A No.
8
9

10 A No.

11 Q
so the sum and substance of the conversation

12 during
was about ending the affair?

13 A Ending the affair.

14

15 Q
16

17 A
18
19

20 Q
And that that was your recommendation, or that

21 was the --?

22 A
23
24
25
26
17
IIIMI-SSCE0000752
1 Q
I see .
2
3

4 A
5
6
7
8

9 A
10
11

12 A

13 Q
Okay.

14 A
15
16
17

18 A
19
20

21 A
22
23
24

25A Okay.
26
18
IIM-SSCE0000753
1
Q
-- I think that's helpful, thank you.

2 A Okay.

3 Q
Last September, I think you may recall there was

4 an article in The New Yorker concerning this matter, and

5 they talked about a second confrontation. Do you recollect

6 what I'm referring to?

7 A No.

8 : We'll mark this as NV.

9 (Deposition Exhibit III-2 was marked for

10 identification.)

11 : Give= a chance to read this?

12 : Well, I just want to draw attention to

13 the date at this point. We're not going to ask questions

14 about the article itself at this time.

15 THE WITNESS: Okay. I remember seeing this.

16 BY

17 Q
You remember seeing this?

18 A Yes.

19 Q
Did you read the article when it came out?

20 A I did.

21 Q
This refers to a second confrontation, and I'd

22 like to ask about that in a second.

23
24
25
26
19
IISS0E0000754
5
6
A No.
7 A No.
8
9 A
10
11
12 Q
But is that around this time, or is this later?
13 A No, this was before this. Before this article
14 came out.
15 Q
Before --?
16 A I don't recall the second confrontation, so
17 you're going to have to put a timeline for me.
18 Q
Okay. According to the article, and it's
19 discussed in the first couple of pages here: Within a few
20
weeks after the first confrontation, there was this second
21 meeting that, according to the article,
22 A Yes. Okay, yes, I --
23
24 A Okay, I -- yes.
25 Q
so, I'm sorry. To be clear, the bookends here
26
IIIMI-SSCE0000755
1 are this first confrontation, and then this second one with
2

3 A Okay, yes.

4
Q
-- who according to the article,
5

6 A Yes.
7
8
9

10 A No.
11
12

13 A No.
14

15 A No.

16 Q
No, okay.

17
So now were to the second confrontation here. Can you

18 please describe what you recall about that?

19 A
20
21
22
23

24 Q
Right.

25 A
26
21
.111.-SSCE0000756
1
2
To help your recollection, I can tell you who is there,

4 according to the article.

5 A
6
7
8

9 Q
According to the article, again if you'd like a

10 second to read it -- but I can tell you who is reported to

11 be there:
12
13

14 A Yes.
15
16
17
18

19 A
20

21 Q
What was Senator Ensign's reaction?

22 A Tearful, remorseful.
23
24

25 A
26
22
IIIIIIISSCE0000757
1
2
3
4
5 A No.
6
7
8 A No.
9
10 A No.
11
Q
Okay.
12 Do you want to pass those back so we can keep this
13 organized. (Exhibits returned to Committee Staff).
14
Q
Thanks. In terms of the chronology, what do you
15 recall happening next after this second confrontation?
16 A
17
18
19
20
21 A
22
23
Q
Another document to help your recollection here.
24 This is 1-3. It's very brief;
25
26
23
1-SSCE0000758
1 (Document to counsel and Witness.)

2
(Deposition Exhibit 1111-3 was marked for

3 identification.)

4 BY

5 Q
Do you recall seeing this?

6 A No.

7 Q
What's the date of this e-mail, for the record?

8 A March 12, 2008.

9
10
11
12
13

14 A

15 Q
Do you recall attending this meeting?

16 A
17
18

19 A
Yes. I mean, it's just the time where he would

20
be challenged. I mean, before and after

21 Q
I see.

22 A
-- this affair. I don't think that's unusual at

23 all.
24

25 A
26
24
IIIMISSCE0000759
8

9 A No.

10
Q
Matters --

11 A
12
13
14
15
16
17
18
19

20 Q
Ever.

21 A Not for me.

A Yes, I do, and I understand that.
1
2
3
4
5
6
A
25
22
23
24 A
25
26
-SSCE0000760
1 I'm not aware.
What do you recall learning from what you were
3

4 A You mean about reconciling?

5 Q
Yes.

6 A Yes, that he should reconcile.

Could you describe what you mean by reconcile.

8 A
9
10

11 A
12
13
14
15
16
17

18 A
19
20
21
22
23

24 A I'm not sure I can recall specific conversations

25 with that.
26
26
-SSCE0000761
1
2
3

4 A I'm not sure. I'm not sure I understand what

5 'generally' means.

6
11.1

7 Q
Okay.
A
9
10
11
12

13 THE WITNESS: Yes. Yes.

14
-- he's talking about --

15 THE WITNESS:

16
and --

17 : So you are talking away from each other

18 a bit.

19
: Well, let me -- I can get more specific,

20 and I will do that.

21 THE WITNESS: Okay.

22
Do you care if I answer an e-mail real quick?

23
By all means.

24
THE WITNESS: Make sure it's not anything new.

25 Okay, thank you.

26
27
IMIIISSCE0000762
28

: Absolutely.

(Deposition Exhibit 11[4 was marked for

identification.)

