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A
A

I did not, not at that point, no.


A
When you say "John," you mean John Ensign?
A I'm sorry, Senator Ensign.
Q
M-SSCE0003928
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5 A
6 Q
That was the first time you had heard
7 that?
8 A Yes.
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.1111.-SSCE0003929
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3 A I'm sorry, repeat that.
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6 A
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11 Q Okay.
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15 A
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Q
so that's what happened in this instance?
20 A Yes.
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-SSCE0003931
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IIIIIIIIIIIIII : Who else was present?
THE WITNESS:
BY
Q What did the Senator say?
A
A
BY
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MrSSCE0003932
MMISSCE0003933
A I
don't
remember.
BY
A
And
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BY

Q Okay.
thenwhat?
A
Yeah, I don't remember.
15 two?
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25 A
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158

1
1111111

: This is the same thing?


3

4 THE WITNESS:
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7

8 BY
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12

13 A Right.

14 Q
Was there any separation between those
-SSCE0003935
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A
A I don't remember.
Didyou hear. --
A I don't remember.
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-SSCE0003936
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12 In between that time period, I didn, t
13 learn anything new, as I can recall.
14 DYNE.'"
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Q
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18 A Right.
19 Q
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23 A Right.
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Q
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-SSCE0003937
1

A
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15 BY

16
Q
Whoelse got phone calls?

17 A
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SSCE0003938
1

2 A I don't remember.
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5

6 A I'm not aware. I'm not aware.

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BY 11111111:
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11 A
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13

14 A After that?

15 Q After that call, about this topic.

16 A
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Q
Tell me about that call.

25 A
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IIII-SSCE0003940
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6 A Huh-uh, no.

7
Q

8 A No.

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Q 11111111111111111 11
10

11 A
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24 A
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-SSCE0003941
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7
Q
Thank you for that information, follow-up

8 call.
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13 A I don't remember.
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Q Okay.
A I don't remember a time line.
Q
MNIIMIMMIIMINall
A Yes, definitely.
Q That's helpful. All right.
166
111.11-SSCE0003943
So it was a long conversation. About how
did it last?
A I would say 30 to 45 maybe minutes.
Okay. It took place here in the Senate?
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21 long
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24 A It did, in his conference room, his
25 personal office.
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-SSCE0003944
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3 A
4

Q Okay.
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6 A
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16 A Yes, yes.
17

Q Okay. So talk to us about that


18 conversation.
19 A
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-SSCE0003945
A
A Yes.
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=1111-SSCE0003946
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22 A Yes.
23 Q Okay.
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8 A
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11 Q
I can show you a set of those to refresh

12 your recollection as need be.


13

14 A Sure.
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17 A Yes.
18
19

20

A Right.

21 Q
I want to show you actually -- I have some

22 notes, and I don't think they're from this day, but

23
I'd like to get some information from you about what

24 they may have related to. I want to show you

25 Exhibit 10.
26
1111. 111111-SSCE000394 7
170
1 (Exhibit 11110 identified.)

2 BY

3 Q
This will be 11-10, and the Bates number

4 is 1381. If you could just place these in context,

5 because they didn't seem to go exactly with the

6 earlier notes.
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8

9 A
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19 A

20

Just like it sounds.

21 A Exactly.
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25

A Exactly.
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171
-SSCE0003948
1
Q
Okay.
2

3 A Right.

4
Q
Do you know what you were referring to

5 there?

6 A
8
9
10

11 A
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13

14
Q
I don't know which e-mail?

15 : Do you recall before we

16 show you?

17 THE WITNESS: No, I don't.


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19

20
BY 11111111:
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22

23 A
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-SSCE0003949
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Q
A
Q
A I don' t .
-SSCE0003950
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Q
Okay.
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on this issue at the time? There should be a lot of
notes?
A

: I understand. Any other

questions?

BY 1111.1111111111111 :

Yes. On this exhibit, it appears that --

is there something that was on the page above this,


are you aware?

7 A Yes.

8
Q
Do you know what that was?

9 A No.

10
Q
Do you know if it relates to this whole

11 matter?

12 A I assume so. I don't know what it was,

13 though, so I can't be sure. Because I had both

14 legislative notes and obviously notes about all of

15 the stuff that was happening.

16
Q
Why do you assume so?

17

A Because there was a lot of -- I was taking

18 a lot of notes on this issue at the time.

19
Q
So there are a lot of notes that you took
EIMSSCE0003951
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4 A I would say a rough estimate is maybe 20

5 pages.

6 Q
20 pages of notes from this time period

7 or --

8 A
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12

13
: Okay. Thank you.

