Klayman v Judicial Watch FLSD 1:13-cv-20610 127_1

EXHIBIT “1”

Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 of 243

In The Matter Of:

LARRY E. KLAYMAN

v.

JUDICIAL WATCH, INC.

___________________________________________________

GEORGE MILLER ‐ Vol. 1 May 23, 2014

___________________________________________________


GEORGE MILLER - 5/23/2014

1-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New York

Page 1

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

LARRY E. KLAYMAN, ) ) Plaintiff, ) ) -vs- ) CASE NO. ) 13-20610-CIV- JUDICIAL WATCH, INC., ) ALTONAGA/Simonton ) Defendant. ) _________________________________)

DEPOSITION OF GEORGE MILLER

FRIDAY, MAY 23, 2014

7:40 a.m.

REPORTED BY: ERIKA SJOQUIST, C.S.R., R.P.R., C.R.R.C.S.R. No. 12350




Page 2

1 DEPOSITION OF GEORGE MILLER, VOLUME 1, TAKEN AT 7:40

2 A.M., FRIDAY, MAY 23, 2014, AT 5700 RALSTON, SUITE 100,

3 VENTURA, CALIFORNIA, BEFORE ERIKA A. SJOQUIST, C.S.R.,

4 R.P.R., C.R.R., C.S.R. NO. 12350, CERTIFIED SHORTHAND

5 REPORTER, IN AND FOR THE STATE OF CALIFORNIA.

6

7

8 APPEARANCES OF COUNSEL:

9FOR THE PLAINTIFF:

10 LARRY KLAYMAN, ESQ.

11 ATTORNEY AT LAW IN PRO PER

12 2520 CORAL WAY, SUITE 2027 MIAMI, FLORIDA 33145

13 310-595-0800 [email protected]

14 (VIA VIDEO CONFERENCING)

15ALSO PRESENT: DINA JAMES, PARALEGAL TO MR. KLAYMAN


17FOR THE DEFENDANT:

18 SCHWED KAHLE & KRESS, P.A.

19 DOUGLAS J. KRESS ATTORNEY AT LAW

20 11410 NORTH JOG ROAD, SUITE 100 PALM BEACH GARDENS, FLORIDA 33418

21 561-694-0700 [email protected]


23

24

25




Page 3

1 I N D E X

2 DEPONENT EXAMINATION PAGE

3 GEORGE MILLER (MR. KRESS) 5, 135 (MR. KLAYMAN) 128

4

5

6

7 E X H I B I T S

8 NO. PAGE DESCRIPTION

9 Exhibit 1 95 Cuyahoga County Court of Common Pleas Criminal Court Division,

10 True Bill Indictment for Criminal Nonsupport - F5

11 State of Ohio vs. Larry Klayman

12 Exhibit 2 82 Cuyahoga County Prosecutor web page - Press Release -- 2/3/12

13Exhibit 3 95 Court of Common Pleas Division of

14 Domestic Relations Cuyahoga County, Ohio, Case No. DR07

15 316840, Judgment Entry Re: 7/28/2009

16Exhibit 4 96 Court of Common Pleas Division of

17 Domestic Relations Cuyahoga County, Ohio, Case No. DR07

18 316840, Judgment Entry Re: 7/2/2010

19Exhibit 5 102 Case No. DR07 316840, 2/22/2010

20 Capias Ordered for Plaintiff Larry Elliot Klayman

21Exhibit 6 24 2/8/2012 e-mail from Larry

22 Klayman to George J. Miller, re: Retention Agreement with Klayman

23 Law Firm

24 Exhibit 7 40 5/7/2012 e-mail string between George Miller and Larry Klayman

25 Re: Voeltz vs. Obama, et al -




Page 4

1 Exhibit 8 37 7/23/12 Klayman Law Firm Billing Statement

2Exhibit 9 43 9/12/12 e-mail from Larry Klayman

3 to George Miller, re: Retention Agreement with Klayman Law Firm

4Exhibit 10 5 Conwebwatch web page - "Larry

5 Klayman, Failed Lawyer" - 8/10/12

6 Exhibit 11 5 The Nation web page - "Klayman Watch" - 7/10/07

7Exhibit 12 5 Miami New Times web page - "Larry

8 Klayman, Conservative Wingnut Lawyer, Gets Reprimanded By

9 Florida Bar, Is Broke" - 11/1/11

10 Exhibit 13 5 Renew America web page - "The good virgin's birther case" -

11 12/8/12

12 Exhibit 14 47 Orly Taitz, Esquire web page - "My yesterday's presentation to

13 CCIR and update on article2SuperPAC-Larry Klayman

14 $25,000 fundraising for non-existent law suit affair" -

15 2/23/2012

16 Exhibit 15 104 Orly Taitz, Esquire web page - "Clarification regarding

17 article2legal fund and Larry Klayman" - 2/26/2012

18

19

20 INSTRUCTION NOT TO ANSWER: 15:20, 16:17, 19:20, 20:2, 20:9, 83:17, 87:17, 87:24

21

22

23

24

25




Page 5

1 VENTURA, CALIFORNIA

2 FRIDAY, MAY 23, 2014

3 7:40 a.m.

4

5

6 (Exhibits 1 - 15 premarked before deposition.)

7

8 GEORGE MILLER,

9 HAVING BEEN FIRST DULY SWORN BY THE REPORTER, WAS

10 EXAMINED AND TESTIFIED AS FOLLOWS:

11

12 DIRECT EXAMINATION

13

14 BY MR. KRESS:

15 Q Good morning, Mr. Miller.

16 A Good morning.

17 Q My name is Doug Kress, and we met via video

18 conference just a few minutes ago. I represent Judicial

19 Watch in a lawsuit filed by Larry Klayman. And this

20 morning, I'm going to take your deposition.

21 And since we are doing this by video

22 conference, it's important that we take our time and try

23 not to speak at the same time because that would become

24 confusing for both of us and difficult for the court

25 reporter. And I'll ask you to follow that rule as well




Page 6

1 as a few additional ground rules.

2 If I ask you a question, please answer it out

3 loud and clearly so we can all hear you and so the court

4 reporter can take it down for the record. If the

5 question calls for a "yes" or "no," please try to say

6 "yes" or "no" as opposed to "huh-uh" or "uh-huh" because

7 those get confusing.

8 If you do not understand me, do not answer the

9 question. Tell me you don't understand, and I will

10 rephrase it so you do understand. Uhm, if you should

11 need a break for any reason, let us know, and we will

12 let you take a break.

13 A Yes.

14 Q Do all the rules sound fair and reasonable to

15 you?

16 A They do.

17 Q Okay.

18 MR. KLAYMAN: And I might add, Mr. Miller, I'm

19 counsel for myself, pro se, Larry Klayman, as you know.

20 Before you ask a question, pause to give me an

21 opportunity to object if I need to make an objection.

22 THE WITNESS: Yes.

23 MR. KLAYMAN: And try to look into the camera

24 as much as you can.

25 BY MR. KRESS:




Page 7

1 Q What is your address, Mr. Miller?

2 A 2041 Jamestown Way, Oxnard, California.

3 Q And how old are you?

4 A Sixty-six.

5 Q Can you tell me about your professional

6 background or work experience? I'll let you just tell

7 me instead of trying to ask you a bunch of questions

8 about it.

9 A I'm retired now, but originally, I was a

10 mechanical engineer and transitioned into manufacturing

11 operations in the 1960s; worked in the consulting field

12 for firms like Booz Allen Hamilton in New York.

13 I came out to California in 1980 to run an

14 operation locally, and started my own business in 1986

15 and ran that until I retired around 2010.

16 Q What was the name of your business?

17 A I had two businesses; one was Proaction

18 Management Consultants, and one was The Facilitative

19 Group, both involved in similar businesses of operations

20 management consulting.

21 Q Proaction Management & Consultants, and what

22 was the other one?

23 A Proaction, not "proactive."

24 Q Okay. Proaction Management Consultants?

25 A Proaction, T-I-O-N.




Page 8

1 Q Okay. I think that's what I'm saying.

2 A Okay. It's not coming across.

3 Q Management Consultants?

4 A Correct.

5 Q And the other one was the --

6 A Facilitator.

7 Q -- Facilitator Group?

8 A Facilitator Group, correct.

9 Q What was the nature of the business of

10 Proaction Management Consultants?

11 A Operations management consulting and related

12 business systems.

13 Q What's that mean in lay terms?

14 A Operations management consulting is the science

15 of managing a manufacturing business and all the related

16 systems required to provide the information to support

17 that.

18 Q Okay. And what -- what was the nature of the

19 business of The Facilitator Group?

20 A It was almost identical.

21 Q So, also operations management?

22 A Consulting, right.

23 Q Were both businesses located in California?

24 A Yes.

25 Q Did they operate outside of California?




Page 9

1 A Mostly outside of California and outside of the

2 USA.

3 Q Okay. Did they operate in Florida?

4 A We have done work in Florida.

5 Q What kind of work have you done in Florida?

6 A Mostly --

7 MR. KLAYMAN: Objection. Relevancy.

8 THE WITNESS: -- onsite analyses of

9 manufacturing firms, providing information on operations

10 management, and consulting in compliance with government

11 contracting regulations related to finance and

12 operations.

13 BY MR. KRESS:

14 Q Okay. So your education I believe is as a

15 mechanical engineer?

16 A That's right, originally. And then I took some

17 business courses subsequently since I drifted into

18 business in the late 1960s.

19 Q And you retired in 2010, you said, correct?

20 A Yes. I actually kind of phased my work out

21 because I was spending more and more time on political

22 activism and less and less time on work, and I just

23 thought it was more important. So I stopped working and

24 focused on this just about exclusively.

25 Q Okay. So now, do you consider yourself to be a




Page 10

1 political activist?

2 A Yes.

3 Q Tell me the nature of your activities as a

4 political activist?

5 MR. KLAYMAN: And George, I instruct you just

6 to answer the questions that he's asking you, okay?

7 THE WITNESS: Yes, okay.

8 MR. KLAYMAN: Okay.

9 THE WITNESS: I originally started off in about

10 -- in 2008 or 2009, I was very upset because of the

11 economic crash and the huge detrimental effect it had on

12 my investments. So I started studying why that occurred

13 and how the markets were made to crash, how real estate

14 crashed, how the stock market crashed, how currencies

15 were manipulated, and how that related to election

16 politics. And I concluded that some of that really

17 didn't have to occur at all.

18 And then after that, the national election came

19 up, and Obama was elected. And during my studies, I

20 found out this was really not a good guy to be running

21 the country at all. So I began to actively oppose that

22 at the national level, and that's really what led me,

23 ultimately, to meet -- to meet Larry Klayman.

24 I also, when this tea party movement started in

25 2009, I joined a tea party initially to take action. At




Page 11

1 that time, people weren't very politically

2 sophisticated. We were mostly new to this. We knew

3 nothing about what was going on at all. That was quite

4 an eye opener. I subsequently started the Ventura

5 County Tea Party later in 2010. And part of our

6 activity is that the membership voted that we should

7 investigate Obama more thoroughly, which we did. And in

8 carrying out the wishes of the membership, we,

9 ultimately, worked on engaging Larry to support some of

10 the cases at the national level as well.

11 And then I was also involved in local politics,

12 being involved -- working with one of the major

13 political parties, the Republicans. You know, they were

14 both pretty bad, but Republicans looked a little -- a

15 little less worse. And I was a state delegate. I was a

16 member of different political organizations. I

17 campaigned for various candidates. I wrote publicity

18 for various candidates.

19 And then last year, we -- we ended up starting

20 a newspaper because we felt there really wasn't good

21 news in Ventura County at all. And I spend a lot of my

22 time on that now as well.

23 BY MR. KRESS:

24 Q What's the name of the newspaper?

25 A CitizensJournal.US.




Page 12

1 Q Is it an online paper then --

2 A Yes.

3 Q -- or is it a -- okay.

4 A It is online.

5 Q And what is your role in the Citizens Journal?

6 Are you publisher or?

7 A I am the publisher.

8 Q Have you been elected to any political offices?

9 A I don't really have the -- the demeanor or the

10 desire to be in elective office. I work behind the

11 scenes.

12 MR. KLAYMAN: George, when I question asks for

13 a "yes" or "no," just give a "yes" or "no."


15 MR. KLAYMAN: That's what I'm directing you.

16 BY MR. KRESS:

17 Q Mr. Miller, are you represented by counsel for

18 the purposes of this deposition?

19 A I'm sorry. For what? For this deposition?

20 Q For this deposition, are you represented -- are

21 you represented by counsel?

22 MR. KLAYMAN: I'll stipulate to that. He's

23 represented by me.

24 BY MR. KRESS:

25 Q So, it's your belief you are represented by




Page 13

1 Mr. Klayman in this matter?

2 MR. KLAYMAN: For purposes of the deposition.

3 THE WITNESS: For this deposition. I don't

4 feel he, you know, he's representing me as a client or

5 anything like that. But I've been in contact with him

6 about it, and we have similar interests in this matter.

7 BY MR. KRESS:

8 Q Are you -- are you compensating Mr. Klayman for

9 his assistance to you in this deposition?

10 A No.

11 Q Paying him?

12 A No.

13 Q Is he paying you in any fashion for testimony?

14 A No.

15 MR. KLAYMAN: I'll let you answer that.

16 That's a totally objectionable question,

17 Mr. Kress. It invades the attorney-client privilege and

18 invades work product.

19 MR. KRESS: Well, are you his -- are you

20 stating --

21 MR. KLAYMAN: He just answered the question.

22 You can go on, Mr. Kress.

23 MR. KRESS: Are you stating you are his

24 attorney?

25 MR. KLAYMAN: For purpose of this deposition,




Page 14

1 yeah, I just stipulated to that.

2 MR. KRESS: Okay. Are you his attorney for

3 purposes of trial?

4 MR. KLAYMAN: I will be representing him for

5 purposes of trial in terms of objecting to your

6 questions, yes, because I'm a plaintiff pro se. And I

7 have a right to object to the questions.

8 MR. KRESS: I understand you have a right to

9 object, but --

10 MR. KLAYMAN: I am not being deposed,

11 Mr. Kress. Move on.

12 MR. KRESS: I'm just -- I'm trying to determine

13 whether I should ask questions. Like, for instance --

14 MR. KLAYMAN: That's as far as you are going to

15 get because you are getting into attorney-client

16 privilege.

17 MR. KRESS: All right. Well, I'm going to ask

18 this question. I'm sure you are going to object and

19 instruct him not to answer, but...

20 BY MR. KRESS:

21 Q Before the deposition began, you stepped out

22 and spoke privately to Mr. Klayman, correct?

23 MR. KLAYMAN: You can answer that, George, but

24 not the substance of the conversation.

25 THE WITNESS: Well, he approached me about the




Page 15

1 trial and asked me if I would --

2 MR. KLAYMAN: No, no. That calls for a "yes"

3 or "no," George.

4 MR. KRESS: Well, and I'll get into that later.

5 MR. KLAYMAN: When a question asks "yes" or

6 "no," you respond either "yes" or "no."

7 THE WITNESS: Would you ask the question again,

8 Mr. Kress?

9 BY MR. KRESS:

10 Q I will, yes.

11 Before we began here, we were sitting in the

12 room, and then Mr. Klayman called you privately, and you

13 went and stepped into another room and spoke to

14 Mr. Klayman, correct?

15 A I did, yes.

16 Q What did you talk about?

17 MR. KLAYMAN: You are not -- instruct you not

18 to answer.

19

20 (Witness instructed not to answer.)

21

22 MR. KRESS: All right. We may address that

23 later.

24 THE WITNESS: May I say something? May I say

25 something?




Page 16

1 MR. KLAYMAN: No, you may not.

2 THE WITNESS: Okay. It's really quite simple.

3 MR. KLAYMAN: I instruct you not to answer.

4 Okay. That's work product, attorney client.

5 MR. KRESS: Uhm...

6 MR. KLAYMAN: Just answer questions.

7 THE WITNESS: Which question?

8 MR. KLAYMAN: There's no question pending.

9 MR. KRESS: There's no question pending, but

10 one will be coming.

11 BY MR. KRESS:

12 Q When did Mr. Klayman first approach you about

13 testifying in this case?

14 MR. KLAYMAN: You are not to respond to that.

15 George, you are not to respond to that. Okay?

16


18


20 MR. KLAYMAN: That's attorney-client privilege.

21 MR. KRESS: I think we might to have the court

22 intervene. This is a witness.

23 MR. KLAYMAN: That -- I'm representing him for

24 purposes of this deposition.

25 MR. KRESS: All right. We -- I'm going get




Page 17

1 through the substance of it, and then we may have to

2 call --

3 MR. KLAYMAN: We can talk about it, but get

4 your questions out there.

5 MR. KRESS: Because he's a -- he's a -- he's a

6 witness. I mean, you can't prevent me from finding out

7 what was discussed with the witness by saying there's an

8 attorney -- you are his attorney.

9 MR. KLAYMAN: Yes, I can because that's

10 attorney-client privilege, Mr. Kress.

11 BY MR. KRESS:

12 Q Do you have any type of fee agreement or

13 retainer agreement with respect to -- with Mr. Klayman

14 with respect to this deposition or the testimony at

15 trial?

16 MR. KLAYMAN: You can answer that.

17 THE WITNESS: We have no financial agreement.

18 BY MR. KRESS:

19 Q Any written agreement whatsoever?

20 A We have no --

21 MR. KLAYMAN: You can answer that.

22 THE WITNESS: We have no written agreement.

23 BY MR. KRESS:

24 Q What verbal agreement do you have, if any?

25 A Well, I was asked if I would testify on this




Page 18

1 matter, and I said that I would.

2 Q Okay.

3 A And he said --

4 Q When was that?

5 A This goes way back. This is two years ago when

6 these events happened. At the time, we both were

7 extremely upset at the lies told by your company. And

8 at that time, Larry said that he was going to sue. I

9 didn't believe him. So, I really had no idea this would

10 ever happen, I'd be sitting here today, but at the time,

11 I said, "If you need help, I will testify as to what

12 happened and what was done to -- to our fundraising

13 effort for Article II PAC, for Constitution Action Fund,

14 for our case, for Michael Voeltz, for our boarded case

15 in California, and that you people really screwed up big

16 time. So, yes, I was very motivated to testify. Any

17 other questions?

18 Q I have a lot of questions.

19 A Go ahead.

20 Q We are going to be -- we're going to be here

21 for a while.

22 A Okay.

23 MR. KLAYMAN: Please avoid the sarcasm,

24 Mr. Kress.

25 MR. KRESS: He asked me if I had more




Page 19

1 questions.

2 MR. KLAYMAN: That's fine, but no more sarcasm.

3 Just be -- just be a gentleman to my client.

4 MR. KRESS: I am being a gentleman with your

5 client.

6 MR. KLAYMAN: Thank you.

7 BY MR. KRESS:

8 Q And -- okay. Do you intend to travel to

9 Florida for the trial?

10 A Excuse me?

11 Q Do you intend to travel to Florida for the

12 trial?

13 A It was my intention I had to go to Miami for a

14 trial, which has been postponed once already.

15 Q Who is paying for your airfare?

16 A It's my impression --

17 MR. KLAYMAN: You are not to answer that. You

18 are not to answer that.

19


21

22 BY MR. KRESS:

23 Q Are you paying for your own airfare?

24 MR. KLAYMAN: You are not to answer that.

25 Attorney-client privilege.




Page 20

1


3

4 BY MR. KRESS:

5 Q Who is paying for your hotel when you are here?

6 MR. KLAYMAN: You are not to answer that.

7 Attorney-client privilege.

8


10

11 BY MR. KRESS:

12 Q Okay. When did you first meet Larry Klayman?

13 A I first met Larry Klayman in December of 2011,

14 but I had -- face to face.

15 Q Okay. Did you speak to him or communicate with

16 him before December 2011?

17 A Yes.

18 Q And in what circumstances did you speak to him

19 prior to December of 2011?

20 A Well, you know, Larry's a very famous person,

21 having been the founder of the organization, which now

22 pays you. And he's been involved extensively in various

23 causes for liberty and justice. And I've always been a

24 great admirer of Larry, and I contacted him a couple of

25 times, once when he was running a rally in Washington,




Page 21

1 DC. And numerous times, I tried to get him to work for

2 us to take on cases, but it wasn't until December

3 of 2011 where I actually met him and was able to talk in

4 detail about it.

5 Q Okay. So, you -- but you contacted him before

6 that and tried to get him to help you?

7 A Excuse me?

8 Q You had contacted him before December of 2011

9 and sought his assistance, correct?

10 A Correct.

11 Q In other matters?

12 A Yes.

13 Q Tell me what occurred in December of 2011 with

14 respect to Mr. Klayman?

15 A Well, I met him, and I immediately brought up

16 the topic, which is of mutual interest. I told him what

17 we were trying to accomplish. He indicated that he

18 agreed with it. And I asked him if he would consider

19 representing us, and he was amenable to that. And we

20 met the following week and worked out a tentative

21 agreement, which I then had to get ratification for from

22 my group of people.

23 So, we had a major teleconference after that,

24 and we agreed -- we hammered out the details of how it

25 would work, and then we moved forward from there.




Page 22

1 Q Who is your group?

2 A Well, uhm, at that time, I was involved in the

3 Obama Ballot Challenge effort, which was a national

4 group, a very loose affiliation of people, who

5 communicated by telephone and e-mail. And we started

6 off with the New Hampshire Ballot Challenge, since

7 that's the first one in the country, and developed some

8 relationships during that time.

9 I was also the lead person that ran a website

10 called "Obama Ballot Challenge" that attempted to report

11 on what was happening in that movement and also reported

12 -- attempted to motivate people to get involved in the

13 movement, to contribute money, to contribute legal

14 services, to file cases all over the nation.

15 And then subsequently, I was involved with some

16 different organizations that were being used as vehicles

17 to raise funds.

18 Q So, you've extensively worked on the Obama

19 challenges even before communicating with Mr. Klayman,

20 correct?

21 A Yes, yes.

22 Q For instance, Mr. Klayman was not involved in

23 the New Hampshire matter?

24 A I don't know if he was or not.

25 Q Well, you didn't involve him in the New




Page 23

1 Hampshire matter, did you?

2 A No. No, I didn't.

3 Q You're an admirer of Larry Klayman?

4 A Yes.

5 Q Are you a friend of Larry Klayman?

6 A I would consider myself a friend now just

7 because we've worked together and been through a lot of

8 battles together.

9 Q Okay.

10 A I mean, he hasn't been to my house. I haven't

11 been to his house or anything like that, but, you know,

12 we are on very -- we are on good terms.

13 Q Okay. What was the -- you talked -- you talked

14 about a couple of these groups.

15 What was the name of the group that was looking

16 to hire Larry Klayman?

17 A The name of the group. It was just some

18 individuals, you know. We are just people. We didn't

19 have a corporation. We didn't have an organization.

20 Q Who are the names -- who are the names of the

21 people?

22 A Well, there are really dozens of people. But

23 the ones that were most centrally involved in the

24 organization were myself, Captain Pamela Barnett, Sam

25 Sewell. We are the ones that actually formed the




Page 24

1 fundraising organization. There were many others

2 involved, too.

3 One of the things we had to do is figure out

4 which cases we were going to work on. So, some people

5 submitted different cases; among them, Mike Voeltz from

6 Florida, and Pamela Barnett for the California case.

7 Those are the two cases that we initially wanted to have

8 Larry represent us on. And then we had delusions of

9 grandeur, it turned out because we wanted to have him go

10 through several states and work with lawyers in

11 different states and have more of a coordinated effort.

12 And you, folks, did a really good job of sabotaging that

13 for us. Thank you.

14 MR. KRESS: Move to strike as nonresponsive.

15 MR. KLAYMAN: It was responsive.

16 BY MR. KRESS:

17 Q So, let's go to the exhibits, Mr. Miller. Do

18 you have those in front of you?

19 A I do, yes.

20 Q Can you, please, go to Exhibit 6?

21

22 (Exhibit 6 identified.)

23

24 A Yes. The retention agreement?

25 Q Yes. Okay. You are familiar with this




Page 25

1 document, correct?

2 A Yes.

3 Q It's an e-mail from Larry Klayman to you, dated

4 February 8, 2012, correct?

5 A That's correct.

6 Q And is this -- is this the only retention

7 agreement that you have with Mr. Klayman related to the

8 Obama cases?

9 MR. KLAYMAN: Objection. Assumes facts not in

10 evidence. Leading.

11 BY MR. KRESS:

12 Q You can answer.

13 MR. KLAYMAN: You can answer. That's a legal

14 objection.

15 THE WITNESS: Yes, as far as I know.

16 BY MR. KRESS:

17 Q Okay. Let me ask it a different way. I just

18 want to try to avoid any objections.

19 Did -- did you, personally, enter into any

20 other agreements with Larry Klayman with respect to

21 Obama litigation?


23 evidence. Leading.

24 You can respond.

25 THE WITNESS: No.




Page 26

1 BY MR. KRESS:

2 Q Okay. Did you hire Larry Klayman to file an

3 Obama challenge?

4 A Well, it depends on what you mean by "you." I

5 did not personally take on any obligation, but I did

6 commit our fundraising efforts to do that. And many

7 people attempted to help me with that, and we intended

8 to raise enough money to not only do the Voeltz case,

9 but the California case and cases in other states as

10 well; and, if necessary, take this to the Supreme Court,

11 which we knew would be quite expensive, you know, beyond

12 our personal means to finance. So we needed to raise

13 funds from people who were motivated to act on this.

14 Q Okay. Well, the letter that's before us, as

15 Exhibit 6, is only -- you are the only recipient of the

16 letter, correct?

17 MR. KLAYMAN: Objection. Leading. Assumes

18 facts not in evidence. And document speaks for itself.

19 BY MR. KRESS:


21 MR. KLAYMAN: You can answer.

22 THE WITNESS: I was the point person.

23 MR. KLAYMAN: It was an improper question, but

24 you can answer that. Okay.

25 THE WITNESS: Okay. Answer an improper




Page 27

1 question. I was the point person on this thing. I was

2 the one that was the entrepreneur that found Larry

3 Klayman, met Larry Klayman, made the proposal,

4 marshalled the resources, wrote the agreements, but

5 other people were involved in this as well.

6 BY MR. KRESS:

7 Q Okay. And the other people, you mentioned

8 Pamela Barnett and Sam Sewell.

9 Anyone else that you can identify?

10 A I'm not sure I want to identify them and drag

11 them into this thing unless that's necessary for the

12 case.

13 MR. KLAYMAN: You can identify them, George.

14 THE WITNESS: I can answer it?

15 MR. KLAYMAN: You can identify them, George.

16 Yeah, you can answer.

17 THE WITNESS: Okay. Well, for example, the

18 following week after I met Larry Klayman, Tony Dolz

19 (phonetic) accompanied me for the negotiations to hammer

20 out the scope of the case and the financial arrangements

21 in Beverly Hills, meeting Larry Klayman.

22 BY MR. KRESS:

23 Q Let's go through the process of hiring Larry in

24 a little more detail. You communicated with him in

25 December of 2011. And then was that by phone or -- that




Page 28

1 was in person, correct?

2 A I met him in person at the time.

3 Q Okay. What happened next with respect to

4 hiring Larry Klayman, either through you or through a

5 group you are affiliated with?

6 A Well, I followed up with a call, which he did

7 not respond to. And I had a mutual friend call him and

8 persuade him to talk to me. And then we talked, and

9 then we established a meeting, a face-to-face meeting in

10 Beverly Hills, which we did that -- the very next week,

11 I think, or maybe the week after. I can't remember the

12 exact chronology.

13 And then I had to go out to our followers and

14 -- and I communicated to them the essence of what Larry

15 wanted to do and what we had tentatively agreed on with

16 Tony, and we got agreement from a lot of people to do

17 that because they said they would help spread the word

18 and raise the money, and they were in accord with what

19 Larry and I wanted to do.

20 Q Okay. So, there's this collective effort to

21 hire Larry.

22 MR. KLAYMAN: Please don't characterize his

23 testimony.

24 MR. KRESS: Larry --

25 MR. KLAYMAN: That's improper.




Page 29

1 MR. KRESS: Let me just as the questions.

2 BY MR. KRESS:

3 Q Who hired Larry to represent -- who hired Larry

4 for the purposes of the Florida Obama litigation?

5 A Well, this group of people, basically.

6 Q Okay. Is there a written agreement with --

7 between Larry and a group of people?

8 A The only thing we have is this document --

9 MR. KLAYMAN: Asked and answered. George --

10 MR. KRESS: Please let him answer.

11 MR. KLAYMAN: I'm allowed to make an objection.

12 MR. KRESS: You can object to the form.

13 MR. KLAYMAN: I am. Asked and answered.

14 THE WITNESS: Excuse me? Answer it?

15 MR. KLAYMAN: Objection is asked and answered,

16 George.

17 BY MR. KRESS:

18 Q And you can answer the question, which is --

19 MR. KLAYMAN: Yeah, after I make the objection,

20 you can answer the question.

21 MR. KRESS: Of course.

22 THE WITNESS: Yeah, it was understood with the

23 group I was speaking for them. So we perceived the

24 agreement was the group, and that our commitment was to

25 raise funds through our fundraising vehicles, which




Page 30

1 would fuel this effort.

2 BY MR. KRESS:

3 Q Who is the client?

4 A Who was the client?

5 MR. KLAYMAN: That's both a legal conclusion

6 and calls for legal conclusion.

7 MR. KRESS: Larry, you are being very invasive

8 and --

9 MR. KLAYMAN: You are asking improper

10 questions, Mr. Kress.

11 MR. KRESS: No, I am not.

12 BY MR. KRESS:

13 Q Who was the client?

14 MR. KLAYMAN: I'm allowed to object.

15 MR. KRESS: You are allowed to object to some

16 extent.

17 MR. KLAYMAN: I will object, and please be

18 respectful to me as well as my client, and let me make

19 my objection. Do not talk over me. That's

20 attorney-client privilege.

21 MR. KRESS: Not who the client was.

22 MR. KLAYMAN: He already testified. Asked and

23 answered. He already testified to it.

24 MR. KRESS: I don't think we do --

25 BY MR. KRESS:




Page 31

1 Q What -- what's the name of the client?

2 MR. KLAYMAN: You can answer the question,

3 George, that's fine, but I have to make a question, so

4 please -- objection. Don't talk over me when I have an

5 opportunity to make an objection. You can answer the

6 question.

7 BY MR. KRESS:

8 Q And the question is: What was the name of the

9 client subject to Mr. Klayman's --

10 MR. KLAYMAN: (Inaudible.)

11 (Mr. Klayman talking at the same time.

12 Mr. Kress and witness are talking.)

13 THE WITNESS: There are some legalities

14 involved in there, which I may not understand. Let me

15 give you an analogy of something I do understand. When

16 I was in the consulting business --

17 BY MR. KRESS:

18 Q I just want you to --

19 MR. KLAYMAN: Wait, let him answer.

20 THE WITNESS: Would you just listen, please?

21 MR. KLAYMAN: Be respectful of my client,

22 please.

23 THE WITNESS: When I was in the consulting

24 business, we had both a client and a customer. The

25 client was the ultimate beneficiary of the work. The




Page 32

1 customer might be the one that engaged me. So, I would

2 characterize myself as Larry's customer, but the client

3 was Michael Voeltz, in this particular case.

