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UNITED STATES SENATE
Select Committee on Ethics
Washington, D.C.
IN RE: ENSIGN INQUIRY
CONFIDENTIAL DEPOSITION OF
1

Tuesday, June 15, 2010
Hart Senate Office Building
Suite 220
REPORTED BY:


SCE0003438
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1 Deposition of called for
2 examination pursuant to notice of deposition, on
3 Tuesday, June 15, 2010, in Washington, DC, at the
Senate Select Committee on Ethics, Hart Senate
Office Building, Suite 220, at 10:30 a.m., before
a Notary Public within and for the
District of Columbia, when were present on behalf of
the respective parties:
United States Senate Select
Committee on Ethics
220 Hart Senate Office Building
Washington, DC 20510
On behalf of Senate Ethics Committee
-- continued --
S0E0003439
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1 APPEARANCES (Continued):
2
United States Senate Select
Committee on Ethics
220 Hart Senate Office Building
Washington, DC 20510
On behalf of Senate Ethics Committee
3
25
SCE0003440
cautions and information that we read to all
witnesses. Okay?
he Senate Select Committee on
Ethics has summoned you here today for this
deposition as a witness in connection with the
Committee's preliminary inquiry concerning Senator
John Ensign. I'm a counsel on the
Committee Staff. I'm joined today by the Chief
Counsel
counsel

s the
Deputy Staff Director for the Committee.
Also we have ill be the court
reporter today and will be swearing you in and
taking down the testimony. We, the Counsel, have

1 PROCEEDINGS

2 hank you for coming

3 today. We're going to start off with a set of


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18 been authorized by the Chairman and the Vice

19 Chairman of the Committee to conduct this

20 questioning.

21 The questions and answers will be recorded

22 by the court reporter. Because this is a deposition

23 before a legislative branch agency, your statements

24 today are subject to the False Statement Statute,

25 which is Section 1001 of Title XVIII of the U.S.


26
4
SCE0003441
was called as a witness and, having first been duly
sworn, was examined and testified as follows:
EXAMINATION

1 Code.

2 Additionally, because this is a sworn

3 deposition, your statements are subject to penalty

4 of perjury under Section 7B of the Supplementary

5 Procedural Rules of the Senate Select Committee on

6 Ethics and Section 1621 of Title XVIII of the U.S.

7 Code as well as the Obstruction of Congress Statute,

8 Section 1505 of Title XVIII.

9 Thus, you may not make any intentionally

10

false statements or knowingly mislead the committee

11

through your answers today.

12

Do you understand all that?


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14

=Yes.
At this point, I'd ask that
you be sworn in. 15

16 Whereupon,
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20

21 BY

22

Do you understand that your statements

23

today are subject to statutes and committee rules

24

concerning false statements, perjury and obstruction

25

of Congress?
26
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SCE0003442
1 A Yes.

2
Q
Thank you.

3 The record will reflect that you are not

4 here represented by counsel here today. We wish to

5 make perfectly clear you're entitled to counsel and

6 if at any time you feel that you need to take a

7 break, if you need to make a phone call or anything

8 like that, let us know and we'll afford you whatever

9 opportunities that you need. Okay?

10 A Thank you.

11
Q
You've been provided there with a copy of

12 our procedural rules. As a general matter,

13 Supplementary Procedural Rule 8 dictates strict

14 confidentiality on our part regarding the fact of

15 this deposition and all statements today. These

16 rules do not govern your own discussions of this

17 interview.

18 However, it is the Committee's expectation

19 that no witness will tailor or coordinate his or her

20 testimony based on an earlier deposition. Thus, we

21 request that you refrain from discussing our

22 questions and your answers with anyone other than

23 any counsel should you choose to consult with them.

24 Pursuant to Supplementary Procedural Rule

25 6, you are entitled to the opportunity to inspect


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SCE0003443
17 going?
18 A No.
19 (Exhibit
20 BY
dentified.)
7

1 the transcript of your deposition in the Committee's

2 offices here and request that any transcription

3 errors be corrected. Any errors of fact must be

4 brought to the Committee's attention through the

5 submission of a sworn statement. If you wish to

inspect the transcript, let us know in the next week

or two and we'll be happy to arrange a time.

If you need any time during this

deposition to take a break, just let us know. Okay?

10

I will ask throughout the questioning when you

11

answer, we do need verbal answers instead of nods.

12

A Sure.

13

So I'll just ask now, do you understand

14

all the matters I just reviewed with you?

15

A Yes.

16

Do you have any questions before we get


21
22 and I'm going to show this to you and ask if
23 you recognize this.
24 A Yes, I do
25
Q
What do you recognize that as?
26
I'm going to start off marking Exhibit
SCE0003444
SCE0003445
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A
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A I believe this is the summons that I
received to appear today
Q Thank you.
Just for the record, can you state and
spell your name.
4
We'll start with some background
questions, some easy ones. Why don't you give us
your educational background.
A I was hired by Senator Ensign's office.
8
A
A
Generally, what type of work did you do?
A
So when did you start in the Senator's
office?
A I believe it was I believe
that's right.
What was your position then?
A
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SCE0003446
A Yes. I was assigned to both
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Did you work out of the Nevada office or
the Washington office?
A Washington office.
What were those additional
responsibilities?
10
ER
SCE0003447
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1 A Yes.

2
Q

3 A

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Q
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9 A

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Q

11 A
12

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Q

14 A
What was that?
Describe for us what that is.
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11111 SCE0003448
SCE0003449
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A
Did you continue also your previous work
That's right.
A
A
A

Yes.
Who else was in this Nevada shop?
Q
At that time, what was
title?
Q
A
SCE0003450
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1 A
I'm not exactly 2
3 clear.

Can you describe throughout this time what

5 your relationship with Senator Ensign was.

