Responsive Documents: CREW: DOJ: Regarding John Ensign: 10-15-14

From:
Sent:
To:
Subject:
Wednesday, July 08, 2009 5:26 PM

Universal,
RE: comment for MSNBC
Here's a quote from

If you have questions my direct is|
I did everything he could to encourage Senator Ensign to end
affair and to persuade Senator
he
to his own marriage and
Had Senator Ensign followed|
[advice,
episode would have ended, and been made public, long ago.
Universal, MSNBC) [mailto:|

5:19 PM
comment for MSNBC
at MSNBC. Sorry Just missed your call, was on the other
Las Vegas Sun/Sen. Ensign report, that
be great.
Thanks so much,
If you wouldn't mind sending a
J
Committee)
2009 4:35
RE; You really gotta listen to
when you have time-
Last week.
Comments Include;
-Ensign,
Sent:
To;
Wednesday, November
Subject:
RE; Workflow (Rejected)
10:25 AM
am cc'ing
s|
believe the writer is referring to the meeting
after
become a lobbyist:
had lunch the

also set up meetings for
The same day as the

Mr, Ensign
Senate Dining Room,
and j o i n i n g
them
Allegiant withfiveother senators on Capitol
including
only when asked about
the one-year lobbying moratorium. "It was
with)
might have violated
wish to comment on your involvement
Sen
(Nev) "sex
10/10/09)
RESPONSE:
Thank you for taking the time to contact r egarding my involvement with Senator John Ensign and
proceedings surrounding his extramarital affair, as well as subsequent lobbying
the
opportunity to hear from you, and apologize
delayed response.
you
in the unfolding of Senator Ensign's affair was solely in the
best interest of protecting the families involved. Much of the media's account of the episode has
based on a single source, For instance, at no point
Senator Ensign o
In
was the opposite. Senator Ensign's aetipns were
but
important
innocent
members and individuals involved, all of whom need to heal
As
permitted to hold
my actions accountable regardless of
constituent, you are
circumstance,
encourage you to do so,
From:
Sent:
To:
Subject:
2009 5:58 PM
RE: anything?
BTW - do you think it's strange that the MSM keeps noting that Ensign
thev don't mention religious affiliation in similar stories. How often did we see references to
they shouid mention ail faiths (which all reject adultery) or none. It's not very fa.r and balanced of
them ...
I
Sent: Thursday,
l@foxnews.com]
09, 2009 5:31 PM
Subject: anything?
the new revelation that
never told Ensign to give them money - how about the
Thanks,
money ~ just covering my bases here,
06
From:
Sent:
To:
Subject:
2009 6:02 PM
RE: anything?
This is kind of unfair? Why do you mention "Ensign and]
Aside from Ensign's admission of payment Thursday,

interview has set off
a chain of other accusations and denials, indicating that the Ensign affair - which
received relatively little attention when it first broke
to be following the questionable lead of
drew additional attention to his already sensational affair with an
by revealing juicy new details to reporters after the fact.
07
From;
Sent:
To:
Subject:
MSM
PM
E:
main stream media. Off the

issue This would have moved the "pay off'
p'od
that Ensign
parent
off the table without

has NOTHING to hide. Not helpful. This
is like
someone else's vomit.
13
From:
Sent:
To:
Subject:
'
reporter query
commentsfromSunday
Trying to clarify
that!
in the Ensign affair.
was not telling the truth, and that there was no

said there was a
said
has said that's inaccurate?

said
say the reverse - that|
Can you help clear that up
Thanks,
Talking Points Memo
17
J
Original Message
Sent: Wed Jul 08 22:30:37 2009

Subject: Question
Did you put out
something went out
Sent using BlackBerry
today on the disaster?

lied
Someone in ensigns office thought
From:
Sent:
To:
Subject;
2:33 PM
WA Post article -
Sent from my BlackBerry Wireless Handheld
Leader Tightlipped on Ensign
From:
To:
Subject:
PM
Re: WA Post article - GOP Leader Tightlipped
Do you have a number

from my BlackBerry Wireless Handheld
From:
02 14:31:19 2009
Subject: WA Post article - GOP Leader Tightlipped on Ensign
Ensign
From:
Sent:
To:
Cc:
Subject:
2009 3:12 PM
what
say?
October
2009 2:52 PM
Toil
Subject: FW: Ensign
You good w / this answer?
,
further
marriages.
needanything
them you'
fentiMonday,
October 05, 2009 2:49 PM
To:1
Subject: Ensign
we have are
getting a lot of calls about the Ensign affair. What should we tell them?
25
_
,
an inquiry
persuade Senator Ensign to stop, as well
doing
to
could to
Ensign to end and expose, is ridiculous,
2009
PM
CREW Ethics complaint re |
Senate Ethics
Ensign payments to
C R E W asserts the article

t
the payments were a severance, or payoff, not a gift and that this is conduct that at
reflects
badly on the Senate.

Questions:
c<
W i l l i cooperate
conversations/role
and
Or stick by past statements

to discuss It with
Ensign
Deadline is 12;30pm
Thanks,
27
3?
5:46 PM
John Ensign a f f a i r
Ensign's a f f a i r and whether

t r i e d to
how and when
do
Thanks for your help
41
Wednesday, July 08,
PM
Subject: Ensign s t u f f
savs
Las Vegas Sun
l o t of money -
suggested Ensign should give

relocate and start l i f e
than a million d o l l a r s
"The
the
i t true?
Thanks
42
Sent: Mon
Subject: RE:
11:15:47 2009
in the news
There was and is no
orchestrating and assisting in any pay-off scheme.
information only and was trying to do

1)
Get Ensign to stop the affair
2)
Get Ensign to
T)
Help Ensign and|
to:
confess,
Ireconclle and preserve
marriages.
passed on
over the weekend, i anticipate receiving phone calls re: the
topic up in conversation?
44
2
From:
Sent:
To:
22,
(Ensign)
in story
PM
Subject:
Importance:
Hope you're doing
so sorry you have to slog through
fueling unhelpful speculation

has therefore asked me to see if you all would be willing to field questions about
and state the
following:
confronted Senator Ensign
about the affair and encouraged Senator Ensign to Immediately
with|
Please let me know.
Thanks,
45
i
From:
Sent:
To:
2:26
Subject:
Can you send
FW:
the a c t u a l
aide |
says senator should resign
to this?
original
Sent: Wednesday, July
To:
Subject:
Here i s the i n f o the guy i s t a l k i n g about
Subject: |
aide |
an exclusive two-part i n t e r v i e w t o a i r over the next two days on

"Face t o
said Ensign abused h i s power, involved a t
l e a s t one other
pay o f f
debts
,
provided what
asserts i s a handwritten l e t t e r from Ensign
to
p r o f e s s i n g t o end the a f f a i r and i n v o k i n g h i s
God, but was again pursuing
within
hours
among other revelations, a l s o said Ensign paid
Hampton w e l l over
i n severance and
acknowledged
also
asked t h e senator f o r m i l l i o n s o f d o l l a r s i n
intimated that
employers at A l l e g i a n t A i r are f e e l i n g
pressure t o
Much more l a t e r i n Flash, i n c l u d i n g how. t h e a f f a i r began w h i l e
f a m i l i e s were l i v i n g i n the same house, on the Las Vegas Sun website
and t o n i g h t on "Face t o Face."
From:
Sent:
To:
Cc:
Subject:
08, 2009 5:02 PM
approved
comment
me based on the questions
w / your boss to pay off the
everything he could to encourage Senator Ensign to end his affair and to persuade Senator Ensign to
repair the damage
had caused to his own marriage and
1 advice, this episode would have ended, and been made public, long ago.
49
r o l e w i t h Ensign's marriage
suggested Sen. Ensign pay some
Can you respond t o
or a l l o f t h e
mortgage?
allegation
labout actual Senate b i z , l i k e t h e

forward t o t a l k i n g with you and
development
was
last
Quarterly
l@cq.com
64
t
From:
Sent:
To:
Subject;
Thursday. July 09, 2009 6:22 PM
It's the Ensign scandal,,,,
This is unfair. Why do you mention "Ensign

the one who decided to suggest that|
\ didn't trigger this scandal and was trying to
had a bigger role in this

...
65
From:
Sent:
To:
Subject:
Not
Monday, October
Re: Ensign
Let me check,
Monday, October
Ensign
2009 2:49 PM
3:13 PM
F r i Oct 02
Subject: Re: ny
open but I hope t h i s d o e s n ' t t r i g g e r more follow-ups from less
ban
i s on t h e l o b b y i s t
That could be a l i n e o f attack i n t h e f u t u r e
Thu Oct 01 21:02:22 2009

Subject: Re: ny times
S t i c k a f o r k i n Ensign.
This should put everyone on notice about using an o f f i c i a l o f f i c e t o
"help f r i e n d s . "

discrepancy?
Thanks
Politico
Sent: Thursday, July 09, 2009 11:31 AM

CAUGHT
BY HOMETOWN PAPER WHEN ASKED in
FELLOWHIP" -- "I know very little about it," Ensign said of
foundation
ABOUT TRIPS
BY "THE
Tx
Original Message -----
FELLOWHIP" - "I know very little about it," Ensign said of the foundation
"I know very little about it," Ensign said of

you about that
either."
foundation. "When I was in the House, I went on a trip to Hong Kong, and couldn't tell
From:
Sent:
To:
Subject:
Wednesday, July
To: undisclosed-recipients
Politico:
Thursday. July
PM
FW:
Ensign to go public with affair
PM
Ensign to go public
not address an allegation in the

dollar mortgage.
I encouraged
102
From:
To:
PM
R E : Appc the new statement on
Subject:
in
keep asking
for stuff. I
here (thanks f o r s e n d i n g ) ,
the
apart, the I .
the
coverage i s not h e l p i n g .
Chrs, and thanks.
From: .
Sent:
To:
Subject:
I'm covering the

laddressed it. Any
possible.
Thursday, July 09, 2009 2:57 PM

Ensign comments from today
'
and it looks like we didn't have anyone there today when

phoner today? We'd really like to get more from
if
|
Thanks
104
From:
Sent:
To:
Subject:
PM
Re: legal question
Ensign's
Ensign
may)
From:
|@foxnews,com]
PM
radav.
To:
Subject:
Re: it's the Ensign
my BlackBerry
2009
Subject: RE: It's the Ensign
Another point
that we had
torn
... you can offer me PR advice, but

l@foxnews.com]
Subject: Re: It's the Ensign scandal

get
from my BlackBerry
119
From:
To:
Subject:
Thursday. July 09, 2009 6:52 PM

Re: anything?
Oh my gosh - that's an AWESOME way to put

can't
SO te.
cahoots" -
is my answer,
many people have asked
or an,
members to throw money at the problem,
a bit odd today talking abt the "patient
the privelege?
All of this sucks for u guys -- no doubt.
man.
Oof.
it
people scratching their heads thinking.. J
From:
Sent:
To:
Subject:
Give me
Call
Jul 14 16:17:22 2009

Subject: RE: Radio Interview?
Wowl don't
to
is one of several that advised
right with
discuss those things
more fuel for the
Heard mornings 6:00 to 9:00AM CT

on
Tulsa, OK
918-743-7814 E x t 124
Jout?
, why they
advised Ensign to end the affair, make
very confusing. You have to
discuss c o ntroversial
Sent:
To:
Subject:
October
6:36
ensign question
| Concerning the Times story on Ensign, there's a part that says

senators
lobbying ban was broken? Does the
to comment on the meeting?
167
From:
Sent:
To:
Subject:
PM
& Ensign Connection
The story below just hit the news Wires. What is the latest development In this story and what is the|
response?
From:
Sent:
To:
Subject;
Hey
intermediary?
October
2009 10:33 AM
ensign
you
Also, can u confirm,
confirm and do you have a statement about the ny times
as lobbied
From:
Sent:
To:
Subject:
009 10:40 AM
story about Ensign
statements in the NY Times story flatly contradict

about restitution payments, I'm wondering how the stories could be so different, If
appreciate it,
Thanks,
in talks
could clarify for me, I'd really
From:
Sent:
To:
Subject:
Friday. October
AM
RE: NY Times story about Ensign
toldmeHwasiVtl^
was involved in negotiations with Ensign aboutrestitution an
a specific
It wasn't all false what
don't remember ever
- to tell me
every opportunity in tha
was involved in negotiations about restitution,
was, ne
what had transpired,
Friday. October 02, 2009 11:01 AM

To:
Subject: RE: NY Times story about Ensign

Sure.
think you're remember this story - see my comments below.
From:
Sent:
To:
Subject:
2009
PM
Re; NY Times story about Ensign
Sent from my BlackBerry Wireless
Sent: Fri Oct 02 12:10:49 2009

Subject: RE; NY Times story about Ensign
From: | _
Friday, October 02, 2009 12:10 PM
Subject: Re: NY Times story about Ensign
be glad to talk
2:38 PM
Subject:
Sorry, don't,
RE: WA Post article - GOP Leader Tightlipped on Ensign
don't even
From:
Sent: Friday. October 02, 2009 2:34 PM
Toil
Subject: Re: WA Post article - GOP Leader Tightlipped on Ensign
Do you have a number for|
for
nytimes.com]
009 2:42 PM
From:
Sent:
To:
Subject:
Thanks much. Do you figure there'll be an ethics investigation? It sounds from what we're
today that they II have
to broaden their inquiry after the initial stuff in June related to the
there concern about that? Oust on
background, if you want, unless you
to address that question on the record)
Sent: Friday, October 02, 2009 2:08 PM

Subject: RE:
haven't heard anything

the AP
which implies a more formai role.
clarify this section below a number of times.
than "offered".
was reacting
Also, if you
role a bit. You reported "intermediary while they

been asked to
a minor point but I would have
"was asked and agreed rather
request.
please try to clarity that the burden on following the one-year ban is
lobbyist/former staffer,
hats off to you for your
October 02, 2009 11:08 AM
very thorough and fair
the
Subject:
Hi, we're following up on the Ensign story today, if you hear of anything of
Thanks
From:
Sent:
To:
Subject:
PM
update
CREW i s going t o expand t h e i r e t h i c s complaint t o

w i t h t h e f i n a n c i a l d i s c u s s i o n s between
and Ensign.
involvement
Group's comments cover claims such as l y i n g and a s s i s t i n g Ensign i n c o v e r i n g up t h e
affair.
S t i l l no reax?
This e m a i l has been scanned by t h e MessageLabs Email S e c u r i t y System.
For more i n f o r m a t i o n please v i s i t
193
From:
Sent:
To:
Subject:
Monday. October 05, 2009 3:49 PM

RE: concerns with story
mediating, CREW will of course still
negotiating
the difference in how it sounds
of
of
arranging a payment
I'll check and lot you know if we can't change,
October 05, 2009 3:41 PM

concerns with story
Here's our concern:
restart their lives in

quiet."
.
You're implying two things that are untrue and
acting
was acting on
a
At the
to serve
short,
claimed
of Ensign as
in
and threatening "go
because neither
an
that
just as easily
which prompted
a number of $2.5 million to
from
acting on behalf
Ensign to go
this go-between
precisely
to^^MM^'^^'m
other.
an intermediary between
me know.
202
x
Good response
Wireless Handheld
20
From:
Sent:
To:
Subject:
4:12 PM
Mv editor feels the distinction between negotiation on behalf of one party and mediation is a matter of
not a fectual issue, especially In light of back and forth described. Also, as mentioned, since the allegation
helped arrange
advocated for Ensign or just acted as an intermediary seems
issue GREWs premise is that
talked money with both
advocated for Ensign
look worse, but is not the key thing. Also, please note the article emphasized
statement that
Ensign to go public from the start.
Our offer would be that w a n t s to talk more
talk
about it for a follow up story.
role and elaborate on that distinction, we would love to
But CongressDaily isn't ready to change the story due to the view that we'd be opening ourselves up to various wording
changes that are less than corrections.
But as mentioned, you can take this up
Thanks,
From:
Sent: Monday, October 05, 2009 3:50 PM
Subject: RE: concerns with story
i hear you. Thanks, let me know.
|@nationaljournal.com]
Subject: RE: concerns with story
Regardless of
negotiating or mediating, CREW will of course still
was arranging a payment
of hush money. But understand the difference in how it sounds.