4 BY MR. KRESS:

5 Q Okay. That's fine. Thank you.

6 Are you aware of a written agreement between

7 Larry Klayman and Michael Voeltz for the purpose of the

8 Obama litigation?

9 A I don't know. That's really not my bailiwick.

10 Q Okay. Don't know one way or the other?

11 A I don't know, no. I don't know.

12 Q Okay. And just so it's clear on the record,

13 because all the objections and the talking --

14 MR. KLAYMAN: Wait a second. Wait a second.

15 MR. KRESS: I haven't even asked a question

16 yet.

17 MR. KLAYMAN: Yeah, but you are making

18 sarcastic --

19 MR. KRESS: I'm not making sarcastic remarks.

20 I'm trying to clarify the record. I'm going to do it.

21 MR. KLAYMAN: I'm allowed to make objections.

22 MR. KRESS: I haven't asked a question yet.

23 MR. KLAYMAN: But let me make objections, and

24 you won't have a problem. If you give me an opportunity

25 to object, like I did when your clients were being




Page 33

1 represented and made their own objections without even

2 you. So give me an opportunity and don't be sarcastic

3 with George.

4 MR. KRESS: Okay.

5 BY MR. KRESS:

6 Q Just to make sure we are clear on the record,

7 I'm trying to speak as evenly as possible, the only

8 agreement for the retention -- only written agreement

9 for the retention of Larry Klayman's services with

10 respect to the Florida Obama litigation is what's

11 reflected in Exhibit 6, correct?

12 MR. KLAYMAN: Asked and answered.

13 MR. KRESS: And he can answer it again.

14 MR. KLAYMAN: Ask and answered.

15 MR. KRESS: He can answer the question.


17 MR. KLAYMAN: He testified to quite long

18 answer.

19 MR. KRESS: Thank you.

20 THE WITNESS: Yes, again.

21 COURT REPORTER: Counsel...

22 MR. KRESS: Yes.

23 COURT REPORTER: Please, do not talk over one

24 another. You're starting to make me angry, and I can't

25 throw my shoe through the phone. (Laughter.)




Page 34

1 MR. KRESS: All right. You could, but it

2 wouldn't do much good for you or anyone else. I

3 apologize, and we'll try.

4 BY MR. KRESS:

5 Q Okay. So let's -- let's talk about this

6 agreement here in -- in Exhibit 6, but first of all, did

7 you, either independently or on behalf of the group,

8 agree to the terms reflected in Exhibit 6?

9 A Well, what we agreed to is that we would make a

10 maximal effort to raise money from our donors.

11 Q Okay. The agreement refers to an upfront

12 retainer of $18,000.

13 Was that paid?

14 MR. KLAYMAN: Objection. Mischaracterizes the

15 document. The document for itself.

16 George, take a look at the document.

17 THE WITNESS: Okay. I'm looking at it.

18 MR. KLAYMAN: I ask, Mr. Kress, that you don't

19 mischaracterize documents please. That's not --

20 MR. KRESS: I'll read it word for word.

21 MR. KLAYMAN: It's not correct or ethical.

22 BY MR. KRESS:

23 Q I'll read it word for word then.

24 In paragraph 2, it says:

25 "To file suit in Florida, we will need




Page 35

1 an upfront retainer of 18K, which will need to

2 be kept at this level throughout the course of

3 the case replenishing it monthly."

4 And it goes on to say:

5 "I will bill for out-of-pocket

6 disbursements and expenses and my hourly rate

7 of $395 per hour, which is reduced from my

8 usual minimum rate of $600 per hour. The

9 statements will issue on the 1st of each month

10 and be payable upon -- or payable on receipt."

11 Did I read that correctly?

12 A Yes.

13 MR. KLAYMAN: It's not accurate.

14 MR. KRESS: I'm asking --

15 MR. KLAYMAN: No, no, it's not accurate because

16 you are mischaracterizing the document. What you are

17 doing is unethical.

18 MR. KRESS: It's not unethical.

19 MR. KLAYMAN: It's unethical. Read the next

20 line.

21 MR. KRESS: Okay. We can -- I want to ask him

22 questions about that.

23 MR. KLAYMAN: The objection, because you are

24 distorting the document, the document speaks for itself,

25 and you are not reading the whole document.




Page 36

1 BY MR. KRESS:

2 Q Was an upfront retainer of $18,000 paid by

3 Larry Klayman -- paid to Larry Klayman?

4 A Not -- not on the terms that were done here.

5 We were not able to all the money before he started, but

6 to his eternal credit, he agreed to start anyway in the

7 interests of our country.

8 Q Okay. Was the $18,000 retainer paid at some

9 point?

10 A Yes.

11 Q At what point was it paid?

12 A It was actually after the hearing. So, he

13 actually went and did the hearing without having the

14 full amount, but we finally did raise that and part of

15 the expense money.

16 Q How much was -- how much was Larry paying --

17 Larry Klayman paid in total from the group related to

18 the Florida Obama litigation?

19 A It was about 21,000 something. I don't

20 remember the exact amount anymore.

21 Q Did that -- was that based on fees, expenses or

22 both?

23 A Well, the retainer was 18,000. There was some

24 feels over and above that, which we were able to

25 partially reimburse him for.




Page 37

1 Q Okay. Did you pay for any of his -- his

2 expenses?

3 A Again, 18,000 was retainer and the rest was --

4 went towards his expenses. So, I think that would be a

5 yes.

6 Q Okay. Did Larry Klayman issue any billing

7 statements to you or to the group?

8 A Yes. I believe there's one in the exhibits, is

9 there not?

10 Q Yes. Is that -- we will refer to that one. If

11 you could look at George Miller Deposition Exhibit 8,

12 please.

13


15

16 A Exhibit 8. Yes, I see it.

17 Q Okay. And you are familiar with this document,

18 correct?

19 A I am, yes.

20 Q Other than this billing statement -- well, let

21 me ask it -- let me ask it a little bit more clearly.

22 Did Larry Klayman issue any bills to you or to

23 your group related to the Florida Obama litigation?

24 MR. KLAYMAN: Hold on, George.

25 Asked and answered. You already referred to a




Page 38

1 prior document, which set forth amounts of retainers,

2 and you misstated what was in there as well. There was

3 18,000 that was Florida and 25 of it was California as

4 well.

5 Go ahead. You can answer, George. I just want

6 to make sure you focus on the question.

7 THE WITNESS: Yeah. There was the initial --

8 there was the initial retainer agreement and some

9 dunning on that, and there was this particular bill in

10 Exhibit 8, plus he referred to much larger amount of

11 time he had put in that he did bill us for. And at that

12 time, he felt he was not going to be compensated for it.

13 BY MR. KRESS:

14 Q Okay. So, let's just break that down a little

15 bit.

16 Mr. Klayman sent you Exhibit 6, correct?

17 A Let me go back to Exhibit 6 again. I don't

18 remember which one it is. Yes. Yes, he did.

19 Q Okay. And that refers -- I will try to

20 characterize it because -- there's some reference in

21 there to retainers and so forth. And then he sent you

22 Exhibit 8, which is a billing statement.

23 Did Larry Klayman send you any other written

24 bills or billing statements or invoices for his services

25 in the Obama -- Florida Obama litigation?




Page 39

1 A I didn't see any hard copy or digital image,

2 but we discussed the scope of what he had done for us

3 that exceeded both of these substantially.

4 Q Okay. I just want to -- but I just want to

5 make sure it's clear on the record.

6 Did he send you any written documents -- I'm

7 looking for written documents right now -- that were

8 bills or invoices for his services in the Florida Obama

9 litigation other than Exhibit 6 and Exhibit 8?

10 A Not that I'm aware of, no.

11 Q Okay. And I just to make sure that I'm clear

12 on this. Uhm... regardless of the amounts stated in

13 Exhibit 6 and Exhibit 8, it's your recollection that

14 Larry Klayman was paid approximately $21,000 by the

15 group for the Florida Obama litigation?

16 MR. KLAYMAN: Objection. Improper question.

17 Compound. You are mixing apples and oranges. You can

18 ask him for each particular document, but not on a

19 compound question like that.

20 BY MR. KRESS:

21 Q You can answer, if you understand.

22 A Why don't you ask them separately so even I can

23 understand.

24 Q When you -- you testified earlier, I believe,

25 that the group paid Larry Klayman approximately $21,000




Page 40

1 for his services in the Florida Obama litigation,

2 correct?

3 A Correct, yes.

4 Q Was that based on -- well, at what time was he

5 paid? Do you remember what month?

6 A He was paid in dribs and drabs, as we could

7 collect the money. And we would save enough to send it,

8 and he would call us up begging for it sooner. So we

9 would send it pretty much whenever he asked when we had

10 some.

11 Q Uhm-hum. And if you could refer to Exhibit 7,

12 please.

13


15

16 A Yes.

17 Q Okay. There's actually two e-mails referenced

18 on this one page. The first one is at the bottom of the

19 page, and it's from Larry Klayman to George Miller,

20 May 7, 2012, at 8:43 p.m. And it states:

21 "George, Sam and Pamela."

22 So that's you, Sam Sewell, and Pamela Barnett,

23 correct?

24 A Yes.

25 Q And it states:




Page 41

1 "This confirms that I will take this

2 through the hearing on defendant's motion to

3 dismiss if you pay the agreed retainer in full

4 of 18,000 before the hearing. You agreed to

5 pay about 3,000 this week with more coming next

6 week. The remainder of the retainer at this

7 point in time is 11K. Thank you for your

8 cooperation and best, Larry Klayman."

9 If you know, is the 18K that's referenced in

10 this May 7, 2012, e-mail from Larry Klayman the $18,000

11 retainer referenced in the February 8, 2012, e-mail?

12 A It's all the original retainer, yes.

13 Q Okay. Thank you.

14 And then if we go to the e-mail above that,

15 this appears to be from microma- --

16 [email protected].

17 Do you know whose e-mail address that is?

18 A Yeah, that's mine.

19 Q Is that yours?

20 A It's my -- my address.

21 Q So, that's from you to Larry Klayman. It says:

22 "We have already paid at least 9K."

23 And then I'm not going to read the whole thing.

24 I'm not trying to misrepresent it. I just don't think I

25 need to read the whole thing.




Page 42

1 MR. KLAYMAN: Well, but -- objection.

2 Objection. If you're -- well, take it --

3 MR. KRESS: I am not --

4 MR. KLAYMAN: Give me an opportunity to object.

5 MR. KRESS: Okay.

6 MR. KLAYMAN: If you distort this the way you

7 distorted the other one.

8 MR. KRESS: I object to your characterization.

9 BY MR. KRESS:

10 Q The first -- just reading the first sentence,

11 it says:

12 "We've already paid at least 9,000."

13 And then the last sentence says:

14 "That would leave 9K or less to go

15 according to my math. Where did I go wrong?"

16 What did you mean by -- by that statement,

17 "That would leave 9K or less to, go according to my

18 math. Where did I go wrong?"

19 A I think the memo speaks for itself. Add up the

20 numbers. It comes to eight, nine, $9,300. That would

21 mean that I owe -- that we owe less than 9,000 since the

22 retainer was 18,000.

23 Correct?

24 Q That makes sense to me.

25 A Okay.




Page 43

1 MR. KLAYMAN: Object. Move to strike.

2 Mr. Kress, please avoid the colloquy, okay, because

3 that's what causes me to have to object. I don't want

4 to have to interrupt your questioning, but please don't

5 put your own thoughts on the record. You are not

6 testifying. You're not under oath. I'll put you under

7 oath, and I can depose you.

8 MR. KRESS: Your client is asking questions.

9 MR. KLAYMAN: No, but it's improper.

10 BY MR. KRESS:

11 Q Well, let's go to Exhibit 9. Take a moment to

12 read this, please.

13


15

16 A Yes.

17 Q You are familiar with this e-mail?

18 A Yes, I am.

19 Q You recall receiving it from Larry Klayman on

20 or about August 9th of 2012?

21 A At this point, I can't deny it. It's something

22 we've discussed before. I remember hearing e-mails.

23 Did I receive it on that exact date? I don't know. It

24 looks like it from this copy.

25 Q Uhm-hum. I want to refer you to paragraph 3.




Page 44

1 It says:

2 "There is no formal contract" -- I'm

3 sorry, I misread that. It states:

4 "That there is no formal written

5 contract is not controlling. There is written

6 evidence of our agreement in the form of

7 e-mails and you owe the moneys under the legal

8 doctrines of promissory estoppel, quantum

9 meruit and unjust enrichment as well as breach

10 of contract. A contract can be oral as well as

11 written."

12 As the recipient of this e-mail, what did that

13 mean to you?

14 A Well, he's attempting to say that I,

15 personally, owe the money. I did subsequently clarify

16 that it was -- it was an effort to raise funds, and that

17 we had committed to try to raise those funds.

18 Otherwise, I agreed pretty much. I'm not a lawyer. I

19 couldn't tell you exactly what the word "estoppel"

20 means, but the bottom line is that we wanted to do this

21 project. We agreed to work and raise the funds with our

22 best efforts, and we continued to attempt to do that

23 during the life of this relationship.

24 Q Thank you.

25 But as of August 9, 2012, was Larry Klayman




Page 45

1 asking that you and Pamela Barnett and Sam Sewell pay

2 his bill?

3 A Well, depends again what you mean by "you." He

4 used "you" in there, but again, as I told you, we were

5 attempting to bring the group together to raise the

6 funds, yes.

7 Q Okay. Did you, personally, refuse to

8 contribute to Larry's legal bills or Larry's efforts

9 because of any comments that you read on Orly Taitz

10 website?

11 A Well, I will tell you --

12 MR. KLAYMAN: Objection. Assumes facts.

13 Objection. George, hold on.

14 MR. KRESS: Wait. Don't -- let's not coach

15 him.

16 MR. KLAYMAN: I'm not coaching him.

17 MR. KRESS: If you have an objection, don't

18 coach him -- he's your client.

19 MR. KLAYMAN: It assumes facts not testified

20 to. Not in evidence.

21 MR. KRESS: I'll break it down a little bit.

22 MR. KLAYMAN: Break it down, please.

23 BY MR. KRESS:

24 Q I know that you, at some point, read that Orly

25 Taitz posted on her website that Connie Ruffley said




Page 46

1 that Larry Klayman had been convicted of a crime of not

2 paying child support; is that correct?

3 A Correct.

4 MR. KLAYMAN: Object. That mischaracterizes --

5 hold it, George. Just a moment.

6 That mischaracterizes what was on the website.

7 It was that I was convicted of a crime, and the

8 information should be given that I --

9 MR. KRESS: I object.

10 MR. KLAYMAN: Let me -- let me tell you

11 something.

12 MR. KRESS: I ask --

13 MR. KLAYMAN: The questions that you you are

14 asking are misleading, and they mischaracterize what's

15 in -- what Connie Ruffley said. So, consequently,

16 please read to him that which was published on the

17 website because otherwise it's not ethical to do this.

18 MR. KRESS: This is plenty ethical.

19 MR. KLAYMAN: It's not. It's not.

20 BY MR. KRESS:

21 Q Mr. -- Mr. Miller, do you recall reading Connie

22 Ruffley's -- I'm sorry.

23 Do you recall reading Orly Taitz's website

24 posting from February 23, 2012?

25 A I don't remember the exact date, but it was in




Page 47

1 February, and she -- she used Connie's --

2 Q My question is -- okay. We can -- we can go to

3 Exhibit Number 14.

4 MR. KLAYMAN: Let's do that.

5 MR. KRESS: Let's do that.

6 THE WITNESS: Okay.

7


9

10 BY MR. KRESS:

11 Q So, you are familiar with Exhibit 14, correct?

12 A Yes, I am.

13 Q Let me ask you this --

14 MR. KLAYMAN: Give him an opportunity to review

15 it if you are going to ask him questions.

16 Go ahead, George, read it.

17 MR. KRESS: Well, I don't --

18 MR. KLAYMAN: He's entitled to do that if you

19 are going to ask him questions on the exhibit.

20 BY MR. KRESS:

21 Q If you need to read the whole thing --

22 MR. KLAYMAN: I'm instructing him to do it

23 because that's the way you should ask questions; give

24 him the opportunity to look at the document first.

25 That's the ethical thing to do.




Page 48

1 THE WITNESS: Okay. There's a lot in here.

2 What are your specific questions?

3 BY MR. KRESS:

4 Q My question is, did anything in Exhibit 14,

5 after you read it, cause you to refrain personally from

6 contributing to any of -- contributing money to any --

7 MR. KLAYMAN: Hold it, George.

8 MR. KRESS: Let me ask the question.

9 MR. KLAYMAN: Ask it, but do not answer the

10 question because it's an improper question. I need to

11 make an objection.

12 BY MR. KRESS:

13 Q Let me start again, Mr. Miller. Hopefully, I

14 won't be interrupted this time.

15 Does any --

16 MR. KLAYMAN: You are interrupted because the

17 questions are -- are inappropriate and unethical.

18 MR. KRESS: I will just state this on the

19 record. Mr. Miller was not originally identified as a

20 witness. He was -- we objected to him being called at

21 trial. The judge stated that he can only testify at

22 trial if you gave me the opportunity to depose him.

23 MR. KLAYMAN: That's fine.

24 MR. KRESS: If you are interfering with my

25 ability to depose him, then you are further -- it's




Page 49

1 further prejudicing us.

2 MR. KLAYMAN: No. What's -- what's -- what's

3 improper, Mr. Kress, is that you've asked him a

4 question, and you never asked him a foundation question

5 about whether he made contributions, okay. You are

6 assuming in your question.

7 MR. KRESS: Okay.

8 MR. KLAYMAN: And you are doing that

9 intentionally.

10 MR. KRESS: No, I am not.

11 MR. KLAYMAN: And that's what's unethical. You

12 are doing it intentionally, okay, and it's an improper

13 question.

14 MR. KRESS: It's improper of accusing me

15 unethical conduct.

16 MR. KLAYMAN: Well, then I'm asking that you to

17 stick to what -- what is, you know, what question was is

18 that you are assuming facts that he never testified to,

19 okay. You are putting him in his mouth. Just break the

20 questions down, and you can ask them.

21 BY MR. KRESS:

22 Q Mr. Miller, did you ever refuse to contribute

23 money to Larry Klayman's Florida Obama efforts, legal

24 services, because of anything that you read in

25 Exhibit 14?




Page 50

1 MR. KLAYMAN: Objection. It assumes facts not

2 testified to. He never said he contributed anything.

3 BY MR. KRESS:

4 Q You can answer the question.

5 A It definitely inhibited me from giving more. I

6 gave him some money prior to that. And, you know,

7 frankly, we had a really heavy heart-to-heart talk after

8 this came out because it really shook my confidence

9 quite a bit. I mean, look at this thing. This is

10 Ruffley --

11 Q There's no question --

12 MR. KLAYMAN: Let him answer the question.

13 MR. KRESS: There's no question before --

14 THE WITNESS: I'd like to read you --

15

16 (Mr. Klayman, Mr. Kress, and the

17 witness all speaking at the same time.)

18

19 COURT REPORTER: Stop, stop, stop, stop. Stop,

20 stop, stop. Stop. I don't know how many fingers you

21 think I have, but I can't do it. One person at a time.

22 Sorry. Excuse me. I'm talking. If you want this done,

23 if you want me to certify it, you will speak one at a

24 time. Got it? Does everybody understand one at a time?

25 MR. KRESS: We understand.




Page 51

1 COURT REPORTER: Thank you.

2 MR. KLAYMAN: You asked for it, and he's going

3 to answer.

4 THE WITNESS: This is the most --

5

6



9

10 COURT REPORTER: Stop. You're doing it again.

11



14

15 COURT REPORTER: You're doing it again. Stop.

16 Please, stop. There has to be control. There has to be

17 order in this deposition. You have to speak one at a

18 time. That includes the witness. That includes both

19 the attorneys. One at a time. I will not certify this

20 record if you keep talking over each other because I

21 will not be able to get everything.


23 MR. KLAYMAN: George, just answer the question.

24 THE WITNESS: Okay. May I read you the words

25 that caused me the most angst and did the most damage to




Page 52

1 our program that you people have just about destroyed.

2 May I do that?

3 BY MR. KRESS:

4 Q Yes.

5 A Thank you. Okay.

6 "Mrs. Ruffley" -- these are Orly

7 Taitz's words in her blog.

8 "Mrs. Ruffley actually advised me that

9 Larry Klayman is not licensed in California" --

10 which, by the way, is misleading, which I'll explain

11 later.

12 "She told me that he no longer works

13 for Judicial Watch" -- not that he said that he

14 did.

15 -- "and that donors should know about

16 litigation in Ohio" -- which is where the

17 litigation took place on the child support --

18 -- "where he was convicted" --

19 Really? Convicted? This was news to me. This

20 was quite a shock.

21 -- "recently of not paying large

22 amount in child support. She provided a lot of

23 information."

24 Really? I wonder what that was.

25 "I will publish only what is a public




Page 53

1 record. I am not publishing anything that is

2 not in public record."

3 Show me, please, where this is in the public

4 record that your employee, Judicial Watch, the manager

5 of the California thing, who has high visibility, who

6 shows up at public events, who crashes Orly Taitz's

7 session, volunteers this information. Are you kidding?

8 Yes. I'm very concerned, and I'm very angry. You've

9 destroyed our program, and you hurt our nation as well.

10 Any other questions?

11 BY MR. KRESS:

12 Q Are you finished with your answer, Mr. Miller?

13 I have a lot more questions.

14 A Good. Fire away.

15 Q Okay. So you read the paragraph that caused

16 you the most concern, correct?

17 A Correct.

18 Q All right. Do you know whether it was true or

19 false that Larry Klayman was not licensed in California?

20 A I've known that all along. He was supposed to

21 go pro hac vice. We knew that he is licensed to

22 practice in Washington, DC. and Florida. He sent me a

23 copy of his law license before we started this

24 assignment.

25 Q Okay. But just make sure we have it clear on




Page 54

1 the record, you understood that he was not licensed in

2 California, correct?

3 A I understood that. But the way Orly writes

4 this, it's like he can't even work on the case. She

5 only mentions the facts that were most pertinent, and

6 Mrs. Ruffley as well.

7 Now, why is Mrs. Ruffley making a big deal

8 about the fact that he's not licensed to work in

9 California when he can easily work in California, as

10 attorneys do all over the country, using pro hac vice?

11 It's very, very deceptive on her part, very misleading,

12 especially for someone, who is supposedly a legal expert

13 that works for the world's leading public interest firm,

14 Judicial Watch, which Mr. Klayman founded, by the way.

15 MR. KRESS: Objection. Move to strike as

16 nonresponsive.

17 BY MR. KRESS:

18 Q It was correct that he no longer worked at

19 Judicial Watch, correct?

20 A Correct.

21 Q There was litigation in Ohio, correct?

22 A Correct.

23 Q Prior --

24 MR. KLAYMAN: Wait a minute.

25 BY MR. KRESS:




Page 55

1 Q Prior --

2 MR. KLAYMAN: Objection. It's indefinite as to

3 time as to when he had knowledge. Objection. Move to

4 strike.

5 MR. KRESS: I'm going to follow up on that.

6 MR. KLAYMAN: Go ahead.

7 BY MR. KRESS:

8 Q As of February 23, 2012, did -- were you aware

9 -- well, let me strike that and start over again.

10 Prior to reading this website article, did --

11 did you know that Larry Klayman was involved in some

12 type of litigation in Ohio related to child support?

13 A I did not know there was litigation. I had

14 heard he was behind on his child support payments. At

15 that time, we asked him. He explained the situation to

16 our satisfaction. I knew nothing about a conviction. I

17 didn't even know that this was a criminal matter. I

18 thought it was a civil matter, actually.

19 Q Okay. So, before the group hired Larry, you

20 knew there was some type of child support issue in Ohio,

21 correct?

22 A I can't remember the exact timing. You know,

23 we did some basic due diligence, and we knew of all

24 kinds of things on the blogs. You know, people attack

25 Larry Klayman all the time. We try to sort out what was




Page 56

1 true from what was not true. Basically, we concluded

2 that he was behind on his child support payments, and

3 that's due in part that he works for low rent clients

4 like us, and he puts in a lot of time on his own,

5 dedication time. So, to me, that was really, to some

6 extent, uhm, a pro; that this guy is struggling, trying

7 to make ends meet, working on cases like us, trying to

8 help the country. He's not one of these shyster lawyers

9 that charges high prices and profits vastly. This is a

10 cause for him.

11 Q Okay. All right. So, a few things to ask you

12 about what you just said.

13 You, as part of your due diligence, reviewed

14 Larry Klayman's background, correct?

15 A To some extent, yes.

16 Q And you found a lot of things on the web that

17 were, uhm, critical --

18 MR. KLAYMAN: Objection.

19 BY MR. KRESS:

20 Q -- of Larry Klayman, correct?

21 MR. KLAYMAN: Objection. He never testified to

22 that. Assumes facts not in evidence.

23 MR. KRESS: Let me ask it this way.

24 MR. KLAYMAN: Yes, please, ask it in a

25 different way.




Page 57

1 BY MR. KRESS:

2 Q Did you find any information during your due

3 diligence regarding Larry Klayman that reflected

4 negatively on Larry Klayman?


6 You can answer.

7 BY MR. KRESS:

8 Q You can answer.

9 A Well, sure. Lots of stuff. He's not exactly

10 popular with the left. He's not exactly popular with

11 government or organizations that are being investigated.

12 He is certainly not popular with Bill Clinton or Barack

13 Obama or any of their minions.

14 Q So, did you read any, for instance, articles

15 that were critical of Larry Klayman?

16 MR. KLAYMAN: Objection. Relevancy. Judge has

17 already ruled the articles are inadmissible.

18 BY MR. KRESS:


20 A We read various things on blogs. I can't say

21 that we read those particular exhibits that you have in

22 there. They didn't look familiar to me.

23 Q Okay. But you were aware that there was

24 negative press related to Larry Klayman before you --

25 before you hired him, correct?




Page 58

1 A Well, yes. Any great man leaves a wake.

2 Q Okay. So, there's some good stuff out there,

3 there's some bad stuff out there, correct?

4 A Correct, yes.

5 Q But you --

6 MR. KLAYMAN: Objection to using the word good

7 and bad. Vague and ambiguous. And move to strike.

8 BY MR. KRESS:

9 Q Do you understand the words "good" and "bad"?

10 A I have my own understanding.

11 Q I'll withdraw the question. I'll withdraw the

12 question.

13 But you -- you -- you gathered that

14 information, and you sorted through it to determine what

15 was, in your view, true or false, correct?

16 A To some extent, yes.

17 Q Okay. As of -- well, prior to reading Orly

18 Taitz's publication, which was Exhibit 14, did you know

19 that Larry Klayman had been criminally indicted for

20 failure to pay child support?

21 A No.

22 Q Okay. So, prior to this time, prior to reading

23 this, on February 23, 2012, internet blog or article,

24 you thought it was merely a civil matter, correct?

25 A Yes.




Page 59

1 Q The fact that he was indicted speaks negatively

2 of Mr. Klayman, doesn't it?

3 MR. KLAYMAN: Objection. Facts speak for

4 itself.

5 THE WITNESS: Is a person not innocent until

6 proved guilty anymore?

7

8 (Mr. Klayman speaking at the same

9 time as witness.)

10

11 BY MR. KRESS:

12 Q You mentioned that you thought it was only a

13 civil matter. You didn't know it was a criminal matter.

14 MR. KLAYMAN: Objection. Compound question.

15 You can answer, George.

16 BY MR. KRESS:

17 Q I'll withdraw the question because you've

18 already said it.

19 A I've already said it.

20 Q Okay. And in fact, if we go down back to

21 Exhibit 14 and read further on, couple paragraphs down,

22 it states:

23 "Larry" --

24 MR. KLAYMAN: Paragraph 14 of what?

25 MR. KRESS: Exhibit 14.




Page 60


2 MR. KRESS: The last full paragraph on the

3 third -- well, what I'm showing as the second page of

4 the article.

5 MR. KLAYMAN: All right.

6 BY MR. KRESS:

7 Q And it states --

8 MR. KLAYMAN: Let me make an objection. The

9 document speaks for itself.

10 MR. KRESS: Okay. I haven't asked a question

11 yet.

12 MR. KLAYMAN: I know the way you ask questions,

13 Mr. Kress. I'm just trying to get an objection, so you

14 can ask the question in a correct way.

15 BY MR. KRESS:

16 Q The last paragraph states:

17 "Larry Klayman, 60, of Los Angeles,

18 California was indicted on two counts of

19 criminal nonsupport. He owes $78,861.76 for

20 his two children, ages of 11 and 14. Two

21 hearings were held in domestic relations court

22 between 2009 and 2010. The last voluntary

23 payment was made on August 30, 2011, in the

24 amount of $1,014.26. Arraignment is scheduled

25 for February 7, 2012."




Page 61

1 Prior to reading Orly Taitz's posting, were you

2 aware of the information that I just read to you?

3 A I don't remember the exact amount. All I

4 remember is he was substantially behind in child

5 support, and I did not know it was a criminal thing. I

6 did not know he was indicted. I certainly didn't know

7 he had been convicted because he wasn't. A little bit

8 of misinformation there, yes?

9 Q So, Mr. Miller, going back to where I was --

10 how much money did you contribute to Larry Klayman's

11 efforts in the Florida Obama litigation?

12 MR. KLAYMAN: Objection. That's leading, and

13 it doesn't ask the foundation question, Mr. Kress. I

14 can only assume, because you keep doing this, that you

15 are doing it intensionally. And that's why -- that's

16 why I consider this to be unethical because I don't mean

17 to be abrasive, but you know what to do. You are an

18 experienced lawyer. You've been a lawyer for a long

19 time. Ask the foundation question. Don't ask questions

20 that assume facts that are not in evidence.

21 BY MR. KRESS:

22 Q Mr. Miller, didn't you already tell us that you

23 contributed money to Larry Klayman's Florida Obama

24 Challenge efforts?

25 A Yes.




Page 62

1 Q How much?

2 A I did a contribution of a thousand, and I think

3 I did more, too. I can't remember the exact amount

4 anymore. It was over a thousand dollars from my

5 personal funds.


7 Do you believe that you, personally -- well,

8 let me ask it this way. Let me back up.

9 Did you ever, personally, make a decision to

10 refuse to contribute any funds to Larry Klayman's

11 Florida Obama Challenge as a result of reading that

12 paragraph that concerned you?

13 A I was certainly more inhibited. I mean,

14 there's a number of factors that go into making a

15 donation, like how much money you have, how strongly you

16 feel about the cause, how likely this is to succeed, and

17 all those other things. But that did make me less

18 likely to contribute more money, yes.

19 Q Okay. Did you ever make a conscious decision

20 to say, "I'm not going to contribute money because I

21 read on this internet blog that Mr. Klayman had been

22 convicted"?


24 You can answer.

25 THE WITNESS: I -- I don't -- I don't know. I




Page 63

1 know it was definitely a factor, but I can't tell you

2 exactly how that weighed with everything else, but it

3 was a negative factor for sure as it was for hundreds,

4 if not thousands, of other people probably.