4 BY

Let me show you another document. I don't know

if you've seen this before or not; I'll give you a chance to

look at it. This is IM-4.

8

I'll give you a second to look at it.

10

A (Pause) Okay.

11

Ready? Okay.
12
13
14
15
16
17
18
19
20

21 A No.
22
23

24 A No.
25
26
.111111111-SSCE0000763
1
2 A No.
3
4
5
6
7
8
9 A No.
10
Q
11
12
13 A
14
Q
Okay, I'm just --
15 A Yes.
16
Q
-- going off of what's here.
17
18 Were those matters during this time,
19 April 2008, that you had any discussion with Senator Ensign
20 about?
21 A No.
22
23
24 A No.
25
26
29
-SSCE0000764
3
4

5 A
6
7
8

9 Q
Do you recall the time of that conversation?

10 A It was warm, I know,

11

12 Q
I see.

13 A So I would imagine that would have been June.

14 May or June.
15
16
17
18

19 A
I really don't know when it was. We're so far

20
out from that now I'm having trouble.
21
22

23 Q
Okay.

24 A
That's my time when I get to think and do what I

25 need to do.
26
IllIll-SSCE0000765
1
Q
I see.
2
3

4 A Again.

5 Q
Yes.

6 A News to me.

7 Q
Okay. But let me ask you this, and I know time

8
has passed, but just to kind of make sure the record is as

9 complete as possible here.

10
11
12
13
14
15

16 A
17

18 Q
-- let me just

19 ask \some follow up questions because maybe it will prompt

20 something.

21 A Okay.
22
23
24

25 A Again, I'm trying to recall. I don't know when I

26
31
-SSCE0000766
1 knew what I knew.
2
3

4 Q
You don't think you did. Well, let me ask this

5 specific question then.

6 A Okay.
7
8

9 A
10
11
12
13

14 A Yes,

15 Q
But you don't have a recollection of it?

16 A No, I don't.
17
18
19

20 A No.
21
22
23

24 A No.

25 Q
Never mentioned --?
26
32
MII-SSCE0000767
A
2
3
4

5
Q
I see.

6 111111111 Before we leave this,

7
: As far as we are aware,
9

10 : Okay.

11 BY
12
13

14 Can you just describe what those conversations were

15 that you had with Senator Ensign?

16 A Well, there are the two conversations that we had

17 in months.

18
Q
Were there any additional ones?

19 A Not that I'm aware of.

20
Q
Okay.

21 A
22
23

24
111111111111111111111111111111111111111111
25
26
33
SSCE0000768
1
2 A No. No.
3 Q
I see.
4 A
6
7 THE WITNESS: No.
8
9
10
11
12 : I see.
13 THE WITNESS: Do you want these back?
14
Yes, please.
15
(Deposition Exhibit 1115 was marked for
16 identification.)
17
: This is for the record.
18 BY
19 Q
Give you a second to look at it.
20 A (Pause). Okay.
21 Q
So my first question is, do you recall this
22 e-mail exchange?
23 A I do recall this e-mail. I thought it was a very
24 thoughtful e-mail.
25
26
1 you would for the record, please?

2 A

3 Q
4

5 A
6
7
8
9
10

11 A

12 it.
13
14

15 A
16
17
18
19

A No.
20
21
22

A No, he did not.

23
24

A No.
25
26
35
I don't have any recollection of
IIIIM-SSCE0000770
1
2
3 A I don't know if John ever specifically said that
4 tome.
5
6
A
8
9
10
11
12
13
14
15
16
17
18
I still want to make sure -
19
20
21
22
23
24
25 A I'm not sure. I want to be clear.
26
36
MIIIIISSCE0000771
A The election, yes.
1
2
3
4

5 A No.
6
7

8 A No, he didn't.
9
10
11
12
13

14 A Yes.
15

16 A
17
18
19
20
21
22
23
24
25
26
37
1.11111.-SSCE0000772
1
2
3
4
5
6
7
8
9
A Same thing.
Same thing.
A Yes.
10
11

Thank you.
12
13
14 A
15
16
17
18 A Yes, I think so.
19
20
21
22 A
23
24
25 A
26
38
SSCE0000773
I see. So in this call where you're checking in

4 on him, do you recall what he said?

5 A No. No. It was superficial;

7
8

9 Q
And did Illhappen to bring up what

10 be doing after Illeft the Senate

11 A No, no.

12 Q
-- with his spiritual --?

13 A No, it was all spiritual in terms of trying

14 to support him.

15 Q
I see. That's all I have for this document.

16 A Okay.

17 (Pause)

18 Q Let's move ahead in time to February of 2009.

19 Around this time did you learn that was

20 going to be traveling to D.C. on behalf of Allegiant who was

21 at this point employer?

22 A I don't know when I learned.

23

24 Q
Before that meeting occurred, do you recall any

25
of the communications you might have received from
26
-SSCE0000774
1

2 A I recall a phone call that said, 'Would you see

3 these folks?' And I said yes.

4
Q
It was a phone call as opposed to an e-mail?

5 A I don't remember how I learned it. What I did

6 was is, I have a real open door policy in my office, and I'd

7 see almost anybody that has business before the U.S.

8 Congress.

9 Q
Why don't you go ahead, for the committee, and

10 just describe what you recall about that meeting. If you

11 could start, who attended?