I'll check and lot you know if we can't

Subject: concerns with story
Here's our concern:
204
From:
Sent:
To:
Subject:
October
5:57 PM
RE; another question in story
complaint, Senate Ethics has already opened a preliminary investigation into Ensign's
can be expanded if new material comes to
on its complaint (which we will monitor) then the investigation can be expanded, hence
likely
tede
complaints generate a
Inquiry, but most get dismissed pretty quickly
and don't reach the stage of the current Ensign investigation,
Station
From:
Sent:
To:
Subject:
I'm doing
why
kind of punted on
|@polltico,com]
October 06, 2009 2:49 PM
today - and
to talk to investigators and what that may mean to the case. asked
willing to talk
pretty explicit earlier about not testifying before Ethics - a n d
but if you want to shed some light on that, please do.
Also - do you have a response on the C R E W complaint

The letter to the Senate ethics committee also asks
at least one
clients, Allegiant A i r , be investigated
violate the lobbying ban. CREW also asked the committee to
categorically denied serving as an intermediary i n
Times
Sen. Ensign, w h o rejected it.
|
to reporters
to secure restitution from Sen.
for a $2 m i l l i o n payment to
And the OK
are
well
want to respond. Their chairman e-mailed me this:
of
course, concerned about any ethical violations
may have committed, and trust that will be thoroughly
been
story
investigated. But of deep concern to me also is the fact that
role in this matter. First " c a t e g o r i c a l l y denied" any involvement; then
a national newspaper
served
as go-between during the
negotiations. For someone who
Washington outsider,
lis sure behaving like a typical Beltway politician.
Filing at 4:45. Thanks.
203
1
Just wanted to see if you had any comment

Thanks
__________
...
From;
Sent:
To:
Subject;
2009 4:21 PM
CREW Ethics complaint re
From:
Subject: Question re pending CREW Ethics complaint re
the Times
Friday, Citizens for Responsibly and Ethics
Washington say they will file a
Monday
rticle show
badly on the Senate.

Questions:
Can you comment on this?
Deadline is 12:30pm Monday.
'
<
From:
Sent:
To:
Subject:
Friday, October 09,
PM
up on
l i s on t h e
attack.
Sent: F r i d a y . October 09, 2009 12:09 PM

To:
.
S u b j e c t : f o l o up on
s t o r y . I have a number of q u e s t i o n s ,
on t hon
e H
working
a iflol l otoday
up onsot h e
t h e best number.
Questions i n c l u d e but not l i m i t e d
Why d i d n ' t
to:
the
to follow
own advice
Ensign, which was t o go p u b l i c w i t h
situation?
Weren't _
in
comments about
Any d e t a i l s on t h e meeting w i t h the
involvement c o r r e c t ? Why d i s p u t e them back
c l i e n t , A l l e g i a n t A i r ? Who attended t h e meeting?
clients?
bv t h e MessageLabs
213
1
214
216
1
From
20
Subject: Nightline comment -
s this.
did confront Senator Ensign
about afinancial
Those
to listen. Senator Ensign

Unfortunately, these facts have been viewed through political
filters. Some reports have implied

Senator Ensign
sugg
was
never
From:
Sent:
To:
Subject:
@abc.com]
, 2009 4:41 PM
Re: Nightline
Thanks
One more
totally blanked on the question
Allegiant Air. know in the NYT

stand at that?
at the March meeting with

said "it was wrong." Did you want to add anything to
let it
From:
abc.com>'
Sent:
Nov 20 15:06:47 2009
Subject: RE: Nightline
...
You can attribute
in this ordeal was to help two friends and families

B did confront Senator Ensign about the
not only urged Senator Ensign to end the affair but to publlcally admit his mistakes.
exaggerated
conversations were initiated
pass on information to Senator Ensign,
Ensign
role
a
Those
ask
be willing to
would only if Senator Ensign was willing to listen. Senator
passed on information on behalf of
Unfortunately, these facts have been viewed through political and personal
Some reports have implied
attempting to extort money from Senator Ensign, while other reports have suggested Senator Ensign was offeringl
hush money. Neither explanation is accurate.
has also been viewed through political and personal
help two friends and families reconcile. In response to questions
your business" in a more artful way.
was never more than to

does regret not saying "it's none of
The reality is two individuals in a difficult and emotionally charged situation tried to reach a settlement and failed.
in
of many poor decisions by both parties
involved
pursue the difficult path of ,
for the sake of their families and marriages,
Thanks,
22?
1
Sent: Fri
20 17:12:20 2009
Subject: RE: Nightline
never met with Ensign about Allegiant
nothing to do
s e t up a meeting for an
the meeting
You can use this:
activities.
asked about it by the New York Times,
pabc.com]
November
4:41 PM
Subject: Re: Nightline

Thanks
more
totally blanked on the question
presence
the March meeting with Ensign
not
To:|
Subject: Ethics
We should expect
be called to testified at the Ensign ethics investigation. Do we need to discuss this
this week or is this outside of our purview?
The nonprofit, 501(c)(3) organization promotes ethics and accountability in government and public life and
ad
complaint against Ensign in
the ethics committee has a h,story of not
wanting to look into such matters,
New
250
PM
From:
Sent:
To:
Subject:
RE:
great
stuff
...
not
Message-
S u b j e c t : RE: Ensign s t u f f
Subject:
Ensign s t u f f
ugh
S u b j e c t : Ensign s t u f f
suggested Ensign should g i v e

Vegas sun says
l o t of
- more than a m i l l i o n
Is
Thanks
263
From:
Sent:
To:
4:31 PM
FW: please approve -comment on Ensign situation
Subject:
High
Importance:
this ASAP - look ok?
From:
2009 4:31 PM
-comment on Ensign situation
Ok
Sent:
08 16:30:24 2009
Subject: please approve -comment on Ensign situation
The calls are coming
on the Las Vegas Sun report
to
off their $1 million-plus mortgage and move them to a new
assistance to
away from Ens.gn.
t h i n k it's vital we respond strongly and carefully (without going Into great detail) to squash the conclusion reporters will
want to make that this was hush money, when
Please approve quote from
the opposite goal.
as |
could to encourage Senator Ensign
end his affair and to persuade Senator Ensign to
this episode would have ended, and been made public, long ago.
264.
S u b j e c t : Re:
t h i n k Ensign should r e s i g n ?
From:
Sent:
To:
Subject:

RE: Ensign
statement is false.
From
8, 2009 6:32 PM
Subject: RE: Ensign
Thanks,
advised Sen, Ensign to
282
From:
Sent:
To:
Subject:
2009 3:32 PM
RE: Statement Request
Sure, you can

everything he could to encourage Senator Ensign
end
affair and to persuade Senator Ensign to
he had caused to his own marriage and
Had Senator Ensign followed
ladvice, this episode would have ended, and been made public, long ago."
2009 3:28 PM
Subject: Statement Request
Can we get a statement about claims that J
knew about Sen. John Ensign's affair and suggested Sen. Ensign
give
Thanks.
Oklahoma City, OK
283
From:

Coburn, Tom
accused you of participating in a cover up
To:
Subject;
High
Importance:
gave the Las Vegas Sun a copy of a letter Ensign wrote in your presence. I'll put a copy in your box
Background:
an interview with Channel 8 news in Las Vegas
c l a i m s that in a February
only urged Ensign to end the relationship but also urged Ensign to essentially pay off of
order to sweep the matter under the rug in an attempt to protect Ensign's political career,
at C
From:
Sent:
To:
Subject:
PM
update on Ensign story
Mentions of
reached out to
intermediaries involved in a Christian
powerful Washingtonfigureslive
and move them to a new life awayfiomEnsign.
5:06
Sent:
To:
Subject:
please call Chris re: the Ensign story

| talked with reporters today and wants to get your denial straight
act In the best of the families.
I to be soft
You were trying to
would characterize your
From:
Sent:
To:
Subject:
5:05 PM
Nightline
Where
From:
a meeting with
Ailegiant Air?
.
November 20, 2009 4:41 PM
To:l
Subject: Re: Nightline
.
Ailegiant
stand at that?
of
presence at the March meeting with
From:
Sent:
To:
Cc:
Subject:
AM
mentions
trying to track the actual video. Was that what
(Ensign)
9 1:52 PM
From:
Sent:
To:
Subject:
eyeing JE senate seat
FW: RJ;
Senator John Ensign (NV)

Sign Up f o r E n s i g n ' s Weekly Update
Original
From:
Fw: RJ;
(Ensign)
2009 9:49 AM
(Ensign)
|(Ensign)
S e n t : Mon J u l 13 0 9 : 4 5 : 4 7 2009
S u b j e c t : RJ;
POLITICAL
eyes Ensign's Senate seat S i x - t e r m

w i t h encouragement
Democratic lawmaker
(Ensign)
2009 1:55 PM
From:
Sent:
To:
Subject:
Something
is going on with Ensign.
harsh
John Ensign (NV)

Sign Up f o r Ensign's Weekly Update
Original
From:
(Ensign)
July
PM
(Ensign)
Subject:
RJ;
Something funny i s going on w i t h Ensign.
523
1
(Ensign)
Wednesday. April 30, 2008 5:03 PM
l(Ensign);
From:
Sent:
To:
(Ensign)
RE: Happy
Subject:
fori
|
(Ensign)
From:
Sent: Tuesday, April 29, 2008 6:45 PM
(Ensign); |
ensign.senate.gov); |
|
ensign
l@ensign.senate.gov)
|
Ensign)
@ensign.senate,gov); |
Subject: Happy Hour

Good evening, all!
On Wednesday evening at 5:30pm, we will gather at the Dubliner for drinks, good cheer and to bid farewell to our dear
Please join us.
U.S. Senator John Ensign

119 Russell Senate Building
Washington,
20510
525
1
(Ensign)
8, 2009
From:
Sent:
To:
Subject:
it.
AM.
the
S t i l l not g o i n g .
To:
S e n t : Thu Jun 18 08:44:28 2009
S u b j e c t : Re:
name i s
lawyer?
yesterday.
From:
To:
Sent:
S u b j e c t : Re: I s
Ensign)
E x a c t l y what i was t h i n k i n g
O r i g i n a l Message
(Ensign)
To:
S e n t : Thu Jun 18
Good excuse n o t t o go t o t h e wedding

Sent u s i n g
From:
To;
S e n t : Thu Jun
(Ensign)
(Ensign)
affair/.
To:
S e n t : Thu Jun 18
P r o b a b l y . Wow
53'
Sent using B l a c k B e r r y
To:
Sent: Thu
Subject;
i
(Ensign);
2009 9:47 AM
To:
Subject:
RE: Vegas Sun story
I'll keep you looped in. No worries.
Sent: Friday, June 19, 2009 9:46 AM

Subject: RE: Vegas Sun story
does end
Sending them over is fine. We are mining information to see who has what
something to say, give us a heads up. I'm sure you would anyway.
SIGN UP FOR
with
also, if |
WEEKLY UPDATE
From:l
Sent: Friday, June
9:40 AM
(Ensign)
Subject: FW: Vegas Sun story
sure
will not have a comment today, but figured would give you a heads up. If you don't want me
sending them on just let me know.
From
Sent: Friday, June 19, 2009 9:23 AM
Subject: Vegas
story
H i ,
The
Sun published a letter
reference to your boss...
seeking a comment per se, but wanted to give u the opportunity to confirm, deny or
ignore...
"The unethical behavior and immoral choice of Senator Ensign has been confronted by me and others on a number of
occasions
this past year. In
one of the
in Washington
DC (sic) with a group of his peers. One of the attendee's (sic)
well as several
other men who are close to the Senator. Senator Ensign's conduct and relentless pursuit
to our dismissal
would like to say he stopped his heinous conduct and pursuit upon our leaving, but that was not the
in April of
case and his actions did not subside until August of 2008."
POLITICO
545
From:
Sent:
To:
Subject:
| (Ensign)
FW: Sun; Spouse in Ensign affair says senator should resign
Here is link and a follow up story.
IS) SIGN UP
WEEKLY
UPDATE
(Ensign)
Sent: Wednesday, July 08, 2009 2:09 PM
Elmer (Ensign)
Subject: Sun; Spouse in Ensign affair says senator should resign
(Ensign);
(Ensign)
2009
From:
Sent:
To:
Subject:
"betrayed everything
PM
letter to lover invokes God, says he

believed
he
U.S. Senator John Ensign
www.ensign.senate.gov
0 SIGN UP FOR ENSIGN'S WEEKLY UPDATE
Original
HHHB@vegas.com
Sent;
July
To:
2009 2:34 PM
says
he "betrayed everything I believed i n "

The l e t t e r , which
[ t a l k s about tonight on "Face to F a c e , " i s posted here:
tter.jpg
a l s o a s s e r t e d that Ensign sent the l e t t e r but then immediately
began
From:
To:
Subject:

|
Subject:
Ensignto
Please
Thanks,
2009 4:13 PM
FW;
4:12 PM
over at Politico and am trying to get a comment

re thesenew allegations
a central role, including, according
to^^"ging
them a new life away from Ensign."
From:
To:
Subject:
2009 5:06 PM
FW: Husband of Ensign's Mistress
lothers Urged Payment
56
From:
Sent:
To:
Subject:
July 08, 2009 5:53 PM

I reacting to "Face to Face" says Ensign should have
ended affair
From:
To: Tatro, Don (Coburn)
Subject: RE:
to "Face to Face" says Ensign should have ended affair
From: |
Subject:
reacting to "Face to Face" says Ensign should have ended affair
sday, July 08, 2009 2:35 PM

Subject:
reacting to "Face to Face" says Ensign should have ended affair
570
See the program here:
0
1
(Ensign)
From:
Sent:
To:
Subject:
PM
e: Do you have a story where your boss says|
lied?
Good times!
Senator Ensign (R-NV)

Russell Senate Building
(Ensign)
Sent: Wed Jul 08 22:43:50 2009
Subject: Re: Do you have a story where your boss says |
lied?
Well there you have it. Good