5 BY MR. KRESS:

6 Q Okay. What other factors led to your decisions

7 regarding whether or not to -- well, let me ask it this

8 way. You said you contributed a thousand, maybe a

9 little bit more.

10 A Yes.

11 Q What other factors led to your decision not to

12 contribute more?

13 A I already told you that.


15 evidence. He didn't -- he hasn't testify to that.

16 BY MR. KRESS:

17 Q Well, you mentioned that you considered a lot

18 of factors, and this -- this internet article was

19 something that inhibited you.

20 A Yes.

21 Q What other factors did you consider?

22 A I thought I told you that already. Should I do

23 it again?

24 Q I didn't hear that. So, if you could, please.

25 A Okay. I mentioned when you -- when you




Page 64

1 contribute to a cause, you ask a lot of questions, like

2 how strongly you feel about the cause, how righteous is

3 it, how likely is it to succeed, how competent are the

4 people doing it, what are the opposition. Those are all

5 factors.

6 This is obviously a very big one and, you know,

7 based on the reaction we had from potential donors and

8 the public, in general, this was a disaster. It dried

9 up our funds. It hurt our credibility very badly, and

10 it was worse by the fact that it came from the very

11 organization that he founded. Kind of like, "Et tu,

12 Brutus."

13 This was just terrible when it happened. You

14 just -- it was -- everyone was kind of moping around,

15 and we tried to figure out how to react to it. I

16 finally wrote that open letter to Taitz to try to get

17 out to the public what the situation was; that these

18 weren't accurate charges, really, and also, they were

19 very colored.

20 It's interesting that she mentioned about --

21 she mentioned about the child support, but she never

22 said a thing about the Hartman decision and the fact

23 that the divorce was actually done in Virginia,

24 originally, not in Ohio at all. And that the judge

25 probably did something illegal in that ruling. So, she




Page 65

1 didn't tell the whole story about what went on at all.

2 She didn't also mention that the ex-wife had

3 refused visitation rights to Larry Klayman, which, under

4 the Hartman case, he was perfectly justified. She

5 didn't mention that he had given her a house; that had

6 he paid over a million dollars already; that these

7 children were living comfortably in upper middle class

8 circumstances, and they were hardly starving. Instead,

9 giving the impression that he's a heartless bastard, who

10 is starving his kids. Excuse me. That's BS.

11 Q That's the way you read it, correct?

12 A That's the way a lot of people read it, sir.

13 MR. KLAYMAN: That's not what he testified to.

14 BY MR. KRESS:

15 Q Okay. Let me ask you some more questions. And

16 I can stay as long as I want, but I would ask you to

17 please try to direct your answers to my questions.

18 Are there any written documents in which you

19 stated or suggested that you were not going contribute

20 money to Larry Klayman's Florida Obama efforts because

21 of what was read on Orly Taitz's website?

22 A I don't know.

23 Q Okay.

24 A There was various e-mails going back and forth.

25 There might have been something. I can't say for sure.




Page 66

1 Q You guys didn't fire Larry Klayman, did you?

2 A No, we didn't.

3 Q Okay. He continued to represent Mr. Voeltz, as

4 the client, and the group, as the customer, as you put

5 it, correct?

6 A Correct.

7 Q Do you know -- let's me ask you this.

8 Did -- did anyone, to your knowledge, based on

9 your interactions with the group, did anyone know, prior

10 to reading Orly Taitz's website, that Larry Klayman had

11 been indicted, criminally indicted, for failure to pay

12 child support?

13 A I can't tell you what other people knew. I

14 didn't know it, and no one told me that he had been

15 indicted. So, no. We are not aware of that.

16 Q Okay. So, you have no personal knowledge based

17 on anything someone told you or wrote to you, correct?

18 A Correct.

19 Q Okay. For instance, you know, Sam Sewell never

20 said, "Hey, did you know Larry Klayman has been indicted

21 for failure to pay child support?"

22 A He didn't use the word "indicted." All we knew

23 was about he was behind on his child support. That was

24 common knowledge.

25 Q Okay. Do you know what impact the indictment




Page 67

1 had on donors as opposed to this comment about -- this

2 alleged comment from -- that's on the website about

3 conviction?

4 MR. KLAYMAN: Objection. Assumes facts not

5 testified to. Not in evidence.

6 BY MR. KRESS:

7 Q You can answer.

8 MR. KLAYMAN: Compound question.

9 THE WITNESS: Repeat the questions

10 individually, please.

11 BY MR. KRESS:

12 Q Sure. Sure.

13 Do you know if Larry Klayman's indictment for

14 failure to pay child support impacted donors with

15 respect to the Florida Obama litigation?

16 MR. KLAYMAN: Do you understand the question,

17 George?

18 THE WITNESS: Excuse me?

19 BY MR. KRESS:

20 Q If you don't --

21 MR. KLAYMAN: Can the court reporter read back

22 the question?

23 THE WITNESS: Based on the feedback we heard,

24 yes, it definitely impacted donors. In fact, there's

25 even evidence here and comments on Orly Taitz's website.




Page 68

1 BY MR. KRESS:

2 Q That the indictment had an impact?

3 MR. KLAYMAN: No. Objection. That's not what

4 he testified to. Not in evidence.

5 BY MR. KRESS:

6 Q That's what the -- let me make sure we are

7 clear. I don't want there to be any confusion.

8 Did Larry Klayman's indictment for failure to

9 pay child support have an impact on donors with respect

10 to the Florida Obama litigation?

11 A Yes.

12 MR. KLAYMAN: He's asking about --

13 BY MR. KRESS:


15 And the effect would be a negative effect,

16 correct?

17 MR. KLAYMAN: Objection. Calls for

18 characterization.

19 MR. KRESS: It does.

20 THE WITNESS: The sum total of all these

21 comments had an effect. I cannot pars how much was for

22 the indictment or how much about the lie about the

23 conviction and how much about the misleading and the

24 other things. No, I can't. How can I possibly break

25 that down into portions? I don't know.




Page 69

1 BY MR. KRESS:

2 Q Okay. Understood.

3 In fact, if we go to the next page of the

4 article, uhm -- and just so we are clear, the top it

5 says "page 3 of 12" -- there's also reference there to,

6 uhm, a Florida Bar grievance against Larry Klayman,

7 correct?

8 A Correct.

9 Q Do you know what impact, if any, that the --

10 let me strike that. Let me ask it this way.

11 Prior to reading Orly Taitz's website article,

12 dated February 23, 2012, did you know that Larry Klayman

13 had been the subject of a Florida Bar grievance?

14 A Yes.

15 Q Okay. Did donors know that, other donors, if

16 you know?

17 A They -- they did, but at the time, we contacted

18 Larry to get the details on that. And the way that the

19 blogs wrote it made it appear like he just stiffed this

20 gal for 25,000 and walked away, and it turns out that

21 wasn't the case at all. He performed substantial work

22 for her. She had many other problems. She was a very,

23 you know, very tough client to work with; that Larry

24 worked with her, visited her in jail, performed services

25 for her. It was only when she was transferred to




Page 70

1 Orlando that he wasn't representing her anymore, by her

2 choice, not by his, by the way. But the way this is

3 presented is like she stiffed him (sic).

4 Now, I'm sure that your Mrs. Ruffley knew that;

5 yet, she characterized Larry as a deadbeat in doing

6 that, which was very, very misleading.

7 Q Do you know if this comment about the Florida

8 Bar case came from Connie Ruffley or from Orly Taitz?

9 Do you know one way or the other?

10 MR. KLAYMAN: Document speaks for itself.

11 Objection.

12 BY MR. KRESS:

13 Q I'm just asking if you know. Well, let me ask

14 it this way.

15 Did you hear the conversation between Connie

16 Ruffley and Orly Taitz?

17 A No. I wasn't there. All I have is her

18 characterization of what happened there. Presumably,

19 you deposed Ms. Ruffley, and Larry has, too.

20 Q Okay. Do you know what, if any, impact the

21 comments regarding the Florida Bar complaint had on

22 donors with respect to Larry's Florida Obama litigation?

23 A No, I don't.


25 THE WITNESS: No.




Page 71

1 BY MR. KRESS:

2 Q Okay. Do you think it had a negative impact on

3 potential donors?

4 A Well --


6 speculation.

7 THE WITNESS: The way it was presented on --

8 MR. KLAYMAN: George, hold on, hold on, hold

9 on. George, let me -- objection. Calls for

10 speculation.

11 You can answer.

12 BY MR. KRESS:


14 MR. KLAYMAN: I have to make an objection as to

15 form. Okay.


17 MR. KLAYMAN: And substance.

18 Go ahead. Go ahead.

19 THE WITNESS: Can I measure the impact, no?

20 BY MR. KRESS:

21 Q Okay. Do you believe it had some impact?

22 A Do I believe it had impact?

23 Q The Florida Bar complaint?


25 BY MR. KRESS:




Page 72

1 Q You can answer.

2 MR. KLAYMAN: You can answer, George.

3 THE WITNESS: I can answer. Okay. You know,

4 it did have an impact on us when we were first

5 investigating it until we found out what really

6 happened. But this information, given, in itself,

7 without a balanced approach, is obviously -- I would

8 think it would have a negative impact on donors.

9 BY MR. KRESS:

10 Q Okay.


12 speculation. Move to strike.

13 BY MR. KRESS:

14 Q Prior to retaining Larry Klayman, did you know

15 that he had been -- or that he had sued his own mother?

16 MR. KLAYMAN: Objection. Relevancy. That's

17 not even part of this case. I mean, it's -- you can

18 answer, George.

19 Relevancy.

20 BY MR. KRESS:

21 Q Did you know he sued his mother?

22 A I read the descriptions on the blog, and then I

23 researched it and found out what really happened.

24 Q Okay. Did you -- prior to hiring Larry

25 Klayman, did you know that an Ohio magistrate -- and I'm




Page 73

1 not suggesting this happened by any means -- that an

2 Ohio magistrate had found that Larry Klayman had

3 improperly touched his children?

4 A No. I only found that out --


6 THE WITNESS: I only found out later.

7 BY MR. KRESS:

8 Q When did you find that out?

9 A I can't remember the exact date, but it was

10 well after we had engaged him. And again, that was also

11 -- turned out to be a lie also.

12 Q Okay. But that wasn't a lie from --

13 MR. KLAYMAN: Objection. You are not to

14 characterize what the magistrate did. It speaks for

15 itself.

16 MR. KRESS: I haven't even asked the question.

17 MR. KLAYMAN: I can see where you are going,

18 Mr. Kress. It's one of your calculated ways to twist.

19 MR. KRESS: Please stop.

20 MR. KLAYMAN: Your comments are inappropriate.

21 Ask the appropriate questions, and you will get an

22 objection.

23 MR. KRESS: If I can just ask a question before

24 I get an objection, I'd be --

25 MR. KLAYMAN: Well, I have to -- I have to




Page 74

1 object.

2 BY MR. KRESS:

3 Q Let's back it up.

4 At some point, you learned that a magistrate

5 had made that finding about Larry Klayman and his

6 children?


8 BY MR. KRESS:

9 Q Correct?

10 A At some point, yes.

11 Q Okay. Do you remember how soon after retaining

12 Larry Klayman, you learned that?

13 MR. KLAYMAN: Objection. That assumes facts

14 not in evidence, not testified to.

15 THE WITNESS: I can't remember the exact timing

16 anymore. It was, like, years ago.

17 BY MR. KRESS:

18 Q Okay. Was it, uhm, within a couple months, if

19 you know?

20 MR. KLAYMAN: Objection. It's indefinite as to

21 time. You haven't said the time, and he just said he

22 doesn't know the time.

23 BY MR. KRESS:

24 Q Was it before Larry Klayman issued his bill on

25 July 23, 2012?




Page 75

1 A Most likely. I can't say for sure. Probably

2 was, though.

3 Q Okay. From what source did you learn that

4 Larry Klayman -- that an Ohio magistrate had made that

5 finding?

6 A It was something on the blogs. We do searches

7 all the time, and this stuff comes up. And there's

8 Obama -- pro Obama sites, such as Obama Conspiracy and

9 all that; run those things right away. So, we hear them

10 from the opposition.

11 Q Okay. Do you know whether that magistrate's

12 decision had an impact on donors?

13 MR. KLAYMAN: Calls for speculation.

14 BY MR. KRESS:


16 A It certainly couldn't have done any good.

17 Q Okay. And you mentioned that the whole thing

18 about -- I don't want to mischaracterize your testimony,

19 but you said something about the magistrate's decision

20 was a lie.

21 Did you recall stating that?

22 A Do I recall what?

23 Q You said about the magistrate's decision being

24 a lie?

25 A When I first heard it, I investigated it, and




Page 76

1 Larry pointed out to us that magistrate had come to that

2 conclusion; that there was absolutely no proof; that it

3 had subsequently been reversed; and that there's no

4 conviction; there's no finding beyond that. So, it's

5 very possible that in a divorce proceeding, that a

6 bitter, estranged wife would say something like that for

7 her advantage, which is a very unethical, probably

8 illegal thing, but those thing happen regularly, don't

9 they.

10 Q And regardless of whether it's a lie or not a

11 lie, it was out there on the internet, correct?

12 A Well, to some extent. If someone presents only

13 that fact without the other facts, they're shading and

14 misleading the situation. And someone, who is in the

15 legal profession, even if not a lawyer and in the bar,

16 should know that. So, I would think that Judicial Watch

17 should be held to an even higher standard than the

18 layman, would you not?

19 MR. KRESS: Objection. Move to strike.

20 BY MR. KRESS:

21 Q Whose blog did you read this information on

22 about the -- about the contact with the children?

23 A I can't remember exactly anymore.

24 Q Okay. It wasn't attributed to Judicial Watch

25 in any way, was it?




Page 77

1 MR. KLAYMAN: Objection. That is facts not

2 testified to. He said he can't remember. So,

3 consequently, how are you able to ask him that question,

4 Mr. Kress? That's an improper question.

5 BY MR. KRESS:

6 Q Well, did you --

7 A I already told you I didn't remember where. I

8 understand what you're trying to accomplish. You're

9 doing everything you can to protect your organization,

10 and that's your job, but I really don't know, sir.

11 Q That's fine.

12 At that time, you had already -- well, we will

13 leave that for now.

14 So, you are not aware of any documents in which

15 -- well, strike that. Let me start again.

16 Are you aware of any written documents in which

17 a donor stated or potential donor stated that he or she

18 would not be contributing to Larry Klayman's Florida

19 Obama Challenge because of what was stated on Orly

20 Taitz's website?

21 Please, don't answer for him.

22 Are you aware of any written comments?

23 A I had received --

24 MR. KLAYMAN: My objection is documents speak

25 for themselves.




Page 78

1 Go ahead, George. Go ahead and answer.

2 THE WITNESS: I received e-mails to that

3 effect. I received phone calls to that effect. I had

4 received calls that, quote, Larry is damaged goods.

5 When someone is damaged goods and he's a lawyer and has

6 to trust the public, that makes it very hard to raise

7 money, indeed.

8 Our job became almost impossible after that.

9 And the donations went off to a trickle. You can

10 correlate the donations with the different announcements

11 and things that went on. That's a matter of fact. I

12 did not save all those documents because I never thought

13 I would be sitting here today doing a deposition on it.

14 BY MR. KRESS:

15 Q Okay. So, you don't -- you don't have in your

16 possession any documents which state that donors would

17 not be donating because of comments on the Orly Taitz

18 website?

19 A I might. I don't know. I could search. It's

20 possible.

21 Q You haven't given any to Mr. Klayman?

22 A I don't remember what I might have sent him

23 back in 2012. I don't recall. I might have.

24 Q Okay. All right. You said someone had said

25 that Larry Klayman was damaged goods.




Page 79

1 Do you remember who that was?

2 A No. I've had so many conversations, so much

3 e-mail, but that was the general tenor of what happened

4 after that. There were people that didn't want to use

5 him after that. There were people that slowed down or

6 stopped their contributions. There were people that

7 didn't voice the same level of vocal support that didn't

8 want to be associated with him because of all those

9 things. Yes.

10 Q When you say all those -- when you say "all

11 those things," what are "all those things"?

12 A Well, basically negative things that come out;

13 especially things like Mrs. Ruffley's statement. This

14 was the worst one of all because it came from the

15 organization that he founded, from something that has

16 high credibility in the conservative community. So, it

17 was the most damaging statement of anything that could

18 possibly happen.

19 If Obama, himself, got up and said something,

20 it would not have been as bad as this, coming from our

21 supposed ally.

22 MR. KRESS: Move to strike.

23 BY MR. KRESS:

24 Q But there were -- there were other things

25 besides the conviction comment, correct?




Page 80

1 MR. KLAYMAN: Ask and answered.

2 MR. KRESS: No. Also the indictment -- please,

3 I haven't even finished my question.

4 BY MR. KRESS:

5 Q Was the indictment --

6 MR. KLAYMAN: Motion to strike.

7 BY MR. KRESS:

8 Q -- also one of the negative things that was out

9 there?

10 MR. KLAYMAN: Ask and answered. We've now been

11 over this several times. Asked and answered.

12 BY MR. KRESS:


14 A Probably.

15 Q Okay. Was the --

16 MR. KLAYMAN: Objection. Move to strike.

17 Calls for speculation. Go on.

18 BY MR. KRESS:

19 Q Was the finding from the Ohio magistrate about

20 touching the children also one of those negative things

21 that impacted --


23 speculation.

24 THE WITNESS: That came out later. So, I don't

25 recall that was an issue then, really. I'm just -- it's




Page 81

1 just the icing on the cake, I guess. But that's just

2 speculation, like he says.

3 BY MR. KRESS:

4 Q Okay. But the Florida Bar issue was also out

5 there, correct, at the time?

6 MR. KLAYMAN: Objection. Asked and answered.

7 Calls for speculation.

8 THE WITNESS: Presented the way it was

9 presented here, it was very unbalanced. So it had more

10 negative effect than it did to the people who had been

11 fully informed. There was a few people, who were very

12 informed. There are large masses of people who only got

13 this propaganda, which is far more negative than seeing

14 the whole situation.

15 BY MR. KRESS:

16 Q Okay. Uhm... going back to Exhibit 14, I'm

17 going to refer you again to page 2 of 12, and then I

18 want to also refer you to Exhibit 2.

19 MR. KLAYMAN: Please do one at a time so as not

20 to be confused.

21 MR. KRESS: I'll ask the questions.

22 MR. KLAYMAN: I'll have a continuing objection.

23 MR. KRESS: Okay.

24 THE WITNESS: Which one, 14 or 2?

25 BY MR. KRESS:




Page 82

1 Q Okay. Look at that -- look at the last

2 paragraph --

3 A 14 or 2? Which exhibit?

4 Q 14.

5 A 14, okay.

6 Q 14. Look at the last paragraph, which starts

7 with: "Larry Klayman, 60, of Los Angeles, California."

8 Let's do it this way, since Mr. Klayman will probably

9 object.

10 Can you, please, read for me into the record

11 the last paragraph of page 2 of 12 on Exhibit 14?

12 MR. KLAYMAN: If you are going to ask him to

13 read a portion of a document, then I'm going to ask him

14 to read the whole document because that's a distortion

15 of the document. So, objection.

16 BY MR. KRESS:

17 Q I guess, let's -- because I want to get out of

18 here before it's too late, is -- take a look for

19 yourself, just read paragraph -- the last paragraph of 2

20 of 12. Let me know when you are done.

21 A Done.

22 Q Okay. Then go to Exhibit 2.

23


25




Page 83

1 A Got it.

2 Q And read what's -- what's labeled as, uhm,

3 paragraph 1 to yourself.

4 MR. KLAYMAN: Objection. The document speaks

5 for itself. Go ahead. I'll object again. And wait for

6 my objection, Mr. Miller.

7 THE WITNESS: Okay. Where am I on this now?

8 Am I answering it or not?

9 BY MR. KRESS:

10 Q Okay. Here's the question.

11 Isn't paragraph 1 on Exhibit 2 identical to

12 paragraph the last paragraph on page 2 of 12 on

13 Exhibit 14?

14 MR. KLAYMAN: Don't answer that. The document

15 speaks for itself.

16


18

19 MR. KRESS: You are telling the witness not to

20 answer that question?

21 MR. KLAYMAN: Correct. The document speaks for

22 itself. I mean -- what is the issue here, Doug?

23 MR. KRESS: It's Mr. Kress.

24 MR. KLAYMAN: You know, the documents speak for

25 themselves.




Page 84

1 BY MR. KRESS:

2 Q Let me ask you this. Exhibit 2. Exhibit 2

3 appears to be a press release from the Cuyahoga County

4 Prosecutor, February 3, 2012.

5 Have you ever seen this press release before?

6 A Not until this -- not until these proceedings,

7 no.

8 Q Not until the lawsuit?

9 MR. KLAYMAN: Objection.

10 THE WITNESS: Not until right now.

11 MR. KRESS: Okay. That's what I'm trying to

12 clarify what he means by "these proceedings."

13 MR. KLAYMAN: You -- you weren't trying to

14 clarify. That was a very improper way to try to elicit

15 something and not giving him a chance to testify. Cute,

16 but not correct.

17 BY MR. KRESS:

18 Q What did you mean by "these proceedings,"

19 Mr. Miller?

20 A Excuse me?

21 Q When you said "these proceedings," what did you

22 mean by "these proceedings"?

23 A Well, the deposition.


25 MR. KLAYMAN: You should have asked the




Page 85

1 question that way the first time, Mr. Kress. That's why

2 I have to object.

3 MR. KRESS: It meant the same thing.

4 MR. KLAYMAN: It didn't mean the same thing.

5 And I object and move to strike.

6 BY MR. KRESS:

7 Q Based on what you see here, doesn't it appear

8 that Orly Taitz obtained the last paragraph of page 2 of

9 12 from this press release?


11 speculation. And I'm not going to have him sit here

12 look at every single word. The documents speak for

13 themselves.

14 BY MR. KRESS:

15 Q They appear to be identical, correct?

16 A I didn't pars every word.

17 MR. KLAYMAN: Same objection. Same objection.

18 BY MR. KRESS:

19 Q Do they appear to be -- even without parsing

20 any word, they appear to be at least almost identical,

21 correct?

22 A When you work with lawyers, you have to pars

23 words.

24 MR. KLAYMAN: Same objections.

25 BY MR. KRESS:




Page 86

1 Q Okay. Wasn't Orly Taitz getting information

2 from sources other than the Connie Ruffley?

3 MR. KLAYMAN: Objection. Calls for him to be

4 in her state of mind.

5 BY MR. KRESS:

6 Q Let me ask this way.

7 MR. KLAYMAN: He's not capable of answering

8 that.

9 BY MR. KRESS:

10 Q Are you capable of answering that, Mr. Miller?

11 A Well, the question is so broad. Does Orly

12 Taitz get information from other people? She does a lot

13 of other things besides interact with Constance Ruffley

14 in many other spheres of endeavors. So that question is

15 almost meaningless. Can you make it more --

16 MR. KLAYMAN: Lacks -- objection. Lacks

17 foundation. You didn't ask the foundation question.

18 This has been a problem throughout this deposition.


20 BY MR. KRESS:

21 Q Mr. Miller, uhm, what did you do to get ready

22 for this deposition today?

23 A I read all the documents I had previously sent

24 Klayman, that were mostly off Orly Taitz's website. And

25 we had conversations about the impact of all this. That




Page 87

1 was, like, a couple years ago. And only more recently,

2 he asked me if I --

3 MR. KLAYMAN: You are not to get into

4 substance, George; just that you had the conversations.


6 MR. KLAYMAN: Attorney-client privilege here.

7 There's an attorney-client privilege. I'm going to make

8 an objection. You are not to get into the substance of

9 our conversations.


11 BY MR. KRESS:

12 Q I'm asking you what the substance of the

13 conversation was.

14 MR. KLAYMAN: And I'm going to instruct you not

15 to answer as attorney-client privilege.

16


18

19 BY MR. KRESS:

20 Q What was the substance of the conversation

21 with Larry Klayman?

22 MR. KLAYMAN: Instruct you not to answer.

23


25




Page 88

1 BY MR. KRESS:

2 Q Are you going to follow that instruction?

3 A Well, would you listen to your attorney?

4 Q So Mr. Klayman is your attorney?

5 A That's what you told me before, right?

6 Q I didn't tell you that. But is Mr. Klayman

7 your attorney?

8 MR. KLAYMAN: For purposes of the deposition.

9 MR. KRESS: I would like to hear it from the

10 witness.

11 BY MR. KRESS:

12 Q Is Larry Klayman your attorney?

13 A We had this conversation earlier. We spent

14 about 10 minutes on it, did we not?

15 Q Is Larry Klayman your attorney?

16 A Refer back to our earlier conversation.

17 MR. KLAYMAN: Answer the question, George.

18

19 (Mr. Klayman speaking at the same

20 time as the witness.)

21


23 BY MR. KRESS:

24 Q The question was posed for purposes of

25 deposition.




Page 89

1 A Right. We had this discussion.


3 THE WITNESS: I thought that everyone left it

4 that he was helping me for this deposition. Was that

5 not your understanding also at the time?

6 BY MR. KRESS:

7 Q Do you -- do you view Larry Klayman as your

8 attorney for this -- for this deposition or this case in

9 general?

10 MR. KLAYMAN: No. That's a compound question.

11 For the deposition.

12 BY MR. KRESS:

13 Q Do you view Larry Klayman as your attorney for

14 the purpose of this deposition?

15 MR. KLAYMAN: Fine. That's fine.

16 THE WITNESS: We had this conversation already,

17 and that was the --

18 BY MR. KRESS:

19 Q It's a "yes" or "no" question, sir.

20 MR. KLAYMAN: You can answer, George.

21 THE WITNESS: Yes, again. Deposition.

22 BY MR. KRESS:


24 All right. Uhm... as of -- as a person who is

25 considering donating to Larry Klayman's Florida Obama




Page 90

1 efforts, did you weigh all the evidence related to Larry

2 Klayman, the evidence and information?

3 MR. KLAYMAN: Asked and answered. This is

4 badgering the witness at this point.

5 MR. KRESS: This is not.

6 MR. KLAYMAN: It's badgering.

7 BY MR. KRESS:

8 Q Did you weigh the evidence?

9 A Again, yes.

10 MR. KLAYMAN: Wait, wait, wait. I object to

11 the use of the word "evidence." That's a legal

12 conclusion. I object to that. That's a

13 mischaracterization. And asked and answered. You are

14 badgering the witness. You've asked this three, four,

15 five times.

16 MR. KRESS: At this point, we are going to take

17 a break from the deposition. I want to call the court

18 -- the court to get a ruling on whether this gentleman

19 is your client and whether you can instruct him not to

20 answer.

21 MR. KLAYMAN: He said I was representing him

22 for purposes of the deposition. You can take this up

23 with the judge at trial. And that's the way she

24 instructed it to be done. She's in trial right now.

25 MR. KRESS: I think I can talk to a magistrate.




Page 91

1 MR. KLAYMAN: I don't think that's what you can

2 do.

3 MR. KRESS: I understand. I will call, and we

4 can stay on the record. I'm going to make a call to the

5 -- attempt to make a call to the magistrate.

6 MR. KLAYMAN: If the court rules in your favor,

7 which I don't believe it will, he can certainly testify

8 live.

9 MR. KRESS: There are things we would like to

10 know in discovery.

11

12 (Mr. Kress making phone call.)

13

14 MR. KRESS: Hi, my name is Doug Kress. I'm an

15 attorney.

16 MR. KLAYMAN: Can you put her on speakerphone,

17 please?

18 MR. KRESS: Sure. Can you hear me? This is

19 Doug Kress, and actually, I have Larry Klayman with me.

20 We are in a deposition. And I have a concern regarding

21 objections being raised; that if possible, if the

22 magistrate or the judge is available, I would like to

23 speak to either the magistrate or the judge.

24 UNIDENTIFIED PERSON: If it's a discovery

25 issue, you would need to talk to Judge O'Sullivan's




Page 92

1 office.

2 MR. KRESS: Do you have that contact

3 information?

4 UNIDENTIFIED PERSON: It should have been in

5 the docket when you -- when you filed, uhm, you know,

6 the judge entered the order, the trial order. I don't

7 have it right offhand. Like the procedure for discovery

8 matters.

9 MR. KRESS: Okay. I will -- I'll call my

10 office. I think when the -- when the order went out, I

11 think that Judge Simonton or which --

12 UNIDENTIFIED PERSON: Okay.

13 MR. KLAYMAN: She's no longer the magistrate on

14 the case.

15 UNIDENTIFIED PERSON: Okay. Hold on.

16 UNIDENTIFIED PERSON: Judge O'Sullivan's

17 chambers. Brendan speaking.

18 MR. KRESS: My name is Doug Kress. I'm an

19 attorney. We are in a deposition on a case that's

20 pending before Judge Altonaga and Judge O'Sullivan, I

21 believe, was recently added as the magistrate. We have

22 an issue that -- we have certain -- I have certain

23 objections or plaintiff has made certain objections in

24 the deposition that I would like to, if possible,

25 discuss with the magistrate and try to get a ruling on




Page 93

1 as to how to proceed if the magistrate is available.

2 UNIDENTIFIED PERSON: Sure. I will see if he's

3 available. I'm not sure if he is right now, but I

4 didn't get your name. Would you mind repeating it for

5 me?

6 MR. KRESS: Doug Kress, K-R-E-S-S.

7 UNIDENTIFIED PERSON: K-R-A-E-S-S.

8 MR. KRESS: K-R-E-S-S.

9 UNIDENTIFIED PERSON: Oh, K-R-E-S-S.

10 MR. KRESS: Yes.

11 UNIDENTIFIED PERSON: Okay. I will

12 double-check to see if he's available, and I will be

13 right back. All right. Thanks for holding, Mr. Kress.


15 UNIDENTIFIED PERSON: I do think the judge has

16 stepped out for lunch, but I would be happy to take a

17 message and make sure that he calls you back when he

18 does return.

19 MR. KRESS: Okay.

20 UNIDENTIFIED PERSON: What's the best phone

21 number for you?

22 MR. KRESS: I'll give you my cell phone number,

23 which is (561) 693-9897.

24 UNIDENTIFIED PERSON: Just to make sure I have

25 it right, (561) 693-9897, correct?




Page 94

1 MR. KRESS: Correct. And I can give you the

2 case name and case number just so if -- you have that.

3 UNIDENTIFIED PERSON: Sure.

4 MR. KRESS: The case is Klayman, K-L-A-Y-M-A-N,

5 versus Judicial Watch. And the case --

6 UNIDENTIFIED PERSON: You said Judicial Watch?

7 MR. KRESS: Yes. And the case number is

8 1320610.

9 UNIDENTIFIED PERSON: 13-20610?

10 MR. KRESS: Yes.

11 UNIDENTIFIED PERSON: All right. Thanks very

12 much.


14 UNIDENTIFIED PERSON: I'll have him call you

15 back when he returns.


17 UNIDENTIFIED PERSON: Okay. Bye-bye.

18 MR. KRESS: We will continue on and see if the

19 magistrate returns the call.

20 Is the court reporter there still and ready to

21 continue on?