A I don't know. I worked for him. I didn't

have a close personal relationship or anything like

that. I was just an employee.

How often did you meet or work with him?

10 A I rarely talked to Senator Ensign

11 personally. We met maybe once -- three times a week

12 in legislative staff meetings that I would attend.

13 Q
Are those also called leg. time?

14 A Yeah.

15
Q
Have you ever been to any of Senator

16 Ensign's residences before?

17 A
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24

A No.
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SCE0003451
A
A
A
I believe so, yes.
A
A
Around when was that?
I honestly don't remember.
A
A Yes.
Was anybody else with the two of you?
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SCE0003452
A
Could the other have been either
A
A
A Not that I recall, no.
Did

ame come up?


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Do you recall what company they were from?
A

Huh-uh.
16
A

Those names don't ring a bell to me.


Did you ever play golf or tennis with
Senator Ensign?
A No.
SCE0003453
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1
Q
This would have been sometime in or about
2 October or November of '08?
3 A That could have been. It wasn't hot in
4 Las Vegas. I know that. It wasn't summertime. I'm
sorry. I don't know the date.
BY
affair?
A Yes.
Prior to the Senator's announcement of the
I have a question.
Thank you.
SCE0003454
Thank you.
My relationship to I have a
Do you continue to talk with today?
That's the best way I can describe it, the way that
office is set up.
BY

5 Q
Can you describe for us your relationship

6 with

7 A Sure.
8
9

10 A
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12

13 A
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17 A

18 4
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20 A It was probably several months.


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Thank you.
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24 A No.
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Have you talked about this matter with
MSCE0003455
was closest to If you had to say who
SCE0003456
in the office, who would that have been?
A Probably
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A
BY
A
BY
A
Were there people in the office that
was closer to socially?
I wouldn't say that. I don't think so,
no.
1
2

3 A
4

5 A
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10

11 A
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13

14 A Yes.

15 Q
And anyone else?

16 A No.

17 Q
Who were your closest friends or people

18 you were closest to in the office?

19 A I wouldn't say I necessarily had all close

20 friends. I think I was friendly with everybody. We

21 played softball together.

22 Q
Who do you remain friendly with today?

23 A I don't know. I guess I remain friendly

24 with
d those guys.

25 Q Was there any kind of core group you would


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3SCE0003457
SCE0003458
A I don't really know.
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socialize with while you worked in the office?
A Pretty much those guys.
Can you describe your relationship at the
time you were in the office or to date with
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I have no idea.

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Did you ever work on any projects directly
for
A No.
Did you ever socialize with
A No.
Did you consider a friend?
A No.
A
Do you believe that you learned at the
same time that the office as a whole learned?
A Yeah, I believe so.
A
A No.
That's all I knew about
SCE0003459
1 what was doing.

2
Q
Who was making the announcement?

3 A Senator Ensign was in the room, and I

4 believe he made the announcement.


5
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7

8 A No.
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12 A No.

13 Q
Did you know

14 A I knew of

15 no.

16 Q
Did you know of November Inc.?

17 A Yes.

18 Q
Did you ever hear name in

19 association with those two before left?

20 A No.
Did you have any discussions with anybody
or did you ever hear the topic come
leaving about ethics
regulations or criminal laws or anything like that?
A Can you repeat the question?
23
but I didn't know
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up related to
rules or
MSSCE0003460
A
I thought that was
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A No.
Did you talk to anybody else in the office
leaving the office?
A

I'm sure I did. I mean, it was kind of a


big deal.
Do you recall any conversations?
A I don't.
Did you have any conversations with
before left'the office?
A No.
BY
Q Why was it a big deal?
a big deal.
MSCE0003461
about
that I recall.
BY
A No. That could have happened, but nothing

Did you hear anybody talk about that

7 reason?

8 A No, not necessarily.

9 Q
Did anybody else speculate there was any

10 other reason that you recall?

11 A No.
12
13

14 A
15

16 A
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21 A
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3SCE0003462
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SCE0003463
4 A

13 Q Did anything about suggestions with
14 the Senator about t h i s matter?
15 A No.
18 A I had no reason to believe at that time,
no.
2 0 Q Do you have any reason to believe since
21 to the Senator?
2 2 A There's a l o t of speculation based on
2 3 what's been i n the newspapers about what may or may
24 not have happened. I don't have any proof or any
2 5 evidence or anything l i k e that. I t ' s j u s t
26
;SCE0003465

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Q You haven't talked with anybody about any
conversations?
A No.
Q I'm going to ask you, i t ' s always
important at some point during the deposition, I ask
you t o keep your up and remember to t a l k
slowly.
A
Was there any occasion that that meeting
was a r e s u l t of anything happening?
A Are you t a l k i n g about the leg. s t a f f
meeting?
Q
A I'm not I know what
made that meeting come together and why that was
discussed.
Q
A No, I'm not aware of that, no.

Q
SCE0003466
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A I'm not aware of but --
Q You were going to say something else?
A

A No.
|
Q You described e a r l i e r meetings as leg.
A Yes.
SCE0003467
Q And leg. gathering would be attended
by the Senator?
A
Q And members of the l e g i s l a t i v e team?
A Yes.
A
Q And
A Yes.
Q You the leg. time meetings
between what you described as leg. s t a f f meetings?