Sent: Wed Jul 08 22:42:30 2009

Subject: Re: Do you have a story where your boss
"categorically denies"
You're
lied?
I claims about money.
Senator Ensign (R-NV)

To:
Sent: Wed Jul 08 22:35:55 2009
Subject: Re: Do you have a story where your boss says
Possible, but don't
lied?
Check politico articles on it. It would be |
reporter think
(Ensign)
Sent: Wed Jul 08 22:33:47 2009
Subject: Re: Do you have a story where your boss says
I'm wondering if JE meant that
| lied?
a reporter
585
From:|
Sent: Wed Jul 08 22:32:04 2009
Subject; Re: Do
have a story where your boss says|
lied?
It is added to the politico story guess

Sent using
Sent: Wed Jul 08 22:31:34 2009

Subject: RE: Do you have a story where your boss saysl
Okay, there isn't a story on the wires yet.
From:
10:29 PM
lied?
Subject: Re: Do you have a story where your boss

Uh, not that I'm aware of. I'll check.
Sent: Wed Jul 08 22:28:37 2009

Subject: RE: Do you have a story where your boss s a y s
JE just told us that
put out a statement
From:
Re:
vou
where vour buss
don't think so. Just the crap that came out today.
Ensign)
From:
To:
Sent: Wed Jul 08 22:27:08 2009
Subject: Do you have a story where your boss says
2
Senator John Ensign (R-NV)

Rnssell Senate Building
Sign Up for
Weekly Update
825
1
Worst
"I fully plan on working, staying in office.
If only he would leave it would all go away.
From:
Sent:
Tuesday. October
RE:
Subject:
They do.
2009 2:32 PM
tell Ethics about Ensign
that,
From:
2:31 PM
I'll tell Ethics about Ensign

Hmm- they have a point... Seems like |
Oct 06
is contradicting
(Ensign)
2009
tell Ethics about Ensign
l@kvbc.com]
From:
Sent:
To:
Subject:
07, 2009 6:35 PM

REQUEST WITH|
| regarding John Ensign.
was just checking on our request to speak with |

Is there a time
can do a
with us?
KVBC CH. 3 NBC LAS VEGAS

Lane
Las
NV89101
Newsroom
Direct Line:
uuww.kvbc.com
841
i
From:
Sent:
To:
Subject:
PM
RE: Dont know if you all have seen this,,
Wow, That won't be fun.
From:
Sent: Tuesday, November
2009 4:10 PM
Subject: FW: Dont know if you all have seen

Fabulous

Up for
Weekly Update
(Ensign)
Sent: Tuesday, November 03, 2009 4:00 PM
(Ensign)
Subject: FW: Dont know if you all have seen
Tuesday, November 03, 2009 3:58 PM

(Ensign);
(Ensign)
Subject: Dont know if you all have seen
...
United States Senator John Ensign

119 Russell
Washington,
Building
DC 20510
845
848
i
From:
Sent:
To:
Subject
(Ensign)
2009 1:26 PM
FW: RJ

Up for Ensign's Weekly Update
ABC News posts more previews of |
interview
From:
Sent:
To:
Subject:
December 04. 2009 2:02 PM

FW: Politico; Ethics Commitee issues subpoenas on Ensign
Senator John Ensign (N\

Up for
Weekly Update
Sent: Friday, December 04, 2009 1:44 PM

To:
Subject: Fw: Politico; Ethics Commitee Issues subpoenas on Ensign
From:
Sent:
To:
Subject:
Let's
25,
PM
ABC - National Programming - Who Wants to Be a Millionaire
out
this place.
2010 4:18 PM
Ensign] ABC - National Programming - Who Wants to Be a Millionaire
Special.
Senator John
Up for
Weekly Update
Sent; Monday, January
(Ensign)
ABC - National Programming - Who Wants to Be
So our boss was a question on
Wants to be a
the question was
the other
I in a high-profile affair with which politician".
Monday, January 25, 2010 12:38 PM

Ensign] ABC - National Programming - Who Wants to Be a Millionaire
Sent: Monday, January
12:37:51 P M
Programming - Who Wants to Be a Millionaire
Auto forwarded by a Rule
863
From:
Sent:
To:
Subject:
09. 2009 6:36 PM

C l a i m s Constitutional Shield on Advice to Ensign
Ahhhh gEeeeeeeeee
From:
Thu
2009
Constitutional Shield on Advice to Ensign
It's the topic on local talk radio in
now!
Sent: Thu Jul 09 15:07:49 2009

Subject;
Claims Constitutional Shield on
Ensign
everywhere!
From:
Subject:
Claims Constitutional Shield on Advice to Ensign
That privileged communications statement

in the middle of
now. The
as
to keep private conversations private, but don't think they will buy
a challenge.
D.d
Ensign seek medical treatment for his affair?

feel
Subject: Re:
been forced into the middle of a |
Claims Constitutional Shield on Advice to Ensign
Watch for this: The likely angle will be that
so high-and-mighty about transparency and sunshine, yet
hiding behind the shield of confidentiality.

That will
from my
eyebrows to be raised.
Wireless Handheld
941
Sent: Thu Jul 09 14:32:38 2009

Subject: Re:
haven't heard anything -
But we should expect this
grow legs,
One of our field reps did get a call from someone about it,
(Coburn);|
Sent:
Jul 09 14:29:59 2009
Subject:
haven't heard a lot. It really hasn't been covered much here yet, but this constitutional shield/payoffdiscussion
I article Is coming. This is too good for the
pass
make it a more attractive story. have to think a|
cover story.
All this other stuff makes for good gossip columns, but the C Street angle worries me sometimes,
From:
Constitutional
This one
a slighter better article:
Are normal people talking about
at all in OK?
an Advice to Ensign
as a
From:
Sent:
To:
Subject;
it exaggerate:
good.
02.
10:52 AM
RE: Ensign's ex-mistress, husband sought $8,5 million
role
and based upon
nothing illegal as far as
can see, but
doesn't look
AM
Subject: Ensign's ex-mistress, husband sought $8,5 million
Do you think there Is any shred of truth in this story re; |
afloat?
|Are they just using
keep the story/lawsuit
What do you guys think?

I'm over cleaning up other people's vomit,
20091005
From:
Sent:
To:
Subject;
So what should
09 5:30 PM
in the news
add to our Ensign
addresses this new issue? Our previous language
below
constituents email (we have gotten many
Constituent email:
regard to a news article Jgst read, (noted at bottom of page) was truly distressed to learn of your involvement in
of representing Senator Ensign In this very ugly affair. Is this protection of the
of your so
T e d family values theme? just hope this
business' was conducted off of 'company
and not part of your
official duties, am very disappointed.
Thank you for taking the time to contact me regarding my relationship

Senator
Ensign, and
my
the proceedings surrounding his extramarital affair. I appreciate the opportunity to hear
from you, and apologize for my delayed response.
I understand your concerns, and the concerns of all of my constituents. I was heartbroken
Mends and colleagues, Senator John Ensign, had engaged in an extramarital
individual, elected official or lay person breaks a sacred trust between
a spouse or significant other by engaging in and lying about an extramarital affair.
one of my
102
From:
To:
Subject:
Well we haven't gotten any Ensign letters in a while, but just got like 20 since it was brought up in the news again.
|comments-l would say in between 60 and 80-but
really haven't been keeping track.
DRAFT
(PLANNING DRAFT)
E n s i g n (V.7)
Afghanistan
F e b r u a r y 2008
Kuwait,
7-12
CODEL PARTICIPANTS: (12

Sen, John E n s i g n (R-NV)
Sen,
A l l times
PURPOSE; To
with m i l i t a r y , d i p l o m a t i c , p o l i t i c a l and aooncanio l e a d e r s h i p i n
c o i n c i d e n t w i t h Senate o v e r s i g h t
Thursday,
February 2008 (Washington
to Kuwait)
Casual
Recommended
Anticipated
Depart C a p i t o l H i l l i n government v a n en r o u t e to D u l l e s I n t e r n a t i o n a l A i r p o r t
6 :45pm
PM
A r r i v e U n i t e d A i r l i n e s Check-in
PM '
Depart Washington DC en route t o Kuwait C i t y ,
8 February 2008 (Washington

Anticipated
continued)
TBD
meet i n c o n t r o l room
Evening Meal
RON
Saturday,
to Kuwait,
Kuwait,
COMAIR / UNITED AIRLINES 982D
F l i g h t Time: 1 2 r s ,
Time Change: +5
Kuwait C i t y I n t e r n a t i o n a l A i r p o r t . Meet C o n t r o l O f f i c e r :
A r r i v e Lodging,
8:00pm
Counter
A t t i r e ; Casual
WX:
Arrive
Recommended
A f g h a n i s t a n and
Kuwait
SAS H o t e l
P.O. BOX 26199,
13122
Kuwait
T e l : +965-5756000, Fax: +965-5750155/66
City
February 2008 (Kuwait to I r a q )

A t t i r e : Casual
(Field)
Wake up C a l l , Baggage C a l l
6:00am
Depart H o t e l
Arrive
7:30am .
Load
Depart f o r Baghdad
MILAIR
F l i g h t Time:
3 0min
Time Change: None
Arrive Al
TBD
Salem A i r Base.
Airbase
T r a n s i t i o n t o R o t a r y wing
Depart A i r b a s e en r o u t e t o Ar Ramadi / Camp
1098
From:
Sent:
To:
Subject:
Attachments:
CODELENSIGN (FEB OB)

CODEL ENSIGN (FEB 08) version 7.doc
Updated itinerary - don't think much has changed.
From:
Sent:
To:
Subject:
Attachments:
February 05, 2008 11:28 AM

Traveler Information, version 1
Dear Traveler Letter CODEL Ensign.doc; Info & Preference sheet
find
earlier.
.
Please return the preference sheet as soon as possible. Regarding aircraft seating, all members have been given The Dear
Traveler" provides amplifying information about the places that we will
Of note, there a paragraph dedicated
weather in each of our destinations, in case your Senator has a question on what to expect for packing purposes. Please let
me know if there are any questions or concerns.
My contact number throughout the trip
Many Thanks!
Marine Senate Liaison Office

182 Russell Building, Washin.
20510
(0(202
E-Mail:
-Original
From
Sent: Friday. February
Subject: Traveler Information, version 1

Attached vou willfindtwo documents to assist you in your
for next week. Thefirstis a Dear Traveler Letter,
details on clothing, weather, commercial airline travel, and packing considerations. The second
information and preference sheet
will
to complete and return to the Senate
by
Tuesday,
5 January. Please give me a call if there are any questions.
I
to
with our control officers again on Sunday (the first day of the work
them) tofirmup the schedule
our requested
If there are specific requests that you would
me to relay to our
Gentlemen,
We are writing this on
difficult spot
divorce
heard details from the news,
us to communicate
on Tuesday, depending how things go
prayer
filed for
there not
We are all grieved and are asking for God's grace to get through this as a group
ml
1179
From:
Sent:
To:
Subject:
Wanted to forward it on to you guys. We talked about this before.
Sent:
25
Subject: Stake
2009
Jusr arrived at c street a reporter and photographer were there and wanted to tallk to me. I siad no as I had to run to committre. Tell
everyone to say "no comment" I do not have the email for everyone
On Wed, Jul
at 6:19
wrote:
we
Outline raises more questions then it
realize
will supplement but it will raise more questions!
need to know about the
Foundation, last night you said no connection but certainly the people
consulted with and even Ensign have connections to the International Foundation and the discussions took place at C
street. If you are going to lift the veil of secrecy, the International connection and members are the most intriguing issues
amongst the
From:
Sent:
Friday. July
5mail.house.gov]
9:18 AM
To:
Subject:
Re: Fwd:
says we should all pray, hunker down and stay put til Labor Day, then see what it looks like,!
anyone leaves the house, it should be Ensign.
said if
Subject:
Re: Fwd:
From my perspective, everything from student leadership to the NPB itself is now In jeopardy if the team does notgo on
the offensive setting the record straight on
the Fellowship is and is not, This
now
and can tell you all for certain that have a great dilemna because every newspaper interview or talk radio interview do
includes questions about this mess, will not be able to avoid this and cannot continue to
need
to
off the couch besides those of us in elected office or we will all be tarred by
and then ask the question if this is the kind of person Tenn needs as its next
to hire a "crisis communications" firm and get in front of this storm before it kills us
all.
Sent from my
Wireless Handheld
Re: conference call tonight
Subject:
My team just recommended that stay totally quite and not respond to anything so if this is about me, just postpone the
call and ride it out for a day or two but am sure this is not going
Sent from my
Wireless Handheld
Sent:
Jul 20
2009
Subject: Re: conference call tonight
on from 9are in a mark up but if we have a chance am sure we would jum|on the
in
town
and
is
with
me.
have a
pm, you may wish to wait until
been brutal,
through
Wednesday
on
this
fund raiser tomorrow night but would be there by 8 pm, Still, expect to be in a
Health Care mark up!
using BlackBerry
Sent: Mon Jul 20 13:15:35 2009

Subject: conference call tonight
Guys,
has suggested we get together on a conference call tonight. I've set up a dial in
number
behalf. We will try and get started tonight at 9:15p. Would be good if
In.
The dial in number is:

The access code is:
Talk to you tonight.
From:
20.
Sent:
To:
Cc:
Subject:
Re: C Street
Not me. But then again, unless

state over and over again.
call
happen to be on the campaign bus between stop, no time is good for me.
over the
Subject; C Street conf call
We spoke
andBhas few ideas and thoughts of the comings and goings of C Street.
In light of all the heat that's surrounding our unity we feel it is
to be on the same page as
we move
We think it would be helpful for all of of us to
so we are proposing a
conference
as soon as possible. Does
the 24th at
EST work for everyone?
From:
Sent:
ggmail.com)
PM
October
Subject:
don't forget to send something in for

THEM B E C A U S E IT'S A
life sure is rough in
flBand
can send
anniversary
you write
TO
sunny and very warm.
On Wed, Oct 28, 2009 at 3:24 PM,
i).gmail.com> wrote;
you please try and send a note/story in

putting
it asap. I know it would mean alot to them
Street Them serving there was a huge part of their life and I
email me the letter and I can get it
Or you can send
they received stuff from you guys at C

alot to them. You can
Thanks.
120:
Original
Message
From:
To: I
Johnson, Elmer
Sent: Mon May 17 11:41:57

S u b j e c t : Re:
I'll
l e t you know.
My schedule
i s unclear.
O r i g i n a l Message
From:
To:
Sent: Mon May 17 11:39:01
Subject:
having a dinner f o r interns tonight at my
ree amigos would l i k e to come?
Johnson, Elmer (Ensign)
this is
l a s t week, any chance any of
1206
To:
Subject:
Ensign question
i s doing a story tonight at 10

l e t t e r and
suggestion that
News 9 i n
w e r e present at a C S t r e e t meeting. Some people (mostly Democrats) are asking
knew and what
to Ensign. Do
want to comment? I f s o , simply saying
encouraged Ensign to end h i s a f f a i r could be an option.
From:
T.46 PM
Sent:
To:
Subject:
RE: Ensign clarification
ok
Sent! Monday, June 22, 2009 1:46 PM
Subject: Re: Ensign clarification