12 A Two people from Allegiant; I don't remember their

13 names, and They were just telling me about their

14 business; it was strictly an introductory call, and what

15
Allegiant was and what they were trying to do. And I don't

16 remember the details.

17

18 A
19
20

21

Well, we might be able to refresh your

22 recollection about that.

23

24 THE WITNESS: Okay, I don't remember.

25
: We'll get there in a second, and I just
26
40
Mill-SSCE0000775
1 want to test what you remember at this point.

2 THE WITNESS: Okay.

3 BY

4 Q
Again, they talked about perhaps Allegiant doing
business in the state? I guess my question is, what do you

6 recall in terms of specific topics of that conversation?

7 A Not much. Again, if I recall it was a fairly

8 specific, a nonspecific, general introduction to the

9 principals; they're here, we're a grown business, we're in

10 the airline business. We want to succeed.

11 Q
Did speak up during the meeting?

12 A No, just formal introductions.

13
Q
So you attend the meeting, the meeting occurs,

14 informal introductions, they talk a little bit. What

15 happened at the conclusion of the meeting?

16 A I'm not sure I recall.

17 Q
Do you recall if stayed back for a second?

18 A II may have. II may have, may very well have.

19 Q
Do you remember if he mentioned to you -- well,

20 first of all, thanking you for help?

21 A I don't recall whatillsaid. I gave 1111a hug as

22 Illwent out the door.

23 Q
Did mention, to your recollection, anything

24 about how things were going at Allegiant?

25 A No. No, not that I recall.

26
41
SSCE0000776
1
Q
Did III mention at this time any troubles was

2 having with Senator Ensign?

A No.

4 Q Did Illmention, at any point during the meeting

5 or towards the end that =talk about -- you know, the

6 other meetings Illmight be having on Capitol Hill at that

7 time?

A Not that I can recall.

During the course of the meeting with the

10 Allegiant folks, did the topic of a meeting with Secretary

11 LaHood come up?

12 A It could have. Again, I have some, I have no

13 idea what.

14
Q
Did you come to know at some point that

15 would be meeting with Secretary LaHood? Do you have any

16 knowledge about that?

17 A No, that's news to me.

18
Q
Do you have any knowledge about how that meeting

19 got set up?

20 A No.

21
Q
Did mention any assistance that

22 Senator Ensign's office had provided to in setting up

23 these meetings on the Hill?

24 A No. No, I don't have any knowledge of that.

25
Q
You never came to know of any way about how --?
26
42
1 A I didn't -- news to me that Illwas meeting with

2 Secretary LaHood, today.

3 Q
Why don't we try to nail down some dates here.

4 This is 1116. ,

5 (Deposition ExhibitIIII-6 was marked for

6 identification.)

7
I want to showyou one other document,

8 too.

9 Here's III-7, which will help map that point as well.

10 (Deposition ExhibitillF7 was marked for

11 identification.)

12 BY

13 Q
Okay?

14 A Yes.

15 Q
Have you had a chance to reviewthese?

16 A Uh-huh (affirmative).

17 Q
Okay. I'll ask about the Outlook e-mail here.

18 Looks like it's fromIt's concerning a

19 meeting with CEO of Allegiant, in the D.C. office.

20 This is the meeting we've been referring to here?

21
Meeting with Allegiant. This is the meeting, to the best of

22 your recollection?

23 A I guess so.

24 Q
And this is dated March 11, 2009.

25 A Uh-huh.
26
43
IIIIMSSCE0000778
1
Q
It does say on the Outlook page here, Document

2 1081: Required attendees,

3 Does this help refresh your recollection as to whether

4 or not might have attended the meeting?

5 A must have.

6 Q
Must have.

7 A Yes.

8 Q
Document .11 8.

9
(Deposition Exhibit III-8 was marked for

10 identification.)

11 : This is from you know.

12 THE WITNESS: I'm getting that.

13 Okay.

14
I'm going to ask about that.

15
at the request of the

16 Department of Justice.

17
: Well, I'm going to ask that question; you

18
can put that answer on the record, then.

19 : Yes.

20 (Pause)

21 BY

22 Q
Have you had a chance to review this document?

23 A Uh-huh (affirmative).

24 Q
I don't believe you're the author of this

25
document. Do you know who the author of this document is?
26
44
MESSCE0000779
1 A I don't.

2 : Counsel, can you please explain for the

3 record who authored this document and why it was created?

During the Department of Justice search, we

5 came up with the e-mail I just showed you with

6 name on it.
7

THE WITNESS: Yes,

9
10
11
12
13

14 THE WITNESS: in trouble, because they're supposed

15 to write a record after every.meeting.

16 : There was no record.

17 : If you could identify the exhibit on the

18 record.
19

20 : Thank you,

21 BY

22
Q
does this help refresh your

23 recollection about the topics of conversations?

24 A Yes.

25
Q
Do you think this is accurate, to the best of
26
45
MSSCE0000780
1 your recollection?

2 A Probably. Probably.

3 Q
Just so the record is clear here, this document

4 in the body refers to FAA authorization; talks about labor

5 regulations. It says, and I'll quote from this: They

6 and I think by 'they' they refer to the Allegiant

7 representatives -- did not ask for any specific action from

8 such as writing a letter or supporting a certain

9 policy amendment, et cetera.