3 A No. You have to understand these leg.
4 time meetings are very, very They usually
5 l a s t about 20 minutes or so, maybe a half hour, i t ' s
6 a boom, boom, boom around the table where people
7 have issues brought up to Senator Ensign have t h e i r
8 two or three minutes to deal with. I t was
9 businesslike, quick. There wasn't any sort of
10 e d i t o r i a l i z i n g i f you w i l l .
20 A
21 Q
22 Energy.
23
24 Q
25 contacts
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Not that I can r e c a l l , no.
I want to t a l k a l i t t l e b i t about NV
SCE0003469

SCE0003470
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So I say, how often, i n a given
month or given year? I I would say
probably -- i t ' s r e a l l y hard to say. Let me think
about that f o r a l i t t l e b i t .
Q Is i t less than 10, less than 50, less
that 100?
A Less than 50.
Q
SCE0003472
36

1 A NO.
8 Q Do you r e c a l l a meeting i n June of 2 008,
12 A I don't r e c a l l a meeting but
14 o f f i c e a few times since I worked there.
16 document going to mark I t has a Bates
17 number of 679 on i t .
2 0 Q I'd ask you to take a look at t h i s .
21 A Okay.
22 Q Do you r e c a l l t h i s e-mail?
2 3 A No.
24 Q Do you r e c a l l the meeting that i t ' s
2 5 t a l k i n g about?
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SCE0003474
38
;SCE0003475
A Do you have a copy of the l e t t e r by any
9 chance?
12 i t , but at the top each page i s pages 1 or 2 or 3 of
13 5. The bottom i s a Web s i t e , Ensign.Senate.gov, and
14 yesterday's date, June 14, 2 007. Inside there there
15 should be a press release and l e t t e r .
18 Q I'd ask you to review those and t e l l us i f
19 that refreshes your r e c o l l e c t i o n .
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SCE0003476
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Q Do you r e c a l l any conversations about
|in r e l a t i o n t o matter?
A No.
Q Do you r e c a l l who requested that t h i s
l e t t e r be i n the place?
A No, I don't.
A Yeah, probably that would be accurate.
Q Do you r e c a l l learning of i t before the
scandal, the a f f a i r ?
A Yeah. That would be accurate as w e l l .

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A No.
(Exhibit |
BY
I'm going to show you a document marked
I t has a Bates number on i t of 131. Do you
r e c a l l t h i s e-mail?
A I don't r e c a l l i t .
Q T e l l me i f i t ' s correct, i t appears to be
e-mail from
i s that correct?
A Yes.
Q Read the sentence that appears that


5 Q Having read t h i s and gone over t h i s , does
your r e c o l l e c t i o n
9 don't r e c a l l i f they had conversations. I t c l e a r l y
10 shows that they did, but I wasn't aware they were
11 having those conversations.
12 Q Would you agree t h i s e-mail suggests there
13 was a basis f o r you to be aware at the time;
14 correct?
19 Q Let me ask you t h i s : what point were
2 0 you aware there were r e s t r i c t i o n s i n
21 place that affected a l l Senate employees?
22 A I believe I attended ethics t r a i n i n g , and
23 I don't know when that happened.
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;SCE0003479
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Probably, yes
Who would you have spoken to about that i f
A
Q
anyone ?
A
Q Your testimony i s you don't r e c a l l being
aware of i t ; i s that correct?
A
Does i t refresh your r e c o l l e c t i o n -- do
you have any r e c o l l e c t i o n at any l e v e l , whether i t ' s
vague or s p e c i f i c or at any l e v e l ,
SCE0003480
44
4,5
46
9 Q Do r e c a l l whether i n t h i s context or
10 any other context being given the impression i n the
11 Senator's o f f i c e that a former s t a f f e r w i t h i n t h e i r
12 ban period could contact the o f f i c e about
13 o f f i c i a l matters on behalf of a c l i e n t i n some
14 appropriate way?
15 A I don't know. I don't know i f there i s --
16 I imagine -- I don't know. Maybe there would be. I
17 don't r e a l l y know. I don't know the specifics of
18 what the ban i s . I don't know i f there are caveats
to the ban.
22 I had no idea.
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;SCE0003484
48
SCE0003486
3 There was the r i g h t turn issue i n
4 Las
5 Q Describe
6 A There are a group of c i t i z e n s -- residents
7 i n Las Vegas that were complaining to a l l the
8 congressional o f f i c e s because the FAA changed the
9 r u l e that would allow planes to take o f f from
10 McCarran and turn Turning r i g h t , there's
11 tons of houses out there and they were concerned
12 because they could hear the noise. That was a new
13 proposal, and there was quite a b i t of contact, as
14 you might imagine.
15 Previous to that, a i r l i n e s would take o f f ,
16 go over the desert take a r i g h t or l e f t or
17 whatever.
18 Did you work with anyone at A l l e g i a n t on
19 that issue?
2 0 A
26

15 A Yes, that's r i g h t .
16 Q And that included on A l l e g i a n t ; correct?
A On any transportation issue.


21 A Yes.
22 Q Were you aware i n early summer,
23 summer of 2008 of communications between your o f f i c e
24 and the Department of Transportation on behalf of
25 Allegiant Airlines?
26

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A No. On i s s u e ?
Q The f i r s t q u e s t i o n was i n g e n e r a l .
A I d o n ' t b e l i e v e so. No, I d o n ' t t h i n k so.
Q t h e S e n a t o r and
asked t o c o n t a c t t h e Department o f T r a n s p o r t a t i o n on
b e h a l f o f A l l e g i a n t , w o u l d you e x p e c t
t o be i n v o l v e d i n t h a t e f f o r t ?
A
Q i n v o l v e d i n t h a t
w o u l d you somehow be i n v o l v e d a t a l l o r n o t
n e c e s s a r i l y ?
A I t have t h a t r e l a t i o n s h i p .
| l i k e d t o do e v e r y t h i n g way.
Q Why d o n ' t we t a k e a m i n u t e and d e s c r i b e
f o r us y o u r r e l a t i o n s h i p w i t h

53
17 A No.
18 Q I'm g o i n g t o ask you a few names o f p e o p l e
19 a t A l l e g i a n t . You s a i d you d o n ' t b e l i e v e you spoke
2 0 t o p e o p l e , b u t I'm g o i n g t o b r i n g t h e names up i n
21 case i t r e f r e s h e s y o u r r e c o l l e c t i o n .
22 A G r e a t .
24 A No.
26
SCE0003490
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A No.
Q Anyone e l s e a t A l l e g i a n t ?
A No.
Q Do you r e c a l l b e i n g asked t o summarize a
consent decree A l l e g i a n t A i r l i n e s and t h e
Department o f T r a n s p o r t a t i o n ?
A No.