22 COURT REPORTER: I would like to have a

23 5-minute break to use the rest room.

24 MR. KRESS: Absolutely. Let's do that.

25




Page 95

1 (Off the record.)

2

3 BY MR. KRESS:

4 Q Let's take this a little bit at a time to go

5 through some of these exhibits. And the ones we haven't

6 referred to yet. Please look at Exhibit 1.

7


9

10 A Got it.

11 Q Have you seen Exhibit 1 before today?

12 A No.

13 Q Okay. I'll represent to you that it's the

14 criminal indictment of Larry Klayman. I take it --

15 well, I leave it at that. I don't need to ask more

16 questions about that.

17 We have already referred to Exhibit 2. So

18 let's skip that one, and if we can go to Exhibit 3.

19


21

22 A Okay.

23 Q And I'll represent that this is a decision from

24 an Ohio domestic relations judge, which found

25 Mr. Klayman in contempt of court.




Page 96

1 MR. KLAYMAN: Object. What's the point of this

2 if you are just identifying documents, which were

3 already in the record. Are you just running out the

4 clock?

5 BY MR. KRESS:

6 Q Have you ever seen this document before Mr. --

7 A No, I haven't.

8 Q -- Mr. Miller?

9 A No.

10 Q Okay.

11 MR. KLAYMAN: If you want, I can do my cross.

12 I mean --

13 MR. KRESS: No. I -- I -- I want to -- I want

14 to ask these questions.

15 MR. KLAYMAN: That's fine, as long as you are

16 asking questions, and you are not running out the clock.

17 MR. KRESS: I have these and I have actually

18 more. I'm not running out the clock.

19 BY MR. KRESS:

20 Q Can you refer to Exhibit 4, please?

21


23

24 A Okay.

25 Q This appears to be similar to Exhibit 3.




Page 97


2 for itself.

3 BY MR. KRESS:

4 Q Well, let me just ask it this way.

5 Have you seen Exhibit 4 before?

6 A No.

7 Q Prior to retaining Larry Klayman in February of

8 -- of 2011, did you know that he had been found in

9 contempt of court twice by an Ohio court for failure to

10 pay child support?


12 Facts not testified to. Lacks foundation. See, this is

13 the problem, is that you are testifying and putting

14 words in his mouth in an improper way, Mr. Kress, and

15 that's why -- I am sorry if I have to use that language,

16 but that is not an ethical approach to asking questions.

17 BY MR. KRESS:

18 Q Sir, did you know, prior to retaining Larry

19 Klayman to represent your group in the Florida Obama

20 Challenge, whether -- I'm sorry. We had an interruption

21 there. Something happened with connection, so I just

22 want to ask the question again.

23 Did you know prior to retaining Larry Klayman,

24 for the purposes of the Florida Obama litigation, that

25 he had been found in contempt of court twice in Ohio for




Page 98

1 failure to pay child support?


3 evidence. No foundation.

4 BY MR. KRESS:

5 Q Did you know that, sir?

6 A No.

7 MR. KLAYMAN: You can answer.

8 THE WITNESS: No.

9 BY MR. KRESS:

10 Q Thank you.

11 MR. KLAYMAN: And relevancy.

12 BY MR. KRESS:

13 Q Do you know whether -- well, in your meetings

14 with the other members of your group, prior to retaining

15 Larry Klayman, was -- was -- or were findings of

16 contempt of court against Larry Klayman ever discussed?

17 A Excuse me?

18 Q I understand that you talked to members of the

19 group before you hired Larry Klayman for the purposes of

20 the Florida Obama litigation, correct?

21 A Correct.

22 Q Did anyone, during any of those meetings,

23 mention the findings of contempt of court from Ohio?

24 A Well, all I recall is he was behind on child

25 support. I didn't know there was anything criminal or




Page 99

1 anything like that. This is news to me.

2 Q You didn't know there were contempt of court

3 findings?

4 A No.


6 evidence.

7 BY MR. KRESS:

8 Q In your mind, as a potential donor, would

9 contempt of court findings reflect negatively on Larry

10 Klayman?


12 speculation. Compound question. Indefinite as to time.

13 You can answer, George.

14 THE WITNESS: All we knew is he was behind on

15 his child support. We did not know about the exact

16 legal nature of these things. And when we heard he was

17 behind, we asked for an explanation. He gave us an

18 explanation, which was satisfactory, which is quite a

19 bit different than what happened from Mrs. Ruffley,

20 where she only presented one side of the story, which

21 appears to be an intent to mislead people.

22 BY MR. KRESS:

23 Q You didn't hear Mrs. Ruffley's comment, did

24 you?

25 A No. Again, as I told you earlier --




Page 100

1 MR. KLAYMAN: Asked and answered. Asked and

2 answered. Why do we have to keep answering the same

3 questions? It's badgering with the witness.

4 MR. KRESS: It's not badgering the witness.

5 MR. KLAYMAN: You are asking the same questions

6 over and over again.

7 MR. KRESS: I think you are badgering the

8 attorney.

9 MR. KLAYMAN: No, I'm not badgering you because

10 you are not doing it proper. I have to make an

11 objection.

12 MR. KRESS: I believe I am.

13 BY MR. KRESS:

14 Q Do you have an understanding of what contempt

15 of court is?

16 MR. KLAYMAN: Objection. Calls for legal

17 conclusion.

18 THE WITNESS: I am not a lawyer.

19 BY MR. KRESS:

20 Q Based on your lay understanding of legal terms,

21 whatever that may be, what do you think about the term

22 "contempt of court"?

23 A It's very negative.

24 MR. KLAYMAN: Objection. That's vague and

25 ambiguous.




Page 101

1 BY MR. KRESS:

2 Q I can't hear the answers.

3 MR. KLAYMAN: Objection. Vague and ambiguous.

4 Calls for legal conclusion.

5 BY MR. KRESS:

6 Q What -- what -- what impact does the term

7 "contempt of court" have on you?

8 MR. KLAYMAN: Objection. Calls for legal

9 conclusion. And indefinite as to time. Irrelevant.

10 Contempt to court as to him generally? Irrelevant.

11 Overly broad. Calls for legal conclusion.

12 BY MR. KRESS:

13 Q Mr. Miller, can you answer the question,

14 please?

15 A Again, I'm not a lawyer, so I would only give

16 you a very rough layman's perception of what it is. So,

17 if you would hold me to that, then I might give an

18 answer which is legally incorrect.

19 Q But that's all I'm looking for, is what is your

20 understanding of the phrase "contempt of court"?

21 MR. KLAYMAN: In a general -- objection. In a

22 general sense? Or in a specific sense? That's what I

23 -- that's why I say it's vague. It's vague.

24 BY MR. KRESS:

25 Q Okay. In a -- what is your -- I can ask it in




Page 102

1 a general sense.

2 What is your understanding of the phrase

3 "contempt of court"?

4 A Well, five years ago, it would be a very

5 negative term to me, but since I've seen it applied to

6 people doing right and still being held in contempt of

7 court, all it means is that it is a disagreement with

8 the judge, and the judge wants to impose some kind of a

9 sanction that's a prelude to doing that.

10 Q As of the time you hired Larry Klayman or your

11 group hired Larry Klayman, however it worked out, how

12 did you view the term "contempt of court"?

13 A About the same as I just described.

14 Q Okay. If you can refer to Exhibit 5, please.

15


17

18 A Okay. Excuse me. I'm on 3. Okay.

19 Q I'll represent to you that Exhibit 5 is an

20 order from the Ohio -- an Ohio court, domestic relations

21 court, dated February 22, 2010, in which a capias was

22 ordered for Larry Klayman.

23 MR. KLAYMAN: I object to the characterization

24 of the document. The document speaks for itself.

25 BY MR. KRESS:




Page 103

1 Q Do you know what a capias is?

2 A No.

3 Q Did you know that in February of 2010, two

4 years before Larry Klayman was hired, a capias had been

5 issued for his arrest?

6 MR. KLAYMAN: Objection. Calls for facts not

7 testified to. Lacks foundation. That's your testimony,

8 not his.

9 BY MR. KRESS:

10 Q Did you know that a capias had been issued for

11 Larry Klayman's arrest in February 2010?

12 MR. KLAYMAN: Same objection.

13 BY MR. KRESS:


15 A No.

16 Q Does that reflect negatively on Larry Klayman?

17 MR. KLAYMAN: Objection. He just testified he

18 didn't know what a capias is.

19 BY MR. KRESS:

20 Q Does the issuance of an arrest warrant affect

21 -- negatively reflect on the person --

22 MR. KLAYMAN: Same objection. Lacks

23 foundation. Facts not testified to.

24 THE WITNESS: It might.

25 BY MR. KRESS:




Page 104


2 Skipping ahead to Exhibit 15.

3


5

6 A Okay.

7 Q And specifically, page 3 of 12.

8 A Yes.

9 Q And if we look at that paragraph 4 -- well, let

10 me back up one second. I need to start again. Let's

11 look at page 2 of 12.

12 Do you recall reading this article from Orly

13 Taitz?

14 A Yes.

15 Q And it was posted on February 26, 2012,

16 correct?

17 A Correct.

18 Q "For Clarification Regarding Article 2 Legal

19 Fund and Larry Klayman." So, this -- you understood

20 this to be a clarification of Orly Taitz's e-mail

21 posting from three days earlier, correct?

22 MR. KLAYMAN: Objection. I object to the

23 characterization of the language used by Orly Taitz. He

24 can certainly testify based on his understanding --

25 MR. KRESS: The call is coming from the court.




Page 105


2 MR. KRESS: Oh, shoot. We can go off the

3 record for a second.

4

5 (Off the record.)

6

7 MR. KRESS: We can go back on the record.

8 We'll wait.

9 BY MR. KRESS:

10 Q Regardless of the characterization, the article

11 is entitled "Clarification Regarding Article 2 Legal

12 Fund and Larry Klayman," correct?

13 A That's what it says, yes.


15 for itself.

16 BY MR. KRESS:

17 Q And in fact, if we look at page 3 of 12 now,

18 let's -- let's start under number 3. There's a line

19 there that says: "Response from" -- well, let's start

20 with the top at number 3.

21 "Mr. Klayman writes: 'You stated that

22 I had not done work on the project.'"

23 And it says there below:

24 "Response from Orly: I simply posted

25 a link to the complaint filed by the Florida




Page 106

1 Bar against Larry Klayman. Other" --

2 A I'm sorry. Where are you now? Where are you?

3 Q Paragraph 3.

4 A You are on page 3?

5 Q Page 3 of 12.

6 A Yeah.

7 Q And then towards the top, there's a heading for

8 number 3.

9 A Yes. "I have not done work on the project."

10 Q Right.

11 A Uhm-hum.

12 Q And below that, it says:

13 "Response from Orly: I simply

14 posted a link to the complaint filed by the

15 Florida Bar against attorney Klayman."

16 So there's -- isn't that indicating to you that

17 this information came from the Florida Bar and not from

18 Connie Ruffley?

19 MR. KLAYMAN: Objection. Objection. The

20 document speaks for itself. The document speaks for

21 itself. Calls for speculation.

22 MR. KRESS: If we could just hold again because

23 we are getting a call.

24

25 (Pause in proceedings.)




Page 107

1

2 MR. KRESS: Hello. Yes. Yes.

3 MR. KLAYMAN: Would you put it on speakerphone?

4 MR. KRESS: Yeah. I'm going to. Can I put you

5 on speaker phone? Okay. Thank you. All right.

6 UNIDENTIFIED PERSON: I just wanted you to know

7 the judge is not back from lunch yet. Are you

8 requesting an emergency hearing today?

9 MR. KRESS: Yeah, because we have an ongoing

10 deposition, and if possible, we would like to get an

11 order on some objections.

12 UNIDENTIFIED PERSON: Okay. As soon as he

13 comes in, I will let him know you called and you're

14 requesting an emergency hearing for today, and I will

15 let you know when he's in, okay?

16 MR. KRESS: Okay. Thank you.

17 UNIDENTIFIED PERSON: And Mr. Kress, you

18 represent plaintiff or defendant?

19 MR. KRESS: Defendant.

20 UNIDENTIFIED PERSON: Defendant, okay. Thank

21 you.

22 MR. KRESS: Could the court reporter please

23 read back the last question? I forget where I was.

24

25 (Requested text read by the reporter.)




Page 108

1


3 speculation. Document speaks for itself.

4 BY MR. KRESS:

5 Q You can answer.

6 A That's what it says.

7 Q All right. And do you know whether that

8 information is truthful or untruthful?

9 MR. KLAYMAN: Objection. He can't testify to

10 that. That calls for speculation. He didn't write

11 this.

12 MR. KRESS: If he doesn't know, he can tell me.

13 THE WITNESS: All I know is what she said here.

14 I don't know if she really got it from there or not.

15 That's what she said.

16 BY MR. KRESS:

17 Q Okay. And she, being Orly Taitz, correct?

18 A Correct.


20 for itself.

21 BY MR. KRESS:

22 Q All right. In your experience as a donor, do

23 sanctions against an attorney reflect negatively on the

24 attorney?

25 MR. KLAYMAN: Objection. That's overly broad.




Page 109

1 And vague. And irrelevant.

2 THE WITNESS: Am I supposed to answer this

3 vague and irrelevant question?

4 BY MR. KRESS:

5 Q You are.

6 A Well, normally, it would, which is why we delve

7 further to find the basis behind it, and I told you what

8 we found already. But, you know, presented as it is,

9 without the mitigating stuff, it looks very damaging,

10 doesn't it?

11 Q And you said you -- you researched it. Do you

12 know whether other people researched deeper in the

13 Florida Bar sanctions?

14 A I first became aware of it because other people

15 sent me the information.

16 Q Okay.

17 A As soon as Larry's name became public, we were

18 just deluged with information, both pro and con, with

19 people from all over the country; allies, enemies, and

20 in between.

21 Q All right. So, you got a lot of information

22 regarding Larry?

23 A A lot of data.


25 THE WITNESS: I'm not sure how much




Page 110

1 information.

2 BY MR. KRESS:

3 Q A lot of data. And you were able to sort

4 through that?

5 A Well, I think -- I think we were.

6 Q Okay. And if we look at paragraph 4 of

7 Exhibit 15, page 3 of 12, there's some -- I know that

8 Mr. Klayman does not like the way it was --

9 MR. KLAYMAN: Wait.

10 BY MR. KRESS:

11 Q I'll strike that and start again.

12 If you could look at exhibit -- I'm sorry.

13 Paragraph 4, page 3 of 4, and just read it to yourself.

14 A Uhm, read it to myself. Okay. The one that

15 starts: "I read the first post"?

16 Q Yep.

17 A Uhm-hum. Yes, I read it.

18 Q Okay. Would you agree with me that this is

19 some effort at clarifying the prior comment regarding

20 conviction?


22 for itself.

23 BY MR. KRESS:

24 Q You are a potential donor reading this --

25 MR. KLAYMAN: Well, I want the thing read.




Page 111

1 Read it, George.

2 THE WITNESS: If I was a potential donor --

3 BY MR. KRESS:

4 Q Wait, wait, wait. Stop. This is -- this is my

5 questioning. If you want to ask him on cross, do it.

6 This is my questioning.

7 MR. KLAYMAN: It's vague and ambiguous.

8 MR. KRESS: Make your objection.

9 MR. KLAYMAN: And I'm not sure what it is you

10 are referring to in 4.

11 MR. KRESS: Make an objection.

12 MR. KLAYMAN: It's an improper question.

13 George, take your time and read it first, and

14 then answer his question. Read it first, paragraph 4.

15 THE WITNESS: I'll read it again.

16 MR. KLAYMAN: To yourself. That's what I

17 wanted, is him to have the time to actually read it.

18 MR. KRESS: He just read did, but he can read

19 it again.

20 MR. KLAYMAN: Nobody can read it that fast, not

21 even a speed reader.


23 MR. KLAYMAN: Read the whole thing, the whole

24 paragraph.

25 THE WITNESS: I did.




Page 112

1 MR. KLAYMAN: Okay. Thank you.

2 MR. KRESS: Can the court reporter, please,

3 read my last question back?

4

5 (Requested text read by the reporter.)

6

7 THE WITNESS: No.

8 BY MR. KRESS:

9 Q Okay. Fair enough.

10 Well, she does state in here that he was

11 convicted, correct? Or not convicted yet?

12 MR. KLAYMAN: Please read the entire --

13 MR. KRESS: Larry, I will ask the questions the

14 way I will ask the questions. I've been very tolerant

15 of you. I will ask the questions the way I want to ask

16 the questions.

17 MR. KLAYMAN: No, I've been very tolerant of

18 you because what you try to do is you try to -- you try

19 to pervert the meaning of what's -- or the written word

20 of what's in here. Just read him what was written here

21 and then ask him a question, that's all I'm asking for.

22 That's all I've been asking for three hours.

23 MR. KRESS: We've only been here for two and --

24 MR. KLAYMAN: Whatever. Feels like three.

25 MR. KRESS: Feels like four to me.




Page 113

1 MR. KLAYMAN: Just read -- read what it is you

2 want him to talk about rather than -- you are

3 mischaracterizing what was written.

4 BY MR. KRESS:

5 Q There's a phrase in there that says "he was not

6 convicted yet," correct?

7 A Correct.

8 MR. KLAYMAN: Read the phrase.

9 BY MR. KRESS:

10 Q Thank you.

11 A I'll read the whole sentence.

12 "So there was an error. Mr. Klayman

13 was indicted in the state of Ohio."

14 MR. KRESS: Strike, strike.

15 BY MR. KRESS:

16 Q I am not asking you to read it. If you want me

17 to fight with you, if you want me to make this last all

18 day, we can.

19 A I don't really care how long this lasts.

20 That's not my problem.

21 Q I'm trying to do this efficiently. I'm trying

22 to conduct your deposition and trying to do it in good

23 faith. Let's just stick to the questions and the

24 answers.

25 This -- this -- this is appeared on the same




Page 114

1 website as the February 23, 2012, website, correct?

2 A The OrlyTaitzESQ.com website.

3 Q Yes. They appeared on the same website,

4 correct?

5 A Correct.

6 Q All right. So, a reader finding the

7 February 23, 2012, uhm, posting would find the

8 February 26, 2012, posting, correct?

9 A Correct.

10 Q Thank you.

11 So, you first contacted Larry Klayman about

12 this Florida Obama Challenge in December of 2011.

13 You've told us that. And I'm just trying to set the

14 background. The retainer e-mail was sent by Larry

15 Klayman on February 8, 2012.

16 How much money had you raised by -- if any, by

17 February 8, 2012?

18 MR. KLAYMAN: Calls for compound question.

19 THE WITNESS: I can't remember the exact amount

20 at that time. I didn't time phase the donations, but we

21 were getting a lot of money early on, and it kind of

22 took a plunge off a cliff toward the end of the month.

23 BY MR. KRESS:

24 Q So, let me ask it -- I'm going to break this

25 down a lot as much as we can.




Page 115

1 Had you raised any money to pay Larry Klayman

2 by February 8, 2012?

3 A Yes.

4 MR. KLAYMAN: February, what date?

5 BY MR. KRESS:

6 Q February 8, 2012.

7 A Yes, yes.

8 Q Do you know how much, either exactly or as a

9 ballpark?

10 A I don't remember. I know we had like a few

11 large donations up front. I think we actually raised

12 most of it before all this happened, and slowed down

13 quite a bit after that, but I don't remember the exact

14 time phasing, honestly.

15 Q When did you donate your thousand dollars?

16 A The date? I think it was before this.

17 Q Before February 8th?

18 A I can't -- I can get that information because

19 it would be in my check register if that's necessary.

20 Q Okay. All right. So, you don't really know

21 exactly how much you raised by February 8th of 2012,

22 correct?

23 A I don't remember. I don't remember.

24 Q But you got -- you indicated that most of the

25 donations came in early, correct?




Page 116

1 A Yes. They did, yes.

2 Q And how much -- how much in donations came in

3 between February 8th, 2012 and February 23, 2012?

4 A I don't remember.

5 Q Okay. Well, if we look at Exhibit 7, as of --

6 take your time to get there.

7 A Okay.

8 Q And I'm referring to the top e-mail there. I'm

9 going to give Mr. Klayman a chance to get his copies in

10 front of him.

11 A Go ahead.

12 Q As of May 7, 2012, what had been paid was, for

13 sure, was 5,000 plus 3,300 plus 1,000 correct?

14 A That's what it says.

15 Q Okay. To be fair, it does say below that:

16 "An unknown amount was sent directly

17 from people given your address and bank number

18 while we were trying to get

19 ConstitutionalActionFund.com, Inc. started."

20 And you asked him how much he received

21 directly. Did he ever answer you?

22 A He said not much.

23 Q Okay. But as of May, you knew that $9,300 had

24 been raised for this Obama challenge?

25 A Correct.




Page 117

1 Q Is it fair for me to assume then or would it be

2 accurate to assume that some number less than $9,300 had

3 been raised before February 23, 2012?

4 A That would be a --


6 speculation. Calls for speculation.

7 BY MR. KRESS:

8 Q If you answered, I couldn't hear you.

9 A Probably.

10 Q Okay. Do you know how much was raised between

11 February of 23, 2012 and May 7, 2012?

12 A No.

13 Q Did you or the group ever promise a specific

14 amount that would be raised for Larry Klayman?

15 A We did say that we would raise the retainer and

16 pay expenses and then that we would pay $395 per hour

17 thereafter when we got past that threshold.

18 Q But in terms of a specific amount, whether that

19 was another $20,000 or hundred thousand dollars, never

20 made any specific reference?

21 A We knew it was by big number. We didn't know

22 what it was at that point.

23 Q So, as of May 2012, May 7, 2012, you had raised

24 this $9,300. And Mr. Klayman was paid at least nine --

25 a total of $21,000, approximately. So it's fair to




Page 118

1 assume that somewhere between May 7, 2012, and the

2 conclusion of the representation, the group was able to

3 raise another approximately $12,000?

4 MR. KLAYMAN: Wait. Objection. Assumes facts

5 not testified to. He never testified to that.

6 MR. KRESS: He can tell me if it's wrong.

7 THE WITNESS: Well, since we gave him --

8 MR. KLAYMAN: Do you understand the question?

9 I don't.

10 THE WITNESS: -- the nine and we gave him more

11 than that afterwards, that would have to be

12 mathematically correct, yes.

13 BY MR. KRESS:

14 Q In other words, the difference between the

15 21,000 approximately and the 9,300 was raised subsequent

16 to May 7, 2012?

17 A It was. That's all we were able to find in

18 spite of the fact that we had a national publicity

19 campaign going.

20 Q Okay. Your thousand dollars, is that accounted

21 for in this May 7, 2012, e-mail?

22 A I think so. Pretty sure I had.

23 Q Where?

24 A I'm pretty sure I had already denoted. I

25 didn't itemized the -- I just had payments. I didn't




Page 119

1 have itemization of the sources in this document.

2 Q Okay. Did it come -- was the --

3 MR. KRESS: Let's stop again because the call

4 is coming in from the court.

5 Hello.

6 UNIDENTIFIED PERSON: This is Brendan calling

7 from Judge O'Sullivan's chambers. I just wanted to let

8 you know that the clerks handle the schedules, and what

9 they came up with was if you guys want to try and call

10 back at 2:30, see if the judge is available, he was open

11 to that suggestion, but I guess that's the best he can

12 do right now.

13 MR. KRESS: Look, can I think about that and

14 call you back?

15 UNIDENTIFIED PERSON: Sure, that's fine.

16 MR. KRESS: What number is should I use to call

17 you back?

18 UNIDENTIFIED PERSON: You know, with the judge,

19 (305) 923-5920.


21 MR. KLAYMAN: Can we go off the record for a

22 second?

23

24 (Off the record.)

25




Page 120

1 BY MR. KRESS:

2 Q Before we went off the record, uhm, I had asked

3 you where your thousand-dollar contribution was

4 referenced in plaintiff's exhibit, I'm sorry, Exhibit 7.

5 I don't think you had a chance to answer that yet or

6 maybe you started to.

7 A I did not itemize the contributions. I merely

8 put the dates of the payments. So, at this -- at --

9 this particular letter does not show a specific

10 contribution from me or any other person.

11 Q Is your contribution, though, within the

12 dollars referenced in Exhibit 7?

13 A Yeah. I'm pretty sure it is. Yes.

14 Q Okay. Did you contribute anything after May 7,

15 2012?

16 A I don't think so.

17 Q Why not?

18 A Well, we were pretty close to the hearing by

19 then, and I had limited means also because I have other

20 causes that I support besides this. I might have put

21 more in. If you are getting around to, did this inhibit

22 me? You know, it might have, I don't know.

23 Q Okay. And I believe you indicated that most of

24 the donations came in early or something to that effect.

25 That's what my notes say.




Page 121

1 Do you agree that most of the donations came in

2 early in the representation?

3 A Yes.

4 Q And what is your definition of "early" in this

5 context with respect to the donations?

6 A Early, before the contested times of late

7 February.

8 Q Okay. Were you aware that Mr. Klayman also

9 filed an Obama Challenge case in Alabama?

10 A Yes.

11 Q Did you have any involvement in that?

12 A Did I? Only in publicity, and I know some

13 people involved in the case. I know Virgil Goode, and I

14 also am familiar with some of the people that supported

15 it.

16 Q Virgil Goode? Did you a Goode?

17 A Goode, yeah. G-O-O-D-E.

18 Q He is the plaintiff, a named plaintiff in the

19 Alabama case, correct?

20 A He was one of the plaintiffs, yeah. There were

21 two plaintiffs. The other name alludes me at the

22 moment.

23 Q Did you make any monetary contributions, either

24 individually or through any of your organizations, to

25 the Alabama Obama litigation?




Page 122

1 A No.

2 Q Do you know anyone who did?

3 A I can't remember specific amounts, but some

4 people said they were supporting it, but I don't have

5 detailed knowledge of who contributed, no.

6 Q Who do you recall saying they were going to

7 contribute to that Alabama case?

8 A I would rather not mention any names right now.

9 Q I'm sorry, but that's -- I understand you would

10 rather not, but I'm actually --

11 A I think Brian Riley, for example, was very

12 interested. That's one name that pops up of someone who

13 was very motivated about that case and actually knows

14 the -- the head of the Supreme Court in Alabama, Judge

15 Moore.

16 MR. KLAYMAN: Just answer the question,

17 Mr. Miller.

18 BY MR. KRESS:

19 Q Do you know how much Brian Riley contributed?

20 A I have no idea.

21 MR. KLAYMAN: Objection. Assumes facts not in.

22 It's not in evidence. He said he didn't know.

23 BY MR. KRESS:

24 Q Do you know anyone else who contributed to the

25 Obama litigation filed in Alabama by Larry Klayman?




Page 123

1 A I do not have any detailed knowledge about

2 that.

3 Q Did you encourage people to contribute to the

4 Alabama Obama litigation filed by Mr. Klayman?

5 A Yes.

6 Q When was the Alabama Obama litigation filed?

7 A Oh, quite a while ago. I think it was in late

8 2011. This goes back -- it was over a year. I know it

9 took a year from the time it was filed, well over a year

10 to finally have the hearing, and that was done well

11 after the election.

12 Q Do you know if the Alabama Obama litigation was

13 filed before or after the Florida Obama litigation?

14 A The Florida was filed in, I believe, January of

15 2012. I'm thinking that was before the Alabama case.

16 Q So, the Alabama case --

17 A Larry didn't get involved in that case

18 initially. He came in later on, as I recall. Am I

19 right, Larry?

20 MR. KLAYMAN: I can't testify here contrary to

21 my esteemed counsel, who testifies sometimes.

22 MR. KRESS: I object to that comment, but.

23 BY MR. KRESS:

24 Q But just so I understand you, I think that what

25 you are saying is the Alabama litigation been filed




Page 124

1 before the Florida litigation, but that Larry did not

2 get on -- get involved in the Alabama litigation right

3 away?

4 MR. KLAYMAN: Objection. Compound question.

5 BY MR. KRESS:

6 Q Is that correct?

7 A That's my perception, yes.

8 Q Okay. Were you encouraging -- well, let me ask

9 it this way. To your knowledge, was Larry's first

10 involvement with an Obama litigation challenge the

11 Florida litigation?

12 A Excuse me? Was Larry's what?

13 Q To your knowledge, to your knowledge, was

14 Mr. Klayman's first involvement with the Obama

15 litigation the Florida litigation?

16 A Well, they are all Obama litigations. The

17 Florida case was Obama litigation. The Alabama case was

18 also related to the eligibility on the ballot placement

19 of Obama.

20 Q Okay. I asked -- I asked the question wrong.

21 Which state did Larry become involved in first

22 if you know? Did he become involved first in Florida or

23 Alabama?

24 A I believe it was Alabama -- excuse me.

25 Florida, and that the Alabama came later. As far as I




Page 125

1 know, we were the ones that introduced him into the

2 eligibility movement and litigation. To the best of my

3 knowledge, but I can't speak for everything Larry did.

4 I don't know what he does. He's not accountable to me.

5 Q Did you contribute to -- I'm sorry.

6 Did you encourage people to contribute to the

7 Alabama litigation after Larry became involved?

8 A I've always encouraged people to contribute to

9 all of the eligibility cases.

10 Q Including the Alabama litigation after Larry

11 became involved?

12 A All cases. The question is, did they? My

13 commitment -- my commitment has not been diminished as a

14 result of this. Certainly been tried, but I've kept my

15 commitment up until today.

16 MR. KRESS: Okay. Are you going to have some

17 questions?

18 MR. KLAYMAN: I may. I have to take a break

19 and let you know.

20 MR. KRESS: Let's take a short break then.

21 I'll think about whether I have more questions.

22 MR. KLAYMAN: Are you done for the moment?

23 MR. KRESS: We can go off the record.

24





Page 126

1

2 BY MR. KRESS:

3 Q Mr. Miller, have you ever communicated with

4 anyone from Judicial Watch?

5 A Yes.

6 Q With whom?

7 A I can't remember the name of the person, but I

8 called Judicial Watch multiple times and also saw them

9 at various events where they had booths, asking them if

10 they would represent us in the eligibility effort, and

11 they turned us down flat.

12 Q Okay. Have you had any other contacts with

13 Judicial Watch?

14 A I don't think so.

15 Q Okay. Was there a reason stated for turning

16 you down for the Obama cases?

17 A On one, I was told they didn't get into that

18 area. Another one --


20 THE WITNESS: Okay. No, I wasn't.


22 THE WITNESS: Just what I told you.

23 BY MR. KRESS:

24 Q I couldn't understand what you said, I'm sorry,

25 because Mr. Klayman was objecting.




Page 127

1 MR. KLAYMAN: Objection on relevancy.

2 BY MR. KRESS:

3 Q I'm sorry, I just couldn't hear you. What was

4 -- what was the reason, if any, stated for not accepting

5 the cases or helping with the cases?

6 A I've just been told it was irrelevant.

7 MR. KLAYMAN: You can respond. That's an

8 objection on the record.

9 THE WITNESS: Okay. Once, I was told that they

10 didn't get into that sort of thing, and the other times

11 I was not given a reason.

12 MR. KRESS: All right. Thank you. Those are

13 all the questions I have for you for now.

14 MR. KLAYMAN: Okay. We are going to take a

15 5-minute break.