10

11 So --?

12 A There's not an airline that comes in my office

13 that doesn't have something to say about the FAA.

14 Q
Sure.

15
At this meeting, did Allegiant's air service to Cuba

16 come up, by any chance?

17 A No.

18 Q
No.

19
: May I say something about that? There's no

20
recollection in the office that that topic was an Allegiant

21 topic.

22 : Okay.

23 (Deposition Exhibit
U-9
was marked for

24 identification.)

25 BY
26
46
IIII.-SSCE0000781
47
1

This is Document 1111.9. Take a quick look at it.

2 A Okay. (Pause).

3 Q
Have you had an opportunity to review this

4 document?
A Yes.

6 Q
Do you recall this document?

7 A No.

8 Q
So the record reflects that it's an e-mail

9 communication on or about March 20th, 2009, from

10 In text,

11
thanking you for the meeting with the Allegiant Air folks.

12
Says, "it was great to see you, appreciate your comments and

13 recommendations."

14
Does this help prompt any other recollections --?

15 A No. That's just a courtesy 'thank you' for

16 seeing them.

17 Q
Okay. Anything else about this document that

18 refreshes your recollection?

19 A Uh-uh (negative).

20
(Deposition Exhibit NI-10 was marked for

21 identification.)

22 BY

23 Q
111[10 is the next document. I'll give you a

24 second to look at it.

25 (Pause)
26
1 Does this help?

2 A I don't have any recall.

3 Q
You don't have any recall?

A No.

5 Q
The Customs & Border Protection, did that come up

6 in the March 11 meeting, to your recollection?

7 A No, not that I recall.

8
Q
So you think this might have been introduced

9 later?

10 A Yes. I don't recall.

11 Q
And again, it's your testimony that service to

12 Cuba didn't come up at that meeting.

13 A No, no.

14 : Just for the record, based on this e-mail, I

15 tried to do staff research on who staffed any subsequent

16 meetings. There's no history of any subsequent meeting

17 taking place.

18 : There's a reference in the e-mail to

19

20 THE WITNESS:
21

22 THE WITNESS: Yes.

23
24

25 BY
26
48
SSCE0000783
1

Did 11111
2 just for the record.
3 A
-- if we could get the spelling
I think.

4 Q
Did ever tell you that'll hadreceived

5 a communication from

6 A On, no.

7 Q
Okay. Show you another document here.

8 Before I show the document, the meeting on the 11th of

9 March, 2009 occurs -- when's the next time you recall

10 hearing from

11 Could you restate that?

12 The premise is that there's the meeting

13 with the Allegiant folks on March 11, 2009.

14
when was the next time you
,

15 recall hearing from

16 THE WITNESS: Well, my recollection is now whenever

17 those e-mails were, the thank you e-mail and the other one;

18

that's the only thing I --.

19 : Okay. Show you another document.

20 (Deposition Exhibit 11-11 was marked for

21 identification.)

22 III-11 is the next document, the brief one.

23 BY

24 Q
Do you have any recollection of why you sent

25 this?
26
=III-SSCE0000784
1 A No.

2 Q
It's possible had tried to reach out

3 to you around this time?

4 A Again, I don't have any recollection. As a

5 matter of fact, don't even have any recollection that I

6 called

7 Q
Do you have a recollection of hearing from

8 Senator Ensign around this time, asking you to reach out to

9

10 A No.

11 Q
It says, the e-mail says: Remind me to call
12
13

14 A I never correct my e-mails. Just get them out of

15 the way.

16 Q
Okay. All right, and the document's dated May

17 13, 2009.

18 A Yes.

19 Q
So this is after you've met the Allegiant folks.

20 A Yes. I have no idea.

21 Q
No idea?

22 A No. It could have been in relation to

23
24

25 Q
Isee.
26
50
-SSCE0000785
1 A And it could have been that, because that happens

2 about that time of year.

3 Q
Incidentally, is that how you came to known.
4
5

6 A Well, I think I met afterlicame to work --

7

8 and I can't tell you the year it was.

9 Q
Okay.

10 A And I assume it's after came to work for John.

11
Q
Around the time of the e-mail I've just showed

12 you, which is May 13, 2009, do you have any recollection of

13 whether was going to be in town soon? Did you ever

14 come to learn that came in for a meeting with the

15 Transportation committee staff, or members around this time?

16 A No.

17
Q
You never recall learning that from Senator

18 Ensign?

19 A No.
20
21
22
23

24 A Okay.

25
Q
If you have a
26
51
II-SSCE0000786
1 different way of describing it, we'd be interested in

2 knowing how you would describe it.

3 A
4
5
6
7
8

9 A No.

10 Q
What happened.

11 A
12
13
14
15
16
17

18 A I called John Ensign. I said, "Do you want me to

19 listen to him?" He said "You can listen, but I have no

20 interest.".
21
22

23 Q
So what did say?

24 A
25
26
52
-SSCE0000787
1
2

3 A
4

5 Q
Who is lawyer?

6 A I don't even remember his name.

7 Q
We can help you with that in a minute.

8 A Yes.
9

10 What did you say to -

11 A
12
13

14 Q
And what happened next?

15 A
16
17
18
19
20

21 A
22
23

24 A No, not that I recall.

25 Q
Not that you recall.
26
53
-SSCE0000788
1
A You know, I don't remember what it was. I had

3 one other number come up and I passed it on to John. John

4 said no.
Your recollection, he said no right then and

6 there on the phone?