BY
Q I ' l l show you a document I ' v e marked
I t has a Bates number o f 660 on i t .
A
Q Do you r e c a l l t h i s e-mail?
A No, I d o n ' t .
Do you r e c a l l t h e consent d e c r e e i n
g e n e r a l ?
A No. I don't r e a l l y know what t h a t i s .
;SCE0003491
55
1 Do you r e c a l l any i s s u e between A l l e g i a n t
2 A i r l i n e s and t h e Department o f T r a n s p o r t a t i o n h a v i n g
3 t o do w i t h t h e i r Web s i t e o r c o n v e n i e n c e fees?
4 A Yeah, I do r e c a l l t h a t .
5 Q What do you r e c a l l about t h a t ?
6 A I t seems l i k e my r e c o l l e c t i o n i s t h a t
7 A l l e g i a n t was b e i n g f i n e d o r assessed a f e e by t h e
8 Department o f T r a n s p o r t a t i o n because o f how t h e i r
9 Web s i t e was s e t up. When passengers w o u l d t i c k e t
10 on t h e i r Web s i t e , i f my r e c o l l e c t i o n i s c o r r e c t ,
11 t h e r e was some way t h e passenger was n o t g e t t i n g
12 e x a c t l y what he p a i d f o r . There was e x t r a f e e s
13 i n v o l v e d o r something l i k e t h a t . I do r e c a l l t h a t
14 i s s u e .
15 Q Do you r e c a l l w o r k i n g on t h a t i s s u e ?
19 Q B r i n g i n g t h a t i s s u e back t o y o u r memory,
2 0 do you r e c a l l any communication by t h e S e n a t o r o r
21 t h e S e c r e t a r y o f T r a n s p o r t a t i o n
22 r e g a r d i n g t h a t i s s u e ?
2 3 A
24 Do you r e c a l l a n y t h i n g t h a t t h e o f f i c e d i d
2 5 r e g a r d i n g t h a t i s s u e ?
26


A NO.
A
Q I'm g o i n g t o ask you t o t u r n t o t h e second
page, That appears t o be, as you s a i d , a PDF
o f some newspaper a r t i c l e s ; i s t h a t r i g h t ?
SCE0003493
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A Looks l i k e N a t i o n a l J o u r n a l Congress
D a i l y .
Do you see on t h e page a c o u p l e o f
h a n d w r i t i n g s ? One says and t h e o t h e r i s a

A
Q
A I r e c a l l s e e i n g t h e s t a r , b u t I don't
r e c a l l s e e i n g t h e name w r i t t e n on
Q What do you r e c a l l about t h e s t a r ?
A I j u s t - - i t was s t a r r e d so I r e a d i t and
I saw i t s a i d John E n s i g n , and i t was a subcommittee
h e a r i n g , yes.
Q Do you r e c a l l a n y t h i n g e l s e about t h a t
i s s u e o r any c o n v e r s a t i o n s w i t h
t h i s i s s u e ?
A No.
iSCE0003494
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I'm g o i n g i t t h r o w some t h o u g h t s o u t
t h e r e and see i f a n y t h i n g r e f r e s h e s y o u r
r e c o l l e c t i o n .
A
t h a t ?
A C o u l d
Q Do you r e c a l l any such c o n v e r s a t i o n ?
A No.
s p o s s i b l e you
A U n l i k e l y .

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A I d o n ' t t h i n k so. I t h i n k I would have
r e c a l l e d t h a t .
A
Q Throwing a l l t h e s e p o s s i b i l i t i e s o u t ,
a n y t h i n g s p a r k any l e v e l o f memory?
A About --
Q About how you o u t
worked --
A
Okay.
Q Does i t s p a r k any b e t t e r r e c o l l e c t i o n o f
who m i g h t have t o l d you t h a t ?
A I t c o u l d have been I t c o u l d
have


was n o t
;SCE0003496
4 A
5 Q T e l l us s p e c i f i c a l l y what you r e c a l l about
6
12 You r e c a l l t h a t b e i n g a c o n c e r n --
13 A Yes.
16 A Yes.

2 0 A No, I d o n ' t t h i n k so.
Q Do you r e c a l l d i s c u s s i n g t h i s r e q u e s t w i t h
22 anybody e l s e ?
2 3 A No, I d o n ' t t h i n k so.
24 Q L e t ' s l o o k a t t h e f i r s t page.
25
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Yeah
Q T a l k about t h a t a l i t t l e b i t . What were
y o u r t h o u g h t s i n r e l a t i o n t o t h a t when you were
asked t o do t h a t ?
A I t h o u g h t i t . was w e i r d .
Q What do you mean by "weird"?
A I h a d n ' t -- I d o n ' t r e c a l l .
Q How d i d you g e t address?
A I d o n ' t know. T h a t ' s a good q u e s t i o n . I
imagine i t was p r o b a b l y p o p u l a t e d i n my o u t l o o k .
Q

14 Q Do you r e c a l l whose c o n t a c t s --

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Q Who e l s e r i g h t i n t h a t v i c i n i t y ?
A L e t ' s see --
Q D i d you d i s c u s s t h i s w i t h e i t h e r
A I d o n ' t r e c a l l , no.
Q Do you r e c a l l d i s c u s s i n g i t w i t h anybody
e l s e i n t h e o f f i c e ?
A No.
Q Not |
A No, n o t t h a t I r e c a l l .
Q L e t ' s go back t o t h e f i r s t page o f t h i s
E x h i b i t