16


18

19 MR. KLAYMAN: Back on the record. We are going

20 to get into our cross-examination.


22

23

24

25




Page 128

1 CROSS-EXAMINATION

2

3 BY MR. KLAYMAN:

4 Q Okay. Mr. Miller.

5 A Yes. Can you hear me?

6 Q Yes.

7 A I'll turn your attention to Exhibit 14.

8 Q Okay. Turn to the section called "Comments,"

9 which is on page 4.

10 A Got it.

11 Q The first comment, Bloodless Coup, February 23,

12 2012, 7:20 a.m., can you read that?

13 A Yeah.

14 MR. KRESS: I'm going to object. The document

15 speak for itself.

16 MR. KLAYMAN: I'm actually asking him to read

17 it, Mr. Kress. I'm not mischaracterizing it. That's

18 the difference between my questioning.

19 MR. KRESS: I won't do it again. I was just

20 making a joke.

21 MR. KLAYMAN: All right. That's fine.

22 THE WITNESS: "I was initially excited about

23 Larry Klayman and helped the news about him to

24 go viral. Now I'm wondering about him and what

25 his true motives might be."




Page 129

1 BY MR. KLAYMAN:

2 Q Did you see that in and around the time it was

3 published on Mrs. Taitz's website?

4 A Yes.

5 Q And how did you take that to mean with regard

6 to potential donors at the time, if at all?

7 MR. KRESS: Objection.

8 THE WITNESS: Donations from him at least would

9 dry up and other similar comments I heard from others

10 were the same basic sentiments.

11 BY MR. KLAYMAN:

12 Q Okay. Mrs. Taitz's website, how widely read is

13 it based on your experience and eligibility issues?

14 MR. KRESS: Objection. Form.

15 THE WITNESS: Most people who are involved in

16 the eligibility movement read it, and opponents read it.

17 It's been quoted extensively by both friends and

18 enemies. So, you know, it -- thousands and thousands of

19 people read that.

20 BY MR. KLAYMAN:

21 Q Can you explain for us the types of individuals

22 that are interested in eligibility and related issues

23 based on your experience dealing with these issues?

24 A Well, the core group would be the patriot

25 conservative community, who believe that Obama doesn't




Page 130

1 have any legal right to be present by virtue of the fact

2 that his father was a foreigner, which, according to

3 legal precedents and documents of the founders, say

4 should be excluded from the presidency. And in Article

5 II, section 1, clause 5 of the Constitution was written

6 with that in mind, but did not specifically call out

7 those requirements, which can only be gotten by looking

8 at legal precedents and founders' documents. So,

9 those --

10 MR. KRESS: I also would object.


12 MR. KRESS: Please continue. I didn't mean to

13 interrupt you.


15 MR. KRESS: But I do want to note an objection.

16 MR. KLAYMAN: That's fine.

17 MR. KRESS: I object to the extent any of this

18 is expert testimony because he has not been identified

19 as an expert.

20 MR. KLAYMAN: I asked him based on his

21 experience.

22 BY MR. KLAYMAN:

23 Q Mr. Miller, with regard to the statements --

24 and I'll turn your attention again to Exhibit 14, page

25 2. Can you read the paragraph beginning: "Ms. Ruffley




Page 131

1 actually advised me that Larry Klayman"?

2 A Okay. "Ms. Ruffley actually advised me that

3 Larry Klayman is not licensed in California.

4 She told me he no longer works at the Judicial

5 Watch and that donors should know about

6 litigation in Ohio, where he was convicted just

7 recently of not paying a large amount in child

8 support. She provided a lot of other

9 information. I will publish only what is

10 public record. I am not publishing anything

11 that is not in the public record."

12 Q Now, the phrase, uhm, "Donors should know about

13 litigation in Ohio, where he was convicted just recently

14 of not paying large amount in child support," did you

15 take that to mean at the time that Ms. Ruffley was

16 referring to give that donors supporting Larry Klayman's

17 eligibility lawsuits --


19 BY MR. KLAYMAN:

20 Q -- and other legal matters?



23 BY MR. KLAYMAN:

24 Q The statement that "donors should know about

25 litigation in Ohio where he was convicted just recently




Page 132

1 of not paying large amount in child support" --

2 A Right.

3 Q -- did you take that to mean when you read it

4 -- did you take that to mean when you read it that

5 Ms. Ruffley was telling Orly Taitz to give this to Larry

6 Klayman's donors for eligibility in other legal matters?

7 MR. KRESS: Objection. Form. Speculation.

8 You can answer.

9 THE WITNESS: It would seem to me that she's

10 cautioning donors to not donate to someone who has been

11 convicted of a crime, as she says. But that's -- that's

12 the reading I got from it anyway and other people that I

13 spoke to or corresponded with.

14 BY MR. KLAYMAN:

15 Q Now, of all the things that are said in the

16 context of this Exhibit 14, which do you consider to be

17 the most damning that Ms. Ruffley said about Larry

18 Klayman?


20 THE WITNESS: Well, the conviction. The

21 conviction is the worst thing because my understanding,

22 if the lawyer is convicted, he's not a lawyer anymore,

23 he get disbarred. So, that would be full stop on our

24 program if that was true. And if people perceived it to

25 be true, even if it was a lie, it would still dry up our




Page 133

1 donations, which would still stop the case. So my

2 question is, is she trying to stop this case? Or is she

3 doing this as a public service so donors won't waste

4 their money on a felon? You tell me.

5 BY MR. KLAYMAN:

6 Q Now, with regard to the $11,000 that you claim

7 or you testified were paid to Larry Klayman by your

8 group of individuals, who were raising money -- back up.

9 You do remember testifying that $11,000 were

10 paid on top of the initial payment after the defamatory

11 statement, alleged defamatory statement was made,

12 correct?

13 A Yes.

14 MR. KRESS: I think he said 12.

15 THE WITNESS: Well, the total came to 21

16 something.

17 BY MR. KLAYMAN:

18 Q Okay. Now, how do you explain, if at all, that

19 you got $11,000 after the defamatory statement?

20 A Well, we had ramped up --

21 Q After the alleged defamatory statement?


23 THE WITNESS: Okay to answer?

24 MR. KRESS: Yes.

25 THE WITNESS: Oh. Okay. I get caught in the




Page 134

1 crossfire between you guys. We were ramping up a

2 national campaign. We expected six figures. So, 11,000

3 is chicken feed compared to what we thought we could

4 raise, in what was the highest visibility case, by the

5 highest visibility, most famous lawyer that was ever

6 brought into the eligibility movement. And we fell flat

7 on our faces. Thank you. 11,000.

8 BY MR. KLAYMAN:

9 Q Now, based on your understanding of an

10 indictment having been issued with regard to Larry

11 Klayman and child support, was it your understanding,

12 when you learned of that, that an indictment was

13 equivalent of being convicted?

14 A Well, I know the difference --


16 THE WITNESS: -- but a lot of people perceive

17 an indictment is tantamount to conviction; that the

18 state is always right, you know. So, an indictment is

19 very, very damning, let's face it, but a conviction,

20 that's -- that's ending. That's much worse. Everyone

21 knows that a conviction means that you are a felon at

22 that point. You are legally a felon. So that's a

23 pretty big deal.

24 BY MR. KLAYMAN:

25 Q In this country, you are innocent until proven




Page 135

1 guilty?


3 THE WITNESS: That's what the law says.

4 MR. KLAYMAN: I have no further questions.

5 MR. KRESS: I have just a few.

6

7

8

9 REDIRECT EXAMINATION

10

11 BY MR. KRESS:

12 Q You -- you knew that Larry Klayman was not

13 disbarred, correct?

14 A Correct.

15 Q And you knew that he was licensed in Florida,

16 correct?

17 A Correct.

18 Q You probably didn't know this, but you are

19 assuming that the -- the child support charge was a

20 felony, correct?

21 A I thought initially, it was civil. I didn't

22 know it was a felony until afterward.

23 Q But you just -- in your testimony, you were

24 just referring to a felony, correct?

25 A Well, yes. I know that now. I didn't know




Page 136

1 that back then, as I told you earlier.

2 Q Well, would you be surprised to know that the

3 judge just ruled that it wasn't a felony?

4 MR. KLAYMAN: I'm going to object to that

5 because, in fact -- and we are going to be moving to

6 correct the summary judgment -- it was a felony because

7 of the nonpayment of more than 26 weeks. There was an

8 error in that judgment. So I don't want you to put

9 words in his mouth.

10 MR. KRESS: I'm not putting word in his mouth.

11 It's words in my mouth.

12 MR. KLAYMAN: And that's a public record the

13 court can take judicial notice of, to correct the

14 summary judgment.

15 BY MR. KRESS:

16 Q Whatever it is, you are assuming it was a

17 felony, correct?

18 A Now I am.

19 Q Okay. At the time, did you assume it was a

20 felony?

21 A No. At the time, I thought what was actually

22 happening was -- was civil. Until I saw this thing from

23 Ruffley, I had no clue there was a felony involved in

24 this thing.

25 Q At the time, you thought it was a felony rather




Page 137

1 than a misdemeanor, correct?

2 A At what time? Oh, on February 23rd?

3 Q Yes.

4 A All I knew is what I saw in Orly Taitz's blog,

5 which I often take with a grain of salt, but a lot of

6 people take as gospel.

7 Q Are you aware that Larry Klayman agreed to pay

8 an amount of child support to -- to settle the criminal

9 matter in April of 2012?

10 MR. KLAYMAN: Objection. It's facts not

11 testified to. Again --

12 MR. KRESS: Please just let him answer. He can

13 answer.

14 MR. KLAYMAN: No, because it's improper. You

15 didn't lay a foundation, and it hasn't been testified

16 to. You are putting -- you are putting information in

17 front of him, which is not --

18 MR. KRESS: This is a discovery --

19 MR. KLAYMAN: -- which has not been developed.

20 MR. KRESS: This is a discovery deposition.

21 MR. KLAYMAN: It's an improper question. I

22 object on the basis of improper question.

23 MR. KRESS: He can answer.

24 MR. KLAYMAN: This is done intentionally. It's

25 improper.




Page 138

1 MR. KRESS: It's not improper. It's not

2 intentional. It's intentional in asking a question and

3 trying to conclude the deposition.

4 BY MR. KRESS:

5 Q Were you aware that Larry Klayman's indictment

6 was not dismissed until April of 2012?

7 A I don't know the exact date.

8 MR. KLAYMAN: Same objection.

9 BY MR. KRESS:

10 Q Okay. Were you aware that Mr. Klayman agreed

11 to pay child support -- pay back child support related

12 to the dismissal of the indictment?

13 A I know he had to pay something. I don't know

14 how much it was or whether it was brought current and

15 whether the amounts were in dispute. I don't know

16 anything about that.

17 Q Okay. Is there any other testimony you plan to

18 give at trial that you haven't already told us about?

19 MR. KLAYMAN: Objection. That's objectionable

20 testimony. He doesn't know what he's going to be asked.

21 MR. KRESS: Well, he can tell me.

22 MR. KLAYMAN: It's an objectionable question.

23 Totally objectionable.

24 MR. KRESS: You can answer. He can answer.

25 THE WITNESS: I don't intend to do any




Page 139

1 surprises based on just answering questions as they come

2 up. I don't have any ambushes planned or anything like

3 that. Do you?

4 MR. KRESS: Not yet. I do not. I do not. I'm

5 trying to conclude this. I want to make sure we've

6 covered everything with you, and I want to make sure we

7 -- we -- we know what your testimony is going to be.

8 That's the purpose of the question.

9 Uhm, with that, I have no other questions. I

10 will -- I will raise any issues related to this

11 deposition with Judge Altonaga, but I think it will be

12 unreasonable to expect the magistrate to gather all this

13 information and issue any rulings on the deposition in a

14 few minutes.

15 MR. KLAYMAN: The deposition is closed, but

16 just let the record reflect you had your opportunity to

17 have a hearing with the magistrate. And he said he was

18 available at 2:30. And with regard to the

19 attorney-client issues, your client's claimed attorney

20 client on their own without your even making the

21 objections, and he certainly is entitled to consult with

22 his counsel with regard to this deposition since, as I

23 stipulated and as he testified to, he's being

24 represented by me at this deposition. So, I don't

25 understand what the issue is in that regard, but you are




Page 140

1 free to do what you want. Deposition is closed.



4 --o0o--

5 (Deposition proceedings were

6 concluded at 10:48 a.m.)

7 --ooOoo--

8

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25




Page 141

1 STATE OF CALIFORNIA ) ) ss.

2 COUNTY OF LOS ANGELES )

3

4

5 I, GEORGE MILLER, hereby certify under penalty

6 of perjury under the laws of the State of California

7 that the foregoing is true and correct.

8 Executed this _____ day of __________________,

9 20___, at _______________________, California.

10

11

12 _____________________________

13 GEORGE MILLER

14

15

16

17

18

19

20

21

22

23

24

25




Page 142

1 C E R T I F I C A T I O N

2 I, THE UNDERSIGNED, A CERTIFIED SHORTHAND

3 REPORTER OF THE STATE OF CALIFORNIA, DO HEREBY CERTIFY:

4 THAT THE FOREGOING PROCEEDINGS WERE TAKEN

5 BEFORE ME AT THE TIME AND PLACE HEREIN SET FORTH; THAT

6 ANY WITNESSES IN THE FOREGOING PROCEEDINGS, PRIOR TO

7 TESTIFYING, WERE DULY SWORN; THAT A RECORD OF THE

8 PROCEEDINGS WAS MADE BY ME USING MACHINE SHORTHAND,

9 WHICH WAS THEREAFTER TRANSCRIBED UNDER MY DIRECTION;

10 THAT THE FOREGOING TRANSCRIPT IS A TRUE RECORD OF THE

11 TESTIMONY GIVEN.

12 FURTHER, THAT IF THE FOREGOING PERTAINS TO THE

13 ORIGINAL TRANSCRIPT OF A DEPOSITION IN A FEDERAL CASE,

14 BEFORE COMPLETION OF THE PROCEEDINGS, REVIEW OF THE

15 TRANSCRIPT [ ] WAS [ ] WAS NOT REQUIRED.

16 I FURTHER CERTIFY I AM NEITHER FINANCIALLY

17 INTERESTED IN THE ACTION NOR A RELATIVE OR EMPLOYEE OF

18 ANY ATTORNEY OR PARTY TO THIS ACTION.

19 IN WITNESS WHEREOF, I HAVE THIS DATE SUBSCRIBED MY

20 NAME.

21 DATED: _______________

22

23 __________________________________

24 ERIKA A. SJOQUIST, CSR, RPR, CRR CSR NO. 12350

25




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994:2 43:11,14 44:259K41:22 42:14,179th43:209,00042:12,219,300118:159/12/124:2

923-5920119:19953:9,13963:16


George Miller Deposition

Exhibit 1

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Cuyahoga County Court of Common Pleas Criminal Court Division

State of Ohio, l'laialiff

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A TrJe Billllldictmelll For Criminal No111upport • F5 ~2919,:2 1(11)

l Additional Coum(a)

~Oii' • of otfc~<M (on"" ~bob&~ : 09/2~1201)9 tO 09124/2() ll

The State of Ohio. C~:ylho1!" Counr;

Count Orttl Criminal ~otuupport • FS ~2919.2l(B)

l.ury Klaytn11n Dahl of Ot'l'ei'I:Je On or about Seplt:mbcr 2S, 2009 t~ September 24, 2011

I

T'h1Ju~YJ1'7aj'tlrf Or411rllvryafihl S/(J(IIo/0/:Jo. wlthlllt:md/01' :htlioU,oftniiCDwtiJqfcr&tald, O!'lt11Jir 04thJ. iN THENAMS .tN!J 111' T/!8 -~l117rOJUTY OF THB st.tTE OF OHiO. Jo ftltt/ Cl'ld ;ruGill, t.~tll th• a/Jatit narn..J D<.fomkmt{•), ""or abovt rA• J.>w oft A. a/J?JUUU forth abow, /JJ tlrt Counry cf CwyahcgQ, ~nlgwfolly \

•!id recklessly fail to provido support as established by a court order to Isabelle, w:torn, by coot ordet or decree, Larry KlaymM w11.s legally obligated to 3upport.

FURTIIERMORB,Iho cffender failed to provide support fot & tot!!.l ~urn\llated period ct"m·enty-six, weelcs out ot' one hundred Will' eonstcutivo weeks. \ li:f v{fr~~Uit <:o~fi'Qr)' ~a rh•/C¥m uft/Jt Jla/uff In JWdl ~-mod. .:md pf'I1Pidul, umJ u~ tha pea-:. Ul!d di•""ITJI cf:~t SliJII cf \ vMo. I

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A Tru 81~ lndKtmtl1t

i Count TWo Crlmlmtl Nonsupport· F5 1 ~29t9.2t<a> J Defendant. Larry Klayman I 1

Date ot Offtnse On or about September 2~, 2009to September 24, 2011 I

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The gro,dj~ron, o11thelr o(f]/u,furthu find l~lllihtt D•f411dan~(1) ~nlawfolly .

Jid recklessly fail to provido support at established by a. court order to Lance, whom. by court ordet: '

I or decree, Larry Klayman was legally obllgwd to support ,

FL'RTHER.\10RE, tho offender fuiled to provide support fur a total accumulated period oftwenty-,i:lc I weeks out of one hundred fout consecutive weeks. I :n.t "U''"""Iuonfrai1/o rh•/•1111 aftM 'tt<tllt-t In~.,_ mad• ~""provi<kJ, Jnd agutn~fln« ptacea~td dlrlfl' 11/tloc St~ ~1 1 O~lo.

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Exhibit 2


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! Fit'te$n Defendants Indicted for Owing $410.404.55 in Child Support ; ·):..1:1Jr~12

"OR l\IMEOV. TE RElEASl! F•bn.JOI'I 3. <012

CI.SVELANO- t'.JYt<ilo<,a CruntyP""''"'"tor aa1 wu..,., a-od tt.K nr..., ~d•ru .... ,. ir:<!l<:llld \?rf;JIIUre !0 ~ay enid lltJOPO"', T.1asa n1 ...... dqjandanll.,....... e.<:miM~~ $410,~C4.:,t.n ot>io:l

wll!JO\. ':'No ct•tQe ol o1mll'l!ll n<>n-$1.PI'OIIIs a ft1n d8Q!'M '*"">wHch cam"" a "'""1........, "'"·"''iC" of. ,..,. v•..,., """""· ~•••11-dl<olm""" ""'.-...UIInt~ jomt In·•••~ -..,..., •• cu·;ohog• C«Jnty Child Sui>!>O•.E~tr>Mt Jo~ (CSEAl•nd tt& Cuy ....... <l ~f Prooceutot'S Ol!l~o.

1, l.w>y KI,Ym&l, 00, Q/ L¢1 An9&~. Coii!M~•. waa lntllct<ICI or two> (2) c~<n:s Of C!Wh<ll """' e .oport. ~"• '"""' $7R,S$1. 76 'of hlo tw:> ct.k!"" 011•• 11 ..,.r:; 14, Two nrudoq• ,...,,.. h•ld lfl f'Jl:J,''n~t!G R8!RI:fa~ r .... ml"t h~flln 200)} and 2'0Hl Th~ ;aM ~Jtlt.:ry ~a~ men( WIQ IT':JJrle Oli

·1-.p..•UO, 2Ctl i~l~.eM>CU'll ctS1,014 26, AfTlliSJ1n\l,n!l' •eh"""oo'arF-lfltY T, ~:)12.

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Exhibit 3

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·case 1:13-cv-20610-CMA ,,

LARRY ELLIOT KLAY:\1AN Case No: DR07 316840

Petitioner Judge: DIANE M. PALOS

• vs.-

STEPHANIE .-\l'~N DELUCA JUDGMENT ENTRY

Respondent

This matter came on for hearing on July 20, 2009, before M<~gistrme Timothy R. Brown 'lpon Respondent'sMotioo For Contempt Support (Post-decree) #259350, Respondent'sl\.·lotion For Contempt Support (Post-decree) ri273344. Respondcnt'sMotion For Attorney Fees #273 345, Respondcnt'sMotion For Attorney Fees #277027 and Respondent'sMotion For Contempt Support (Post-decree) #277835. Appearances were ma<.le by Roger L. Kleinman (Attorney For Plamtift), Step!l;u1ie Ann Deluca, Respondent, Suzanne M. Jambe (Attorney For Defendant) ond James H. Roll;nson tAttorney for Def.:ndam). TI1e Court Reporter was Karen S. Lamendola.

T:H.~ Court :1dopts the !1.1agi~trate's Dc~.:ision tiled July 28, 2009, in its entirety.

IT IS HEREHY ORDERED:

PETITIONER'S OBJECTIONS FlLED AUGUST 11,2009 TO THE .\1Mf!STRATE'S DECISION FlLIW JULY 28, 2009 ARI<: HEREBY OV"ERRULED A:'IID THE DECISION OF THE MAGISTRATE APPROVED.

RESl'ONDENT'S OBJECTIONS FilED AUG'UST2l, 2009 TO THE ~IAGISTRA TE'S DECISION FllED JULY 28,2009 ARE HEREBY OVERRULED A."lD THE DECISION OF THE MAGISTRATE ,\PPROVED.

IT fS THEREFORE ORDERED, ADJUDGED AND DECREED that the Obll~or, LARRY ELLIOT KLAYMAN, is in contempt of C11urt. The Court tinds that thi: Obligor, lARRY ELLIOT KLAYMAN. is in arrears in the amount of D..l.._393.00 (including attorney files) computed as of Julv JO\ ~ which is owed Obligee. Stephanie Ann Deluca, her :~ssignee(s), ;md/or the Cuyahoga Support Enfon:ement ,1\gency lCSEA) and is re<hl<ed to judgment upo• whlcb execution may is!ue. This sum i~cludes all previously accrued support arrears and processing charges, and superccdcs :1!1 prior determinations. 'lne Obligor, LARRY ELLIOT KLA Y~l4.N, has been credited with all ~upport pyments, includin~; direcVwlived payments. TI1e arrearage reflects adjustments to processing charge arrears due to directlwahed payments since those payments were not ~ro<:essed by the CSEA.


case 1:13-cv-20610-CMA Document 39·4 Entered on FL.SD Docket 121'05/2013 Page 3 of 6

The Obligor, LAHRY ELLIOT KLA Y:'flAN, is hereby srntenccd (or said contempt to HURTY (30) u11ys lu j<~il, or iu lhe ulternativ~, to perform not Ins than 2.00 houn of community ~ervke in lieu of actual irn:arcention, wbiclt service shall be performed at lhe direttion of Court Cormnunity Servic• and be subjl!tt to the Couri'1 rnlew. The community service shall be completed ~fitbln no days fturn the dale. lite Obligor, LARRY ELLIOT KLA Y:\1AN, Rports IO

Court Community Scervic:e. However, the Obligor, LARRY ELLIOT KLAYMA.~'' sentence will be purged provided that the Obligor, LARRY ELUOT KL\ YMAN, pays SJ.200,00 through the CSEA wltbia JO days of tbe journaliutioa of tbb order. This purge payment i:s In lldditlon to any obligation to pay current support at'ld arrearuge payments, whlth may be due.

All support sbaU be paid througb the Oblo Child Sttpport Payment Central (OCSPC), P.O. Box l8237%, Columba,, Ohio 43US.lJ72. Any payments not made through OCS?C shall not be considered as payment of support. Cash payments may be made at the Cuyahoga County Treasurer's OtTrce. County Administration Building, t•• floor- Cashier, 1219 Ontario Street. Cleveland, Ohio 441 I J. All payment$ 5h~ll include the following: Obligor's oilll'le, Social Security Number, SETS case number, :~n<l Dome~tic Relations Court c:~se number. Checks and money orders must be payable to Ohio Child Support Payment Central.

In the event the Obligor, L'\RRY ELLIOT KLA ~. tloes not purge hi' conttmpt, he i!i hereby ordered to N!port, during regular Cl>urt buJiness boun (8:30-ll :30 A.M. l!ld l :3()..3:30 P.:\1), to the Court Community Service Liaison in Room 306 (Third floor) in the Old O>urlhoun., One Lakesid.e Avtnue, no later tbn fGrty (40) days dter the joumallution of this order, to perform his community service, subj~t to immedillle rclea~~e upon later complianet. UP<Jn the failure to purge. the f:~ilure to complete hi.t community "'l<!rviu within the time spteilled, or if terminated by Court Commuaity Service, the Court, upon the flling or au affidavit uf the Obligee, Stephanie Ann Deluca, or the CSEA with an attached <:er1ified copy of CSE,\/OCSPC payment records and the filing of an affidavit of the Court Community Servite Uahon, shall is11ue a capias for the Obligor, Larry Elliot Klayman, to serve the juil scnteuce ordered above. Said llilidavit($) >hall ~e filed witbia o11e (1) year o{ tho journaliutloa of this order.

IT IS FURTHER ORDERED, ADJUDGED AND DJ:CREED that, :n the event that the Obligor, I..AR.R.Y ELLIOT KLAYMAN, is sentenced to perfonn community service and reports for ,a1d p~rformarn::e, the Obligor1 LARRY ELLIOT KLAYMAN, shall pay the ~urn of seventy dollars (170,0(}) directly to Court Community Service for administrative costS.

IT IS FURTHER ORDERED, ADJUDGED A.'ID DECREED that in lddition to the above >entence :md civil purge, the Obligor, LARRY ELLIOT KL\ YMA,"''', shall do the following:

1) Continue to pay$~ per month, which includes Z% processing ,harge, ~current >up port for the remaining mmor children LJnco, Isabelle (S~ per month per child !lQl including 2% processing charge);

2) J>ay an ~dditional il.(;iQJlQ per month toward the arrearage until the arrearage is paid in full or until further order of Court. Processing charges shall not be collected on the arrearJge payment since the above arrearage includes lll accrued processing charges.

Total montlil)' support ordtr is $2,196.00.

IT IS FURTHLR ORDERED, ADJlJDGED AND DECREED: that this Court reserves jurisdiction to address the issue of unpaid medical expenses.

;iS<SS_T? DOC l!l~"()()6) 2


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Cuse 1:13-cv·20610·CMA Document 39-4 Entered on FLSD Docket 12/05/2013 Page 4 of 6

All support under this order shall be withheld or deductetl from the ineome or assers of the Obligor, LARRY ELLIOT KLAYMAN, pursuMt to a withholding or deduction notice or appropriate order issued in accordance with Ch3pters .3119., J 123., and 3125. of the: Revised Code or a wtthdrnwal directive issued pursuant to sections J 123.24 to J 123.38 of the Revised Code and shall be for.varded to the Obll~, STEPllA.NIE ANN DELUCA. in a~or~ance with Chapters 3119., 3121., 3113., and 3l2S.ofthe Revised Code.

To se~urc the support obligation. the Court further rinds that: (check apprcpri.ne box)

Until tho income source oogins withholding in the appropriate amount. the Obligor shall make payments (check or money onler payable to OCSPC) directly to Ohio Child Support Payment Central (OCSPC).

1:?) Obligor's i~ome source is not atta,hable; that Obligor has the ability to posts cash bond :md therefore an order to post bond in the amcuntofSJ.672.00 which sum includes 2% pra<:essing charge, should issue.

IT 1S FURTHER ORDERED. ADJUDGED AND DECREED that Obligor, LARRY ELLIOT KLA 't'MAN immediately notiiY CSEA, in writing, of the commencement of, or any change in ~mployment (inclu~ing self.employment). Receipt of 3dditional incomeimon1es or termination uf benefits. Obligor. LARRY ELUOT KLA ~fAllf shall include a ,jescription of the nat•ure of the income ;:md the name, business address and telephone number of any income souoce. Obligor, LARRY ELLIOT KLAYMAN, shall immediately notify CSEA of any change 1n the >talus of an account from "hi~h suppol1 is being deducted or the opening of a new account with any financial institution alone with the name, busmess addre~s and account number(s).

JT IS FURTHER ORDERED, ADJUDGED AND DECREED that Obligor, LARRY F:Ll.IOT KLA YJ\IAN, 111d Oblige(!, STEPHANIE ANN DILUC.-\, comply with the request of the CSEA or the Court to provide information regarding their health insuran<:e ber,etits, federal in<:orne tax rerum from the previous year, all pay stub:s wHhin the preceding six (6) months, all other record!! evidencing the receipt of any other salll.l)', wages or compensation wilhin the prceeding six (6) monrhs. Said records include., but are not limited to, proof of unemplo;ment status, linancial instttution accounts .1nd .my benefits (i.e., unemployment. sub pay, sick leave, Workers Compensation, severance pay, retirement, disability, annuities, Social Security and Verer.m's Administr.lticn benei'its).

Either party's failure to provide any earnings/benefits information pursuant to this order, or :·aitun: to comply with the foregoing order of norificaticn 5hall be ~onsiden:d ccntempt of Court, punishable '::ly a fine and/or jail sentence. Attorney fees and Court cosl$ may then be lssessed against the pa.ny held ln contempt.

IT IS FL'RTHER ORDERED, ADJUDGED AND DECREED that the residentilli par-nt and legal custodian of the children immediately notify the Cuyahoga Support Enforcement Agency (CSEA) of any reason for which the support order should terminute, including but not limited to, the child's attaining tho age of majority (age 18) if the child no longer attends an accredited high school on a full· time basis; the 'hild ceases to continuously attend ;tn accrediw:t high school on a full-tirr.e basis after attaining the age of majority; the child's death, marriage, emanctpation, enlistment in the Armed Servi~es, deportation; or change of legal custody of the chiid.