14 BY

15 Q
I'm going to show you just to refresh your

16 recollection, not to go through it line by line,

17
because we don't want to do that, what we're going

18 to call 11111. And the Bates number is 000102 to

19 108, okay? Just have a look at that, please.

20 (ExhibitI11-11 identified.)

21 BY
22
23

24 A It is.
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Hampton-SSCE0003952
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4 A Uh-huh.
5 Q
Is that a fair characterization of what III
6 said?
7 A Yes.
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IIMIESSCE0003953
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Okay.
17 7
SSCE0003954
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4 A In some other conversations about this


conversation.
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7

8 A Yes.
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10

A Exactly.
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12

13

A No.

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Q
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16

17

A Yes.

18

19

A
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22 Q
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I. SSCE0003955
1 A
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11 A
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23 Who was that person, do you recall?
24 A
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-SSCE0003956
A Right, right.
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2

3 A
4
5-

6 BY

7
Q
Yeah, just in regard to your notes, where

8 it said --

: What exhibit are you on? Is

10 that 10?

11

BY
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-SSCE0003957
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3 I
don't
think that we had gone over that,
4 that I remember.
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BY
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A No, I'm talking about this, now that I'm
looking back at the notes.
You testified to --I asked you that
question, and you said you thought it was.
A Okay, sorry. So this was in between.
A Right.
182
19 Q
When you say this, you mean Exhibit 10?
20 A Exhibit 10.
21 : Just for the record.
22 BY
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IIIIM-SSCE0003959
A Correct.
A
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183
11=11-SSCE0003960
1 A With Senator Ensign, you mean?

2 Q
With --

3 A With anyone?
4
5

6 A I don't remember.
7
8

9 Q
Or anyone else?

10 A No, with no one, yeah. Because that's

11
all --those are the only people I talked about it

12 with was --

13
: Do you know how much

14 longer you'll be?

15
: Take a quick break? It's a

16 good time.

17
If we could.

18
: Off the record, please.

19
(Discussion off the record.)

20
: Back on the record.

21 BY

22 Q
as I have mentioned earlier

23
today, you are still under oath, I will remind you

24 of that.

25 A Yes.
26
184
IIIMI-SSCE0003961
1 Q
Great, thanks.
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185
7

A Yes.
8

Q So what did you all do next?


9

A
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Right.
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ENIN-SSCE0003962
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Q

By John, you mean John Ensign?


A I'm sorry, John Ensign, yes.
A
A
Q Okay.
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IIISSCE0003965
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5
Q
That's what I was going to ask. 11111111
6

A Yes.
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10 A
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-SSCE0003966

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A

With anyone, you mean --


A
A
A

IIIIIIISSCE0003968

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Why did you in particular need
information?
A Why did I need the information?
=M-SSCE0003969
1 Q Yes.

2 A
3

4
Q
Just getting informed?

5 A Exactly.

6 Q And you hadn't been there so you were

7 disadvantaged on that; correct?

8 A Exactly. Exactly.
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12 A
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19 Q You did see something?

20 A There was something, yes.


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22

23 A
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193
SSCE0003970
: I'm going to show you a
document and we're going to mark it 11-12. And the
Bates number for this document is 000642.
If anyone has follow-ups before I go on,
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5 A
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194
13 you can ask him while I'm doing this.
14 (Exhibit 11112 identified.)
15 BY
16
Q
Take a moment to review the document and
17 once you're done, just describe it for the record,
18 please.
19 (Witness reviewed the document.)
20 A
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III
IMSSCE0003971
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5 A
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10 Q
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15 A
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20
Q
I'm going to show you what we're going to

21 mark as 11[13, We'll

22 just call it 13, go from there. And the Bates

23 numbers for this document are 001385 to 001391.

24 (Exhibit I1[13 identified.)

25 THE WITNESS:. Okay.


26
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BY
Q Can you describe the document for the
record, please.
A
A ,Yes, definitely.
A Maybe a week?
Was it --
A Or within that week.
Okay.
A
A
198
1.11.111-SSCE0003975
A Uh-huh, yes.
Q
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11 A
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Q Who is we all?
14 A
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16 Q Okay.
17 Looking down at the very bottom, 2385,
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21 A Uh-huh.
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Q
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25 A Yes.
26
IIIMSSCE0003976
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6 A
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17 A Yes.
Q Did you ever receive ethics training?
1
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Q How were you trained?
19 A I think it was the online.
20
Q
So you watch the video or something?
21 A Yes, yes, yeah.
22
Q
Then what did you do?
23 A I think I signed something.
24
Q Who did you give it to? It's a long time
25 ago.
26
.111111.SSCE0003977
1 A I know, I know.
2
3 Q
So you gave it to someone?
A Yeah, yeah, yeah, in the office.
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A


A Yes, correct.
A

A

IIIII.-SSCE0003978
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2

You know, as you said, the Senator had a

policy in place.