7 A Yes.

8
Q
Were you talking to him on the phone, or were

9 these face-to-face meetings?

10 A No, no; phone.

11 Q
Phone.

12 A
13
14
15
16
17

18

A No, never had that discussion.

19
20

21 A I have no idea. All of what I told you is

22 repeat. John said "I'll listen, but not likely.".

23
24

25 A No.
26
IIMIE-SSCE0000789
1

2 A No.
3

4 because I was worried about John.

5 Q
I see.

6 A And his family.

7 Q
Since you became aware of the affair, have you

8 had any conversations

9 A No.
10
11

12 A Not that I recall.

13

14 A No.

15
Q
Okay. I think what we want to do now is, we want

16 to place this in context, and we have something to help with

17 assisting your memory with the dates. We've got some phone

18 records we're going to show.

19 Do you want to take a break, a quick break?

20 Okay.

21 (Recess.)

22 (Deposition Exhibit 11[12 was marked for

23 identification.)

24 BY

25
Q
I've got another document to show you; I'll give
26
55
SSCE0000790
1 you a second to look at it.

2 A Okay.

3
Q
And I'll represent to you that these are Senator

4 Ensign's words.

5 To the best of our understanding.

6 To the best of our understanding, that's

7 right.

8 Well, I'll put it this way: This is a document produced

9 to the committee by Senator Ensign.

10 (Pause)

11 THE WITNESS: Okay.

12 BY

13 Q
You've had a chance to review it now.
14
15
16
17
18

19 A
20

21 A
22
23
24
25
26
56
IIME-SSCE0000791
1
2
Does that again help refresh your recollection as to the

4 kind of the way the discussion went forward?

5 A
6
7

8
Q
I see.

9 A
10
11
12
13
14

15
Q
Right.

16 A And so I did. And John said listen, but not

17 likely.
18
19

20 A I don't think that is accurate; I think it was

21 1.3, if I recall.
22
23
24
25
26
57
.111111-SSCE0000792
Yes. Yes.

1 A Yes.

2
Q
Could you describe the conversation?

3 A
4
5
6
7
8
9
10
11
12

13 A I don't have any recollection of any discussions

14 about
15

16 A Yes, it was part of --

17 Q
Was part of it.

18 A
19

20 A
21

22 A
23

24 BY

25 Q
in your conversation within. when'.
26
58
SSCE0000793
1
called you, what else did II say, other than this is a big

2 issue, that we've mentioned.

3 A That's the only thing we talked about. III asked

4 if I would contact John. And I said if John wants me to,

I'll do this. But I won't do it unless John wants me to.
6
8

9 A Not that I can recall.

10 BY

11 Q
were you surprised to hear from

12 about this matter at this point in time?

13 A I wouldn't -- oh, I don't know how I'd

14
characterize it. Again, I was hoping they could solve their

15 problems, so everybody moved on. We'd solved the big

16
problem, which was their families were staying together. So

17
I was amenable to doing it, but I didn't feel like I was in

18 a position to negotiate it.

19 BY

20 Q
At the time of these communications, and you

21
relayed the substance back to Senator Ensign, did he, in

22 words or substance kind of ask why asking for

23 money now, after already helped

24 A No, he didn't say anything to me at all. All he

25
said is, "that's unacceptable, I'm not doing it."
26
59
.11.-SSCE0000794
1

He at no time ever mentioned that he'd already

2 provided, caused a payment to be made to the

3 A No. My first awareness of that was when it was

4 revealed in the press.

5 Q
And that was after the announcement of the

6 affair, to your recollection?

7 A Yes.

8 Q
Okay.
9
10

11 A
12

13 A
14
15

16 A
17
18
19
20

21 A That's one way of solving this problem, sure. I

22 mean, he did move Into Washington and

1111
did get III to

23 leave another job, to come to work for So I think he

24 caused legitimate damage.

25 Q
And he was owed restitution in some form or
26
60
1111=-SSCE0000795
1 another?

2 A Well, he was owed reconciliation, whatever that

3 came about, how you can get there.

4 Q
I have some phone records. I think in the
interests of time it won't serve us well to walk you through

6 all the particulars. I will represent to the record that it

7 looks to us like

called you on or about May

8 21st, 2009.

9 A Could be.

10 Q
Looks like there might have been a text message

11
at some point during that day. Do you recall receiving a

12 message?

13 A I don't recall it; there could have been.

14 Q
Okay. But the time frame sounds -- you said it

15 was warm.

16 A Yes, it was warm and I was mowing grass, and that

17 would be about the right time.

18
19

20 A Yes.

21 Q
And you've confirmed that that's what it was.

22 A Yes.
23
24
25
26
61
II-SSCE0000796
1 A I don't think so. I think it was all the same

2 day.

3
Q
It's all the same day?
A Yes. My recollection was this all occurred in

5 one day.

6
Q
Okay.
7

8 A

9
Q
And the first call was: "My name is" -- what do

10 you recall about what Illsaid on the first call.