11 Q So t h a t was i n t e n t i o n a l ?
12 A T h a t was d e f i n i t e l y i n t e n t i o n a l because I
13 t h o u g h t i t was w e i r d .
17 A Yeah, p r o b a b l y .
18 Q So was t h a t k i n d o f e x p l a n a t i o n t o y o u r
19 mind r e l e v a n t t o whether o r n o t t h i s was p r o p e r o r
2 0 improper?
26

4 Q What d i d you do about t h a t concern?
be
10 A Uh-huh.
11 Q Your t e s t i m o n y i s you d i d n ' t t a l k t o
12 anybody about t h a t ?
13 A
14 Q You d i d n ' t do a n y t h i n g i n response t o
15 t h a t ?
16 A No. I d i d n ' t do a n y t h i n g . I may have
18 Q I f you t a l k e d t o what was o r
19 have been response t o t h e b e s t o f y o u r
2 0 r e c o l l e c t i o n o r u n d e r s t a n d i n g ?
21 A I know what say. I
22 r e c a l l
23 Were you a t a l l u p s e t w i t h
24 A No.
2 5 Q Why n o t ?
26
SCE0003502
8 Q I'm g o i n g e x p l o r e t h a t , b u t I want t o
9 make p e r f e c t l y c l e a r . We're n o t g r i l l i n g
10 you based on y o u r knowledge t o d a y o f what you've
11 l e a r n e d . We a r e p r o b i n g y o u r u n d e r s t a n d i n g a t t h e
12 t i m e t o h e l p us u n d e r s t a n d t h e c o n t e x t o f t h e s e
13 e v e n t s and t o h e l p r e f r e s h y o u r r e c o l l e c t i o n .
14 As we d i s c u s s e d y o u r t h o u g h t p r o c e s s , t h i s
15 i s t h e way human b e i n g s work. I t t r i g g e r s
16 r e c o l l e c t i o n s i t h e l p s . We v e r y much a p p r e c i a t e
17 t o d a y i s a much d i f f e r e n t w o r l d t h a n back t h e n .
18 We're f o c u s i n g on back t h e n .
19 A I u n d e r s t a n d .
26
ISCE0003504
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A No, no way.
Q The r e c o r d needs t o r e f l e c t t h a t you had a
c h u c k l e i n t h e r e .
A
g o i n g t o mark These a r e a r e
Bates stamp numbers 141 and 142.
Q Take a l o o k a t
document?
Q Do you have o f you?
Yes.
Q
SSCE0003506

A
7 A
Q My q u e s t i o n i s d i f f e r e n t .

15 A I w o u l d agree w i t h t h a t .
19 l o o k t h r o u g h t h a t . Would you agree o f f t h e t o p i t ' s
20 a c h a i n o f e-mails?
21 A Yes.
22 Q I want t o you l o o k t h r o u g h t h a t c h a i n .
2 3 A Okay.
24 Q Are you f a m i l i a r w i t h t h e s e e - m a i l s ?
2 5 A Yes.
26

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Q I s t h a t what you were r e f e r r i n g t o a few .
m i n u t e s ago when you we can g e t t o t h e n e x t
e-mails?
A Yes.
Q K i n d o f d e s c r i b e f o r us t h i s c h a i n and t h e
c o n t e x t and what was g o i n g on when t h i s happened.
Q s s t a r t . You s a i d
and i n f a c t , t h e e - m a i l below t h a t , i s t h a t t h e same
e - m a i l as what we were j u s t r e v i e w i n g i n E x h i b i t
A I t ' s n o t a t t a c h e d -- oh, yes, i t i s .
Q So when you say you mean

responded t o t h e e - m a i l we were j u s t d i s c u s s i n g ?
A Yes.
Q Keep d e s c r i b i n g what happened when t h i s
came i n and g i v e us t h e f u l l c o n t e x t o f t h e s e


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Q L e t ' s have t h e r e c o r d r e f l e c t t h a t y o u ' r e
i n d i c a t i n g I
Q You s a i d t h i s i s a d i f f e r e n t i s s u e f r o m
t h e one t h a t -- t h e newspaper c o n c e r n t h a t you s e n t ,
A
Q . And t h a t newspaper a r t i c l e was E x h i b i t
Yes.
What d i d you do when you g o t t h i s e-mail?
ISCE0003509
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Q What d i d you do a f t e r you s e n t t h i s
e - m a i l ?
A
Q Any o t h e r e - m a i l s t h a t a r e n o t a t t a c h e d t o
t h i s t h a t you r e c a l l ?
A No.
D i d you e v e r hear o f t h i s m a t t e r again?
No.
Q What was y o u r u n d e r s t a n d i n g a b o u t whether
t h e r e was any p r o b l e m w i t h t h a t c o n t a c t ?

A
14 Q Had you e v e r been a d v i s e d o r had any
15 c o n v e r s a t i o n s about what a s t a f f e r needs t o do i f
16 t h e y a r e p u l l e d i n t o v i o l a t i o n t h e one-year
17 ban?
22 You had n e v e r h e a r d
24 i s s u e s a r e f o r s t a f f e r s who g e t , f o r want o f a
2 5 b e t t e r word, p u l l e d i n t o a v i o l a t i o n ?
26

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g o t
A

A
Q
A
Q
A
What d i d you f e e l o r t h i n k o r say when you
response?
P e r f e c t . I'm done.
But you were r e l i e v e d t h a t you weren't?
Yeah.
Because you t h o u g h t i t was wrong?