3


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case 1:13-cv-20610-CMA Document 39-4 Entered on FLSD Docket 12/05i2013 Page 5 of 6

The following infonnation is ;J£0Vided by the parties rbr the use oi the Cuyahoga Support Enforcement Agency (CSEA) in accordance with §3121.24 of the Ohio Rc:vised Code;

OBLIGEE: ~AME: Stephanie Ann Deluca RESIDENCE ADDRESS: 2398 Kerwick Road

Cleveland, Oh 441 I 3-0000

MAILING ADDRESS: 2&98 Kerwick Road Clevelnnd, Oh 44118·0000

SOCIAL SECURITY NO.: DATE OF BIRTH: 11/3011966 DRIVERS LICENSE NO.:

OBLIGOR: NAME: Larrt Elliot Klayman RESmENCE ADDRESS: J415 Sw 24th Street

Miami,f'l 33145·0000

MAILING ADDRESS: 3415 Sw 24th Street ~1iami, Fl 33145-0000

SOC tAL SECURITY NO.: DATE OF AIRTH: 07/20/195! DRJVER.S LICENSE NO.:

EACH PARTY TO THIS SUPPORT ORDER M'UST NOTrFV THE ClULD SUPPORT £NFORCE;\1ENT AGENCY IN WRITl:-fG OF HIS OR HER CURRENT :"rt<\ILL"'G ADDRESS, CURREN! RESIDENCE ADDRESS, ctiRRENT RESIDENCE TELEPHONE Nu:\lBER, Ct;Rlt.J.:NT DRIVER'S LICENSE NU:'t'lDER, ,\!,..D 0£<' ,\.."fY CHANCES IN THAT lNFOR.~t..\TION. t:ACH PARTY :\'1UST NOTIFY THE AGENCY OF ALL CHANGES UNTIL WRTHER NOTICE FROM THE COURT OR AGE:-iCY, WHlCHEVER ISSUED THE SUPPORT ORDER. 1F YOU ARE THE OBLIGOR UNDER A CHfLD SUPPORT ORDER A.">>D YOU FAIL TO MAKE THE REQUIRED NOllFICA fiONS, YOU MAY BE FINED UP TO $50 FOR A fiRST OFFENSE, $100 FOR A SECONU OFFE:;SE, ~"«> i.stlO FOR EACH SUBSEQUENT OFFENSE. IF YOU ARE AN OBLIGOR OR OBLIGEE UNDER A:'oiY SUl'PORT ORDER ISSUED UV A COURT ,\NO YOU WILLFULLY FAlL 1'0 GIVE THE REQUIRED NOTICES, YOU MAY BE FOUND ri CONTEMPT OF COURT AND BE SUBJECTED TO FINES t"J' TO Sl,OO() A..'fD L\IPRISON:'ttENT FOR NOT :"rfORE THA.''i 90 DAYS. IF YOU ARE AN OBLIGOR AND YOU FAlL TO GIVE THE REQUIRED NOTICES, YOU :vtAY RECEIVE NOTICE OF THE FOLLOWING ENFORCEMENT ACTIONS AGAINST YOU: IMPOSITION OF LIENS AGA.lNST YOUR PROPERTY; LOSS OF YOUR PROFF.SSlONAL OR OCCUPATIONAL LICENSE, DRIVER'S LICENSE, OR RECREATIONAL liCENSE; WITlffiOLDING FROM YOUR L"'CO~tE: ACCESS RESTRJCTION AND DEDUCTION FROM YOUR ACCOUNTS m FINANCIAL INSTITUTIONS; AND ANY OTHER ACTION PER.'\UTTED BY L\W TO OBTAIN l\lONEY FROM YOU TO SATISFY YOUR StJPPOHT OBLIGATION.

4


~·--------------------------~--~~~----~-----------------case 1: 13-cv-20610·CMA Document 39-4 Entered on· FLSD Docket 12/05/2013 Page 6 of 6

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Failure to comply with this order ~:an rt::;ult in a contempt action as provided in Ohio !levi sed Code Stction 2705.05, the penalty for which may be imprisonment for not more than :hirty (30) days in jail and/or fine of not more than $250.00 for the tirst otTense, sixty (60) days in jlil :.md/or $500.00 tine for 1he s~ond offense, and up to $1,000.00 tine and/or ninety (90) days inj:~il for third or subsequent offenses.

pap

cc:

Cosls adjudged against Petitioner.

Roger L. Kleinman, Esq. Anorney for Petitioner

Suzanne M. l.lmbe, Esq. Attorney for Respondent

HUS_Tl' [))C ('!-'2006)

RI!CEIV!!O FOR FILING

SEP 2 4 Z009

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) ·-------------------------------------·-·····



Exhibit 4

Jt EXHIBIT _!d_ Depo~tf(.k'k

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) case L13-cv·20610·CMA Document 39·5 Entered on FLSO Docket 12/05/2013 Page 2 ~~~....; . , ocra 7 u

0

COURI OF COMMON PLEAS OIVISfON OF DOMESTIC RELATIONS

CUYAHOGA COUNTY. OHIO

LARRY ELLIOT KLA \'MAN Case No: DR07 .316841).

Petitioner Judge: DIA.'lE ~I. PALOS

- vs.-

STEPHANIE ANN LUCK .nJIJGl\IENT Ei'ITRY

~

This matler ctlme on for hearing on June 23, 1010. before Magistrate Serpil Ergun upon Respondent's Morion To Show C:ltlse For Continued Non-Payment of Child Support (#239099) and :VIotion For Attorney Fees (#ZS9100) !lied October 15, 2009; Petitioner's Motion To '.Vitbdraw Capias V~291722) tiled December 8, 2009; und the Guardian Ad Litem's Motion For Guardian Ad Litem Fees (<1292173) filed December 10, 20D9. Present were Attorney William '.Vhitaker on behalf of the Petilioner, Resp<mdcnt, and Attorney Suzanne Jam be on behalf of the Hespondent. Petitioner and the Guardiun ,\d Litem Jermifer ~1alensyk tailed to appear.

rhe C(11lrt adopts the ~1ag1strate's Decision tiled July l, WW, in its entirety.

IT IS HEREBY ORDERED:

.\fT£R CONSIDERJ:'-!G THE MAGISTRATE'S llECISION FILED J1JL Y 2, 2010, PLEADINGS, EXHlBJTS AND JN THE AUSENCE OF.·\ TRANSCRIPT, I•E.TITIOI'ER'S OBJECTIONS FILED HILY Hi, 2010 AH.E HE!lliHY OVF:RRULEO A~UTH'E DECISION Of Tlif. :\1.-\GISTRATf. ADOl'TED WITHOUT MODIFICATION.

Petitioner's Motion fo Withdraw Capias (#29l 722) filed December 3, 2009 is DISMISSED without preJudice.

rhe Guardnm Ad Litem's :\1otion For Guardian Ad Litem Fees l#29217J) tiled D(..-cember I 0, :::009 is DISMISSED without prejudice.

Respondent's Motion To Show Cause for Continued Non·Paymcm of Child Support 1"12&9099) tiled October 15, 2009 is GRANTED.

Petitioner/Obligor Larry Kla~man is in contempt of Court for failing to comply with ih1s Court's support order journalized September :.24. 2009, ilS well as the divorce decree registered in rhis Co,~H by order journalized August 23, 2007.


c:~se 1:13-cv-20610-CMA Document 39-5 Entered on FLSD Docket 12/05/2013 Page 3 ct 6

PetitiOJler is in :m~3.1's in the amount of S47,600.90 as of :vtay 31, 2010, which is owed the Respondent/Obligee Stephanie DeLuc;1 flkla Stephanie Klayman, Respondent's a:.~signee(sj, and the Child Support Enforcement Agency (CSEA). fhis sum includes all previously accrued ~uppvrt artcdfs and processing charges, itnd suJXrcedc:' all prior determination:s. Petitioner also owes Respondent $5,950.00 for tuition expended for the children for the 2009·2010 and 2010· 2011 school years.

1'11is is Petitioner's second offense in this Court for nonpayment of support.

Petitioner is hereby sentenced for said contempt to silty (60) day! in jail, However, the Petitioner's senten~e will be 'uspended and the conrempa wlll be purged PROVIDED th:~t Petitioner l>ays $10,000.00 throu~ the CSEA within 30 days of the journallzation of this order. This purge payment i3 in :audition Ia any obligation to pay current support and arrearage payment~ that may be due.

.\It support shall be paid througlt Ohio Child .Support t•,yrnent Centr:d (OCSPC), r.O. Oox 182.372, Columbo,, Obi() 43218·2372. Any payments not mode through OCSPC >hall not be: ~.:onsider~:d :iS p<lym~:nt of support. Checks or money orders shall be made payable to "OCSPC". Ca.sh payments to OCSPC may be made at the Cuyahoga County Treasurer'! Office,

.t County Administration 13uilding, I Floor- Cashier, 1219 Ontario Street, Cleveland, Ohio ~4113. All payments shall include the following: Obligor's ntUne, Social Security Number, SETS case number. anJ Domestic Relations Court case number.

In the event P11titioner dou not purgt the (On tempt, the Court, up<Jn I be filing of an affida\·it of the Respondent St<>pbanie OeLuu or the CSEA with an attached certifled copy of CSEAJOCSPC payment records, shall mue a c:~piu for Petitioner Larry Klayman to serve lht jail sentence otdtnd :abQve Said actldavlt shall be filed within one (I) yur of the journalizatiun of this urder.

IT IS FURTHER ORDERED. ADJUDGED ANI> DECREED that in addition to the ;~bove sentence and civil purge, Petitioner shall do the following;

l) Continue to pay $1,!D6.00 per month, ·.vhich includes 2% processing charge, as current suppon for the minor children ls('lbelle Natalie Klayman lDOB 12115/1997} '-lnd Lmce \\/illiam Klayman (008 H-14-1999) ($900.00 per month per chill.! !L\2! including 2.% processing charge);

2} Pay an additional $360.00 per month toward the arre:uagc until the arrearage is paid in full or uno! further order of Court. Processing <:harges shall not be collected on tl':e .1rreJtage payment since the above! arrearage includes <lllaccrued processing charges.

Total monthly qblfgaliou b $2,196.00.

All support under this order shall be witllhcld or deducted from the income or nsscts of !he obligor pursuant to a withholding or deduction notice or appropriate: order issued in

2


)

)

case 1: 13-cv-20610-CMA Document 39-5 Entered·-::-o-::-n -::F:-LS:::-O~D:-:o~ck:-e"":'t"':"l~21:-:::0"':':5/~2~0~l3~P~a~g~e-4:-o""'lt""!61'-"-•

Jccordance with Chapters J I 1 9., J 12 t., J 113., and J 125. of the Revised Code or a withdrawal directive issued pursuant to sections 3123.24 to 3123.38 of the Re'vised Code and shall be forwarded.

The prior order to post bond dated Septcm~r 24, 2009 shall rcm:1in in tull force ;md

lT IS FURTHER ORDERED, ADJUDGED AND DECREED that the Obligor immediately notify the CSEA, in writing, of my change in .:mployment (including self. employment), receipt of additional incomefmonies or termination of benefits. ll':e Obligor shall include a description of the nature of :he employment and the n:une, business address a11d tdephone number of any employer. The Obligor shall immediately notit)' the CSEA of :my .:hange in the status uf an ac~:ount from which support is being deducted or the opemng of a new' account \vith ,my llnancial institution.

lT lS FURTHER ORDERED, ADJUDGED AND DECREED that the Child Support Obligor :md the Child Support Obligee shaH comply with the Nquest of the CSEA in advance •)f an administrative rev1ew of a support order to provide the following: copy of federal income tax return from the previous year, copy of all pay stubs v\<ithin the preceding six { 6) months, copy \![all other records evidencing the receipt of any other salary, wJgt:s or ~;ornpens<ltion within the preceding six {6) months, and, if the Obligor is :s member of the· uniformed services. .lnd en active mditnry duty, n copy of the Obligor's Internal Revenue Servke form W-2, "Wage and Tal< Statement," arni a .:opy of a statement detailing the Obligor's earnings and leave with the t.:niforrned ;;ervice'3. The Child Support Obligor and the Child Support Obligee $hall abo rnwtde a list of av~ilahle group health insurance and health c;ue policies, contracts and plans, :md their costs. the C\lm:nt health insuram:e or h~alth care policy, contract. or plan under which thr.: Obligee andiot Obligor is/are enrolled. and \heir costs, including any Tricare progrJm offered by the United States Department of Defense available 10 the Obligee, and any other infonn~tiun nl!cessary to properly review the child support order.

t:ither party's failure !<l provide any earntn!Ss/benetits intonnation pursuant TO this order, <Jr failure to '!<Hnply with the foregoing order of notification shall be considered contempt of Court, punishable by <l tine and/or jail ~<mtence.

IT IS FURTHER ORDERED. ADJUDGED AND DECREED !hat the residential parent :md legal cu5todian of the child( reo) immediately shall notify, and the obligor under a ~:hild support order may notify, the CSEA of any reason for which the child support order should tenninate, including but not limited to the child's de:~th, maniage, emandpution (age 1 & or high s..:hool completion/termination), enlistment in the Armed Services. t1eportation, or change of legal ..:ustot.ly. A willful faih.:re to notify the CSEA is contempt of court.

l11e following information is provided for the use of the CSEA in accord:mce with §3121.24 and q3121.JO of the Ohio Revised Code:

3


) case 1:13-cv-20610-CMA Document 39·5 Entered on FLSD Docket 12105/2013 Page 5 of 6

OBLIGEE: NAME: )!ephanie Ann Luck RESIDENCE ADDRESS: 2598 Kcrwick Road

Clclvei<Uld1 Oh 44118-0000

MAlUNG ADDRESS: 1598 Kt-rwiclt Road Cleveland. Oh 44118-0000

SCCIAL SECl!RJTY NO.: DATE OF BIRTH: l 1/.30/1966 DRJVERS LICENSE NO.:

OBLIGOR:: NAME: larry Elliot Klayman RESIDENCE ADDRESS: P 0. Goa 2788

Washingto11, De 20013-0000

M,\lLING ADDRESS: P.O. Ro~ zng Washington, De :ZOOIJ-0000

SOCIAL SECURITY NO.: DArE Of BIRTH; 07120/1951 DR.IVERS LICENSE NO.:

.-\ ttomey ;"ees and court Nsts may be Msessed against the party held in contempt.

l11e parties affected by the support order shall inform the CSE:\ of any ehange of name o)f nther change of conditions that may aifect the :ldministration of the order. Willful failure to intorm the CSEA oft he :~bove information and any cha.nges 1s contempt of court

EACH PARTY TO THIS SUPPORT ORDER :\lUST NOTJFY THE CHILD SUPPORT ENFORCEMENT AGENCY IN WRITING OF HIS OR HER CURRENT :\-tAILING ADDRESS, CURRENT RESlDENCE ADDRESS, CURRENT RESIDENCE rELEPHONE NUMBER. CURRENT DIUVER'S LICENSE Nt:MUER, AND OF ANY CHANm;s f.N THAT lNFORMA.TION .. EACH PARTY MUST NO'flFY THE AGENCY OF ALL CHANGES UNTIL FURTHER NOTICE FROM THE COURT OR AGE:"oi'CY, WHICHEVER ISSUED THE SUPPORT ORDER. IF YOU ARE THE OBLIGOR UNOER ,\ CHILD SUPPORT ORDE.R AND YOU FAIL TO MAKE THE REQUIRED NOTIFICATIONS, YOU l\IAY BE FINED UP TO SSO FOR A FlRST OFFENSE, $100 fOR A SECOND OFFENSE, AND SSOO FOR EACH St:BSEQUENT OFFENSE. IF YOU ARE AN OBLIGOR OR OBLIGEE UNDER ,·\NY SUPPORT ORDER ISSUED BY A COliRT ANl) YOU WILLFULLY FAIL TO GIVE THE REQUIRED NOTICES, 'tOU MAY BE FOUND IN CONTEMPT OF COURT AND BE SUBJECTED TO FINES UP TO Sl,OOO AND 11\IPRISONMENT FOR NOT MORE THAI"i 90 DAYS.

IF YOU ARE ,\N OBLIGOR AND YOU FAIL TO GIVE THE REQUIRED ."/OTJCES, YOU 'fAY NOT RECEIVE ."'OTJCE OF THE FOLLOWING ENFORCEMENT ACTIONS AGAINST YOU: IMPOSITION OF LIENS AGAlNST YOUR PROPERTY; LOSS OF YOUR PROFESSIONAL OR OCCUPATIONAL LICE:"lSE, DlUVER'S LICENSE, OR RECREATIONAL liCENSE; WlTHJIOLDING FROM YOUR INCOME; ACCESS RESTRJCOON AND DEDUCTION FROM YOUR


)

\ j

. Gase 1:13-cv-20610-CMA Document 39·5 2ntered en FLSD Docket 12/0512013 Payt: 6 of o

ACCOUNTS I~ FINANCIAL INSTITUTIONS; ,\NO ..\NY OTHER ACTION PEit\UTT'RD UY LAW TO OJlTAlN MONF.Y FROM YOU TO SATISFY YOUR SUPPORf OBUC.\TION.

Failure to comply with this support order can result in a contempt action; and, as provided in Ohio Revised Code §2705.05. lhe penalty for which may be imprisonment for not more thnn thirty (30) day$ in jail and/or tine of not more than 5250.00 for a tirst otfense, r.ot rnure than sixty (60) days in jail and/or tlne of not more tl1an $500.00 for a second o!Tense, and not more than ninety l90) days in jail and/or not more than $1,000.00 fine for a third. or subsequent otTense.

All orders not modifk-d herein shall remain in full fon:e :md effect.

Respondent's Motion For Attorney fees (112891 00) tiled October 15, 2009 is GR.A.'ITED. Petitioner shall p.ay $2,500.00 toward the: Responuent's .!llorney fees a.'i additional spousal.>upport for which judgment is rendered and execution may issue.

pap

cc:

?ctitioner shall pay ::til costs of this action.

Costs adjudged as provided in the above entry.

Roger L Kleinman. Esq. Attorney for Petitioner

Suzanne M. Jambe, Esq. Attorney for Respondent

Jennifer L. Malensc:k, Esq. Guardian ad Litem

RECEIVED FOR FILING JUN 2 4 2011



Exl1ibit 5

~~ Depo n

D~~ WWW.DEPOBOOK.COM


., '· I

C>1se No: DH07 316840 O&A

LARRY ELLIOT KLAYMAN vs. STEPIL\NIE M"N LUCK

'-o i;;:;;l':l ;,_..~

5!;: :!!a ·~ :=a

Judge: DIANE M. PALOS I~ __________________________________________ :~ Date: 02/2212010

CAPIAS ORDERED FOR PLAINTIFF NAME: LA.RR Y ELLIOT KLA YMAi'l ADDRESS: SEE ATTACHED HOLD fN CCSTODY AND BRING BEFORE TH13 COURT WITIIOUT DEL\Y.

·~ :~~

·~~ I .... I I

I j

' .