11 A
12
13

14
Q
So the phone call ends --?
15
16

17
Q
Okay, and then.' comes back with the second

18 number, which --?

19 A I don't know when that was; sometime in those

20 conversations.

21
Q
Sure. So you finished those communications, and

22 then you report back --?

23 A I immediately called John, and John said "No, not

24 doing that.".

25 Q
Did you relay that information back that same
26
62
-SSCE0000797
1 day, or do you think --?

2 A

3 Q
Yes.

4 A I don't remember when I relayed it back. I'm not

5 even sure I relayed it back. I may have.

6 Q
Our records seem to indicate that a number of

7 days passed, and that there are phone records that indicate

8 communications on May 26th. So it would be four days later.

9 A What day of the week is that?

10 Q
Again, we're in 2009 now. So this would have

11 been after Presidents Day -- no, not Presidents Day;

12 Memorial Day weekend. ?

13 A Yes.

14 Q
So the 26th is a Tuesday. So you're at home on

15
the 22nd, which is a Friday, and you receive these calls.

16 A Again, I can't tell you the specific dates.

17 Q
Okay.

18 A My recollection is it all happened -- you know,

19
of what I remember is it all happened on that one afternoon.

20
That may not be the case, but that's how I recall it.

21 Q
It looks like there are some more communications

22
again, after members return from the recess.
23
24

25 A No. I don't think I ever heard from the lawyer

26
11111111-SSCE0000798
1 again after that one day.

2 QIllididn't leave you a message or anything? To

3 inquire about status?

4 . A Not that I recall.

Do you remember talking to about where

6 things stood in terms of the --?

7 A No, I don't. I don't recall whether I actually

8 called and John said no.

9
10
11

12 A
13

14

So your testimony is you don't recall passing

15 that information on to

16 A No.

17 Q
You don't recall it. Is it possible that you

18 did?

19

A Well, it's possible, but I don't recall calling

20

21
Q
Okay.

22 A I wasn't a happy camper, being in the middle

23 here.

24

BY MEI

25 Q
just to confirm, is your personal cell
26
64
-SSCE0000799
1 phone number

2 A It is.

3
Q
Thank you.

4 (Pause)

5 (Deposition Exhibitillt13 was marked for

6 identification.)

7 BY

8
Q
This is III-13, a newspaper. It's an e-mail

9 forwarding a newspaper article. Take a second to review it,

10 please.

11 A (Pause) .

12
Q
Senator, do you recall this e-mail?

13 A No.

14
Q
Do you recall the substance of the article?

15 A Well, I recall the scandal, if that's what you

16 mean, yes.
17
18
19
20
21
22
23

Does this refresh your recollection of a conversation is

24

about
25

A I don't think that's accurate. I don't know --

26
65
MIIISSCE0000800
1 when was this published?

2
Q
This would have been after the announcement of

3 the affair.

4 A I think that's

take on it, but I don't

5 think that's an accurate depiction of the facts.

Well,

7 That was something you'd discussed in terms of what

8 was seeking during the May discussion, wasn't it?

A No. The difference was, I was passing what

10 wanted. I never had that discussion with John, not once.

11 Prior to that I had never gotten into details with John on

12 any of this other than this one time when he asked me to

13 transfer the information from

on what he wanted.

14
Q
So either in May or anytime prior to the May of

15 2009 part of that, you never urged Senator Ensign to make a

16 payment to

17 A No. Not at all. Matter of fact, I advised him

18 against it.
19
20

21 A No. I did not.

22 BY

23 Q
you just said that you advised Senator

24 Ensign against making a payment to

When was that?

25 A Oh, that was early -- way before we had these

26
.111111-SSCE0000801
66
1 conversations with

2
Q
And do you recall if that was back in February or

3 early in 2008?

4 A That was sometime after the affair had become

known to the group.

6
Q
After February 2008 but before your conversations

7 with in 2009?

8 A Yes.

9 Q
I'm going to try and see if we can place that.

10 Was it soon after you learned about the affair? If you can

11 recall.

12 A I don't recall exactly;

13
14

15 Q
Do you recall anything else coming up in that

16 conversation where you told Senator Ensign --?

17 A I don't actually have a recollection of an exact

18 conversation. I know that I just advised John, "If you're

19 going to do anything like this, go get a lawyer and let

20 lawyers settle it.".

21 BY

22
Q
can you recall how that topic came up

23 with Senator Ensign?

24 A No, I don't.

25 Q
It sounds as if you were responding to some
26
67
-SSCE0000802
1 suggestion of a course of action.

A Yes; I don't recall.

3 Q
Do you recall what his response was?

4 A No, I don't. John was a mess then.

(Deposition Exhibit N-14 was marked for

6 identification.)

7 BY

8
Q
I have another article to show you.

9 We're not going to ask tons of questions about this.

10 There are attachments, but there is something I would

11 ask you, and I'll draw your attention to it, it's at the

12 bottom of page 8. So it will be page 8 of 9, towards the

13 bottom of the page, if you could just take a second to

14 review it.

15 A (Pause).

16 Page 8?

17
Q
Page 8 of 9, going on to the final page.

18 Yes, you've got it.

19 A Okay.

20 Q
Let me start with this question: Do you recall

21 being interviewed for this article?