Yes but do not be that specific
From:
To:|
Sent: Mon Jun 22 13:44:51 2009
Subject: Ensign clarification
rsaid
asked Ensign to "admit it" did
mean he should admit it to his wife only or also the public?
From:
Sent:
To:
Subject:
AM
Re: Ensign comment
Ok
Sent: Tue Jun 23 11:52:43 2009

Subject: RE: Ensign comment
think so.
talked to their staff
asked me to run this
first.
From:
Sent: Tuesday, June
2009 11:52 AM
Subject: Re; Ensign comment

Will they do it
Sent:
23 11:12:21
Subject: Ensign comment
How's this as a quote for Ensign:
-If s unfair that some are asking
ong ago. c h a l l e n g e d me
would have followed all
togethe;
and
together
name." - John Ensign
in this ordeal. The fact

me
end my affair and to restore trust
my
a major reason why, in
of my mistakes,
It would be wrongfor my actions to reflect
poor
on
From:
Sent:
To:
Subject:
10:01 AM
please call World Magazine re: C Street
World magazine at
writing a story about C Street and
rage you
to the no comment policy. think at some
to speak out (in a careful way without betraying confidences)because Christ Is on trial.
seeing a lot of ugliness right now. If you don't
toS
situations. I'd
body and the
Suggested points:
1)
Explain why C Street appears secretive. The Fellowship is trying to apply a first century, Christ-centered model
that is pre denominational and pre-lnstitutional. This doesn't mean the local church isn't important,
because it is. The point is that In Washington everyone organizes every relationship around an
affiliation, which is a real hindrance. We put people in boxes. The goal is to be an ambassador for Christ, not an
ambassador for a para-church organization
Christ.
a subt e but important
Washington.
politicians in Washington are terribly lonely and struggle with all sorts
We all struggle and need a place to bring things into the light. The world
hear about the scandals
that impact the house, but you'll never hear about the scandals that were prevented by the house.
The real storv though isn't about C Street, but about human frailty and our need for grace, redemption
we see a high profile failure we shouldn't be discouraged but return to the
basks We need to love one another enough to ask the hard questions and then have the love and
to bear one another's burdens
From:
37 PM
Sent:
To:
Subject:
AP re: ensigns future
AP i s doing a story on E n s i g n ' s future i n the GOP. They want

s u r v i v e , should he r e s i g n , e t c . ? I f
want to weigh in
he'll
From:
Sent:
To:
Subject:
23, 2009
PM
NY Times reporter can come by at 3 pm re: Ensign
Can we schedule?
Key Points:
The two most damaging conclusions this story could make are either
and/or
denials of advocating payment were false
conspired with Ensign to pay hush money,

did discuss that with the
Neither
are true.
was to help bring reconciliation and preserve two marriages.

advocating any sort of
were passing on information because
both
were trying to treat]
unfairly, why would
reach out to you for help?
to be a mediator,
.
however, was inaccurate when

expressing what
you as an advocate for large cash
trusted by
asked|
was
wanted to believe.
Also, be careful about not repeating the claim that

were protected as
ok say |
were expressing frustration about the media's biased coverage
made those comments The media
willingness to write single source stories has been
Moreover, some reporters suspended their own standards
on single sources
of events) because Ensign is both a Republican and a "Christum
hypocritical
was never subjected to
the same level of scrutiny
nor
aboutl
back in
was never present when a letter was written, never made any assessment of paying anybody anything. Those are
untruths, Those are absolute
is in error,
manipulating the situation and you are all buying
s all false, as far as
The NY Times reporter wants to talk

still upset (understandably) about their coverage during
the campaign.
press person said McCain would talk
during lunch,
voice would help the story be about the
doing on earmarks, spending, etc. I'm
mention
Ensign but it should be only in passing. The more
on actual news
work the better ...
Sent:
To:
Subject:
2:52 PM
Ensign and NY Times
should be
questions on the core issues (health care, spending, etc.)
anything else about Ensign, here are some points to remember.
Continue to have a non-combative and calm spirit,
you
honorably and have nothing to hide.
How is the Ensign situation affecting
It's a very sad situation for both families

not worried it, The only people focused on this now are those
trying to score political points. The ethics committee hasn't
they
happy to talk with
them.
Do you regret claiming privilege as a
chose my words poorly. Yet, poor word choice and irritating reporters isn't a basis for an ethics
complaint,
Also, avoid rehashing anything involving the discussion about money

Ensign, particularly If it
involves specific amounts, Mentioning specific amounts will give the attack dogs fodder for their claim that
negotiating rather than acting as a go-between.
Sent:
To:
Subject:
PM
Re: Ensign question
him and ask
to end i t .
othj a
But we have no comment as

There fore no comment
was workin\ within b
Original Message
From:
To:
S e n t : Sun Jun 21 20:17:50 2009
S u b j e c t : Ensign question
News 9 i n OKC i s doing a story tonight at 10
and
suggestion t h a t
you were present at a C S t r e e t meeting.
Some people (mostly Democrats) are asking what
knew and what
s a i d to Ensign.
want to comment? I f s o , simply saying
encouraged Ensign to end h i s a f f a i r could be an option.
176
AFTERNOON SESSION
1
2
(2:20 p.m.)
Whereupon,
3
4
resumed the stand and, having been previously duly
sworn, was examined and testified further as
follows:
: Back on the record.
7
BY
8
9
10
11
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15
Yes.
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-- from Senator Ensign.
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.1.11-SSCE0004394
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Okay.
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A
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Okay.
12
But I'm not 100 percent sure.
13
That's okay.
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Okay.
Yes.
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SSCE0004395
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A No. No.
Okay.
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Yes.
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And tell us about that.
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Yes.
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-SSCE0004396
Okay.
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A
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8
Okay.
Who is just -- I don't recall.
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IMMISSCE0004397
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Okay.
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Okay.
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SSCE0004398
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1
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A
Sure, at times I did.
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Okay.
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Okay.
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-SSCE0004399
Yes.
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Okay.
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Okay.
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Yes.
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Yes.
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-SSCE0004400
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2
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Yes.
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I do not recall.
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Okay.
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11.111-SSCE0004401
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Okay.
1
2
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5
No, I don't recall.
Do you remember there being any
discussion --
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No.
Okay.
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A
No.
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No.
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Okay.
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.1.1-SSCE0004402
185
1
2
3
Okay. So tell us about that.
4
5
6
A
8
9
lo
11
A
12
(Exhibit 11[7 identified.)
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BY
14
I'm going to show you what's been marked
15
16
as
- 7 for identification.
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18
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22
Uh -huh, yes.
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Okay.
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25
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-SSCE0004403
186
1
2
A Uh-huh.
You have to say yes.
Yes.
Okay.
Okay.
8
Okay.
9
10
11
Yes.
12
Oh, no, no, this is a long time ago.
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14
A
Okay.
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16
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Okay.
Okay.
Correct.
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IIIII-SSCE0004404
187
2
3
Okay.
4
A
5
6
7
8
Yes.
Okay.
Yes.
Correct.
Yes.
10
11
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-SSCE0004405
188
Right.
Oh, sure.
Okay.
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2
5
6
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10
Right.
11
All right.
12
So --
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14
All right.
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Yes.
20
Okay.
Not that I remember.
21
22
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MI-SSCE0004406
Oh, absolutely.
Okay. And - -
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4
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-SSCE0004407
190
1
2
3
4
5
6
7
Okay.
No.
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9
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11
12
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14
A 1111111111111111111.111.11111111111111
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16
17
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19
Did there come a time when the -- well,
just try to tell me as best you can your own

narrative.
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IIIIIIISSCE0004408
191
1
2
3
4
5
We'll get to that.
Okay.
7
8
9
Yeah.
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11
12
13
Right.
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15
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Okay.
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1.1.-SSCE0004409
192
Just everything.
Okay.
2
3
4
5
6
7
8
9
10
11
Okay.
12
Yes.
13
Okay.
14
I can't tell you. I know
15
Don't remember?
16
17
I could
not -- I can't remember.
18
Okay.
19
I'm being dead honest.
20
No, I believe you. I believe you,
21
absolutely.
22
23
24
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alli-SSCE000441 0
193
A
2
A
Yes.
Yes, that sounds familiar too.
That probably sums it up.
10
I believe so.
11
Okay.
3
4
5
6
7
8
9
12
13
14
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18

BY
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1111111-SSCE0004411
194
(Witness reviewed the document.)
1
2
3
A Uh-huh.
Yes, you do?.
Yes, I see them. Sorry.
Uh-huh, yes.
11
John Ensign.
12
Okay.
14
Correct.
15
16
17
18
6
7
8
9
10
13
And if you keep flipping through -Okay.
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20
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Okay.
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11111111-SSCE000441 2
1
Okay.
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3
4
5
6
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8
9
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A
All right.
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15
16
Yes.
Yes.
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1.11111-SSCE000441 3
196
1
2
4
All right.
5
6
Yeah.
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SSCE0004414
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5
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8
9
10
Yes.
14
No.
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BY
16
17
I'm going to show you what we're marking
18
19
20
Yes, I remember this.
Okay. And in 111-9,
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-SSCE000441 5
198
1
2
Do you see that?
3
4
Yes.
All right. Now, if you -- you remember
that, as you say?
6
7
Yes.
Okay.
ahead.
10
A Okay.
11
I think we've jumped a little bit
12
13
14
15
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17
A
Right.
22
Yes, yes.
23
Okay.
Yes.
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11.11-SSCE0004416
199
1
2
3
Right.
Yes.
4
5
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Okay.
Yes.
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Ellii-SSCE0004417
200
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No.
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14
All right.
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Okay.
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11.1-SSCE000441 8
201
Both.
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3
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Okay.
7
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11
Yes.
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Okay.
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And - -
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INNI-SSCE000441 9
1
2
3
4
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6
Okay. What was it?
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IIIIIISSCE0004420
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1
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Okay.
15
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I do not remember.
21
Okay. But do you believe --
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-SSCE0004421
204
1
2
3
(Exhibit 11-10 identified.)
BY
Okay. Let me show you what's been marked

Q
as 11[10 for identification and ask you -- you can
6
7
8
9
just move all that paper to a pile and get it out of

your way.
10
11
12
13
Okay. Sorry I didn't keep it in order.

No, no, that's all right. This is 1111-10
for identification.
Okay.
14
15
16
17
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21
I believe so.
All right.
22
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111111111SSCE0004422
205
1
A Okay.
2
3
Yes, yes.
6
7
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Yes.
Yes.
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Okay.
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1.111-SSCE0004423
206
1
2
3
4
Q
All right.
Right.
13
Right.
14
6
7
8
9
10
11
12
But --
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16
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Yes.
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-SSCE0004424
207
1
Okay.
2
3
4
Okay. Okay. And --
5
6
7
8
Yeah.
Okay.
10
11
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13
14
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Okay.
21
22
23
Yes.
24
25
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-SSCE0004425
1
2
3
Oh, I see.
4
5
6
7
8
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12
13
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All right.
22
23
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SSCE0004426
1
2
Uh-huh.
A little bit.
3
4
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8
9
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12
13
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-SSCE0004427
210
4
5
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8
Right.
9
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11
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Q
I see.
22
Whatever it was, right.
23
Okay. All right.
I know nothing about any of that.
20
21
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-SSCE0004428
Okay.
1
2
Oh, Ida.
3
4
5
6
7
8
9
Okay.
All right.
10
11
12
13
14
Right.
Okay.
15
16
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-SSCE0004429
212
1
A
2
3
4
5
8
9
10
11
Okay. All right.
12
13
14
15
(Exhibit111[11 identified.)
16
BY
17
18
Let me show you what's marked as II-11.
19
20
21
22
Yes.
23
24
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11.111-SSCE0004430
213
Okay.
2
3
4
5
6
7
Okay.
Did you discuss this with anyone?
9
10
11
12
13
14
15
16
17
Correct.
18
19
20
21
22
23
Okay.
Okay.
24
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11111.111SSCE0004431
214
1
2
3
I want to say.
A
5
6
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8
did?
9
10
Okay.
11
12
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20
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24
Okay.
25
26
INIIIIISSCE0004432
215
No.
Okay.
And let me ask you -- can you --
3
4
5
BY
6
7
8
No.
okay.
10
11
12
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15
16
Okay.
17
18
19
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11111-SSCE0004433
216
1
2
3
Uh-huh.
4
5
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8
9
10
11
12
13
14
15
Right.
16
17
18
What does that mean to you?
19
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23
I don't know.
24
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-SSCE0004434
217
1
2
3
Okay. Thank you very much. You can put
4
5
that exhibit aside now.
A Okay.
So we -- what happened after that, then?
Uh-huh, uh-huh.
8
9
10
11
12
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15
A Uh-huh.
16
17
A
I do remember this.
23
Okay.
24
18
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SSCE0004435
1
2
3
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Right.
: Last page of number 8.
18
BY
19
20
Do you have it there?
21
Do I have it?
22
I1[8. Off the record.
23
(Discussion off the record.)
24
THE WITNESS:
25
26
1111.11.SSCE0004436
219
BY
Right.
4
5
6
7
8
Right, right.
10
Right.
11
12
13
14
Okay. All right.
15
Okay.
16
And --
17
18
All right.
19
20
21
A Okay. Yes.
22
23
Yes.
24
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....-SSCE0004437
220
3
4
5
6
7
8
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11
A Uh-huh.
12
13
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17
Correct.
18
Okay.
19
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IIIII-SSCE0004438
221
1
Do you see that?
2
3
A Uh-huh.
And then it goes on.
5
6
7
Okay.
Yes.
9
10
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SSCE0004439
222
Oh, one of the -
4
5
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8
Yes.
9
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11
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16
No.
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NIIIISSCE0004440
223
1
2
3
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5
Yes.
Okay.
7
8
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Yes.
13
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16
I know.
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IIMM-SSCE0004441
224
1
2
3
4
5
6
7
A Uh-huh.
I'm sorry, yes?
Yes.
10
Okay.
11
12
13
Okay.
14
Basically.
19
so you're saying --
20
15
16
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18
21
22
23
I'm not --
24
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-SSCE0004442
225
Uh-huh.
All right.
Uh-huh.
And yet -- you have to say yes.
10
Yes.
11
4
5
6
7
12
13
Yes.
14
15
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18
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20
As well?
21
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Yes.
226
2
3
Okay.
4
5
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9
Yes.
No.
10
11
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17
18
Yes.
19
20
Oh, it's right here.
Yes, I see. Okay.
21
22
23
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-SSCE0004444
227
Let me stop you there.
4
5
6
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SSCE0004445
228
: It's 3.
1
BY
III-3, what you're looking at, the --
3
4
Oh, this one?
Yes, yes.
5
6
7
8
9
10
11
12
13
14
15
16
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18
19
Is that correct?
20
That's 'correct.
21
22
23
24
25
Okay.
26
-SSCE0004446
229
Yes.
Yes.
Yes.
11
Right.
12
As far as you know?
13
1
2
3
4
6
7
8
9
10
14
15
16
17
18
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20
21
22
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24
I have no idea.
25
All right.
26
SSCE0004447
2
3
4
5
Go ahead, please.
6
7
Make sure I correct myself on the record.
8
9
10
11
All right.
No.
Yes, yes.
No, I did not.
Okay.
12
13
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11.111.SSCE0004448
231
1
2
Yes.
Okay.
5
6
7
8
9
10
Okay.
11
12
13
14
15
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17
18
19
20
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22
23
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111=11-SSCE0004449
232
Just overall.
I have nothing to do with that.
All right. That's fair.
2
3
4
5
6
7
8
9
10
11
12
13
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16
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20
No.
21
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24
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IIIIII-SSCE0004450
233
1
2
3
4
Okay.
5
6
7
8
9
Okay. Just a few more questions and we're
10
almost done.
11
12
Okay.
13
14
15
16
A Specifically?
17
18
19
Right.
20
21
22
23
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26
-SSCE0004451
234
1
2
3
4
5
6
7
8
9
10
11
12
13
14
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18
Okay.
19
20
21
22
23
24
Correct.
25
26
111.111-SSCE0004452
235
Correct.
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Okay.
21
22
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-SSCE0004453
236
Okay.
Yes.
Yes.
3
4
5
6
7
8
9
10
11
12
13
14
A
Correct.
22
No.
23
Okay.
15
16
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21
24
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-SSCE0004454
237
1
2
3
4
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21
that again.
22
Let me walk you through that again.
23
Please, yeah.
24
You're going to have to walk me through
25
26
SSCE0004455
238
2
3
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8
Okay.
10
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Q
I see.
20
Yes.
21
Okay.
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EMSSCE0004456
239
1
2
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Okay.
8
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18
so then what. happened as a result of that,
19
if you know?
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111111SSCE0004457
240
1
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I believe so.
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Yes.
23
Okay.
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.1.11-SSCE0004458
241
A Uh-huh.
2
3
That's okay.
4
5
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Wasn't going to make it.
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Or for me, yeah.
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SSCE0004459
242
1
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No.
14
All right.
15
And did there
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Yeah.
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MMESSCE0004460
243
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2
Yeah.
Yeah.
Yes.
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A
Uh-huh.
23
Uh-huh.
24
I'm sorry, yes?
25
Yes.
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IIMESSCE0004461
244
1
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3
Yes.
Yes.
No.
4
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7
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Q Okay.
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Yes, yes.
Yes.
Yes.
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IIIMI-SSCE0004462
245
1
2
A Uh-huh.
Yes?
Yes.
No, I did not.
All right.
Yes.
5
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16
All right.
Uh-huh, uh-huh.
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-SSCE0004463
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It sounds like it.
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That's good.
22
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24
Okay.
25
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1.11111-SSCE0004464
247
1
2
3
Okay.
If
4
5
6
you could let us know where you could reach you.