l_,_, COURT COSTS ADJUDGED AGAlNSTj 1,3RRX ELLIQI 1\L.aYJIAJ;:i

~~~t~LOS .\ITORNEY FOR DEFENDANT: SUZANNE M. JA.viBE

ftEC'O FOR FILING

GERALD a I'UERST Clerk of Courts

Court of Common Pleal Division of Domestic Relations

o.J(..:

ORPUTY

RECEIVED FOR FiltH~

• MAR 16 20!0 tiAAul ti"JEAST<~~ .. ",.<J. 'Md4r. ~ :· . ";J ~VII ' f._.,

1 . {

't ' J



Exhibit 6

~1C EXJIIBIT~ Depo~~ D~ff!P-


G·nail- Fwd: Retention Agreement with Kl:.wman Law Finn Page 1 of2

\

Dina James <[email protected]>

Fwd: Retention Agreement with Klayman Law Firm 2 messages

Larry Klayman <[email protected]> Tue. Jan 28, 2014 at 8:59AM To: Dina James <daj14:[email protected]>, \eklayman .:[email protected]>

------ Forwarded messaae ------From: Larry Klayman <[email protected]> Date: Wed, Feb 8, 2012 at 9:44AM Subject: Retention Agreement with Klayman Law Firm To: "George J. M.tler" <[email protected]>

Dear George:

1 w1U prepare a rmre formal legal retention agreement today, but here are the essential terms that you can run by the grouP.

To file su1t in Flor.da w:U need an uo front retainer of 18 K, which will need to be kept at this level throughout the course of the case by replenishing it monthly. I will bill for out of pocket disbursements ard expenses, and my hOurly rate will be S395 per hour. which is reduced from my usual mintmum mte of S500 per 110ur. Statements wtll issue en the first ef each month and be payable on receipt.

If the group decrdes to file 1n California as well, the retainer wdl be ZSK, replenished en the sarne terms. for both legal actions.

I wJil not bill for the time that I c·ut in tryi:-~g to help the gro;;p ratSe funds, and I will rent my direct rr.a1llist to the group at rr.arket rates to help factlitate f:Jndra1sing. I wtll also intervene with WoridNetDaHy and Response Un!im1ted to get the group the best deal poss1ble. As you know, I am close wtth Joseph Farah, :epresent n1m and Jerome Corsi 1n a related swt agallist Esquire magazine. and have a number of contacts elsewhere that w:ll prove helpful.

If we prornoie tn1s correctly, 1t snould be easy to raise the mon1es needed to pursue our legal ob;ect1ves Frankly, vve have no chotce tut to pursue this strategy, as the nation is on 1:s knees and headed down for :he count No Reoublican can currently beat Obama, not even Romney, who took 1t on the chin yest.erday ~~etther he, Santorum or Gtngnch are likely to succeed. Our only hope is to legally remove Obarna, whatever the odds. with God's grace,

Please let me knew who w•ll be the s•gr:atones to the legal representation agreement and I wtll draw it up and send it today.

Sincerely,

Larry

·-------·----------·-·-----·~········-··--- --------··-·----Larry Klayman <le~layman@gma1l com> Tue, Jan 28. 2014 at 9:00AM To: Dina James <daj142182@gma:l.com:-. leklayrran <[email protected]>

hnps:lJJnail.goog!e.com/rnail/wOI'.'ui=2&ik=dce57daaea&vicw=pt&search""inb<



Exhibit 7

J!EXHIBlT~ Dep~ ~RJQ

WWW.DEPOBOOK.COM


_)

l.imail -Fwd: Voelr7. v. Obamn ct. al ·Florida Ballot Chal!C'ngc Page 1 of1

Dina James <[email protected]>

Fwd: Voeltz v. Obama et. al - Florida Ballot Challenge 1 rr.essage

Larry Klayman <[email protected]> Tue, Ja!"l 28, 2014 at 914 ,'lJ\11 ro: Dina James <[email protected]>, ieklayman <lekla~·[email protected]>

···------·· For.varded message-·-··--··· From: <[email protected]> Date; Mon, May 7, 2012 at 10:06 PM SubJect: Re. Voe:tz v. Obama et. al · Flcnda Bailot Chalie:1ge To: leklayman@gmail com

We have already paid at least $9K

- SSOOO was sent via Sam directly to you • • $3300 was sent from our collections when we had the Article II PAC - 51000 was sent to you from Constitutional Action Fund.com, Inc - An unknown amount was sent directly from people given your address and bank number while we were trying to get ConstitutionActionFund.com, Inc started. How much more did you receive directly?

That would leave $9K or less to go, according to my math. Where did I go wrong?

Regards, George Miller http://venturacountytoaparty.com http://obamaballotchallenge.corn

-·--~Ongtt1al 1\:1essage----f;rcrn: Umy Klayman <l.:::klayr1an@grrail com> To. George J. tvli!:er <microcapmaven.gaol.:om> Sent r:.ca. May 7, 2012 8:43 om ::>wb)ect: Voeltz v. Obarr1a ct. al • F:or11a Bailct Ch,JIIewJe

George. Sam an::l Pa:ne:a:

ihis comlrms that I w:ll take th1s through the heanng on ctefend3nts' motion to l11srniss if you pay the a9reed retainer. :n full, of 18K, before t."e heanrg. You agreed :o pay abot:t 3K this •.veek with more com1ng 'lext week. The rerramder of t.1e retainer at !hiS pomt 1n lime 1S 11 K.

T~-.anK ·.:cu tor your ::;opera ton

Best.

Larry Ki;:;ymJn

l:ttps :/!mai I. ~oo glc.com/mail/u;O/'?ui =2&ik "-tlce5 7 daaea&view"'pt&s:!arch::::: int



Exhibit 8

@Ir EXHIBITL

Depo~ D~~'i~~


'~ )

Klayman La'v Firm

July 23, 2012

13ILLI?\G STATB!ENT

FOR SERVICES RENDERED to G~:orge ~Iilkr. P:unda Barndt. S.un Sewell,

ObumaBullotChalknge.com. Article II Super PAC. and the Constitution A.:tion Fund from June

19, 20l2 :o the pn:sent. including but not limitl!d to research ,md preparation and $ervice of

proce:;s of new complaint for decl;mltory relief; legal research ;111d prepar2tion and filing of

2·+ page proposed order with factual and legal citations for Judge Terry Lewis, review of

proposed order of thu Defendants, preparation of second ,ltnended cor:1plaint JIH.I review of

motion to strike and response, preparation for and hearing on leave to file second ~mended

comphint before Judge Terry Lewis, review of judge Terry Lcv,;is' di.!cision and strategy

Jiscussions Jnd other communicJtions With clients ~md preparation of memorandum on

how lu appeJl Jirectly Lo Florida Supreme Court, preparation .wd filing of nolice ur <ippeal,

not;ce of t1ling transcript. preparation and riling of opposition to defenJ.:~nts' motion to

';tnkE', prep:1r<1tion :1nd dissemmation of two press rclt>ases rpgarding Judge LeWL'i'

decislon ;:u1d notice of appeJI, comrnunications wtth media, <lntl reb ted matters:

37 hours x S!50 pa hour for :-.::lVecd \bhboobian. E~q. :.~nJ R7:.m P~ltt<;:rson. Esq .......... S5,55tl.OO

16.5 hours x SJ95 pL>r hour i~Jr Larry Klayman, Esq. (reduc<!d from nomtul billing rate ,lt' 5600

per hour) ............................................................................................................................ $6.51 /.50

!tcmized Expenses (A:tachcd) ........................................................................................... S4.\) J7 .05

r vtal "" ~ 16.03-t. 55



Exhibit 9

@n EXHIBIT'~ :tfikU ~

WWW.DEPOBOOK.COM


\ f

('m:1il - F,•.-d: Rektllion Agrt~ement with Klaym:Jn L~1w Firm

\

---------- ;.:: or.'ll3rded message ---··-----;:rom Larry Klayman <leklaymar.(@gmall com> Date: ihu. Aug 9. 2012 at 3 39 PM SubJect: Fwd: Retention Agreement with Klayman law Firm To: 'George J. Mlller" <rrlcroca~n'aver.@acl com>, Parre!a Barnett <pamel;;b<>rret@m:;d ::om". Sam Sewell <[email protected]> Cc Naveeo l¥1ahbcob an <nmahbooblar·@gm311.co~>

This is what you all agreed to. The 1 SK •.vas just a retainer and 'ees were to bi!l at S395.co per hour. reducea from my crjinary hourly rate ol 3600 per hour.

ihe series of emails ·,•,hrch fo·towed from you all acKnowledges t1rs .Jgreement. In addition, when I Jgreed to file SUit Pamela and Geor:;e :1ssured rre, in tre presence of 'Jiitnesses, :hat I would oe fully paid :or our work.

fh.3t there is r.o for:r1a! written contract is not ccntrol!ing. Tt-:ere is ·:;r:tten ev1cence of our agreem<:mt 1n the form of ema11s and you owe t~1e m::Jr11es under the :egal doc:nn,;s of promssory estoppel. quantum meruit and unjust enricr.ment. as well as breact1 of contmct. A c.::mtract can be orol as we11 as >tmtten.

: Nds p'eased :o rear George corrm!l to J.J3ilf1g wt•at 1s ct.tstanding. as 'AO WOLid r,opc to OVOid SU:t.

I o;;poke w1th George yesterday, and he IS :o give me today confrrrmtior :r.o! the bil:od <Jmount 'Nil I ce paid down installmen:s af'\d that at "agt S 1 ?00 was to be sent today. ~'\I so. th1s confirms that an :Jddr!ional $415 00 ;joilars is to ::;e added to tt1e expenses. as I ::>aid Y.rt 0f rny ;:oock.et what '.'<as cutstundJrg to Transrredia Oro;.;;:>.

Fnnk yc.u for your 1mmedu3te cocpera:ion anc courtesy



Exhibit 10

{t) Jr EXHIBI~O

6fl!lj;j_ WWW.DEPOBOOK.COM


)

)

)

Lmy Klayman, Faiku Lawyer! Con\VebW:uch P::-tge I of 6

.\ 12 Gauge Won't Save You

Discover What Federal Agent> & The Army Don't Want You To Know . .' "• ·.-. c ~~-~t'.J"!":I":'l.t l'r'\!·~;ng ~2m AdChotce-a [t:a

: cruveir~vatch • •...

: ::

Larry I<layman, Failed Lawyer 'NorldNetDaily's favorite lawyer loves filing lawsuits, which lately have been even more unsuccessful than usual.

By Terry Krepel Pes ted di912.0 12

Larry Klayman mJde his name as a ri~ht-win~ lawyer by using millions of dollars in funding from Richard 11ellon Scaife to tile dozens of nuisance lawsuits :11;ainst the Clinton administration through his group, ,Judicial Vvatch. (When Klayman tried filing lawsuits against the Bush aumiuislr.ltion, however, the Con Web buddies who favmed over his antiClinton activism wanted nothing to do with him.) At the same time, KlJyman was suing hlc; mother.

Klayman left Judicial \Vatch to run for a Senate seJt in Florida, in which he linishcd seventh in an ci~ht·person Republican primary despite (or, perhaps. because or) an endorsement by WorldNetDaily's Joseph Farah.

Klayman then formed a,Judicial Watch-esque group, Freedom ·watch, while Jlso suing Judicial Watch. The bad blood between Klayman and .Jndicial Watch continues; in a recent column, Klayman complained that a new book by current Judicial Watch chief Tom Fitton ''chronicles my ;a:hievements at Judicial W;jtch but appears to attribute them to Fitton himself, who is not a lawyer and never appeared in court to advocate any <:ase .... Indeed, my name appears nowhere in the book, even in the index.'' Kla;.man, ot course, has intimated legal action a~ainst Fitton over the book.

Not only is Klayman a sue-happy lawyer. he's also been on the defendant end of ~~~al action as well. Earlier this year, Klayman was indicted for failure to pay child support. ~cedless to 5ay, this Jescended into a legal morass; an Ohio appellate court noted last month that Klayman had apparently engaged in ''inappropriate behavior" with his children-- something he has not denied-~ that he "repeatedly invok(ed] his Fifth

http:t I conwebwatch.uipod.comistorieSt20 12/klaymanlawyer.html

Send thlt page to1

Enter Address Here

Send this paget i '~~--·--'

j 3HflRE •' • ' ; ! .

Ads @ ConWebWatchj

I : [ ~dvertlse 'it CcnW=bWi!t~nt 1

Vl0i20l2


)

Larry Klnymo.n. Failed La\vy·er I Con\Veb\Vatch

Ji¥ W Amendment rights, about whether he inappropriately Larry Klayman touched the children." .md that "!<la}man would not

0ven answer the simple question regarding what he tho\lght inappropriate touching was. ·• The court upheld a lower court's ruling thnt Klayman be ordered to pay $325,000 of his ex-\'lifc's legal costs.

A.nd last November, Klayman was reprimanded by the Florida bar for taking a $25,000 payment from a woman to represent her in a criminal case but f::tiling to do any legal work for her. After he was ordered to return S:;,ooo oi the money as agreed to in mediation, he failed to keep up the payments. Klayman claimed that his "financial situation continues to be tlire." (He claims that he has since repaid the money.) Further, Klayman's license to practice law in Pennsylvania is under ad.Jninistrative suspension.

tn short, Klayman is a hot mess of a lawyer. Yet he continues to nle lawsuits --with WND as a major client-- which are swiftly tossed out of court. Let's look at a few recent cases.

\VND v. White House Col"respondents Association

fn 2010, WNU threw a !lt because the Wnite House Correspondents , \ssociation wouldn't sell it the number of tickets it demanded in order to promote Les Kinsolving's nepotistic, WND-published bio (written by Kinsolvin~·s daughter), At tirst. WND tried to intimidate the WHCA into ~iving \t the tickets it wanted-- claiming that it was ''doing the bidding of ~.he Obama administration in tryin~ to belittle. exclude ;md irreparably harm a leading Internet news outlet, \VorldNetDaily, which has carried commentary critical of the president." Then, Klayman and \VND filed a $to

million lawsuit a~ainst the \VHCA clairnin~ "harm to its business and •Jther relationships·• because of the WHCA's refusal to accede to its dt!mands.

One curious thin~ about the WND story announcing the lawsuit: lt never reported in which court the suit was filed. '.Ve've since learned it was the District of Columbia Superior Court.

,\nother curious thin~: That story was pretty much the last anyone heard about the lawsuit from WND, aside from Klayman's threat to add the \ Vhite House as a defendant. That's because the suit was dismissed :Umost immetliately.

Accordin~ to DC Superior Court records (case No. 2mo-CA·002364),

Kb}man tiled the case on April13, 2010. On May 3, 2010, the WHCA filed a motion for dismissal, which was ~ranted on June 22. The case was slapped down just over two months a iter its tiling.

.\ddin~ insult to injury, the copy ot the order sent to Klayman's otfice was n:turned was returned to the court bemuse it was ''Not Deliverable as .\ddresscd, Unable to Forward." No wonder WND didn't want to talk about :t Jn>more.

h ttp://conwebwatch.tripod.comistoriesi20 12/klaymanlawyer.htm I

Pnge:! of6

The latest from

·:onJveb;bf()g 1

• WND's Kupellan Ues

About Obama,

Military Voting

WOrlrlNetDally

manag111g ed1tor Oav!d

Kupellan uses an AJg.

9 co!umn to claim that

President Obama's re

election campaign is

tryll'lg .•.

• CNS' Jetfn~v Trle$ to

Heather An

Archbishop

The Meola fl.esearc:n

Center's oractlce of

1-'eathertrtq .. berating

,Jna stlunnmg

wnservauves who fa1!

:o marcn in total

·cckstep ...

• NEW ARTtCLe; l<~rrv Klayman, Failed

Lawyer

'.'/orldNetDa 11y's

f.wonte lawyer !Oves

f:llng lawsiJitS, which

~.-tely have tlel;!n even

1nore unsuccessful

:nan usual. Read more

>>

\.''' .:.sscc~r !CN .<tl'fH 1 I ' · lmazon.com.l ~ ,..._..., i

~110/2012


Lury Klayman, Failed Lawyer 1 ConWcbWatch

Even a year later, W'ND and Klayman didn't want to talk about it. When ConWcbWatch queried !<layman during his and WND's dog·and-pony show announcing its lawsuit against Esquire as to why he didn't funher pursue that lawsuit, Klayman brusquely replied: "Well, first of all, we decided not to pursue that. But the issue here is this case, not that case, so if you want to relive that case, we'll do that some other time. •

WND v. Esquire

\ V'ND was absolutely livid about a :\1ay 2011 Esquire parody blog post daimin~ that \VNO is pulling Jerome Corsi's then-newly-released anti· Obama birther book "Wbere's the Birth Certificate?" out of stores because, J(;corilin~ to a made-up quote from Farah, "this book has become problematic, and contains what I now believe to be factual inaccuracies." L,;st anyone miss the parody aspect, the post also stated that Corsi also wrote a book called "Capricorn One: NASA, JFK, and the Great 'Moon Lmding' Cover-Up"-- a reference to the similarly themed movie •

.\).lay 18, 2011, \VND article assailed the blo~ post as "a completely fabricated news story" that prompting editor Joseph Farah to descend even further into conspiracy mode by blaming the Obama White House for it. 1 {ere is an actual quote from Farah: "This has all the earmarkin~ of a White House dirty trick- but, of course, onlv the Nixon administration was capable of dirty tricks like that, according to our watchdog media.~

rarah seemed to have missed anolher parody aspect of Esquire's post: the ) rr:~l.Joseph Farah would never have done somethin~ so reasonable as to

. ,., \o,ithdraw Corsi's book- there wa!$ birther money to be reaped, after all.

) /

;.icverthelcss, Farah threatened to sue Esquire. And sue he did, represented nnce a~;am by Klayman. The lawsuit was announced in a June :10, 2011,

JoK·und~pony show in a rented room at the National Press Club in \ V;1shin~ton where participants m the presser outnumbered the reporters . . \Jso in attendance wt:!re Corsi and self-proclaimed ima)!;e expert :.lara z~best. both of whom spent their time on a tang ental effort to demonstrate thJt Obama's birth certificate is fake, which had nothing whatsoever to do ·,,,th the lawsuit •

. \3 hus become all too familiar for Klayman, his case s;ot laughed out of

.:ourt. W!-JD let Klayman rant about it in a June 4 article, declaring the dismissal "significantly tlawed and intellectually dishonest." Curiously :;:i.ssin~ from the article: the key e\idcnce the jud~~;e used to dismiss the Ln.,.suit .

. \s the I-uling states, Farah "immediately recognized~ that the Esquire trticle was satire-- telling the Daily Caller that the post was ··a very poorly ~~xecuted parody: --until it became "inconvenient" for him to do so. The jmh;e added: "Political satire can be, and often is, uncomfortable to its t.~n~cts, but that does not render it any less satiric or any less an expression •m a topic of public concern.''

That Klayman refused to address the key substantive part of the ruling while

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L:my Klayman. Failed Lawyer t ConWeb\Vatch

ranting about how horrible the ruling is shows you what kind oflawyer he is -- rhat is to say, not a good one.

Brndlee Dean v. Rachel :\laddow

A July 26, 2011, WND article by Bob Unruh announced another Klayman legal venture: suing MSNBC host Rachel )1addow for $50 million on behalf of a Minnesota 'Preacher named Bradlee Dean. whom he claims :Y1addow Jcfamed by selectively editing a rant by Dean to suggest that he favors the execution of gays.

Unruh falsely suggested that ~faddow ignored a disclaimer by Dean that he docs not support the killing of gays; in fact. Maddow specifically said J.tter airing the Dean clip: ":\1r. Br::tdlee with h41o e's later clarified that he didn't really mean to sanction murder of gay people. He said, 'We have nt~,·er and will never call for the execution of homose.wals.' Which is nice."

L"nruh, of course, did not disclose his employer's cont1ict of interest by noting that Klayman is currently representing \VND. He also ignored Dean's lung history of anti-gay rhetoric (perhaps because W:-1'0 himself is so anh:,;ay that its employees believe a ludicrous statement like Dean's claim that ··on avera)l;e, [homosexuals] molest 117 people before they're found out" is 'locumented fact); instead. Unruh serves as public relations agent for 13radlce and his ministry, You Can Run But You Cannot Hide International.

Unruh devoted a second article to the lnw:mit the next day, focusing on Klayman and Dean's claim that ~!addow was ~trying to undercut the presidential campaign of U.S. Rep. ~lichele Bachmann. R-~linn., and to do tbt attacked those with whom she has associated. • In fact. only one of the t'.vo segments that mentioned Dean also mentioned Bachmann, and that ·.vas to note that the two would be sharing a stage at a "tea party nominating nmvcntion."

.\.:;has been a runniu~; theme, Klayman's lawsuit was essentially laughed out , •i court. You wouldn't know that by the •.vay Klayman and his PR a~ents at '. V :'l 0 spun it though;

CnrJh used a July 10 WND article to obfuscate the facts of the dismissal, 1eading instead with Dean and his attorney, Larry Klayman, "asking that the judge in the case be removed because of her biased comments." It's not unttl .1rter he rehashes the case in a biased manner favorable to Dean'pecifically, the 2oth paragraph-- that Unruh t;ets uround to reporting the hi~ news in Dean's lawsuit: that the judge in question had ordered Dean to py around S24,ooo in le~al fees to ~1addow before she would permit Kh)'man's request to move the case from District of Columbia court to federal court in order to get around :Yladdow citing the District's antiSL\PP laws in her defense.

Cnruh uncritically repeated Dean and Klayman's claim that )<1addow's ",!efense work would be equally applicable in the new filin~ in federal ~:curt,'' without explaining how a federal court can address legal fees for .1nothcr lawsuit t1led and v.ithdrawn in another jurisdiction. Also, given that

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Dean and Klayman are admitting they're moving their lawsuit to fedenl ·) court specincally to avoid the District's anti~SLAPP laws, ~Iaddow's defense

.. ?' work could not directly be used since a different set of laws \vould apply.

e nruh also uncritie3lly -- and selectively-- repeated Dean's complaints about the judge's alleged "biased comments,~ which included the laughable complaint that the judge "stated in her order that defendants lawyers are 'distinguished."' while not applying that description on Klayman. Unruh .<ppears not to have considered the concept that Klayman's legal work, -:specially oflate, is not "distinguished" at all-~ or, more to the point, it's distinguished only by its record of failure. (And we haven't even gotten to his O\-nl status as a lawbreaker for nfu.sing to pay child support)

Unruh also cited Dean's complaint of the judge's "mockery of !Gayman's health issues,'' which according lo the affidavit consisted of a broken leg that prevented him from traveling from California to the District of Columbia.

1t seems like Dean has a case against l<layman for inadequate (or incompetent) representation. If Klayman's office is in D.C., v;hy is he living in California?

lJnruh failed to mention that Dean. in his affidavit, personally attacked the jndge, calling her a ''woman scorned." fnsulting the judge is hardly the best • . ...-av to successfully :ngue your case -something Uc.ruh seemed to rccm;nize by not reporting it.

') .f It's also a si15n of Klayman's apparent incompetence as a lawyer that he

)

thinks Dean's insult is acceptable to enter as evidence. No wonder he can't "in a case.

Voeltz'\'. Obama

l(layman is the lawyer for Michael Voeltz, a Florida man who issued a le!!;al ·~hailen~e to Obama's name appearin11; on the ballot in r1orida because, ,',ccordin~ to a May 16 \VND article on the lawsuit, 'There is credible •:vl(icnce indica tin~ that this electronically produced birth certiticate i3 ·!ntirely fraudulent or otherwise altered. • The article quotes Klayman as being totally down with the birther conspiracists: "The eligibility of :ldendant Obama must be dealt with now. Plaintiff Voeltz. and the rest oi :he electors in the state of Florida, must be assured that if they cast their mtes for defendant Obama in the general election that their votes will not be in vain:

:<layman's main argument in the Voeltz case was that Florida's Demoeratic presidential primary (which wasn't actually held) had "elected and :wminated" Obama as l:1orida's nominee for president and, thus, he has been opened up for challen~es to his ''eligibility." But as the Obama Ccnspin<..'Y blog points out, Horida state law considers a primary winner to be a ''candidate for nomination," not actually nominated. and there is no di11,ibility requirement in a preference primary, thus giving Klayman no kt;al basis upon which to sue.

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Larry Klaym:m.Failed L:l.wyerj Ccn\Veb\Vatch

UnsurpriSin!Jly, the judge dismissed lhe case. Also unsurprisingly, WND ) ~ave Klayman a pl:ltfonn to complain about it: J}

" } /

·The decision issued today by Judge Teny Lewis was poorly reasoned and written," Klayman asserts. "It goes against prior l·1orida Supreme Court precedent in particular, thus making <)Ur chances on appeal great. .•. In any event, Plaintiff :Micheal Voeltz filed a new complaint today for declaratory relief, which '.V1JI, in addition to his appeal, now proceed forward. In short, •.ve remain coniidant that if the Florida courts ultimately Jecide to obey their own election law, we will prevail in the end."

Specifically, Klayman objected first to Lewis' assertion that Obama's nomination is a matter for the Democrats' national dmvention and not subject to Florida Jaw.

·He basically said that a pr<'_sidential candidate can never be nominated under Florida law, ever, and tllat'.s just wrong,'' Klayman said. "He made our appeal relatively easy, because he tEes in the face of the Florida statute and also a florida S:.~ preme Court case. There's nothing on which for him to ,:ome to this conclusion. The law is clear here that Obama was :wminated ior office. •

Despite the judge dismissing the lawsuit with prejudice, Klayman .mnounced plans to appeal.

. " .. Klayman has been battin~ zero in court for quite some time now. You'd rhink that would give his dients ·~especially WND ··pause regarding his ~ompetence as a lawyer. Apparently not.

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Klayman Watch

) The Nation.

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Click here to retum to the browser-optimized version or' this page.

T:1is .1rticle can be found on the web nt http://www.thenation.com;docJ20040329/corn

Klayman \Vatch

:,y DAVID CORN

f from the March 29, 2004 issue l

Diu Larry Kln)'man, the conservative lawyer/provocateur who spent much of the 1990s suing Clinton-related tar~ets via his Judicial Watch and accusmg the Bill-and-Hillary crowd of vast corruptions. recently try to skirt ..::unpaign-linance law to obtain an illegal million-dollar boost for his back-of-the-pack US Senate campaign in !;lorida'/ Kl:lyman is litigtous. Newsweek reported in 1998 that he had even sued his mother during a ta.mily spat. So let's just lay out the facts, Jnd readers can reach their own conclusions.

Some background: Klayman started Judicial Watch in 1994 and became tamous--in a cable TV sort of'.vay--by riling wh:.~l seemed like thous:trtds of lawsuits against Clintonitcs. II is work (some might call it :;henanigans) was i'artly underwritten by Richard Mellon Scaife, the right-wing millionaire. And Richard Vif\uerie, the direct-mall :it an Qf the right, raised money for J.Jdicial Watch. Klayman also represented the rvliami rei atives or' EJ i;in ()oru.alez in a law:;mt :.~gamst the Justice Department, and he involved himself in the Florida recount mess. ln recent years he expanded his hit list. Judicinl Watch joined the Sierra Club in suing Vice President Cheney for :ccords of Cheney's energy task force, and it launched a lawsuit against Cheney and Halliburton tbr allegw tccounting fraud (a :ederal court dismissed the case). But Klayman also sruck to his bread and butter, r'.!presl!nt:ng Gennifer Flowers, who tiled -1 suit claiming Hillary Clinton had tried to destroy her, and supportmg .t businessman charged with stock and bank fraud who claimed he secretly made illegal campntgn contnbutions to Hillary Clinton.

On September 23. Klayman left Jt:dicial Watch, which issued a terse three-sentence statement that could he r:!ad ~:sa s1gn that the parting had not bet:n amicable. That day, Klayman announcCIJ he was running iorthc US S~:natc l'rom Florida and that he intended to be Hillary Clinton's "worst nightmare." He joined a large ricld of ;{epublicans seeking :his seat. a group that now includes former Housing Secretary Mel :Yiartinez. former US ~cprcscntative Bill McCollum, Florida House speaker Johnnie Byrd, tormer US Senator l3ob Smith, State Senator Daniel Webster and businessman Doug Gallagher. In a recent poll, Klayman was at 4 percent.

ln the lirst three months of Klayman's campaign, he raised $610.555, mostly through direct-mall fundr.:~ising Londucted by Vigucrie'3 American Target Advertising, according to Federal Election Commission records. In 'tlis period Kla;ma.1 paid A TA $577.358. That is, the revenue barely covered the direct-mail cost--not good r.ews :br any c:.~mpaign. And a report prepared in !ate January by AT A noted that the Klayman campatgn had sent out ;lightly more ti1an l million pieces at a CO!Jt of$ 730.315 ond brought in $703,155.

Viguerie -.vas using an assortment of conservative mailing lists, yet Klayman was scortng reasonably well mainly ·vi th those from Judicial Watch, according to A TA records. These Juuicial Watch lists, thouJ?h, were several years old, and mailing lists tend to deteriorate quickly. Kla~man's direct-mail program could not rely on the older \isis. One obvious answer was to rent Judicial Watch's up-to·date lists. Sources familiar with the campaign say

http:/lwww.thenation.com/ducprint.mhtml?i=2C040329&s=com 7.'1 0/2007


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:<:layman Watch P:tge 2 of 3

:<layman told campaign workers he had tried that, unsuccessfully. (Tom Fitton, Judicial Watch's currt::nt president, denies Klayman made such a request.) But in search of a productive mailing list, Klayman, lccording to ;1 lawsuit tiled against him by a former campaign employee, also came up with an unorthodox remedy.

In December Paul Jensen, that former campaign aide, sued Klayman, charging him with slander. In his -:ornplaint, Jensen says that he quit the campaign because Klayman would noc pay him and that atler he threatened to sue Klayman for back puy, Klayman paid him but then told others Jensen had stolen from the i.:;;.mplign. The complaint :1lso maintains that Klayman-who has culled himself a Jew who believes in Christ·· h)ld a Palm Beach Post reporter he was Jewish but informed prominent Christian conscrvutive:J he was a Christian, and that Klayman instructed Jensen "to lie, if the subject came up, about the fact that Klayman had recently been divorced from his wife." Another person close to the campaign says Klayman told campaign aides :o avoid mentioning his divorce and that campaign workers discussed among themselves Klayman's practice of offering different descriptions of his religious beliefs.

In his complaint, Jensen claims that in September he went with Klayman to a conference in Colorado Springs of the Council for Nutional Policy, ::tn organization of prominent conservatives. Accordinq to Jensen. four wealthy con:;ervut1vcs-William Ball Jr., Stuart Epperson, Dick Bott and Rich Bott--were attending the conference, and Klayman "was prevailing upon [them] to loan one million dollars each to American Target Advertising for its use to iund a direct-mail campaign to bcnclit Klayman's candidacy."

1 ens en declines to talk about the loan or :mything Klayman·connected. citing his ongoing case against Klayman, who has asked a federal court to dismiss Jensen's lawsuit. But with $1 million or more, Vigucrie could test-mml •;arious nght-wing lists and cratt a more ctft:ctive li::Jt for the Klayman campaign,

[ culled Ball, an Indianapolis-based businessman . .md board member of the Center for Scientific Creation. ::md ~tskcd if Klayrnun hod urged him to lend :S l million to Vi15uerie for use in developing a direct-mail list for Klayman's ..:ampaign. 8all replied, "Yeah." He said he discussed this with Klayman at the Council for 0/ational Policy meetmg. He Jdded, ''I've known Richard [Viguerie] for many years. !fl had the funds, l would do it. l'm :'itill hoping I c;:m do 1t. '' But. Ball said. a recent dispute with a bank had lt:t1 him short of funds. He noted he'd ,;ent Klavmun a check for $600. "It's the best I can Jo at the time;' he said. 1 also reuc.:hed Dick Bott, founder and prcsid~:nt of a Christian radio ner.vork. Did Klayman ask him to kick inS 1 million'? "I cannot contirm or deny tlut," he said. ''I've t;:llked to Larry Kllymon several times, and I think he may have, but I'm involved in my other projects."

ln ~October 2 letter to Richard Sc:ufc-wntten days atlcr Klayman had lur.ch with him--Klu:;1nan re1erred to a :oan idea. first he laid out his master plan. "As a senator." he wrote, "l will have considerable powers that I did t:ot have at Judicial Watch, including the ability to investigate and prosecute in the Senate Hillary Clinton much like Richard f'.ii~on did with the communist spy Alger Hiss .... if [am someday to run tor president. I need the ,;rcdcntiuls to do so; being a senator will provide me with this. If not this year, llillary Clinton obviously will :un tor the prc:ndcncy in 2008. 1 plan to oppose her, God be willing." Then he matle a pitch: "Dick, once again I need your hcip to achieve this goul. As explained, I left Judicial Watch without resources and must rely on direct mali to r:1ise the monies to c:ha!lcm;c my m1llionaire opponents. If you know of someone or some entity that can :inance the direct mml Jirm, by prov:ding a loan with an l 3 percent return on investment, I wouh.l be most :;;ratcful." A Scaife spokesperson maintams that Scaife never received this letter. "lfe has not given one dime to \.lr. Klayman's CiUllpaign,'' she adds, "and in fact he discouraged him from running.·•