22 A I do.

23 Q
Does it accurately describe, at the bottom of

24 page 9 -- page 8 going on to page 9, what transpired, to

25 your recollection?
26
68
1 A Well, first of all, this isn't an accurate

2 recollection, because I didn't offer to talk to Mr. Ensign;

3 I was asked to talk to Mr. Ensign. And I only talked to Mr.

4 Ensign after John said it was okay. So I think that's

5 number one. I think the 8.5 is right. And I think the rest

6 of it is accurate.

7
Q
Okay. So again this talks about restitution to

8
You recall

9 that being part of what was discussed at the time?

10 A

11
Q
And this is the first time relocation comes up.

12 These would be the May discussions.

13 A Yes.

14 Q
Yes.

15 (Deposition Exhibit 11[15 was marked for

16 identification.)

17 BY

18
Q
What I'm going to show you next is 11[15, and

19
I'll represent to you that it's excerpts from a transcript

20 of the TV show "This Week" from November of 2009. It's just

21 a few pages, but I think it would be worthwhile if you could

22 just take a quick look through all of it, please. It's just

23 four pages.

24 A (Pause) The thing that's not in here is what

25 said on the video, which you need.

26
69
111111.1-SSCE0000804
You recall being interviewed by Mr.
Stephanopoulos about this matter --?
1
2
3 A
4
5
6
7
Well, we've got a transcript of that, too.

8 A Yes, sure.

9 Q
-- and they showed a preview of his "Nightline"

10 excerpt?

11 A Yes.
12
13
14
15
16
17
18
19
20
21
22
23

24 dollars from --?

25 A No. No. What that is is

26
-SSCE0000805
70
Okay. Bottom of what's listed as page 13 here,
they're quoting
Those are words.
A That never occurred.
That never occurred?
A No.
You never urged to seek millions of
1

2
Q
We've touched on this point throughout your

3 testimony here today, but I do want to focus on it

4 particularly.
5
6

7 you were unaware that Senator Ensign had

8 previously caused a payment to be made to the is

9 that correct?

10 A I was unaware.

11
Q
And it's your testimony today that you became

12 aware of that only after it became reported in the press?

13 A That's right.

14
Q
What do you know about the source of that payment

15 to the

16 A I don't know anything other than what I've read

17 in the press.

18
Q
What you've read in the press. You've never

19 discussed the matter with Senator Ensign at any time?

20 A No.
21

22 A No.

23 Q
Discussed it with anybody else other than your

24 legal counsel here today?

25 A I discussed it with
26
71
Mill-SSCE0000806
1
2
3
4
5
6
Q
A
A
That he had made the payment.
Uh-huh (affirmative).
7 And I'm sorry, Which?
8 A
9
10 A Uh-huh (affirmative).
11 And did he say anything about the source
12 of the payment, or --?
13 A No.
14 Q
No, okay.
15 A No.
16
Q
Did he mention that he had spoken to Senator
17 Ensign about the payment?
18 A No.
19 Q
Do you recollect any conversations where the
20 payment was referred to as a severance or the equivalent of
21 severance?
22 A No.
23
Q
Never discussed that with Senator Ensign?
24 A No.
25
26
72
IMII-SSCE0000807
73
1
2 A No.
3

No, not at all. Okay.

4
5

6 A No. You know, I just was shocked when I saw the

7 news.

8 Q
Why were you shocked?

9 A Because it's John's obligation,

10 Q
Were you concerned that you hadn't known about

11 the payment until after it was publicly released?

12 A
13
14

15
Q
When did you learn that Senator Ensign was going

16 to publicly announce the affair?

17 A I don't know.
18

19 Q
The article I showed you from the New York Times,

20 the substance of it really deals more with alleged

21 post-employment violations.

22 When did you first have any knowledge of such

23 allegations regarding

24 A I don't know, it was sometimes after I had met

25 with Allegiant, because I remember recalling myself I never

26
..11-SSCE0000808
1 thought it about being a violation.

So that thought might have occurred after the

article, correct?

Oh, yes. It didn't until then.

Right.

6 A

You know, I don't think it's my obligation to say

7 whether people are within the law, if they're making a point

8 with us. I would have thought that it's kind of stupid.

9 Q
Did you ever discuss those allegations with

10 Senator Ensign?

11 A No.

12 Q
Other than your counsel, have you ever discussed

13 those allegations with anybody?

14 A Oh, I think I may have had a conversation with my

15 staff about how stupid it was for to come in before

16 what waiver time is.

17
Q
Illione year cooling off period?

18 A Yes.

19 Q
Anything else you recall?

20 A No.

21 Q
Did you ever discuss the allegations with
22

23 A No.

24
Q
When's the last time you talked to

25 A Oh; probably -- the last conversation I had with

26
74
1
2
3
4
--
Mr.
at the time of the - when I was sending information to
Ensign, Senator Ensign.
Q
So May of 2009.
A Yes.
5 Q
Prior to the public announcement?
6 ' A Yes.
7 Q
Any conversations with after the public
8 announcement, to your recollection?
9 A No.
10 : We have one e-mail at the end of May on the
11 Cuba issue.
12 : Right.
13 Right.
14 : Thank you.
15 I'm ready to wrap, if you guys are. Would you like a
16 minute to talk?
17 : Sure.
18 : Can we just take a very brief recess?
19 (Recess.)
20 BY
21
Q
Thank you very much,
22 A You're welcome.
23 Q
-- we're just about ready to wrap up here --
24 A Okay.
25 Q
-- but we do have a couple of questions. And
26
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=SSCE000081 0
I see. Okay.
A Sure. If he wants to work out a deal where he's

1 there are some things we're trying to make sure we

2 understand and can perhaps reconcile.