Thank
BY


12 A Not t h a t I r e c a l l .
14 I ' l l mark E x h i b i t These a r e documents
15 w h i c h have Bates numbers on them o f 2958 and 2959.
18 Q 2958, am I c o r r e c t t h e r e a r e t h r e e e - m a i l s
19 r e f l e c t e d on 2958, i s t h a t r i g h t , w h i c h i s

21 A Three m a i l addresses o r e - m a i l s ?
22 Q Three a c t u a l e - m a i l s . I s i t f a i r t o say
a t the bottom an e-mail you to
2 5 A Yes.
26
3SCE0003514
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Q And dated
A
A
Q On the same date?
A
Q With the same subject l i n e except f o r a
forward, FW?
A Yes.
A
Q look at Exhibit the second page
of that. Do you recognize that?
A Not r e a l l y . I t looks l i k e a grant notice,

Q go back to the page and deal
w i t h the e-mail on the bottom from you to
Do you r e c a l l that e-mail?

A

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When you say that, you're r e f e r r i n g to
Yes .

going to show you an
e x h i b i t mark s a document w i t h the
Bates number 3143.
(Exhibit
BY
Q At t h i s point, we might be done by 12:30,
12:45. I can't guarantee that. Do you have any
need to take a five-minute break?
A Yeah. I f I could send an e-mail t o

80
1 someone r e a l l y quick, I'd l i k e to take a quick
2
4 break and we'll come back.
5 (Recess.)
warn
7 Q We're back on the record.
8 For the record, I ' l l remind you that you
9 are s t i l l under oath. When we l e f t o f f , I had given
10 you a document that I marked i s that
11 correct?
12 A Yes.
13 Q Have you an opportunity to review t h i s
14 e-mail?
15 A Yes.
16 Q Does t h i s appear to be the same request
17 b a s i c a l l y from the l a s t e-mail that you reviewed
18 j u s t a month l a t e r , substantively?
19 A Look at the old document. I think t h i s i s
2 0 d i f f e r e n t actually.
21 Help us understand. We've j u s t handed you
23 A Maybe not. I'm sorry. You're accurate.
26
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Q Do you r e c a l l getting t h i s as kind of a
repeat request from a month e a r l i e r ?
A Not r e a l l y .
Q Let's c l a r i f y . You talked about how there
was a l o t of t h i s going on. I know you gave us
e a r l i e r a b r i e f description of your r e s p o n s i b i l i t i e s
A Sure. Quite frankly, had I not thought
about the Allegiant A i r l i n e component, I would
assume t h i s was f o r McCarran A i r p o r t and Reno
International and not f o r a p a r t i c u l a r a i r l i n e
because i t talks about runway incursions and systems

82
1 and t h i s and that. To me, i t i s
2 grants f o r a i r p o r t s .
13 A Yeah, I'm sure.
14 Q They can both be that way i f
15 they were aware of something a Nevada constituent
16 needed that you would gather some information and
17 put something together?
18 A Yes.
19 Q And i s i t more t y p i c a l f o r them to give
2 0 you information or did they t y p i c a l l y have you to
21 send information to that company or lobbyist,
22 et cetera?
2 3 A I t would be more t y p i c a l I would send i t
24 to them, but there would be times when I would send
2 5 i t d i r e c t l y to the lobbyist i f i t was something I
26
SCE0003519
was working on d i r e c t or i f I had a r e l a t i o n s h i p ,
that type of thing.
A No. Well, Nevada. That's a gamut,
mining, you name
understood?
A No.
Q And were you aware else that
they were doing the. time?
A No.
iSCE0003520
SCE0003521

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A No, t say anything l i k e that.
Q
Q Did they say -- how did you become aware
that the person they were meeting wasn't there?
A
Q I don't.
THE WITNESS: There's an anteroom. And
kind of around and looked i n and
came back said 11 wait, you can go.
Q Did say anything else to you
on the way over?
lis!


87
1 A No. We took the tram over from the
3 a d i f f e r e n t car.
4 Q Why was that?
5 A I t was crowded and I don't r e c a l l what we
6 talked about, something stupid l i k e the weather. I
7 think I t o l d had a great a i r l i n e , something
8 l i k e that.
10 A
12 Q Had you ever flown the a i r l i n e ?
13 A Yeah, I had.
14 . Q say anything back to you?
15 A No. One minute to r i d e there. I t was
16 j u s t small t a l k .
17 Q


else to you?
A
19 Q At the time you were walking to dining
2 0 room from the subway, any further conversation?
A No, because I kind of led and they walked
22 behind me.
2 3 Q Did you ever overhear any of t h e i r
24 conversation?
2 5 A No.
26
;SCE0003524
1 Q Did and say hello to anybody
2 else on the way?
3 A No.
4 Q Once again, were you aware of anything
6 that day or week?
7 A No.
9
10
11
12
13
14.
15
16

18
19
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21
22
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Q Did you discuss that with anybody other
A I may have discussed i t with
Q Again, searching your r e c o l l e c t i o n one
more time, do you r e c a l l any --do you have any
r e c o l l e c t i o n , whether vague or more than vague,
about that conversation w i t h
A No, I don't. We talked several times a
I
going to ask you a
question a f t e r the next session. Did you have
anything else?
I do.

BY
Q
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A No, because I don't t h i n k w a s i n the
o f f i c e at that time.
Q
A I think i t was a f t e r Senator Ensign
resigned or a f t e r he made the announcement of the

Several months had gone by.
BY
Q When you said Senator Ensign resigned, you
mean his p o s i t i o n w i t h RPC?
A
BY
Q
A No.
Thank you.
We'll come back to
postdisclosure questions.
Q Quick question.