A
7
8
9
10
Q Understood.
11
So that's fine.
12
13
14
: Absolutely.
15
BY
16
17
We'll be happy to. Do you have any
18
questions of us or is there anything else you'd like
19
to say at this point?
20
No. Well, I do. Do you
I mean, I know
21
you don't know. Can you just tell me the
22
possibility if there will be a hearing?
23
We can't speak to that.
24
You can't speak to that.
25
We have to finish our work.
26
II.III-SSCE0004465
248
So I probably will be hearing from you.
One way or the other, we'll give you the

Like if it's not going to go forward,
courtesy.
we'll be in touch with you.
way or the other.
6
7
8
If it is, we will.
One
Thank you.
(Whereupon, at 3:39 p.m., the deposition
was concluded.)
9
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SSCE0004466
249
I HEREBY CERTIFY that I have read this
transcript of my deposition and that this transcript
accurately states the testimony given by me, with
the changes or corrections, if any, as noted.
7
8
9
10
11
12
Subscribed and sworn to before me this
day of
, 20
13
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17
Notary Public
18
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21
My commission expires:
22
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EMSSCE0004467
250
CONTENTS
2
3
WITNESS
EXAMINATION
4
5
by
6
7
8
9
EXHIBITS
10
EXHIBIT NUMBER
11
Exhibit
1 identified
11
12
Exhibit
2 identified
113
13
Exhibit
3 identified
140
14
Exhibit
4 identified
144
15
Exhibit
5 identified
165
16
Exhibit
6 identified
172
17
Exhibit
7 identified
185
18
Exhibit
8 identified
193
19
Exhibit
9 identified
197
20
Exhibit
10 identified
204
21
Exhibit
11 identified
212
IDENTIFIED
22
23
24
25
MIMIII-SSCE0004468
UNITED STATES SENATE
Select Committee on Ethics
Washington, D.C.
4
5
IN RE: ENSIGN INQUIRY
6
7
CONFIDENTIAL DEPOSITION OF
8
9
10
11
12
Monday, March 21, 2011
13
14
15
16
Hart Senate Office Building
17
Suite 220
18
19
20
REPORTED BY:
21
22
23
24
25
SSCE000421 9
called for
Deposition of
examination pursuant to notice of deposition, on
Monday, March 21, 2011, in Washington, DC, at the
Senate Select Committee on Ethics, Hart Senate
Office Building, Suite 220, at 10:19 a.m., before
a Notary Public within and for the
District of Columbia, when were present on behalf of
the respective parties:
9
ESQ.
10
ESQ.
11
12
K&L Gates LLP
13
1601 K Street, NW
14
Washington, DC 20006-1600
15
202-778-9000
16
On behalf of Senate Ethics Committee
17
18
19
20
21
22
23
24
--continued-25
26
-SSCE0004220
APPEARANCES (continued):
2
3
ESQ.
ESQ.
5
6
United States Senate Select

Committee on Ethics
220 Hart Senate Office Building
Washington, DC 20510
202-224-2981
10
11111111111111ethics.senate.gov
11
11111111111@ethics . senate . gov
12
13
14
15
16

Committee on Ethics
17
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19
202-
20
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25
1111.1-SSCE0004221
PROCEEDINGS
1
2
Whereupon,
3
4
was called as a witness and, having first been duly
sworn, was examined and testified as follows:

EXAMINATION
6
BY
Good morning.
A
Good morning.
First thing I'd like to do is -- you just
10
11
informally met everyone when you came in. But I'd
12
like for them to introduce themselves. First, I'm

special counsel appointed to
13
14
advise and assist the Senate committee on ethics
15
with respect to investigation of Senator John
16
Ensign.
To my left.
17
I'm
18
19
I work
with
Chief
20
21
Counsel, Staff Director. Good morning. Thank you
22
for being here.
23
THE WITNESS: Thank you.

: Hi,
24
25
I'm counsel
to the committee.
26
IIII-SSCE0004222
BY
1
Q
And there's one preamble that I have to
read to every single witness, not just to you, so
don't take this personally.
4
5
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
But this is just warning and advice of
rights and everything.

The Senate Select Committee on Ethics has
8
9
Okay.
summoned you here for -- today for a deposition as a

witness in connection with the committee's
preliminary inquiry concerning John -- Senator John
Ensign.
Our questions and your answers will be
recorded by the court reporter, and because this is
a deposition before a legislative branch agency,
your statements today are subject to what's known as
the False Statements Statute, which is Title XVIII,
Section 1001 of the United States Code.
So it's a crime to give a false statement
to legislative investigators.
Additionally, because this is a sworn
deposition, it's not just a statement that you're
giving in an interview, your statements are subject
to the penalty of perjury, both under Section 7(b)
of the Supplementary Procedural Rules of the Select
26
IIIIMSSCE0004223
Committee on Ethics, as well as Title XVIII, Section
1621 of the United States Code.
And there's also an obstruction of justice
statute, Title XVIII, Section 1505. So a witness
who gives false testimony under oath in a proceeding
5
6
7
8
or just gives false testimony to the investigators

is somebody who could also be prosecuted for
obstructing Congress in its investigation.
Thus, you may not make any intentionally
9
10
11
false statements or knowingly mislead the committee

through your answers today.
Also, I want to let you know about some
12
13
14
15
16
17
18
19
20
21
22
23
24
25
rules regarding this proceeding. Supplementary

Procedural Rule 8 dictates strict confidentiality on
our part regarding the fact of this deposition and
all our statements made here today. This rule does
not govern your own discussions of the interview,
though.
However, it's our expectation that no
witness will tailor or coordinate III testimony
based on earlier depositions or will go out and
speak to witnesses who have not yet testified so
that they can coordinate and tailor their testimony.
And more importantly, I think just for the
entire investigation, it's important that matters
26
-SSCE0004224
that happen in this room be kept confidential until
the preliminary inquiry is over, in fairness to all
parties in volved.
So we are requesting that you refrain from
4
5
discussing -- we're not ordering you because we
can't, but we are requesting that you refrain from
discussing our questions and your answers with
anyone other than an attorney or a family member.

Do you understand that?
9
10
11
Yes.
Additionally, pursuant to Supplementary
12
Procedural Rule 6, you are entitled to the
13
opportunity to inspect the transcript of your
14
deposition, and
15
of your deposition.
16
17
is going to make a transcript
Just ignore that, sorry, it's on buzzer

And
make it pretty quickly, so if
18
you're still here tomorrow, it's conceivable that
19
you could have an opportunity to inspect the
20
deposition to see if there are any transcription
21
errors. You may have said something that
22
as one word when you meant it to be another word,
23
that sort of thing.
24
25
heard
You can't change the substance of it, you

can't say oh, I wish I hadn't said that, and go back
26
1.1-SSCE0004225
and change it altogether, but you can change
basically --
Can it be sent to me? Because I leave
tonight.
4
5
6
No. We can't send
confidential. We can't send it out.
A Okay.
it's all very
You can come back -- I know it's a big
burden to come back.
10
Okay.
11
And you could -- could IIIII ask
12
attorney to take a look at it?

: Sure.
13
BY
14
15
16
17
You could ask your attorney to take a look

Q
at it to see if there are any errors thatIllithinks
took place, and thencan get in touch with you.
18
Okay.
19
Which leads me to something else. You are
20
21
appearing today without counsel present, but you do

have an attorney who you consult with?
22
A Uh-huh.
23
You have to say yes or no.
24
Yes.
25
For all our answers -- answers to every
26
SSCE0004226
question, make sure you say yes or no. We can't say
uh-huh on the record, because
2
3
doesn't get it.
Yes, I'm sorry.

Can you tell us who that attorney is,
please?
5
6
Can you spell his last name for the
reporter?
8
9
10
11
THE WITNESS: Yes.
12
BY
And-- while Illis not present here
13
14
15
today at this deposition, is Illpresent in

Washington, D.C., as far as you know?
As far as I know.
16
17
18
cell phone.
So -- we're going to provide you with

Do we have
cell phone?
: I do. I can give it to

19
20
21
22
23
24
25
and I'm writing it down,
right now.
BY
Would you like -- if at any time during

this deposition, if you would like to take a break
and go speak with
for whatever reason, please
just indicate it and we'll stop the deposition and
26
1111111SSCE0004227
10
And if you'd like to go
you can go speak with
give
is going to be starting and you want
a call now to let
know the deposition

to be
available to you, you're free to do that as well.
Would you like to do that?

6
No, I'm okay.

Finally, if you want to take a break for
any reason, other than calling
8
9
10
11
please let us know. If you want to go to the

room or just take a breather, whatever reason, let
me know and we'll take a break.
12
13
14
15
16
17
18
19
or to call
Okay.
We just prefer that you not take a break
when a question is pending so we can close the

record and go on to the next question when you come
back.
If -- this is not a game on our part.
We're not trying to tick you into answering
questions one way or the other.
So if you don't understand a question that
20
21
22
23
24
25
I've asked, if my phrasing is confusing -- and it

often is. I try not to be confusing, but sometimes
it is -- please tell me that you don't understand
the question or ask me to rephrase it, all right?
A Okay.
26
111111.-SSCE0004228
11
I want to make sure you understand
everything that's being asked of you and that we
understand your answers, all right?
Finally, I want to assure you that we all
understand that this is a difficult subject and that
some of these topics may be sensitive information.
And as you know, it's not our intent to cause you
any personal discomfort during the deposition. And
8
9
10
11
12
we are only investigating matters that are of

concern to the Senate. We're not investigating your
personal matters and your personal life.
A Okay.
13
BY
I will now show you what we have marked as
14
15
16
17
1. If you take a look at that

III 1
document. Have you seen that before?
18
19
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21
22
23
24
25
No.
Would this have been sent to your
attorney?
A
Yes.
And this is, for your information, a

Q
subpoena to appear at the deposition. How did you
find out about the deposition?
A
From my attorney,
26
11111111SSCE0004229
12
Okay. That's just for the record. You're
here pursuant to a subpoena to appear.
2
3
Okay.
Thank you.
THE WITNESS: Give it back?
: Just throw it in the middle
6
there.
THE WITNESS: All right.
: Let's go off the record for a

9
10
moment.
11
12
BY
13
14
15
Let's just start with some personal
background. What's your date of birth?
16
17
18
And what's your educational background?
19
20
21
22
23
24
25
Okay.
26
-SSCE0004230
13
1
2
3
4
Okay. Just, I mean, I don't know how many
jobs you've had since then.

So why don't we
7
8
just stick with major jobs that you had over the
years.
10
11
12
13
Okay.
14
15
16
17
18
Let me go back for a moment. Where were
you born?
A
19
20
21
22
23
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25
All right.
' 26
SSCE0004231
14
1
2
3
A
Okay. And then after that, what did you
5
6
7
do employmentwise?
A
8
9
Okay.
10
11
12
Well, let's -- when -- by whom?
13
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-SSCE0004232
15
The date?
Okay.
Okay.
6
7
Uh-huh, yes.
Okay.
10
11
12
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Yes.
26
111.0-SSCE0004233
16
1
A
2
3
4
5
6
Yes.
Okay.
Not yet.
Not yet.
10
11
12
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18
A
Yes.
21
Yes.
22
Okay.
23
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-SSCE0004234
17
1
2
3
4
Okay.
7
8
Yeah, yes.
Okay.
10
11
Okay. Now, let's go back.
I'm sorry about that.
12
13
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15
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17
A Okay.
18
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21
Okay.
22
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SSCE0004235
18
1
2
3
4
5
6
7
8
9
10
Okay. And if I may -- and I don't mean to
11
jump around like this, but I think we're getting to
12
some very good information by way of background
13
information here.
14
15
16
17
18
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20
21
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23
24
25
Okay.
26
MNISSCE0004236
19
1
2
All right.
3
4
5
6
7
10
11
Yes.
12
Okay.
What would you call that.
17
Okay.
18
19
20
21
13
14
15
16
22
23
24
25
Okay.
26
1.11111-SSCE0004237
20
When you --
1
A
2
3
4
5
6
7
9
10
11
12
13
A Yeah.
14
15
Okay.
Yes.
16
17
18
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20
21
22
Okay.
23
24
25
26
IM.-SSCE0004238
21
2
3
4
5
Correct.
Okay.
Yes.
It was fairly large.
Oh, yes.
7
8
9
10
11
12
13
14
15
16
17
18
Probably.
Okay.
19
20
21
22
23
Okay.
24
25
26
111.111-SSCE0004239
22
Yes.
1
2
3
5
6
7
8
9
Okay.
10
Yes.
11
12
13
14
Okay.
15
16
17
18
19
Yes.
20
And how so?
21
22
23
24
25
A
(Laughter.)
26
IIIIKSSCE0004240
23
3
4
5
6
7
8
9
Okay.
10
11
12
13
14
Well --
15
16
17
A
So it was almost a year.
18
19
All right.
20
21
22
Okay.
No.
23
24
25
26
-SSCE0004241
24
Okay.
Yes.
Okay.
Yes, yes.
6
7
8
9
10
11
Q
Okay.
15
Yes, occasionally.
16
Okay.
No, no.
12
13
14
17
18
Go ahead.
19
20
21
22
23
A Uh-huh.
You have -- yes?
24
25
Yes. I'm sorry.
26
1111111-SSCE0004242
Yes.
Okay.
6
7
8
9
10
11
12
Yes.
13
Okay.
14
15
16
17
18
19
Okay.
20
21
22
23
I do not recall
A
the name.
Q
That's all right.
24
25
I do not recall
26
SSCE0004243
-SSCE0004244
27
29
30
31
And t h i s would be once o r twice a year?