A Right, right.
6
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10

A To be honest, it wasn't directly

11

discussed.

12

We understand. We work here too.

13

A It wasn't directly discussed. But I knew

14

that if I had a question, there would be someone

15

that would be able to answer it in our office.


16
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20 A No, no.
21
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25 A Yes.
26
202
1.11111-SSCE0003979
1
Q
So how are you made aware of what to do if

2 you were to have an ethics problem?

3 A
4
5
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7
8

9
Q
Were you ever told that you could call

10 Ethics yourself?

11 A I was never told that because I it

12 wasn't specifically mentioned as to what I should

13 do. I never asked them who to talk to about it. I

14 just knew if I had a question, I should go to

15 someone on staff, and there would be a point person

16 in charge of contacting you, or Senate Ethics.

17
Q
I'm sorry, you may have told me this. Who

18 is the point person on ethics that's been named as

19 the ethics person that the Senator is referring to?

20 A
21
22
23
24

25 THE WITNESS: Thank you.


26
203
-SSCE0003980
1

: You don't have to tell


2

THE WITNESS: Please don't.


: Of course, everything that

5 happens here stays a secret.

6 THE WITNESS:
7

: Something refreshing about

9 that.

10 BY
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15 A
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25 A
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-SSCE0003981
1

2
Q
That's the last time?

3 A Yeah.

4 BY
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11 A I'm sorry, where are you?

12 Q
1385, middle of the page.

13 A Okay, I see.

14 (Witness reviewed the document.)


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22 A
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SSCE0003982
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8 Q Let ' s break that down.
9 A Yeah, sorry.
10
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12 A Okay.
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Q
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IIM
-SSCE0003983
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2 A Right.
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conversation?
A
So what did the Senator say about that
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A I don't --no, I don't know.
Q

A


.1111111-SSCE0003985
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A
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No.
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A Uh-huh.
Q Do you recall following up on that?
A
210
IMIII-SSCE0003987
Do you today have any further
understanding as to what the answer to that is?

6 A
7
8
9
10

11
Q Have you just described to us all of the

12 information that you have?

13 A On this specific

14
Q Your conversation with Senator Ensign?

15 A Yeah, on this specific issue, yes.


16
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20 A That's correct, I have no further

21 information.

22 BY
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A Right.
Q
A
A No, that was the main.
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-SSCE0003989
1 BY
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5 A Not that I'm aware of but -- yeah, I don't

6 know. Not that I'm aware of.

7 BY
8
9

10 A Okay.

11
: This will be-14.

12 (Exhibit III-14 identified.)

13 BY

14 Q I have a copy of all of the exhibits. I'm

15
just going to mark it as 11115, and we're just going

16 to treat it as one big document.

17 A Big document.

18
(Exhibit1111-15 identified.)

19 BY

20 Q
Can you just for the record --

21
: We're making editorial

22 comments.

23 BY

24 Q
That's okay, so were we. Describe what's

25
contained in Exhibit 14 and Exhibit 15, please.
26
213
MISSCE0003990
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Sure.
214
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7

A Yes.
9

10 A
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13
Q I understand.

14 A

15
Q
I understand.
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19 A
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Mil-SSCE0003991
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9 A
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1 It was in the office.
2
3 A
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A
13 Q
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16 A I don't remember specific conversations.
17 BY
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20 A
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MIIIIISSCE0003993
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A No.
A No.
A
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A As far as - -

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11111111
14 A No.
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24 A Okay.
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-SSCE0003995
1

Well --
2

A I know.
3

I understand, it's tricky how you're --


4 what you have to say. Did you -- did you operate on
5 the belief that these were accurate?
6 A Yes.
7 Q
You've never been told to operate in any
8 other way?
9 A Exactly.
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Okay.
A I was not.
SSCE0003996
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6 A I have no idea.
7
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10 A
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I want to show you a document,
and I believe we're on M-16 now, and Bates number
is 0013464.
(Exhibit 11116 identified.)
: And it goes to 001365.
Here you go,
Who is
: Thank you.
THE WITNESS: Okay.
BY
.111.-SSCE0003997
1
Q
Would you describe the document for the
2 record, please.
3 A
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Q
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-SSCE0003998
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A
A Right, uh-huh.
A
222
1111111
SSCE0003999
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3 A
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8
(Exhibit 11117 identified.)
BY
Let me show you what we've marked as
224

9 11117, and the Bates number is 001149.