A No, I don't believe so.
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Q Do you r e c a l l a company called
A No.
Q You t e s t i f i e d e a r l i e r that you don't
A I no.
going to show you a
I t has a
document that we're going to mark]
Bates number of 113 on the bottom.
THE Oh, okay.
BY
Q Do you r e c a l l that document, that e-mail?
Q I think you also said
A Yes.
Q This would be the other person who was
w i t h
A
Q Let's go over that e-mail. For the
record, am I correct i t ' s
A

4 Q Do you r e c a l l any other meetings that day?
5 A He was speaking at -- oh, gosh. I t was
6 l i k e the anniversary of SNPLMA, Southern
7 Nevada Public Lands Management Act, and he was
8 speaking there along w i t h the rest of the
9 delegation.

11 A Yeah.
12 Q Any other events?
13 A Not that I r e c a l l .
15 A Yeah.


2 3 A Yes.
10 A I don't r e a l l y r e c a l l . I t was
11 something -- an i d e a he i t to
H I _____
12 Senator Senator Ensign
13 b a s i c a l l y 30 seconds why t h a t wouldn't work and t h a t
2 2 Q For the record, you're i n d i c a t i n g Senator
2 3 E n s i g n was on your l e f t ?
26
iSCE0003530
14 A Huh-uh.
15 Q Verbalize that.
16 A No, I don't. I'm sorry.
17 Q I n issue, was
18 about -- t h i s proposal was t h a t
19 something the Senator would have been able to assist
20 i f the Senator agreed with i t ?
A
2 2 Q Was i t a proposal to a federal agency?
2 3 A I f I r e c a l l , and again, I think i t had
24 something to do with l i k e DOD procurement,
2 5 streamlining the process f o r procurement, something
26
6 company called that managed f i n a n c i a l
7 services such as debit cards or c r e d i t cards,
8 et cetera, could i t have been something about using
9 debit cards i n emergency services?
10 A Sure. That sounds probably about r i g h t .
11 There's a reason i t couldn't work f o r whatever
12 reason, and I don't know what that was, and I think
13 i t had something to do with procurement.
2 3 Q Did the Senator express any issues with
24 i t ?
2 5 A
26

4 Q What was the purpose of that?
5 A I don't know. Just to be f r i e n d l y .
9
10 I was going to Nevada maybe four or f i v e times a
1 1 year meeting with d i f f e r e n t constituents, d i f f e r e n t
1 2 c l i e n t s -- not c l i e n t s , but constituents.
13 Q Were you t a l k i n g about s o c i a l i z i n g with

1 5 A Yeah, I think something l i k e that. Again,
1 6 I have never since e-mailed contacted
1 7 I t was kind of a throwaway.
1 8 Q Was that throwaway or that comment or that
1 9 thought, was that something you were doing i n your
2 0 o f f i c i a l capacity, or did you guys h i t i t o f f --
2 1 A No, i t be i n an capacity.
22 I would have no other reason to meet
name ever come up?
2 5 A Not that I r e c a l l , no.
26
SCE0003533
4 A No.
5 Q I you i f there were any concerns.
6 I f you did have any concerns about any e t h i c a l
7 issues, who would you have gone to i n the office?
14 A Yes.
15 Q Had he said that to you or was i t a
16 general o f f i c e policy?
17 A I think i t was a general o f f i c e p o l i c y .
18 Q Do you r e c a l l that i n any s p e c i f i c
19 meetings?
2 0 A Maybe i n that leg. s t a f f meeting.
21 Q So you have a r e c o l l e c t i o n that during the
22 leg. s t a f f meeting, am I correct the one you're
23 r e f e r r i n g to i s

2 5 A Uh-huh.
26

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Q Was t h a t s p e c i f i c a l l y i n r e g a r d to the
| i s s u e or was t h a t i n g e n e r a l ?
A I n
Q anything e l s e i n general about
e t h i c s i s s u e s i n the o f f i c e ?
A No.
Q
A I don't r e c a l l . I don't r e c a l l why i t was
c a l l e d . My takeaway i s t h a t was --we may have
t h a t . I don't r e c a l l .
;SCE0003535
2 A
3 Q Do you believe that those were connected,
4 or do you believe s p e c i f i c a l l y that they were not
5 connected?
6 A I believe they were not connected.
11 Q You don't r e c a l l there was any other topic
12 of ethics discussed?
13 A No. I t may have been i n the context of
14 Senator Ensign's p r o f i l e was getting -- his p r o f i l e
15 was being raised because of his p o s i t i o n at both
16 senatorial and RPC and so I think there was some
17 discussion about making sure that we were doing
18 everything we could t o comply with the Ethics
19 Committee.
2 0 Q You believe t h i s was another topic of
21 discussion at that meeting?
22 A Yeah.
2 3 Q Was that due to the Senator's increased
24 p r o f i l e ?
2 5 A Yes.
26

SCE0003536
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Q Was there also t a l k at the time of -- I
believe there was already t a l k at t h i s time about
the Senator being a p o t e n t i a l p r e s i d e n t i a l
candidate; i s that right? Or was that later?
A That was l a t e r .
Q There was t a l k at the meetings, and now
we've got three things -- w e l l , we have the mention
l i g h t of the Senator's raised p r o f i l e , be sure we're
complying with ethics rules; i s that right?
A
Q Was that related to the jthing
as well as general? Is that f a i r to say?
A
Q I n r e l a t i o n to we need to generally
protect the ethics of the o f f i c e , the i n t e g r i t y of
the office?
A

Q
;SCE0003537
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A Well, I mean, I think i t could be a l i t t l e
b i t of both. Maybe I can help out, you know, and
also, we have to make sure that we protect Senator
Ensign and his or his image, whatever he's

Q Do you r e c a l l any concern that i f you go
to the Ethics Committee, things could get out?
A Yeah, probably.
BY

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Q Do we understand c o r r e c t l y that based on
your reviewing some of the documents you've been
able t o review today, have you learned today of
been aware of p r i o r to today?
A Yes, that's correct.
BY]
Q
A
Q
How were you t o l d about that process?
I n that meeting.
Another question. S i t t i n g i n that area
outside of do you r e c a l l any


the o f f i c e or the o f f i c e ?
A No.