Would it be legal for a Senate candidate to solicit a loan for his or her direct-row! house? I called several lawyers -.•;ho specialize in campalgn law and described the situation to them w:thout mentioning Klaymun's name or the \ucntities or political affiliations of anyone involved. Joseph Sandler, a termer general counsel to the Democratic P:1rty, satd, ''1 thmk that it is clearly illegal.'' A Senate candidate, he explained, is allowed to borrow money only from a bank or from him~ or herself. If a candidate solicits a loan of this sort specitica!ly to help his campaign, :;.tmilcr said, that would VIOlate federnl campaign law. Contnbutors can only uonate up to $2,000 to a primary -:ampai g,n. Providing :S 1 mlllion in working capital to n vendor for a campaign could be seen as an in-kind Jonation that far exceeds the .:52,000 limit. Two other lawyers specializing in election law--both of v;hom asked

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Klilyman Watch Page 3 of3

r:ot to be named--shured Sandler's legal opinion. ''This seems like a way to get around the rules," one said. "It <o;cems like a violation to me.''

How does it seem to Klayman :md Viguerie? Did they nab a millior:·dollar loan? Neither man responded to multiple requests for (,;omment. And by the way, Kl:lymo.n, as of this writing, had not tiled his personal tinancialdisclosure torm with the Senate. as candidates must do within thirty Llays of entering a Senate race. Failure to submit this form can result in an S 11,000 penalty. Tim Judicial Watch motto is ''Secause no one is above the !lw!" Is that the watchword of Klayman's campaign/

http:/iwww.thenaticn.com/docprint.mhtml?i'-"20040329&s"'corn "'II 0/2007



Exhibit 12


) Larry Klayman, Conservative Wingnut Lawyer, Gets Reprimanded By Florida Bar, Is Broke By Gus Garcia~Roberts Published Tue., Nov. 1 2011 at 8:ooAM

\\'hat ·with all of his insane lawsuits against the Clintons, Facebook, Rachel Maddow, President Obama, and his own mother, conservative Florida activist and lawyer Larry Klayman is pretty damn busy.

Too busy to defend his real clients, apparently. The Florida Bar has issued a public reprimand of Klayman for taking a $25,000

payment to represent a woman in a high-profile criminal case and then allegedly failing to, y'know, do any lawyerin'.

·)When he was ordered to pay the client back, Klayman missed /payments, whining in court documents that he's so broke he can't

afford a bankruptcy lawyer.

Allow us to shed a single tear for the man who calls Barack Obama "mullnh in chief'.

Klayman founded .Judicial.Watch, the conservative organization that filed eighteen lawsuits against the Clinton administration in the '9os, and recently St}ed Hillary Clinton. Klayman left Judicial Watch and then, of course sued it. He recently sued Face book for $1 billion for not removing an anti- Israel page, and represented a homophobic preacher in a slander lawsuit against Rachel Maddow. Oh, yeah, and he sued his mom.

According to a complaint filed \•rith the Florida Bar, Klayman was hired in 2007 by Natalia Humm. a Daytona Beach v,roman who along with her husband was accused of arranging sham marriages in an immigration scam. Humm claimed that Klayman didn't provide any legal services for the payment. A mediator ordered him to return $5,000, but he failed to make timely payments.

In a hill.f.r. to the Florida Bar, Klayman lamented:

)

I have and have had very little funds, as my financial situation continues to be dire. I do not ovvn any investments or retirement plans and just have a fevv pieces of jewelry and clothing, a television, a radio, a bed and clothing and shoes. I rent my apartment. The jewelry is a watch which is of negligible value, and consists of a watch and a ring valued currently under $2.oo.oo.


He added: "I cannot afford bankruptcy counsel, having been asked for a $sooo.oo retainer which I cannot afford."

vVhen we reached him by phone, Klayman said that he had since made all of the payments. "The issue )vas the delay in payment," he says, "as I was having financial difficulties."

··· Florida apparently isn't the first state to declare Klayman a deadbeat lawyer. His bar license in Pennsylvania is also under "administrative suspension."

Follow ~Yliami New Iimes on Face book and Twitter @}JiamiNewTimes.



Exhibit 13

fYr EX!_IIBI'F~ Depo~~ ~~0~


December 8, 2012

The good virgin's birther case By Larry Klayman

No, I'm not 'Miting about a sequel to the Steve Carel! comedy flick "The 40 Year Old Virgin," or about the even more low-class holiday issue of Playboy magazine. Believe it or not, this column is about a case 1 filed in Montgomery, Ala .• over the eligibility of Barac!< Hussein Obama, which vvas just decided at the IO\"ver circuit court level by the Honorable Eugene W. Reese, a liberal Democrat Larry Klayman judge. The way this suit oos handled by the court is not funny. It is symptomatic not just of the vvay the judiciary has thus far tried to dodge and deep·six the seriousness of Obama's ineligibility to be president. but the current state of our highly politicized judiciary in general.

Our complaint, filed on behalf of presidential candidate Virgil H. Goode Jr. and Alabama citizen Hugh Mclnnish. seeking to force Alabama Secretary of State Beth Chapman to verify that Obama oos eligible to be placed on the state's presidential ballot- after she told our clients that she •mu!d not- v.tas filed Oct. 12, 2012, with enough time for the court to rule that the state had an affirmative duty to determine- given the S'M:lrn affidavits from Sheriff Joe Arpaio, his investigator Mike Zullo and

) renov,tned investigative reporter and author Jerome Corsi - vvhether or not Obama is a natural born cittzen as is required by the U.S. Constitution. As set forth under oath in these affidavits. there is credible evidence, vvhich was incorporated into the complaint and a simultaneously filed motion for summary judgment. that Obama's claimed long-form birth certificate. produced by the White House years after the issue of hrs place of birth was first raised by none other than his 2008 presidential primary opponent Hillary Clinton, is altered, forged and fraudulent. Thus. Judge Reese had plenty of !ime before the Nov. 6 presidential election to order the Alabama secretary of state to do her job and fulfill her oath of office under not just the Alabama Constitution but the U.S. Constitution. Indeed. •vhite .Alabama statutes are silent about this, analogous law in most states requires that election and ballot challenges are to be given expedited treatment, for obvious reasons.

Under Alabama law. it is clear that the secretary of state has an affirmative duty to verify the eligibility of those seeking office. An Alabama attorney general's opinion provides, "If the Secretary of State has knov.iedge gained from an official source arising from the performance of duties prescribed by law, that a candidate has not met a certifying qualification ... the Secretary of State should not certify the candidate" [Attorney General's Opinion No. 1998-200]. The attorney general's opinion is not binding case precedent. Nevertheless, it constitutes an admission by Alabama's chief law-enforcement officer on behalf of the state that if the secretary of state has kno\·,1edge gained from an official source about a candidate's eligibility, then she "should not" certify the candidate. This should have proven very persuasive before Judge Reese.

Certainly investigative findings that Obama's birth certificate is likely altered, forged and fraudulent, contained in the S\\{)rn affidavits of Sheriff Arpaio and his investigators, come from an official government source. Thus, Secretary of State Beth Chapman had an affirmative duty to determine Obama's eligibility to be president. It did not take rocket science. therefore, for Judge Reese, given the attorney's general's opinion, to order that this be done quickly, before the Nov. 6 presidential election.

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However. rather than deliberating expeditiously on the pleadings before him. Reese dragged his heels, eventually noticing up a hearing for a total of only 15 minutes on this case of great national importance, for Dec. 6, 2012, exactly one month after the NJvember presidential election. He then "graciously" gave each side only seven and a half minutes to argue. Based on this delay, any reasonable person would have to conclude that it '.vas simply a pro forma hearing for the court to say it gave the parties an opportunity to be heard. albeit one month after the election. It \.\laS clear that the hand'M'iting was on the \Vall. Since I have co-counsel in Montgomery, I then filed a motion to appear at this "meaningless" 15-minute hearing by telephone. to save money for the clients, as they have a limited budget. The judge never responded to my motion, and as a result my co-counsel argued our case for seven and a half minutes!

During the hearing, Judge Reese asked no questions about the facts and the law. He sat there like an Egyptian sphinx and stated merely that he had read the briefs. And, about one hour after the parties left the courtroom. the court issued its "well-reasoned" decision. It simply read, incredulously, that the defendant's motion to dismiss "is GRANTED.''

But Judge Reese's judgment did make one bold finding. In the caption of the judgment, he changes the name of my client, a presidential candidate, to "Goode Virgin H. Jr." Even if, in jest, the judge's "blonde" secretary is the culprit, his lack of concern for our clients' and the people of Alabama's rights to an honest presidential election cannot be seen as a joke. Given the stakes of having Obama re-elected as president vvithout so much as the secretary of state being ordered to do her duty to first confirm his eligibility to run for the highest office in the land is a constitutional tragedy. Regrettably, similar scenarios have thus far played out in dozens of eligibility cases in other states, but never to my knov.Aedge v.ith the cavalier indifference to the rule of law and defiant if not insulting display by the liberal Democrat Judge Reese.

As I have written many times before in this \-.eekly column. I am saddened and fearful that the state of ) our judiciary, 'hhich largely protects establishment interests over the rights of ''We the People," has so

,./ deteriorated that v.te no longer have any branch of government that will hear our grievances. We are 236 years removed from 1776. but the situation 1Ne find ourselves in today remains unchanged. As our French allies during the Revolutionary War V.{)Uid put it, "The more things change the more they remain the same."

And now. to not only the Alabama Supreme Court- 'Nhose chief justice thankfully Vvill soon be the courageous Ten Commandments judge, Roy Moore- but to the barricades as '..veil!

'9 Larry Klayman

The views expressed by RenewAmerica columnists are their own and do not necessarily reflect the position of RenewAmerica or its affiliates.

(See RenewAmerica's nublishing standards.)

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\ly )C:!;!l~rday\ prt~SC!Hil!ion io ccm and upda!e on arlkk: :)ur.;rPi\C~Ltrry Klayman $25,0 ... Page 2 or 12

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artic_!~~§.~!erPAC:-I~.arry_i(h!.YHUln $25~00Q. ftl~ldraising for non:cxistcnt Ja\V suit a1Jair

Ye"lc·rday l ;::~v,· ,, 211<:!11' !)!\'''l'lltli!ion n(my pl.!tfinm as ;j (';iltdid:tr,: f<lf the l.IS s~rLtlt:. l he prt'';(•n!diunwns gih·n iu :;t'HIC I O:J t:A vntt'h in illt: \Vo;m~n·s duh of ( ·~lnh:D ( iwn:. i w;h wi,1, tkll n tl'fll\:'.ut!ativc !lf' the JlJdkial \\':Htlt drn' 1: t\)r nv\.'r ;:!l hour !!·om S:m \!:trinn h> h,•:tr me: ~;p,.~~d .. md !;ilk lo tn<'. l g<.l! :1 v~:r} wat ill rctcptilln. a!kr my pn:s,·ntalt<'•f'l pc:npk sto\id 11p and apphtiilt.:tL TIJ\<; l11<':nhn 11! thv i11dici:d watcl1 upprn:tclwd nw nne! g:tve nw h.:r C:lrd. r kr 1:.\IIH: 1\ ( 'nnst:uw,• l~tdlJ.··y and \ih; j, :nl oi'i1<:e :tdtnin;•dl';th~l t<w tlw llldid:ti W;J!ch ill tiL·ir Wc·;tt•rn Et:;•!onall k:l'LiU<nltT··; at ;>·).10 I l11111int~t')'' Dr, S:m \-L11ino. Sh• toid n••'. that dw w;t~d to work t(lr the FBI and that -cJw 1\orJ;~,·d fnr tlw Jiidi(i;ll \V;'!ch fi,r man) )c~;rL;. Sh· :lcttnlly iniri;~td the discu~~;ion abulll !.;my Klayman anJ t;>id nJ<.: :h;ll :;lie h.:;ud t!z:tlll<.: i·, im tllvcd iil binh.·r ; .. JM'•;. l tnl..! h.:r t!t:ot tilb; gn•lifl .. lrli.:IJ.::·;uperp:tr w:p; ~;oliciting

mor:cy.. that thc•y ~en! <HI ~·-111:til :md p<>-,ted on ih .. ~u· ,ite :111 ::dv.:rti-;cment <)!l Ft:hrunry lll. a'ldng li1r :t:~5.000, cktimim: lint the·: n::c·d to r".li·;<· ·P:\POO in 1 J6I••'i!r~. ;1:: llh' cas,::, in l·Jpriola anJ C.llifnrni.tnccd to b .. ' tiled within a 1vcd •. llc.!d l·,·r, th:tl it ·.v;h :1 hare! ~,·tl. the\• \Holt: it i:; nn•;. ·n· rJt:~<tr. ~: 1 \'inr iiral:y Oh:nru·-. tc:nnllll't their ntiil•.:h, dis~:n~·. ·l: t'dr·: ;1fmy tirdeo;·; \q:rk in !lk' prn,·t.:'·\, <llid 1!1 iite ~.:nd ltuthing \v:r~ liln! hy Larry Klaynwn. !tis not clcM \~!1.tt h;tppcnnl to ;J!Int'th• !1H•rtty \hltl wa~; Lli:,ed, v;j,, )!l't il.

ivls. !{u!'ilq lKiually advii>t::d tnt: that Larry Kl;tyman i•; fi>JI lin·n-.·.:d Ill Ctliti1m:a, :;h..: tnh! me that he no lnngcr works with the .!t~dicial W:1tch and that dPm•r:; ~hordd bJP\\ ahqu I itig;l!i('!l in Ofli,·•, wllt:rc he w:t'i c•,nvictvd jll:\(

re,;cntlty nfnut paying lnrge amount in child supporL She provided;\ Jill ,,fP!her inf<mn:Hinn. I will rub!ish only. wlwt j..; u pnhlic rct:nr,J. I am not puhJi.:;iling ;my!hin!!. tll:1l i~ W•l in public rcrNd.

l.arry kJ;:yman. (>0, or Lo•; :\ngd~.:s. ('ali l(lrtJia. wa~ intlkt•:d t lll t•,\ 0 ~.::! Ct!lllll:i of uimin.tl 1101\-Sllppon. I k owe:; ~.7lU>(, l. 76 fN his !\Yo children ;t1,;.cs 1 l and l·L '1\'.n hc:trinl•,·; \H'l'l' lwld in Doi!Jc;til Helation'> C1lmt hclween :;or;<; and :n I 0. Tlw lu'd volnntnry pn"rm:nt \'. >h mndc nn .\tJ;;thl ;o, '0 ll, in th<: annP:nt of S \.111·1.2(1. :\rr:tignmt:ttl i'; <:clli·thtkd for J'dmtaJy 7. 2.012.

2!21 /201.\


\ly y~~;t~rday' s presentation to CCIR ~nd npdafc on uttide:2Sttpcd' :\C-I.any Klayman $25Jl. .. Pag<: 3 of 12

hn p·- i\V \\ \\ .pul i! ~r~l/ i(H lll H .\'f tJn:cul1l'l \1 t:\.t:tti>) ~3 ::i'J~: ·i ~'I~~ d .IIJ~'··. L:nH H T~!i--ll L:\~ 1 \tflt .: ·\.' h:dl-:t:;~' ~ l :hJ~ ·t·l H !H <t~ :~tL )'.1

,)h:HlM· !11 >rid::-2.1 iln: I

l \V!\\', )'l'lllllit•ht wum t\1 r,;,ld lhh ·;uir (h:lowJ tikd ;!;.~.1i11~t K:1\ 111:ttL. i'r0m tk~ tim•~ tJ1i•. suit '.v:1s iikd ;1t2:1insl

!~l:1yn~:m (20~)7), lle lias nnt l:omm:d hi:; p!inni·'c to p:1y ktd; 1\IJ,It th: court ordcrd. ·.~vl':l tlH•ugh it"";'' IHJ\\ht~re rw:H the '::25,000 he was trw;ted 1\'ith. I \\tHJfd l•e 11nrncd t.u, it' I had dnnall'd money U> 1:1is nun

!l'<TI!I~S!if'i{L:,H: UH!Hf OJ FLORID!\ Ill F FI.OIUDA BAR, "upr•:tlW CPw ( c':t-i('

<'n111phinant. -.•:. ;.Jo .. :o II-70.(J)! ( 1 l :\)

Lr\H I< Y l:.t.UO l t~ !.!\ YM:\N, Rc·:p\llt\l<:JlL cm.ll'l XIN 1

3. ( ln nr about ~lnv<:mh.:r ! I, 20fl7, :-;;nalia! lun:lll ( .. ! !tnmn"i tiled .t~;ri.:vancc ;traiH<.t l<,~:.pii!~,k:n 'L1rry l<laym:tll) nlk~;:ing that he: had !t:td L:ikd til provi<h: ~·.>rVtL't~s in f:.:r nitninal.::~:;c ;llkr ·Jw p.ti,J him a $2".000 n:t.til>t'f,

Ln p:.'-'1" "i'\', 11, ·i'id;liYll. o;yi! ll V \ ll ~ 1;\11 ::M I 'Di~ll•. 1.11·; f I Jl •-: \( . I \ il \V !;'~>II ;()!J.J!t; II D>~•jr_·gs <:<;"?SF(( if tl11 :~~·;Hi 'i.! lll-'::-lo220 J~.PD!'

Y~.~st\.'1\lay I ;,•(>1 ,tll c-n<dil rrnm l'dllH:hi llam.:tl t!!l.:d: "Lm·y I-.;,;v:run ,iid ll<'l ;:,·1111:mlv ids rd;tin,:r". \VIlcn fhrncft '-'d'<~!C tll;\l !~laynian did nut f:d ncady his r..:uim:r. \t m~:;un, \hilt he 1~.<>! •;(HlH.'thiJ:g. ll.1rnra did nl't dhclns,-, wh!\t di.i ll,~ eeL Wht dnt"• it rn,·;w? ih:cnrding !<l I he •.(llit'it;lliPn ,,., :: p:ll·k nt'bi•·!·'l'{'/'i 1111hi•·; :~rlich.;:~·..;,,p,;rp:i<.:, all (lf

t!J,:'i~ l•f''i').:ns \<~'r":.·lw;:vilv sn!iritillt; ;, wr:d ,,r'S::'.OOO. t<nh,•!\ Ll't'l'.':. h.m >nlwli ,lid ih~y :ll.lli:dl.~" r::i::e . . \dditin:wlly, tbrnctt ,:L1im·;, th.tf :-L<.: .tnd (.;~;,1_:;,· r11ilk1 ;::\: tHl ii<fJ:•cr .-.. :mn:t..:d wit!t the <trlll:k2:.upc![lilc',

ih:W.;vc·r the· ;\rtkh:.>;llp(·rp:t<.: :IIHI•;nJi, it:uinn l(•r don;ttiPJI' j;,:· :rr:irk.?sllpt:rp.l<: i' luc;Hcd :tllhc: lop oi'thc hlu;,t. ( lb:mdlallotCha!l~·n)!C whtdl is adrninblt'!Td b) lbrnd; ::lid ~.lilk!. ·1 ih.' link

ittlp:<lw,xw.art!::uper)ld(',COm/11ori<bh;!ll<;.t.hlm( ,,Jii·\Y~.lll<' ;:UUJl :lrliclc. Tile l'J)i' illld St.Tl'<:nshn\ .tfl.: a! the \11p or the Jll\!1.' •

.. r,ut 11<\lri) lw; rcti!it:~.:r'' c:lll he $1 :'.000 nt!l "'t' $25,(HHl, II GHJ \1d: l 0.000. Bnltum line', n.-1bod;. know~;, flo•.v nwdt l:J;;::n:an ;:cnully ;:~·!.'Ill.: •lll~·sti()tl i;-;. wLy '>l<,s h,·rnid anytldu;:. if !H.: did Ja•t file tih·ln11· s11it-;, :~> k: wa> :>Uj'JW"':d

l•''

Lila l r•lt .wl'-illail (rom Tony Dolz, who is not''" the· hu:u·d ••lth.: t\rtirk:?Sitpcrp:lc, hut >.vh•l i•. in ,·i-.rJta~:\ with n 1111mbc-r ni'tht' Ln:nd tnt'mlwr~ <lt'this PAC'. \\ho <!:lied, !it:ll l:L' lud a di,cu;;,iPtl \\ith (ieug': \ldkr, 1\lli! i' (lil tk~

h•:trd of11n: :\Hiclt•2sllp('rp.Jr, •.vlm runs a hiP;: OhamalLltlnJUwlknec· tngl'lhl'r 1•:i1lt flan-.ctt. :\n·nrding tu lkol/, \lilkr •.:;nd, tbt Klayman \\d:; not r<~id :m;, thin(',.

I lit.~ l]iH:·;tion is: \\ h> is l) ing? \\'as Kl:1yn1;m p;lid nr nnt'i l!.hc· 11 <1~ paid. thlill it.: m·nl~; to rcfw:d !1~:~ donor~. n~ lw di•! nnt file Ia\\' :;nit:; .t~ !w was s\!j'flllscd tu. If the bio~:!-\cr-, nl~c.i m•m,·; nnd did nor p:l\ 1\l:tym:;n, \11,. bio~~I:t'r$ nc:ed to r •. •fifl,d the rnon•:y lu tlw d•HH.lh. Til~ pn::::, n·ktt~'-. til:11 \\·;t•; j,, .. w:d hy ,\ni..:h:2St!jh:rpiic Pll h:hruary !0, 2012 clc:ll i} stated. that tlh: d<HHJI'3 an· a•;kLI !O dmi<lk s::s.noo fo lW, Larry K laymall, that tht·y h:!\"C !){; h\lllr;i $)

raist• tlti:. l<ll'g\.' 'i;Jill or fllllllt.')'. llw urlick al.;..$ ~t;~!l:d th:ll !h;.: 1.1\V :;uih are ~tlppmcd !o (),: likd wilhill I Vit:Ck. I! b nnw nr 11•.'\·t:r(,;,;,: th.: ltrtick abov~:). So. there \"ere d<:M p:11arnv1c1~; thi;; pad, ol blo;:gcrs '>'>:l~ \olkiting from tl1c pllblic a l:lq:(: s11m o(rnon<.:~· :.pccilicaily to pay ;1Hom<.:y l.:m·y KLt) man· S25JlO() ltl \ilr 2 !nw ·alib in FL and CA wi1hin <~ w.:,:k, hy Ft·bm:11y l'l.~U 12. ·1 hr•se law <;llit;:; w~:re never tiled and th•..: pnbl ic s!Hlldd h? reftHhkd all of rlw mnn,:y that w:h dnn;Hed lill' this ''PL·cili<~ purp<Lc. ,\JI ofth0 b!nn•,·n, who ran this ~olicitalitHl, 11eed to pnwidc ;H:t·nwHing for tlw pohlk lluw mw.:!t ntnlll'Y did liH'.\ rai~e ill total and where did !hi" nHmey gn. :\r~u:dly, donPI''

2!21 120 I ~1


tvfy ye:>tcrdnv's prcsr;ntation io Ct'IR :md upd;ne lllt ;ulidc2SupcrPAC·Lan: l<laynHHl S25.0 ... Pag~.: 4 of 12

can H'!Jorl ihb to their I li1trid '\ttnmcy•,. If tll•: public thmntcd ft•r \pu.:ific ruq1lh\; :Htd ,Ji;! nut 1•ntl:e hT;dit, the pnhlic 1\JS ddbudcd and thi'> i:; a crimin:tltmlkr. [\·t·pl.: IH'IH tn pn.·wn !i>r thillf> !if,,. ill:;!

·;, l\;1h ';~ho;t-hk1g~~cr. ruB·, ORY!t !Clbam;d{tka~cYPurR,·'~'·:d•;; nr Hinh,~d{,:p•>r\ \I f'~>l ltt!n:wa!iun, th:!l Bnh nc·ho11 mq,:lll h: a p\l.'ltdr.mym Jill· 1ichard <.iarotllk. but! i\llt rH•l :;wei

·l. (In •q.;c \ Iiiier nm!; hl,lg ( lhamallni lol( 'ltalkn;~t: tngcthn •.\ itl1 l';utid:i lhmctt (:tl><•ll!c'l' ~lll'l'\•r tl'r ,,!:ttl:.!, tl,;\1 l';mlCL! H::ntdt p; on tile l•o:u d 1 nsb':ld of Cc, 1r••<: \li !ln. l ,au n• •t •.ure about !tnt l

:\d .1!" tht:~·-' ;>cop!.: .:n.~ suppn~cd tn r<!fttml the puh!i~.: <Ill o!'tilc: muncy, tl~at llil~Y rai:.•,:c~ ti-n thv<.l~ I;!\\ '.uit~ t\nt \v.:n~ ~uppo~.:d lo h: iikd hy L11 ry 1.;.1aym::n by 111<..: h;hru.u:-: l '!, 20 l.: dt·:.rdiitw, :1~ t:,uc;e f;m ··llil« '\ er:.' n.:\ er :lbl. The p11hlic ttc\n g"l tl1;; b<:11\::it ol'the wlut riley p:;i.ll(lc.

llti~· is !lie Jl<<J~:on, \\hy! ~;lil!l~d hdi>n~. that ify<•:l w:olt ln>ii:L:th'lo lih: work oL! ·ij'n;ilic" atl!.,mcy, dnn:ne directly ,1-Pil .\ lld Ltr:~·· .. \'/llcr~· ~Lt• t:inncy i~, fJliHg. \Vhl·n ~Ctl donate.,~ id ~~ l~~ll;l~ \)( hlo;:gcr'\. cl.\H'Jl~OF thdt t~"lr.'' :1l(qh,'j' j<\ vning t¢; ;!1~(1f!ii.Y"i 1~)r l~~p,n! :,•\pcn·a·s,) tHI h:t\'e no id,~:~ \V11l't\' tht· ~h~!l'dl\1!1<; .tre J.~cdl~~-··

·\ lteSJH.ln·;·:~ to" kly y,:·,tenlny's pr~~sentation lt.l CCl [{ :wd upd<lli: 011 :wti.: k?SI!pcri',\C· f .;nT;; Kfa) m:m s::s,ooo nu:dtttit,fl!n !(1r lh~tl.-(',\1'-dera l:nv ~u;, an:dr""

I. ! !tntdk··'i Coup Fehm11y ?.Jrd. ?Jil2 ·ii~ 7:20 .1m

l wa' inli:dly cxcih:d nfH,tl! I .drTy !~Llyman, amllwlpcd the n·:\V\ ahntlt ltilll In i-'" \ ir;d \.,,J\\ ! ;nn wu•1dcn1:1;

:d··IIU\ him :Hid ~;lw! hi•; tn1e motive; mit:in ih'.

·! f'lnreth'c' ~tone f\:hntar: 2.'lrd. 201:: !;i ~:)I pm

1 :-;mdkd a r:H from the get-gn. ;\~;kint: !(>r S?.\O!JO iPr 2 !.tll:>lliL '<tl11n1kd W;ly ntH oi'llh: h•illp:Hk 1<1 tnc·, so I did nnt bite. Sl.'t.'lllcd like an ;ltfempt to scnm nwn~·; nn :h·: h1ck•; of pctlrk \I';HJting to V\f'('~e Obama, and Jhlthing rnnrc. (ilml Oriy s!ttys n11 top of thing~ like ll!i!> Ccr u:;. W! !Fi{i·: DOES SillS FIND !'liE THvlE','! 'l ;dk ,Ji·,ut:t multi·ta:-king. l!ltinl; Ody i~ the (,ltH.'GIIllfllu: as ''•<.'il 1

J. l'llillip F. Pcr~nin;_!h'n h·hnt;~rv 27th. 2012 \tl (j·).J illll

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Oh:una's mlmini·>tratilln is doing the :>nllh.' to Ody <l~; \hey did {.u;d M<.: :>till doing) tP Dr Jndy \\'nod k;~:mling "\Vher\' did tlw TtW!i.~r··; r;o". !hey ·di<k n !~Lil lii!O "k:Llin:~ !hlll\''il inlen!ion" dw.\11 ;\ hi!i aml into lh.; fnrc:~t ;rnd :may fnHll the• rtillin t:•n:.et Dt Orly T.1il1 i~ 11w l!nc:.-.t then: j,,~

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My yesterday\ preseniation to CC!R and update un artklc::SIIpvrPAC·Lmy Klnynwn $25.0 ... Pag;; 6 nf 12

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~ ly yeskrday ':; prc~~cnlation !o CCIR ;tnd update flit ;ll·t idc.2Sup,·rl 'i\C ·Larry Klayman $25.0 ... P:q~c 9 nl 12

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Exhibit 15


,Ciarifi~ittion n:~an.ling artkh:21cgal fund umll urry Klaymun i Dr. Orly Taitz, Fsquire Page I of 12

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,Cbri!i~.:ation regarding artick21egal i\md nnd Larry Klayman 1 Dr. Orly Taitz. Esquire

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Page2 of !2

~larification r~~g_ing. articl.e2leg!~l fund and Lart·v I(Iavnutn

2. y1.11J ~tated, lhat..".l ;;;;;;nil! p::r:wir•;,;z: i11 ,,.,:.;,·,in (';,iii'nr;:i:• wmktn;:. <.Aith my •:o!legta.•. whcl is lhx·n~.cd in (';dit<nni;i"

I pos!l'J an <Jdv~rti~.cm<.:nt t>y :\rf.iclc2sup•.:rpc. which ~.r;!lcd, th.lt l.arr) Klayman will he paid $15,000 to lwndle 2 cases: <lllC in Florida and om: in Cal!flnnia on hd1:df n!' lbmct1, ~<oonen :md others. T!w advcrt!asem;:nt did llot

state, !h:.it annn1cy Klaym:m tog.:ther wl!h :mu!ho:r :li!Prncy licensl:d in ( 'n!lllm1ia 1\ ill rc·prcs~.:nt those i.·licnts, provided that the judge will grant .10orn.:y Kl:tym.1n pn1 ha,: vice:, m~·:tning right for an out of state atwrncy to represent clients in the ~t:l!c ul· Cnlil(m1iit lOf:~c·th<.'i with <I spccifk California alt,Jrney.

Thc adv.:rtiscmcnt sl.ltd that :ltt•Hne) l.il!Tl} Klayman •.v1l1 be.: cOl!ihd fnr Barnett. Nocncn and oth.:rs. l believe others arc Wilmolt, Turner, Dnl;, :v!ilh:r. l bel:t:n: then: wt:re ,., }X'(lpk in this ~.:ase. which was fih:d prose so br.(it w;1s fikd \Vitl11Hl1 an attnrney ). ! \Hntc· :1 true :tnd C(lrJt:<.:t ~utvmcnt, :hat Larry Klayman i~ nollict•n!a~d in !he state of California.

!l'in th.:: IIJtun: Arti<:k2 kgul 11md wi!lllin; an:;:h~:r att<>rn~y. ,,hob li~.;;11~t:d in th,· ,;tate oi'Calif(mlia and thcjtldg~.: will allow \!r. Klayman tu he ;t e<H.~Olli<scl trrt;.elili.T with the :Htumr.:y, who is liccmd in Culifomia, than Mr. Klayman Ci\11 be a ~:o-coun~d. h(Jwcver this ~~a h) pothet:caL which may ur ntJy not happen.

JWC00014

http://www.orlytait;.esq.wm''1p"·J2l69 2/21<:?01.1


Clarifkation regarding artklc2kgal fund and Larry Kl<tyman I Dr. Orly Taitz, Esquire Page 3 of 12

fhc~ stal!:m>::nl. which w:l'> made, w:h t:•lrn:c:. :\dveil!Wttment statt:d. that he \1.-i!l bc a nnmsel. P~prcscm\ng thP.>t.: individuals, S(t pt:t>ple w;surn~d. that lh: i:> liccn~;cd i11 California. l wrote a corr.~cl statcnwnt. that lt.: is not lic•~mcd in Cn1ilorllia.

lN I liE SUPRI:rv1E COUH l OF !'LOlUil:\ r!lh FLOIUDA BAH. Supn:rw: Court t';t::': No. CumplainmH, v~. ~o. 20! l-70.62: ( l l /\\

LARRY H.Ll<JT KLt\ Y\iAN, Respond..:nt CO\IPLAI!'H

3 (hl or about ><<lh~nd1<.:r II .. '•111 7• ~;·.i:dia l !u;tll!l <"iluauH"J lrkd a e:rievann: :1g::~imt Rc:;pondc•nt (L:rry

Kbymaa) <dk12in;.; that lw lvd b,l f:tik<J t,, i'l"'ld<: ,;~~vic,·s in h::r criminal case :titer she paid him aS? S.OO\J r~t::::incr.

Lup:, \\'A\1 .•::· Iii\.\\)\.\\\' \1h>·. \c'l :l.lllJ' .• \! 1 VI! ·w :•td!>til11Ull! {l•J•;n;xz:"'l!l! ton~: I .• >:~;

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·1. 1 rl!:ld the i\;<,t po:.l I m:~>b in n:~.~nl'<!s t\1 \·lr f~iaynwn "'l(J 1 ~.n\ tLll ind·~ed there W:t'i an error. J wrmc. !lut \:L Rnf!ky str;1,:,J t!1<d \1r. Kla;;;n;,:; \U:; ju·;! n.:cl'nti: l:unvic:ic:d <•l'non p:lyl!H:nt of child supptwt.lhe link and the: arti~h~ ::ll~h:r i[ ~.tah~d~ liLit l~c \\,h qhL~.,·_~.:d \:1 ,;, J. • .'~)urd-.; ofc:ri:nlna! non~\uppon, that he ov.;es $7k)-\6L76 and nrrignmcr.t \\X' sc:lwdukd ik l dllu;;r~ 7 . .::or: "u. :h~·rl' 1v"' :m t•rror. \1r. Klayrnan was indicted in the s!ulc ,,r Ohio on two O!tmts of ,:rimiJ~:d :LJtl·>upp•"lr',, :';~! f$· w:1s not con\'ii;tcd :-ct. I am making this C<)fl'•.:ctiun. Ms. Rut'lky made an error. it W<E also ;.d r ,·,·idc~:r in th:: I .:hmary 2 ). 20! 2 w1idc, tl5 I posh:d the link righr undL:rncath and the link ~takd, that he \\ ;n indirltd and !lrri~nement ~;dtNiuk·d. The :1rticle was publ hllcd just a cot,ple uf dnys ngn, nn Febwaty 2 3. 201 2 and l ,·,,rrt:l't;.:d il h:bnu:;r 26. 20 i 1.

l.arry Klayman, 60, $f I ih ,\ngck,. \. :dil;;m:::. w:h indict<.:d nnlwn l2l c;Hl!11S 0! ,;riminailiOn-:>npp~>rl. lle owe~; $7R,S6l.76 l(•r his{\\ r> children :lJ..•e:, ·, l ;~JLl I L J ~~,, li~:::ning:: v;crc itctd in Domestic Rdati\~ns Cmlt'l between 200IJ and 20 J 0. The hs! voluntrw; p:1y11 ,,·m >\:v .. m .. d~ lltl ;\ugu~\ JO. ~0 ll. in !h.: :Hn<l\.l!\1 of'£ 1,0 I·L2(>. ;\ rr-al,;nment h. schcdukd for Fdn·twry 7, 20 I:'

tlilll..:ii.'!;>\','W,,[1'-],)jt\!;-::tj!grtlll_L<c:••ll' \:UJ! <::llh"•·l!llL· ·2 i?'l'l1-h,· 1\...10:: ·<kill< 1\'1 :11· liJc- .. ,·l~;t!Jot·' ld kllto\'·l>lliC<'iH ill·d;!.dllh! ..

obam:1-f11'rich.:. hun l

5. In connection v.ith :\nick:?. leba! f,mJ. 1 nuJc a cnrn.::.:t statl'mcm. '!he advcrtbcment by tlle t\rtkh: 2 ::.upl'l'Jlilt:

strttcd, thal $2:",1)00 was nc(:dcd to pay attortlt'Y l.any K!aynwnt within 96 hour~;. ·;o that 2 Jaws11it:> t:ould he filed within I week, •xhich w:1•, supjl•l·;.;d I<• h: l'y Fchnw·y 17th Tho'>>! lav.; s11ih w.~rc not tiled by attonw) I ;wry Klayman :.111d l a5kcd ;1le~itimnh" qtR',;ti<;n: \\ha: happ.:m::d'? W<L'i a!lorrl'J)' Kl:tyman paid or nm? Within a day or t\\() l poo!t.:d an update t'niil> Gc()rg,~ :Vliller. wh•.l :-;utcd, that a!lmney Kiayman Wa$ n!Jt pllld, because the Ariicle 21egal fund could not mise 525,000 reairH.T,!dcpositl as requested hy attorney Klayman.

At this poilll I SU!:gestcd. th:lt if 1l1CI1lbers nf !he ;JIIblic dnn:Hcd for i1 particular purpose or paying il ~pt:d!ic attorrte) to file specific l.tw suit~ by a specific ,h,>;:diitll:. tho.k donor.' .ihnJ!d be rcfunckd.

hltp://www.orlytaitzesq.com/?p -o3:2l 69 JV'/OOC015

2/21!20!3


.Clari!lcation regarding nrtick2lcgat fund and Lurry K l<Jyman I Dr. Orly !'ail'/. Es4uirc Page -l of 12

fode,·d, i\rli..:k2f;Hp\:rpac puhlhlll:d on their '-'t:b ~itr. tkn :-1 rerum! wa·; o(t'\!rt'd 111 the donors, \Vhich onlv cont1nn:>, thilt I was corn:ct. ·

l, ;tlsu, related tu the r•~r!dcrs of my \H"b 'itt•. that Ktording to c\rtkk:'Supcrpac, they deal only witll education and pmmoting undcrstnnding of the i1llic!v :~ c)r the· !;(Hhtilution. They wen.~ 'ltntint; th:lt lht: anil.:lc2h::gal nn:J is a separate (~ntily.

n. who runs :\rtidc 2 !<.:gal fimd'.' lbw m;tny people nm ,\rticlc2 kgal fund'! Wlnt arc their names?

b. What is ;\rtic!t:2 kgal ftmJ'? l:; it a not for J'roiit corporation') is it rcgisH:rcd with a Secretary of Stall::? !n what S[:lfe'f

d. i' then: a bank acnmtH under th<~ name :\rt.. ld kga) Hmd .' \Vim owns this b;u:k ncc<>unt'.' Who an: tht: ~:igoatoci(,;".:·(? \VLo ~iF~Tb Lht:l:k\ rruln dh: !\rth:h~ ::: legal LHHi'!

1: bow much lllOt:cy di,j ,\rtich~2 iq•:ti (und p;t:. a:torn~ys'> Which ;Jt1('!'11C/'; did they pay? I low nHIGh di.i each .. Ht<Jnle.y gtt?

g. Who is ul:rm:nciy rcsponsih!t: f(H· tln.: p;tym~_·w. ul' :11wrncys (ct>! I r ;:n iittom;.:y demdwls :1 reraincr \deposit) of $!0,000 or $25,000, and til<:: Articlt: 2 kga. luuJ coi:t:-..:tcd n11ly $:'.0(;0. who is \:lppo:>t:d tn pay the: dil'fi:n:nce: the plaintiff ()f r'\rtk!c ~. l::gaJ :und')

L Typic:-illy ~lttc;~:~_·y,; ~~sk t(:.r J rct;lin::r; dql,,:,it) a~:d dLJ\1 tih::ir hnuny fees from thh <.kpo,it. What imurly fc~:s wa;, Arlic!c !cg<d fund paying the ;tttnrrc:-·s?

! nu~.k .Ill th;; ci<Hifl~ali\Jn~ and! wn <hkinc k)'.itim~lk' quv:;tion~. l h,,p .. ~ lh;ll all tlw answers will be provided by the indlviduab, who Mt: d<)ing llltsin.;ss 11nd•.~:- the: tlat1li; aniclc2 !e:,~:i; fund ::ncl it should l~!ld !he whok cm::rova:;y,

Comments

I. ba~si

February 2(Jih, 2012 ra; <.HS pn:

On the 23rd Pamel~t ihrndt wa•; !btcd a memhc:r nt'tht: supcrp:1c board:

"!len: an: th.: list;;d i\nidc ll Super Pi\(' B\hlrd M~.:mbtb hnp;//www.an2supapac.com/h(,~tnlJm:mhr;r.,.html

l'amcla 1.3:!rnctt. Richard (Rich) (iamuttc, Geoq_;,: \1il!cr, (;ary Wilmott, IIden Tunscy"

When J dl>~cked their site yc:,l\:rJ;:y nnd w,lay Pamela !irtmctt's name W<JS no longer listed.

t\1y initial pusitivc n:action to th.:·ir site was due lirst tu Carl Swf.:·nsson's cndorscment1 bolstered by Pamda's imohenwnt. liowc .. :er, that has br.:cn nullilicd by Pamela'$ appar-:nt departure. and the apparent gro5s mishandling of their relar:on ... hip "' 1tll Klaym;;n and their proposed Fhlrid:l ;md Califurniu initiativ<:s.

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.Clarifkatiun regarding artidc2lt.:gal i'Lmd and Larry Klayman i Dr. Orly TaitL. Esquire Page S of 12

Carl is still dQing ~::ood work in Cicorgia, but since r11~ither lle nor .tny(m\! dst: appnrcntl)' can find tht:: intcrcsi nr time to provide an Hpdak a~ to what is soing ''ll with Klayman <~JH.l tb: pwpuscr! lcga! IKiiviti..::-. IK· was \nvolved \\ith -I didn't e>ee the update y<•u rd'cm:d !o 1:or:cerning rcfunlh I rcnll) quc>tion their true nwtiw1tion audfor dlility.

! dn nol understand th~· ;<niagm1i~m :n~n;itas or' variou~ eligibility group~ b,wc ww::wd yt)LL fh•: carlicd c:x;nnph~ i r~;nwrnbn sc~:ing Wil' on W;llt Fritz!•:llrick 's ·;ire. JagJ luntcr, a long \'thile ngo where he critici£cd you In what J 1\H)k W<H a drunken nut:bk. l th:kted wy browser's t•ooknmrk (or his site at !hill time. With everything thnt ha~ ha[lp<!ncd Wtlh him since. I have motk:nnd my npiniPn 'It k;tst to the rnint rhatl fccl hl' b genuine in lli::.low !(H' tl1is country and our ~:tmslitution he mn:;t certainly ha~ p.lid his dtws. l'H~ wm;dcteJ i(Cnd's ::ttitmk• towan.b you hns ~nmdhing l(l du .,,jth hi.s n.:btiomhip witil Walt. S,)llldhin~; CC!Llin!y i~ 1;oing on there ;:m! I wi~h it cnu!d h~ ain.:d :md ..;ortcd ntH. bec;lll'il' illls itHightim~ anH•11t·'· thn;;c who an: cHI thi: ~arm: si(l\: bt:nC'liis 1111 nn..: bw our tnerni,;s.

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Klayman v Judicial Watch FLSD 1:13-cv-20610 127_1

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