10

(Witness reviewed the document.)

11

A Okay.
12
13

14 A
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III=111-SSCE0004001
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5 A
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8 Q
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10 A
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: What we're going to do is take
14 about five minutes, and then we'll come back in. If
15 any of us have follow-up questions from earlier
16 today, we'll follow up, but we're going to wrap it
17 up.
18 (Recess.)
19 : Back on the record.
20 BY
21 Q And for the last time today, I'm going to
22 remind you that you are still under oath, of course.
23 A Yes.
24 Q We have some follow-ups and we'll just
25 take turns.
26
IIIIII
-SSCE0004002
(Exhibit 11[18 identified.)

2 BY

3
Q
I'm going to show you a printout from

4 moments ago of an article, I think you can see in

5 the URL line at the bottom that it's a November 24,

6 2009 article, printed off the Internet.


8

9 A Yes, uh-huh.

10
Q
You're free to look at the entire article,

11 but I'll be asking you about the very last paragraph

12 on the second page.

13 A Okay.

14 (Witness reviewed the document.)

15 Okay.

16
Q
Have you had a chance to review that?

17 A Yes.
18
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226
227
1

A Let me think here.

I should ask first, do you recall that

statement?

A Yes, I d
6
7

Q Let's try it this way.


10
11

12

A
13
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22

Maybe if I go through all the documents,

23

it will refresh my memory. I just can't --


24
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EIRSSCE0004004
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Q
Let me focus specifically, and I'll narrow
11 it down.
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17 A
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20 A
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Q
Okay.
23
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228
SSCE0004005
Do you recall that?
A Right, right.

1 A I think I just thought it was a different

2 way to describe it.

3
Q
Okay. That's fine.
4
5

6 A I don't remember a conversation of that

7 specifically.
8
9
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12

13

A I'm sorry, repeat that question.

14
Q
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Q
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23 A
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Mill
-SSCE0004006
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8 A
9

10 BY

11
Q
1
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3

14 A Yes, yes.
15
16
17

18 A If I can remember correctly, that was when

19 I was -- I was not working for him. So yeah, I

20 don't remember specific conversations on that.


21

: Thanks.
22

BY 11111111111111111
23
24
25 A Sure.
26
-SSCE0004007
1
Q So if I could take you back all the way to

2 June 15 of 2009, when you and others met with the

3 Senator at the C Street residence.

4 A Uh-huh.

5
Q
6
7

8 A Right.

9
Q
10

11 A Okay.
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-SSCE0004008
A

To be honest --
A
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Q Now, we have to be careful with the record
15 here, so to make sure that the record is clear.
16 A Sure.
17
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19 A
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-SSCE0004009
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8

9
Q
Well, did the Senator mention an

10 intervention meeting on the night of the 15th?

11 A Yes, yeah, he did. But it was very quick.


12
13
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18

19 Q Okay.
20
21

22 A
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SSCE000401 0
1
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6

7 Q Okay.
8
9
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11
Q
For the record,

12 A
13
14

15
Q
The C Street house --

16 A
17
18
19

20 A
21
22

23 A

24
Q
And Senator Ensign?

25 A Yes.
26
.11-SSCE0004011
1
Q
2 A Yes.
3 Q Okay.
4 A
5
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A
INIMISSCE0004012
235
236

A
2

A I'm sorry, repeat your question.

Okay.
5
6

A I don't remember that specific

8 information.

9

10 Q Right.

11

A Yeah, I don't remember.

12
Q
Let me ask you to take a look at Exhibit

13 III[17, which is in front of you there.

14 A Yeah.

15
Q
11[ 17
16

17 A Uh-huh.

18 Q Right.
19

20 A Uh-huh.

21
Q
22
23
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SSCE000401 3
4
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6

A
9

10
QOkay' 1.111111111111111111111.1.111IM
11
12

13 A I guess.
14
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18 BY
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=I.SSCE0004014
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Yes, yeah.
BY
To -- John Ensign mentioning that to me?
Yes.
Yes.
A No.
238
A
A
.1111.-SSCE000401 5
1 A
239
2
BY
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A
4
A Yeah.
Q
.1111-SSCE000401 6
7
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10 A
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17
BY
Are you aware that there was an article
1
2
3
4
5
240
A

18 published in The Hill on Wednesday, the 23rd,
19 regarding depositions that were being --
20 : 23rd of what month?
21
BY 11111111:
22
Q
Of June, I'm sorry.
23 A This year?
24
Q
Yes, last week -- two weeks ago now. Time
25 is flying by so fast, I'm sorry, with regard to
26
-SSCE0004017
1 depositions in this matter?