103
2 Q Let me ask you a few quick questions about
3 a company or group of companies, they might go by
4 P2SA Equity, BioDiesel, Are you aware of a
5 named
6 A Only something that I would have read
7 while working there l i k e i n the Review Journal,
10 Q Do you r e c a l l any conversations -- what
12 A No.
14 A No.
19 A No. I know anything about that. I
2 0 think I read that i n The New York Times.
Q But you have any independent
22 recollection?
23 A No, I don't.
24 Q Since The New York Times a r t i c l e came out
2 5 or whenever you learned about i t i n the press, did
26


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you have any c o n v e r s a t i o n s w i t h
A
about t h a t ?

A
A
Q
A
Q
A
Q

A
Q
A
Q
NO.
( E x h i b i t
|
L e t me show you a document marked
T e l l me i f you r e c o g n i z e t h a t or what t h a t
I n f a c t , i s t h a t your handwriting?
No.
Except f o r you?

A No, I don't.
Q When you you learn about the
between the Senator and
A 2 0 minutes before he did the press
SCE0003542
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conference i n Las Vegas. He had a s t a f f
c a l l and he announced i t then.
Q What did he t e l l everyone on the s t a f f
conference call?
A He said something to the e f f e c t that he
was very sorry, he's disappointed many people, but
he had an improper relationship
and that was about i t .
A
Q
;SCE0003543
A No.
12 Q After you learned about i t .
13 A Yeah. I think everyone i n the o f f i c e
14 learned about i t at the same time, which was i n the
15 newspaper or the P o l i t i c o or New York Times.
16 Q Was there a common thread as to what
17 people were saying?
Q What was your concern?
26
SCE0003544
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who knew what, when, where, no, nothing l i k e that.
Just how i t
Q Anything about the contacts with]
i t was disclosed?
A No.
Q Did you ever s i t down and have e i t h e r a
one-on-one or small group conversation with Senator
Ensign about any of this?
Q Other than those specific opportunities
that were afforded to s t a f f , did you ever have any
conversations that the Senator was a part of about
any of this?
A No.
SCE0003546
110
2 A No.
4 A
5 Anybody else?
6 A Huh-uh.
m

23 A
24 Q I t seems to be sparking some kind of
2 5 r e c o l l e c t i o n . What i s i t that you're remembering?
2 6
SCE0003549
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A
Why was that?
Just to see what was i n them.
S p e c i f i c a l l y about t h i s issue?
What did think might be
I
I have no idea.
Do you r e c a l l whether t h i s was before or

I don't r e c a l l .
;SCE0003550
7 Q Do you r e c a l l having that impression?
8 A Yeah.
9 Q Do you r e c a l l i t r a i s i n g any concerns f o r
10 you?
11 A Yeah. I was concerned about everything,
12 absolutely.
15 A I believe so'.
18 A Not that I r e c a l l .


2 3 Q Since a l l these disclosures, have you had
24 any conversations with anyone outside of the
25 Senator's o f f i c e about these matters?
26

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11?
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Q Did you ever have occasion to think who
else you might speak to i f you couldn't speak t o
A I probably could speak to]
I have --
Q Are you f i g u r i n g that out or did you ever
have occasion while you were there to think, and
t h i s i s i f I needed to t a l k
to somebody and I t t a l k to I could
t a l k |
A
;SCE0003555
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Q When was that occasion when you thought
that?
A Yeah. That thought d e f i n i t e l y crossed my
mind. Was there an incident that made me think that
i s probably your next question. Not that I can
r e c a l l , but I think I did have that safety net i n
the back of my head.

SSCE0003556

a b i t ago
9 asking you was there anybody who you thought you
10 could go to, and you said yes, I f e l t I could go to
12 A Yes.
A I
17 Q I was j u s t wondering what i t was.
19 minute and we'll wrap up.
20
22 Q For the record, we remind you you're s t i l l
2 3 under oath. We're down to our l a s t question. We
24 ask t h i s same wrap-up question of
2 5 have t r i e d to be as thorough as we can. We've gone
26
;SCE0003557
121
1 p r e t t y much i n depth and I think you've got a sense
2 of the breadth of areas we've been asking you about.
3 Our f i n a l question i s b a s i c a l l y what have
4 we missed, and that i s , do you have any information
5 or are you aware of any information relevant to a l l
6 these questions we've been asking that f o r some
7 reason we didn't get t o , anything you're surprised
8 we didn't ask you about or anything else that you
9 know about related to these questions that we
10 haven't gotten to?
11 A Nothing comes to mind, but I can think on
12 that.
13 Q Please.
14 A No, not anything that I can t h i n k of r i g h t

16 Q We'll ask to you think on i t . Let us know
17 i f you r e c a l l anything else.
18 A Okay.
2 0 you very much.
21 THE WITNESS: Sure. Thank you.
2 3 estimate.
24 (Whereupon, at 1:04 p.m., the deposition
2 5 was concluded.)
26

122
1 I HEREBY CERTIFY that I have read t h i s
2 t r a n s c r i p t of my deposition and that t h i s t r a n s c r i p t
3 accurately states the testimony given by me, with
4 the changes or corrections, i f any, as noted.
5
6
7 X
8
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11 Subscribed and sworn to before me t h i s day of
12 , 20
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16 X
17 Notary Public
18
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21 My commission expires:
22
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;SCE0003559
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3 WITNESS EXAMINATION
7
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10 E X H I B I T S
11 NUMBER IDENTIFIED
23
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;SCE0003560