I b e l i e v e i t was once a year.
I'm
you --
I t ' s j u s t on the o u t s k i r t s .
S SCE0004250
33
34
SSCE0004252
35
36
37
Yes.
9
10
11
No, a f t e r .
A f t e r , okay.
Well, then l e t me go back,
j u s t a l i t t l e b i t more, we're going t o stay i n

background f o r j u s t a l i t t l e w h i l e longer.
12
13
14
15
16
17
19
20
21
22
23
Probably less
24
Okay.
25
26
SSCE0004256
39
40
SSCE0004258
41
ISSCE0004259
Okay.
And do you remember
But do you remember when t h a t conversation
10
took place?
11
12
13
That was another t h i n g , I'm sorry.
14
I should have a t the beginning t o l d you
15
16
17
18
19
20
21
22
23
24
25
26
one of the other r u l e s of a d e p o s i t i o n i s t h a t I

shouldn't i n t e r r u p t you and you shouldn't i n t e r r u p t
me or else
right?
can't w r i t e i t down both a t once, a l l
I'm s o r r y f o r i n t e r r u p t i n g you.
44
NO.
Approximately?
Okay.
I honestly do not.
That's f i n e .
That's a l l you can
do, i s w i t h your best r e c o l l e c t i o n and g i v e us your
best answer.
Okay.
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
I-SSCE0004262
Whatever t h a t was?
I do not b e l i e v e they d i d .
Okay.
You don't b e l i e v e they d i d .
No.
Okay.
Now -'-
S SCE0004263
46
47
S SCE0004265
48
49
50
S SCE0004268
52
53
54
55
56
All right.
1
2
3
4
5
6
7
8
9
10
Now, you said t h a t -- sorry f o r t h e
11
12
noises, t h i s i s an o l d , wonderful b u i l d i n g .
But we
13
do hear every time something goes down a sink.

(Laughter.)
14
15
16
17
18
19
20
21
22
23
24
25
A l l right.
26
-SSCE0004274
57
58
59
60
61
62
63
64
11
Yes.
13
Yes.
Q
15
16
This may be a good time t o stop
take a break.
A
Okay.
Q
18
your coat.
19
room --
20
YOU know where t h e room i s where you put

I f you j u s t want t o go t o
I do.
(Recess.)
23
26
SSCE0004283
l i k e t o go back over some o f those

subjects j u s t a
and then w e ' l l move
along, okay?
SSCE0004284
67
68
SSCE0004287
70
71
SSCE0004289
72
73
74
75
SSCE0004293
76
SSCE0004294
I'm so sorry..
No, no, these are a l o t of dates
78
SSCE0004296
79
80
1
2
You t h i n k you would r e c a l l ?
You t h i n k
you're hearing t h i s f o r the f i r s t time?
3
Q
I'm not saying i t happened.
I do not -- I do not
10
That's what I was j u s t going t o say.
11
That's what I'm t h i n k i n g t h a t i s .
12
All right.
4
5
6
7
8
9
13
14
15
16
17
18
19
20
21
22
23
24
25
26
-SSCE0004298
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SSCE0004300
83
That was t h e one you referenced e a r l i e r i n
your testimony?
25
Yes, yes.
26
-SSCE0004302
85
86
87
88
And before.
And before?
91
That's s o r t of more recent business.

2
3
4
5
And when was t h a t , i f you r e c a l l ?
Let's see.
9
10
11
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Q
Warm?
you remember what time of year i t was?

Cold?
A
Q
I t was c o l d .
I t was c o l d .
SSCE0004310
93
96
7
8
Let me ask you t h i s .
So I'm t r y i n g t o remember.
I t might have
been -- I'm sorry.
10
wasn't hushing you, I was hushing me.

Okay.
might have been the f i r s t , I'm sorry.

15
That's f i n e .
20
Yes.
23
Right.
Okay.
26
99
100
101
102
103
SSCE0004321
104
I-SSCE0004322
105
1
2
3
4
5
6
(Laughter.)
7
8
But what i s your understanding of how
9
10
11
12
13
14
Sorry.
15
16
That's a l l r i g h t .
17
They're a l l over.
18
Well, now you know what I don't do i n my
'19
20
21
22
23
24
25
26
f r e e time
106
107
SSCE0004325
109
110
-SSCE0004329
112
113
SSCE0004331
114
I don't r e c a l l .
Okay.
I'm j u s t t h i n k i n g --
10
So --
11
Sometime i n t h a t time period?
Okay.
14
I'm so sorry.
15
No, t h a t ' s f i n e .
13
'
That's f i n e .
Again, these are a l o t
16
of dates t o be h i t t i n g you w i t h .
17
have very good r e c a l l f o r dates, and I appreciate
18
that.
22
25
A Yes.
And you a c t u a l l y
Okay.
26
-SSCE0004332
115
When was that?
I want t o say a l i t t l e b i t a f t e r .
Okay.
Okay.
And t e l l me the circumstances of
These were --
SSCE0004333
SSCE0004334
SSCE0004336
119
120
121
-SSCE0004339
122
123
124
125
126
1
2
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7
8
9
10
Okay.
11
12
A Somehow.
13
14
All right.
15
16
17
18
19
20
21
22
No, just periodically.
23
24
25
26
-SSCE0004344
Yes, pretty much right after.
Yes.
2
3
4
5
6
7
8
9
10
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Okay.
23
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ININISSCE0004345
128
1
2
3
4
5
Okay.
6
7
8
9
10
11
12
13
14
15
16
17
18
19
Yes.
20
Okay.
21
22
A Uh-huh.
23
I'm sorry, you have to say yes.
24
Yes.
25
Okay.
26
MIIMII-SSCE0004346
129
1
2
3
4
A
Yes.
Yes.
6
7
8
9
All right.
10
11
12
13
14
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19
All right.
Okay.
20
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SSCE0004347
130
1
2
3
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5
6
7
8
9
10
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21
Okay.
22
23
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...-SSCE0004348
131
1
2
A
Yes.
All right.
Yes.
7
8
10
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12
Okay.
13
14
15
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17
18
19
20
21
22
23
Okay.
24
25
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SSCE0004349
132
1
2
3
4
6
7
Yes.
Yes.
Yes.
Yes.
8
9
10
11
12
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16
17
18
Or what happened?
A
19
20
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-SSCE0004350
133
Right.
4
5
Q
Okay.
Yes.
10
6
7
8
11
12
13
Yes.
14
15
16
Yes, yes.
17
Okay.
18
19
20
21
22
23
24
Yes.
25
Okay.
26
-SSCE0004351
1
2
3
4
5
6
Okay.
7
8
10
11
12
13
Okay.
14
15
16
17
18
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20
21
22
23
24
Yes.
25
26
1111.1111.-SSCE0004352
135
2
3
4
5
6
7
8
9
And then what happened?
10
11
12
13
14
15
16
17
Right.
18
19
20
21
22
23
24
What ultimately happened after that?
25
26
IIIMIIISSCE0004353
136
1
2
3
4
5
6
7
8
Sure.
9
10
11
12
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21
No.
Right, right.
22
23
24
25
26
.11.111-SSCE0004354
137
1
2
3
4
5
6
No.
7
8
9
10
11
Yes.
12
All right. Let's rollback a little bit.
16
Yes.
17
All right.
19
Yes.
20
13
14
15
18
21
22
23
24
Yes.
25
26
1.1.11-SSCE0004355
138
1
2
Yes.
3
4
6
7
8
9
10
11
12
13
And this was --
14
15
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21
22
All right.
23
24
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.11111SSCE0004356
139
1
2
3
4
5
7
8
9
10
11
12
13
14
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22
Yeah.
23
24
25
26
A
Sure, absolutely.
140
Number 3 for identification today.
(Exhibit 111-3 identified.)
BY
Were going to go about another half hour,
5
6
A Okay.
Because I want you to get lunch, I want us
7
8
9
to get lunch.
A
And we'll see how far we can go.
10
11
That's fine.
Okay.
12
13
14
15
A Uh-huh.
16
17
A Uh-huh.
18
Yes?
19
Yes.
Yes.
20
21
22
23
24
25
26
111111-SSCE0004358
141
1
2
3
Yes.
5
6
7
10
Yes.
Yes.
11
12
13
14
No.
15
16
Q
All right.
19
Yes.
20
Okay.
Yes, yes.
17
18
21
22
23
24
25
26
-SSCE0004359
142
1
2
3
4
5
Okay.
Uh-huh.
Uh-huh.
Okay.
10
Yes.
11
I'm sorry.
12
I'm sorry I keep doing that.
Yes?
13
14
15
16
17
That's what I was getting to.
18
19
20
21
22
23
24
25
26
-SSCE0004360
143
1
2
No.
Okay. That's fine.
3
4
5
6
Okay.
8
9
10
11
12
13
14
A
It may seem obvious.
15
16
No, I understand.
17
18
19
20
21
22
Thank you.
23
24
25
Okay. Excuse me.

reminds me of
something that I meant to show you earlier.

A
Okay.
26
ME-SSCE0004361
144
1
2
3
4
A Okay.
I'm going to show you what we'll mark as
an exhibit, as
(Exhibit 1114 identified.)
BY
Q
I'm going to represent to you that

Sorry to throw things.
10
THE WITNESS: No, no, no, you're not at
11
12
all.
BY
13
14
15
16
17
18
19
20
21
Do you see?
22
23
Okay.
24
25
26
.11.1-SSCE0004362
145
1
2
Yes.
4
5
No.
Okay.
6
7
8
9
10
11
12
13
14
15
16
17
Yes.
18
Do you recall receiving that e-mail?
19
No.
20
Okay. Take a look at it for a while and
21
see if there's anything in it that refreshes your
22
recollection.
23
24
25
26
IME-SSCE0004363
1
2
3
4
5
Right.
So that was just -- I have no idea.
Uh-huh.
Okay.
23
Pasted, sounds like i
2.4
I don't know.
7
8
9
10
11
12
13
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25
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EIMSSCE0004364
147
1
2
3
4
5
6
7
8
9
10
11
I honestly do not recall, but it
definitely could have been.

Okay. That's fine.
12
13
14
15
16
17
Do you see that?
18
19
Yes.
Yes.
20
21
22
23
24
25
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-SSCE0004365
148
1
2
3
4
5
All right.
6
7
8
9
Okay.
10
11
12
13
14
15
All right.
16
17
18
19
20
No, I don't really -- I don't recall that.
21
22
23
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MIM-SSCE0004366
149
1
2
3
4
5
6
7
8
9
10
11
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15
No.
16
All right.
17
18
19
20
21
22
23
24
25
26
-SSCE0004367
150
That wouldn't stand out to you?
All right.
1
2
3
6
7
Yes.
Q Okay.
10
11
12
13
14
Do you know what that was all about?
15
16
I don't. That's what I'm wondering.
17
18
19
20
21
22
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24
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SSCE0004368
151
1
2
3
4
5
Okay.
6
7
8
10
there.
11
12
Okay. Take a look at what's written
You don't have to read it out loud. Read
13
it to yourself, and tell me if there's anything in
14
there that prompts you to remember --
15
16
17
18
19
20
21
22
All right.
23
24
25
26
MIIIIESSCE0004369
152
1
2
A
just can't recall.
Okay.
5
6
7
8
9
10
11
12
Uh-huh.
Uh-huh, yes.
Yes.
Yes.
13
14
15
16
17
18
19
20
21
22
23
24
25
3.
26
IMIE-SSCE0004370
THE WITNESS:
1
2
3
BY
Right.
A
You might have been, I don't know.
6
7
A
So --
9
10
11
Okay.
12
13
14
15
16
17
Yes.
Yes.
18
19
20
21
22
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24
25
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SSCE0004371
154
1
2
3
4
5
6
7
9
10
11
12
13
14
15
16
17
18
19
20
21
22
Uh-oh.
Right.
23
24
25
Later?
26
MIIM-SSCE0004372
155
Later.
2
3
4
5
6
7
8
9
10
11
12
13
I see.
14
Q
Okay.
Yes.
22
Both.
23
Okay.
24
15
16
17
18
19
20
21
25
26
-SSCE0004373
156
Okay.
2
3
4
6
7
8
9
10
11
12
13
14
15
16
17
18
19
THE WITNESS:
20
BY
I was just going to ask, was it usually
21
22
when it was?
23
24
25
26
-SSCE0004374
157
THE WITNESS: Okay. One of those days.
1
2
3
4
5
BY
6
7
Right.
9
10
A Uh-huh.
11
Yes?
12
Yes.
13
14
15
16
17
18
19
20
21
Same thing.
22
That was?
23
24
25
26
SSCE0004375
Right, okay.
Yes.
I believe so.
You believe so.
12
Correct.
13
Okay.
Yes.
1
2
3
4
5
6
7
10
11
14
15
16
17
18
19
20
21
22
23
Okay.
24
25
26
-SSCE0004376
159
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
Okay.
17
Yes.
18
Q Okay.
19
20
21
All right.
Yes.
22
23
24
25
26
11.1.-SSCE0004377
160
Yes.
2
3
4
5
6
7
Okay.
All right.
8
9
10
11
12
13
14
Right.
Right.
Wait a minute, I'm getting confused here.
15
16
17
18
19
Hold on one second, please.