A Okay.

4 Q
But it was your testimony not too long ago, you

5 said "you were disappointed that Senator Ensign had caused

6 this payment to be made." Is that accurate?

A Yes.

8 Q
And that you had advised Senator Ensign against

9 making a payment.

10 A Yes.

11 Q
But it also seems to be my recollection that you

12 have stated today that you thought was perhaps owed

13 some form of restitution, or --?

14 A
15
16
17
18
19

20
caused harm, then he can -- I think in a court of law you

21
can actually have a contract that does that. He should do

22 it.

23
: Alienation of affection.

24
: Okay. I just wanted to clarify that,

25
because I'm not sure that the record was clear on that
26
SSCE0000811
1 point.

2 do you have something you'd like to follow up with?

3 BY

4 QME I just wanted to make sure that we kind

5 of close the loop on anything that, and give you a chance to

6 clarify.
7
8
9

10 A Well, you know, the way I operate my life is, you

11 reconcile with people, and you do it completely and openly

12 and honestly. And that wasn't open, that wasn't honest, and

13 because it wasn't John doing it. And so he wasn't

14 reconciling. He was not doing what he was taught to do.

15
16
17

18 A Yes.

19 Q
So if he --

20 A And he wasn't transparent with the people that

21 loved him.

22 Q
Okay.

23 A He lied to us.

24 Q
Right. I'm sorry, for me to be clear, I was only

25 referring to the disappointment you felt when you heard

26
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-SSCE0000812
1 about the $96,000 payment in the press --

2 A Yes.
3

4 A
5
6
7
8
9
10
11
12

13 it.
14

15 advised

16 A
17

18 A And all I

19 to be a intermediary to send the information

20 John that, I told Doug that, and I told that

21 not given the right to negotiate or anything

22 what you want, I'll communicate it, and that

23

24 May of '09, the back and forth. It's clear

25 you're talking about early on. You had some

26
something, you do it completely and thoroughly, and you do
A No, that was at a different time.
Absolutely.
A What I had told him is, if you're going to do
-- and why that disappointed you. And I just --
So again to clarify, when you told them, when you
them against --
This was months before ever called me.
Correct. Absolutely.
was doing with and John was trying
. And I told
lawyer: I'm
. You tell me
's it.
Absolutely, and I'm not trying to go back to the
to me that
conversation;
78
SSCE000081 3
79
1

you don't recall the rest of the conversation in which you

2 said to Senator Ensign,
3
4 A
5
6
7
8

9
Q
Okay, so the advice against the payment early on

10 was about it being a single act when a larger context was

11 necessary?

12 A Well, you're describing -- I'm not a lawyer, I

13 don't think in those terms. What I'm thinking of is how do

14 you reconcile? How do you make things right? And you do it

15 the right way.

16 BY

17
Q
Did the Senator ask you for your opinion about

18 making any sort of payment at that time?

19 A No.

20 BY

21 Q
the last bit of testimony that I just

22 wanted to ask you to expand on, you testified I believe that

23 you developed a relationship with over these

24 confrontations or because, or at the time of. Could you

25 give us a little more detail about how you developed that

26
SSCE0000814
1 relationship?
2 A
3
4
5
6
7 Can you tell us a little bit how that happened or
8 how many -- did you have regular meetings with or --?
9 A
10
11
12
13
Q
Did you provide any additional counseling to
14 other than what's been described here today?
15 A Not that I recall.
16 Q
Thank you.
17 BY
18
Q
is there anything that we didn't ask you
19 about today that we thought we'd bring up -
20 A You sound like a reporter.
21 (Laughter)
22
Q
Well, we try to be comprehensive.
23 A No. Humans are a terrible species, aren't they?
24
Q
Lawyers are even worse.
25 A Well, they're human, too.
26
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-SSCE0000815
1

2
Q
Sir, is there --

3 A
4
5

6 Q
Very good. Sir, is there anything else you'd

7 like the committee to know about this matter?

8 A Just an unfortunate playout in life. Sorry it

9 happened to everybody.

10 Q
these are all the questions we have for

11
you today. We are still receiving documents and information

12
in this matter. Should a need arise to ask you additional

13 questions -- ?

14 A I'll come back.

15 Q
Thank you, sir. And again, on behalf of the

16
Committee, thank you very much for appearing here today.

17 A You're welcome. Glad to do it. Well, not glad

18 to do it; I'm glad to get it over with.

19 Q
Very good.
20

21
- -

22
(Whereupon, at 4:54 p.m., the deposition concluded.)

23
- - -
24
25
26
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I-SSCE000081 6
1 I HEREBY CERTIFY that I have read this transcript of my

2 deposition and that this transcript accurately states the

3 testimony given by me, with the changes or corrections, if

4 any, as noted.
6
7
8
9
10

11

Subscribed and sworn to before me this day of

12 20 .
13
14
15
16
17 Notary Public
18
19 My commission expires:
20
21
22
23
24
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