A Yes, I was aware.

Did you read the article?

A Yes.
5
6

7 A
8

Q1111111111111111111111111111111111111111111111

10 A

11
Q
And I don't want to read the whole thing

12 in detail, but I just am going to read a couple of

13 selections to you.

14 A Sure.

15
Q
The article opens by saying, "in

16 depositions to the Senate Ethics Committee, staffers

17 for Senator John Ensign have said that the

18 Republican and his senior aides knew a one-year

19 lobbying ban was being broken when they helped a

20 former staffer set up a short-lived career on

21 K Street, according to two sources close to the

22 investigation."

23 I guess my first question is, do you have

24 any idea who the sources could be?

25 A
26
241
MIIIISSCE000401 8
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depositions in this matter?
A Yes, I was aware.
Q Did you read the article?
A Yes.
Q
A
Q
A
Q And I don't want to read the whole thing
in detail, but I just am going to read a couple of
selections to you.
A Sure.
Q
I guess my first question is, do you have
any idea who the sources could be?
A
III.1..SSCE000401 8
1
Q
And did you have any response to the -- as
2 to the truth of that statement, the notion that --
A 1111.111IIII
242
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A
But yeah, no.
-SSCE000401 9
7
Q
8
9
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14 BY

15
Q
16
17
18

19 A No.

20
Q
21
A Oh, no.
1
2
Q
I understand.
3 A
4
5
243
22 A No. Nobodywanted to talkafter that.
23
Q
24
25 A
26
-SSCE0004020
1
2

A
3
A
= 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1
A
111111111111111111.111111111111111111.11111
A
Yes.
A
A
11.11-SSCE0004021
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12 A
13
14
15
A But that's not the same --
245
16
Q
In response to that inquiry, do you have
17 any further information about that event?
18

A No, no.
19
20 A
21
22
23
24

111111lit Well, we've been


25 here together for some time today, to ask you about
26
-SSCE0004022
2
1

3 Anything that we haven't asked you about

4 today that relates to this matter that you can share

5 with us?

6 THE WITNESS:

7 No.

8 Actually, three housekeeping

9 things to tell you. Number one, as I mentioned, you

10 all are welcome to come back and review the

11 transcript for errors, so that can be done here in

12 our offices. Your counsel can just give us a call

13 and that can happen, okay?

14 THE WITNESS: Sure, thank you.

15 Give us about a week or so.

16 THE WITNESS: Okay.

17 Also, I just wanted to remind

18 you again that our rules of confidentiality don't

19 extend to you, but that we request that you don't

20 disclose any of our questions and your answers with

21 anyone else so that we can maintain the integrity of

22 our investigation.

23 THE WITNESS: Absolutely.

24 NM: And then finally, we are still

25 receiving documents in this matter, so although it


26
246
II=11-SSCE0004023
1 seems unlikely, we can't promise we won't need to

2 have you come back in here and answer a few

3 questions.

4 : Plus we still have the

5 outstanding privilege issue.

6 : Yes. Of course, finally, there

7 is a privilege issue that was -- questions were

8 suspended with regards to, and we' will follow up

9 with that within an appropriate time frame.

10 THE WITNESS: Okay Thank you.

11 Thank you for your time today.

12 We are off the record.

13 (Whereupon, at 4:10 p.m., the deposition

14 was concluded.)
15
16
17
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23
24
25
247
IIIIM-SSCE0004024
1 I HEREBY CERTIFY that I have read this

2 transcript of my deposition and that this transcript

3 accurately states the testimony given by me, with

4 the changes or corrections, if any, as noted.


6

7 X
8
9
10

11 Subscribed and sworn to before me this day of

12 , 20
13
14
15

16 X

17 Notary Public
18
19
20

21 My commission expires:
22
23
24
25
248
-SSCE0004025
1
2
3
CONTENTS
WITNESS EXAMINATION
4 by111111111111111111
5
111111111111111
5
6
7 EXHIBITS
8 EXHIBIT NUMBER IDENTIFIED
9 Exhibit 1111 8
10 Exhibits 1112A, and-2C 54
11 Exhibits-3A, III3B 72
12 Exhibit 4 83
13 Exhibit 5 92
14 Exhibits III7A and 7B 120
15 Exhibits 1118A and III8B 125
16 Exhibit 148
17 Exhibit 10 171
18 Exhibit 11 175
19 Exhibit 12 194
20 Exhibit 13 197
21 Exhibit 14 213
22 Exhibit 15 213
23 Exhibit 16 220
24 Exhibit 17 224
25 Exhibit 18 226
11111M-SSCE0004026

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