Go ahead, please. I'm sorry, you were
20
21
22
saying.
A
Okay.
23
24
25
26
.11.11-SSCE0004378
161
1
2
3
4
Okay.
5
6
7
8
9
10
Yes.
Yes.
No.
Yes.
Yes.
Yes.
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
-SSCE0004379
162
1
2
3
4
5
6
Okay.
7
8
9
10
11
12
13
Okay.
14
15
16
17
18
19
20
21
Okay.
Correct.
22
23
24
25
26
IMSSCE0004380
Okay.
1
2
3
4
5
6
Yes.
Okay.
8
9
10
11
12
Yes.
Yes.
13
14
15
16
17
18
19
20
21
22
Okay.
Yes.
23
24
25
26
IIMSSCE0004381
164
1
2
No.
3
4
5
6
7
Okay.
I'm sure I did, yes.
Okay.
8
9
10
11
12
I'm sure I did.
13
14
15
16
17
18
Q
All right.
21
A lot.
22
Pardon me?
23
There's a lot, yes.
24
That's all right, I understand.
19
20
25
26
11111.SS0E0004382
165
It's okay.
But I'm going to show you what has been
marked as-5 for identification.
(Exhibit III-5 identified.)
BY
6
7
8
Yes.
Have you read that recently?
10
No.
11
Okay. Can you read it over to yourself
12
now while you're sitting here?

13
Okay.
14
15
Q Ready?
16
Yeah.
17
Okay. This is a -- I'm going to read it
18
for the record. It's already in the record, but I'm
19
just going to read it over right now.
20
21
22
23
24
25
26
111111SSCE0004383
166
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
Okay.
22
23
24
25
26
MIII-SSCE0004384
167
1
2
3
4
5
6
7
8
9
10
Okay.
Yes.
Right.
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
SSCE0004385
168
1
2
4
5
Q
Okay.
Yes.
10
Like in other words, what happened next?
11
Yes.
Okay.
6
7
8
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Right.
26
MI-SSCE0004386
169
1
2
3
6
7
8
9
10
Q
Okay.
13
Yes.
14
11
12
15
16
17
18
Yes.
19
20
21
22
23
24
Okay.
25
26
-SSCE0004387
170
1
2
3
4
5
6
7
8
9
10
11
12
13
Okay.
14
And - -
Yes.
15
16
17
18
19
20
21
22
23
24
Okay.
25
26
SSCE0004388
171
Okay.
1
2
3
4
A Right.
Okay.
I just -- I can't remember.
As you sit here right now, you can't
6
7
8
9
10
11
12
remember?
A
13
14
All right.
15
16
17
18
19
20
21
Okay. All right. And what happened as a
result of that, if you know?

A
22
23
24
Okay.
25
26
-SSCE0004389
172
A Right.
Okay.
3
4
: 11[6.
5
6
THE WITNESS:
8
BY
9
10
11
12
John, John Ensign.
13
14
15
16
17
Okay.
18
19
20
21
22
23
Gosh.
24
25
26
-SSCE0004390
173
1
2
3
4
5
6
7.
8
9
A
10
11
12
13
14
15
I do not know.
16
Okay. But it all happened about the same
Right around the same time.
21
I believe so.
22
All right.
17
18
day?
19
20
23
24
25
26
illiM-SSCE0004391
174
1
2
3
4
5
Yes.
Okay.
No.
Yes.
7
8
All right.
9
10
11
12
13
to do?
14
You know, what am I going
Okay.
15
16
17
18
19
20
21
22
23
24
25
26
SSCE0004392
175
2
3
4
Okay.
A
5
6
7
8
9
10
Q
Okay.
15
Okay.
16
You know where the dining room is
17
downstairs?
18
11
12
13
14
19
I don't.
111111111: We'll have someone show you.
: We'll come back at 2:30.
20
21
Longer or shorter?
I think shorter.
22
23
24
was recessed, to be reconvened at 2:30 p.m. this
25
same day.)
26
IIIMI-SSCE0004393
1
1
Washington, D.C.
4
5
6
7
8
9
10
11
12
13
14
Friday, December 3, 2010
15
16
17
18
19
Suite 220
20
21
22
23
24
REPORTED BY:
25
26
1111=1-SSCE0001787
Deposition of...1111111 called for
examination on Friday, December 3, 2010, in
Washington, DC, at the Senate Select Committee on
Ethics, Hart Senate Office Building, Suite 220, at
2:02 p.m., before
within and for the District of Columbia, when were
present on behalf of the respective parties:
a Notary Public
8
ESQ.
10
11
ESQ.
ESQ.
ESQ.
12
13
ESQ.
14
Senate Select Committee on Ethics
15
220 Hart Building
16
17
202-224-2981
18
On behalf of the Committee
19
20
@ethics.senate.gov
@ethics.senate.gov
21
IIIIIIIIIIIIIkethics.senate.gov
22
IIIIIIIIIIIIIIIkethics.senate.gov
23
IIIIIIIIIkethics.senate.gov
24
25
--continued--
26
111111111SSCE0001788
APPEARANCES (continued):
2
3
.1111111111111 ESQ.
Sandler Reiff & Young
300 M Street, SE, Suite 1102
202-
IIIIIIIIksandlerreiff.com
On behalf of the Witness
10
11
ALSO PRESENT:
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
SSCE0001789
PROCEEDINGS
EXAMINATION
2
3
4
BY
Q
Good afternoon. As
indicated, we will read now the warnings that we go
over with every witness. We'll kind of describe
your rights and obligations and the nature of the
proceeding here.
Okay.
10
We advise you that the Senate Select
11
Committee on Ethics has summoned you here today for
12
this deposition as a witness in connection with the
13
committee's preliminary inquiry into -- concerning
14
Senator John Ensign.
15
I'm joined by my
I'm
16
colleagues on the counsel staff for the committee.
17
On my left is
18
staff director. And on
19
and on =left is
our chief counsel and

left is
and on
left is
20
21
As
indicated, we've all been
22
authorized to put questions to you as a witness, but
23
I will take the lead Our questions and your
24
answers will be recorded by the court reporter, who
25
sits on my right.
26
MIIIIIIIISSCE0001790
Because it's a deposition before a
legislative branch agency, your statements today are
subject to the False Statements Statute, Section
1001 of Title XVIII of the United States Code.

Additionally, because it's a sworn
5
6
deposition, your statements are subject to the
penalty of perjury, under Section 7(h) of the
Supplementary Procedural Rules of the Select
Committee on Ethics, a copy of which has been placed
10
before you there, and Section 1621 of Title XVIII of
11
the U.S. Code, as well as the Obstruction of
12
Congress Statute, Section 1505.

13
14
15
through your answers to our questions today.

You understand that?
16
17
I do.
: At this point, I would ask
18
19
the court reporter to administer an oath to you.
20
Whereupon,
21
22
23

BY
24
25
you understand that your
26
SSCE000I 791
statements today are subject to statutes and
committee rules concerning false statements, perjury
and obstruction of Congress?
Yes, sir.
You've been provided with a copy of our
procedural rules. As a general matter,
Supplementary Procedural Rule 8 dictates strict
confidentiality on our part regarding the fact of
this deposition and all statements that you would
10
make today.
11
The rules do not govern your own
12
discussions of this interview, however. It is the
13
committee's expectation, though, that no witness
14
would tailor his or her testimony or coordinate his
15
or her testimony based on any earlier deposition.
16
Therefore, we would ask you to refrain
17
from discussing our questions or your answers in
18
connection with this deposition with anybody except
19
your attorney.
20
Okay.
21
Thank you. And also pursuant to our
22
supplementary rules, Supplementary Procedural Rule
23
6, you and your counsel are entitled to an
24
opportunity to inspect the transcript of the
25
deposition in the committee offices, and you also
26
MII-SSCE0001792
have the right to request that any errors that you
see in the transcription be corrected. Any errors
of fact must be brought to the committee's attention
through the submission of a sworn statement.

If you wish to inspect the transcript, let
5
6
us know in the next week or so. We'll let you know
when the transcript is ready, and you can arrange
with your counsel to come in.
Okay.
10
Finally, throughout the course of the
11
deposition, we've marked certain documents as
12
exhibits. The purpose of that is to be helpful.
13
Okay.
14
They are e-mail conversations. And what
15
we'll be doing is presenting -- marking the
16
exhibits, presenting the exhibits to you.

If at any time you wish to take a break or
17
18
consult with your counsel, just let us know that,
19
and we'll be giving you that opportunity.
20
Okay.
: This would probably be a
21
22
good time for
to enter
appearance.
23
I forgot.
24
It's Friday,
25
I apologize to you,
26
111M-SSCE0001793
We invite you now to enter your
1
2
appearance into the record.
3
law firm of Sandler, Reiff & Young,
4
5
counsel for
: The record should reflect
Deputy Staff Director, is also in
the room with us today, too.

9
is just observing.
questions.
Thank you,
10
BY
11
12
will not be asking
I have placed before you
13
between the two copies of the calendar there, it's a
14
one-page document marked 11-1.
15
(Exhibit IIF1 identified.)
16
BY
17
This appears to be a notice of deposition.
18
So I ask for the record, is this a copy of the
19
notice of deposition that you received from the
20
committee in connection with this deposition today?
21
Yes, it is.
22
Very good, thank you. What I would like
23
to do,
24
present position of employment.
25
is I'll ask you to give us your
Okay.
26
MIN-SSCE0001794
background.
Okay.
I'll ask you to share with the committee
And then I would like to go into your
your educational background and then your employment
history.
Okay.
So if we could start, could you please
9
10
11
identify, by whom are you employed at the present

and in what position?
A
12
13
14
15
Very good. And could you tell us a bit
about your educational background?
16
Sure.
17
Yes.
18
Okay.
Okay. And taking it from there, if you
19
20
21
22
23
24
25
could give us your employment history.

A
Sure.
26
=11111-SSCE0001795
11
2
3
4
5
6
7
9
10
11
12
13
14
15
Did you interview with
for
that position?
A
I did.
16
17
18
19
20
21
22
23
24
25
26
MIIIIII.SSCE0001797
12
Beginning in
I'm sorry?
Beginning in
Yes, sir.
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
IIIMINI-SSCE0001798
66L1.00030SSIM
9Z
SZ
T7Z
*op am 'sax
EZ
ZZ
-CZ
OZ
'APNO
61
8T
LT
91
SI
171
ET
ZT
TT
OT
6
17
ET
15
1
2
3
Q
Ensign?
A
Acquainted? Yes. I mean, he will say hi,

Hi, Senator Ensign. How are you doing?
4
5
Okay. Are you acquainted with Senator
I'll see him on the floor.
6
7
8
9
10
11
12
13
14
15
16
17
Oh, I apologize.
18
No, no, that's okay. If you can just
19
20
explain what you referred to.

A
Right.
21
22
23
24
25
26
II-SSCE0001801
16
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
Could you tell us, have you ever kind of
17
had a one-on-one meeting with Senator Ensign about
18
any matter?
19
Gosh, I don't believe I -- I don't believe
20
so, no. I mean, I had conversations with him, like
21
on the floor, he'll ask what is this amendment about
22
or, you know, what -- what's the procedure going
23
forward?
24
But in terms of sitting down and briefing
25
him, he just recently was named to rules committee,
26
MIIMI-SSCE0001802
17
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
BY
18
19
Can.I follow up on two things?
I do, but I'm not in the lead.
20
21
22
23
24
25
26
11.11111.-SSCE0001803
18
2
3
4
5
6
7
8
9
10
11
12
Gosh. If we were on the floor, depending
13
on what the amendment is, he could have come up on
14
me and said, you know, I don't understand with maybe
15
it was Obama's bundling amendment, or I don't
16
understand how this works, can you walk me through
17
it related to HLOGA, but I don't --
18
19
issue?
20
21
So it would have been a legislative type
It would have been a legislative --
legislative type issue, yes. That I recall.
22
BY
23
Two questions.
24
25
One, just for the record,
could you spell

A
26
.11111-SSCE0001804
19
Do you remember discussing HLOGA,
H-L-O-G-A?
Yeah, I'm sorry. Honest Leadership Open
Government Act.
And more substantively, can you describe
in a little more detail what your responsibilities
for HLOGA were?
8
9
10
11
In -- gosh, let me get my years right.
When we were in the majority, the Republicans

passed -- we passed an ethics reform bill. And
appointed
as kind of
12
the lead to negotiate with the House, where they
13
were in the majority as well.
14
Unfortunately, we were never able to come
15
to an agreement and put it together, largely over
16
there was an issue in the House that they adopted
17
amendment related to 527 campaign finance
18
regulations, and that was kind of the thing that --
19
it blew it up.
20
21
22
We had 55 senators; we didn't have 60. So

we weren't able to go forward.
So fast-forward, obviously S.1, it was the
23
first bill out of the gate the next go-around when
24
we got knocked into the minority, so I was the one
25
that worked, to the extent I could, because
26
SSCE0001805
20
obviously the Democrats drafted the bill.

The base bill, I believe, they started out
with was the bill that was passed in the Senate, as
I recall, under Republican -- when we were in
charge. And so when there were amendments that
would come up, negotiating the amendments, advising
how to vote on the amendments, which ones are
acceptable, which ones are dangerous.
Because you got into a little bit of "I
10
can outreform you" on the floor. So trying to keep
11
people's expectations, that there are a lot of
12
things that can be done, but people need to be able
13
to live and work, so let's -- you know, let's keep
14
our wits about us here.
15
So and then once it passed here, we
16
attempted to go to conference. It was blocked by --
17
well, by ourselves over language related to Rule 44,
18
Congressionally directed spending, which has come
19
back up again.
20
21
22
And so when we were unable to go to

conference, I worked with
I apologize, his folks on some of the
23
provisions to try to help them understand the
24
practical application.
25
One of the biggest ones was the earmark --
26
.1111-SSCE0001806
21
I'm sorry, the bundling provision, and it was a
Senator Obama amendment. And the way he had it
drafted was that it was the lobbyist that was
supposed to report who they bundled for. And I kept

telling -- I would say guys, this is really -- this
is something you want the campaigns to be reporting,
because they are the ones, you know, that should be
doing so.
I worked with them kind of tangentially,
10
11
didn't have the influence that we should have, if we
12
through to its final passage, whenever -- I can't
13
remember when that was.
had been in a conference committee, but then saw it
14
15
16
17
18
19
BY
20
21
Yeah, correct. Correct, yes, sir.
After the passage of HLOGA, did you have
22
any responsibilities in terms of briefing the other
23
offices about what the provisions were?
24
25
No, we didn't, because as part of HLOGA
was the mandatory briefing with
We
26
1=-SSCE0001807
22
went and attended.' briefings and watched the
handcuffs and -- ooh. And then everyone watches
I was telling
But it was one of the things in there, and
4
5
about it, watches the videotape.
it was originally drafted, I believe, it was

supposed to be an annual -- everyone in the entire
Senate was supposed to do it annually. And finally,
we were, like, that's maybe a little tedious for
people in the cabinet shop going every year to get
10
an ethics briefing.
: It's tedious for the ethics
11
12
staff, too.
13
(Laughter.)
14
THE WITNESS: Tedious for the committee,
15
too. But the follow-up was you all -BY
16
17
So there was no additional follow-up from
18
your office on that? If people had questions, would
19
they call you?

Oh, okay. Yes. In terms of, like, mass
20
21
briefings?
Yes.
22
23
Yes. People -- if they had questions,
24
other offices would call me, and other offices still
25
do call. I mean, I always say, look, you know, the
26
.1111111-SSCE0001808
23
ethics committee is there, if you need to call.
But, you know, just much the same as I have a
question on the budget, I go to our budget folks.
don't necessarily call the budget committee. Our on
a healthcare bill, I would ask our healthcare
person, or a healthcare person in someone else's
office, but not necessarily finance.

So same type of thing would apply to this.
8
9
10
If someone had a question, they would give me a

call.
This time of year is particularly a lot of
11
12
questions because everyone is getting invitations.
13
So as a general proposition, it's best, just don't
14
go to anything, unless you have the letter from you
15
guys. And you guys know better than I how tedious
16
that is.
17
And just one follow-up on that. Do you
18
recall if you received any questions from anyone in
19
Senator Ensign's office around the time of the
, 20
21
22
passage of HLOGA about any of its provisions?

A
Gosh. No, I don't. I don't recall that I
received any specific -- any specific questions.

BY
23
What I could do, and as I indicated
24
25
earlier on,
is put before you some
26
MIIIII-SSCE0001809
24
exhibits.
Sure.
I'm going to put three exhibits before
you. I'll be giving a copy to 111Mill Exhibits

1112, 3 and 4. Each exhibit is one page.
(Exhibits-2,-3 and 11.4 identified.)
BY
I'll ask you to focus first

9
10
Okay.
11
Now,
14
Correct.
15
And as we read these e-mails throughout
-2 is a one-page exhibit.
12
13
16
the deposition today, they -- chronologically, they
17
kind of appear in reverse order --
18
Right.
19
-- of when they occurred, all right?
20
Okay.
21
22
23
24
25
26
SSCE0001810
25
2
Okay.
3
4
5
6
Right.
7
8
9
Correct.
10
And this was -- this was before the
11
passage of HLOGA; correct?
12
Correct.
13
Okay.
18
Oh, sure, yes. Yes, sir.
19
Okay.
I do.
14
15
16
17
20
21
22
23
24
25
26
-SSCE0001811
1
2
3
4
5
6
Okay. The next exhibit is III-3,
8
9
10
11
12
13
14
15
16
For the record, for purposes of the
testimony, we should assume that.

A
Okay.
17
18
Okay.
19
And I would invite your attention to the
20
last sentence of the text, which says,
21
Final two sentences.
22
23
Okay.
24
25
26
Mill-SSCE0001812
27
1
2
3
I do remember this. I can't remember what
the event was. But I remember directing him to the
Senate ethics manual, where you have pretty much
if I remember right, it kind of reads like this, the
exception for charitable events.
Right.
10
11
I mean, it's all
12
13
kind of a very gray area.
14
And offices -- other offices have asked as
15
well, you know, which account do I pay for? I mean,
16
I think that the official is pretty cut and dried.
17
The rest of it is kind of a little -- can get a
18
little fuzzy.
19
20
21
22
23
24
25
26
SSCE0001813
28
1
2
3
4
5
6
7
8
9
10
11
What's Battle Born?
12
Brattle Born is Senator Ensign's
13
leadership PAC.
14
How did you know that?
15
Gosh, because one of the things we offered
16
as an amendment to the 527 bill when it was at rules
17
committee was a
18
actually offered it -- to allow for unlimited
19
transferability of leadership PAC funds to national
20
party committees. Always kind of made not a lot of
21
sense that you can send all your campaign cash over
22
to a party committee but not.
23
amendment --
So in doing that, we did plenty of
24
research on who all had leadership PACs, how much
25
money are we talking about, on both sides of the
26
II
-SSCE0001814
29
aisle, to try to elicit help from the other side of
the aisle.
Just as you know Battle Born, there are
3
4
several others like
and such. And I believe that that
5
6
7
is the
was the origin of that.

Q
Okay. So this fits with what you would
describe as -- would you describe it as regular
contact that you would have had with
10
11
about ethics questions?

A
In terms of regular, I don't -- I mean, it

have a
12
wasn't, like, a weekly thing. It was if
13
question,
14
having any inquiries or having any questions. And
15
sometimes, you know, liwould have a question.
ask. Would go months without
But for the most part, most of the
16
17
conversations would occur around, like, the
18
Christmas holiday, and most of it really revolves
19
around what receptions are acceptable to go to and
20
which ones aren't.
21
Okay. I'd ask, then, if you could turn to
22
the next exhibit, which is marked-4. It's a
23
one-page exhibit,
24
25
26
SSCE0001815
30

2
A Okay.
Do you recall this communication with
3
4
5
6
Not -- I recall the theme. I don't
necessarily recall, I mean, this specific language.

I believe
-- I can't remember if
had the point on the Ensign amendment. What they're
referring to is the -- I think it's
10
has a bill to require electronic filing of FEC
11
reports by Senate candidates, and Senator Ensign had
12
an amendment to require financiers of ethics
13
complaints to disclose their donors at the $5,000
14
threshold per filings for 501(c) or a $200 threshold
15
per 527 filings whether with the IRS or the Federal
16
Election Commission.
17
18
As you read this III-4 exhibit, that's what
you're referring to here is the Ensign amendment?
19
Correct.
20
Did it pass?
21
It never has. The other side will not
22
allow a vote on that amendment. So we've had
23
unanimous consent offered to call up the electronic
24
filing, one amendment, 10 minutes of debate, vote on
25
the amendment, vote on the electronic filing. And
26
-SSCE0001816
31
they always object. They don't want to vote on this

2
amendment.
: Okay. Can I just ask my
3
4
colleagues, any questions about those exhibits?

So if you could pass those, thank you,
5
6
back to me so that I don't lose track.
NE
identified.)
(Exhibit
BY
I'm going to now show you an exhibit,
10
11
12
two-page exhibit which we have marked111-5.

A
I start at the bottom and read up;
correct?
13
Yes, please.
14
Okay. Sorry about that.
15
16
Okay.
And I would ask you to begin at the bottom
17
18
and tell us,

is that
19
20
correct?
21
Correct.
22
And if I could read, it was in meeting

I think we can read that as John
23
with J.E.
24
Ensign. Did you read this as John Ensign, J.E.?
25
Yes.
26
-SSCE0001817
32
1
2
3
Correct.
4
Right.
5
6
7
Right.
Okay.
So was this the first that you learned
13
14
that Senator Ensign knew enough of your work to, you
15
know, have such a high opinion of you?
16
17
No, I'd heard through -- well, through
managing the election reform bill on the floor with

for three solid weeks and then
18
19
bringing it back for another week and then through
20
conference committee, I knew
21
appreciative of the work we did, helping him with
22
his amendment.
was very
And like with other members that would say
23
24
nice things about you, it always makes you feel
25
good.
26
MIE-SSCE0001818
33
1
2
3
Oh, yes.
Let me ask you,
5
6
7
8
9
10
What's this about? There's a reference
11
12
below to Christmas in Washington. Are you familiar
13
with the Christmas in Washington?
14
Yeah.
15
It's an annual event?
16
Correct. It happens -- I believe it's a
17
week from this Sunday. It's at the National
18
Building Museum. I've never been. I've been told
19
it's a lovely event. The president goes.
20
So this was referring to the tickets that
21
1111requests, because when you get the request form,
22
it asks you to list names. I'm assuming that's for
23
security clearance for White House personnel or
24
something.
25
But it asks you to put names down. And
26
111=11-SSCE0001 819
34
for some reason, the form says immediate family
member, but when you talk to the organization about
it and say, can I bring a friend, they're like,
yeah, that that's fine.
But the actual form itself -- and to this
day, I mean, I wish they would edit that to make it
clear, that, you know, if you don't have any
immediate family, you don't have to go alone. Or
maybe you do go alone. I've never been, so I don't
10
know. If I go, I'll go alone.
11
12
13
14
A Uh-huh.
15
16
17
I don't.
18
Did III ever tell you?
19
I'm sorry?
20
21
22
He did not, that I recall, no.
23
24
25
I do not -- do not recall.

BY
26
1.111-SSCE0001820
35
Can I just ask one question?
Yes, yes. I don't remember specifically,
2
3
4
but I'm sure it came up in the context of has this

6
been approved by ethics, because we have pretty much
everyone in our office that is invited to it. So I
would have cleared it for us.

And I'm pretty sure either I told
and
10
said, look, this has been cleared, or Masked me,
11
has this been cleared by ethics.

I can't remember if it says on the
12
13
invitation. A lot of folks are very helpful and
14
they do put at the bottom, "has been cleared by
15
Senate ethics." Of course, you call and ask for a
16
copy of the letter afterwards, just in case. But
17
that would -- that's my recollection.
18
But specifically, you don't recall
19
discussing the details of the charitable event
20
exception, anything like that?
21
No, no. I mean, a lot of times with our
22
staff, and with other folks, they're just asking, is
23
it approved or not, not what exception is it.
24
That's a conversation
25
if I tried to get into it with our staff, they would
and I would have. But
26
IIIMIIIIESSCE0001821
36
just glaze over and say, well, is the answer yes or
is the answer no?

Just to be clear, I was talking about any
3
4
recollection of having discussed such issues with
not with your own staff.
Right, right. No, I'm sure when we spoke
about going to Christmas in Washington, that either
I volunteered or' inquired whether it had been
approved by Senate ethics. I mean, usually when we
10
go -- are invited to an outside event, whoever it
11
would be, including
12
blessing is the only way you go to an event.
you know, you-all's
But again,
19
I apologize. I do not.
20
Okay. That's all, thank you.
21
I apologize that I was a little off when I
13
14
15
16
17
18
22
saw the immediate family. It hit that the
23
invitation says you have to take immediate family.
24
I apologize.
25
26
SSCE0001822
37
Okay.
Sir?
Thank you. And we can return, then, to
3
4
if you could -- you're in contact with Senator
Ensign's office on some occasions, I take it, with
Related to that matter, I was, that
particular amendment. Also, when they would come
down to the floor when I was in the whip office, I
10
basically lived on the floor. So whoever rolled
11
down with an amendment or good idea or crazy idea,
12
you know, I would deal with them. So yes, sir.
13
And we know from the e-mails that you were
14
in touch with
15
as well?
in Senator Ensign's office
16
Yes, sir.
17
Now, during a period of time that the

was also
18
committee is examining here,
19
an employee in Senator Ensign's office. Do you know
20
21
I do not.
22
So let me just ask you a couple of
23
questions, just to make sure that the record is
24
clear. You've never -- you've never met
25
Okay. I apologize. I've met
once. I
26
-SSCE0001823
38
When lifirst came on board,
don't know
said to me,
How you doing. And that's it. So, I mean,
3
4
this is
this is
I do not know
I met
once.
And other than pictures in the newspaper,
5
6
but for that, I wouldn't recognize
street.
8
9
10
11
12
15
Okay. Did you have any conversation with
at all while Illwas here working for Senator

Ensign?
A
Just other than the initial meeting is the
only one I recall.

Do you know what
13
14
on the
relationship was at
the time with Senator Ensign?

A
16
17
18
19
20
21
22
23
24
25
26
SSCE0001824
39
Senator Ensign.
2
3
And to your knowledge,
4
5
6
7
8
9
10
11
12
So I just don't know. I have --
13
14
Nobody ever said in Senator Ensign's
15
office, if the question relates to this subject
16
matter, transportation or something else,

Nobody ever said
17
18
19
that?
A
No one ever did.
20
But again, I've asked that
21
22
question, just out of curiosity,
23
in case we have -- no one really knows.
24
25
I want to follow up on that point that you
make that you asked -- you said you asked that
26
11.1.-SSCE0001825
40
question many times,

Of whom did you ask the question?
2
3
A
Many times?
4
5
6
7
8
9
10
11
12
13
14
15
There's another
16
over there that did
17
rules committee issues for a brief period of time
18
named
19
20
21
Did you ever say,
22
23
24
25
26
-SSCE0001826
4
5
6
7
8
9
10
11
Yeah.
12
13
14
15
16
17
18
It wasn't because of Hill experience?
19
20
21
22
23
When did you first meet
24
25
26
-SSCE0001827
43
1
2
3
4
5
A
Correct, yes.
Right. And after the election, what did
10
do?
11
6
7
8
After --
12
13
okay.
14
And the sequencing I can't recall.
15
16
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How do you spell that?

It's -- yeah, it's
22
downtown on 14th Street, and I believe they're based
23
in Oregon.
24
25
26
-SSCE0001829
44
2
3
Because, you know, you get two staffers
during November and December to do the transition

6
and kind of try to put together a team so they can
hit the ground running in January.
Okay.
9
10
11
12
A - I have. We've become better friends as
13
the years have gone on. We stayed in -- because we
14
have a lot of mutual friends, so we've stayed in
15
touch when he got back and then over the years have
16
just become better and better friends.

Q
Okay.
19
I have, yeah.
20
Right.
Yeah, was, I think,
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.11.-SSCE0001830
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1
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did.
Oh,
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Many times?
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Yes,
12
On a regular basis?
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did.
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SSCE0001831
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I apologize.
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No, that's okay.
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BY
16
Okay.
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.1111.-SSCE0001832
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2
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Okay.
6
I can't
7
8
recall the date. Do you recall?

A
That he -- yes.
12
You offered --
13
Had to do the math.
14
That's okay. I was doing it too. Were
9
10
11
15
you all friends by that time when he came here? By
16
then would you say you all were friends?

I would, yes.
17
18
Q Illijoins the Senate, someone you were
19
friendly with. Would you all have conversations
20
about work stuff, what's going on in the office and
21
things that were going on?
22
23
We would, not necessarily so much then,
because
24
25
most everyone it puts them to
26
-SSCE0001833
48
sleep. So there wasn't really a lot to talk about.
2
3
So, you know, we'd talk collegially,
4
5
but in terms of, like, policy things or -- we just
wouldn't because we didn't have any overlap.
7
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Golly.
Okay.
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MIE-SSCE0001834
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Can you tell me about that time?
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In terms of legislative issues?
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-SSCE0001835
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Okay. Right, right.
1
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BY
When was that?
Golly.
6
Thank you.
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MIESSCE0001836
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BY
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And you're referring --
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You and
I'm sorry.
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SSCE0001837
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Right, we were.
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SSCE0001838
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A
I mean, we
10
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wouldn't discuss in detail.
12
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That changed.
18
: Thank you.
19
BY
20
21
Just to stay with this one more minute, I
22
think the phrase you used before was you had heard,
23
observed or were told, and I don't know which one it
24
was,
25
26
MIE-SSCE0001839
54
1
2
I think the specific -- again, not the
specific issues.
3
4
So, you know, some issue du jour would
5
6
come up, and he would want to get involved in it.
8
9
10
So, you know, some staff are more
11
12
territorial than others. Some have really sharp
13
elbows; some are, like, fine, I'd be happy to let
14
you help.
15
But I think they have a lot of folks over
16
there that are the former, the sharp elbow, this is
17
my issue and you ought not be playing in it,
18
otherwise why did you hire me.

So that was the thing that sticks out the
19
20
most.
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.11.-SSCE0001840
And a specific instance?
1
Yes.
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: Thank you.
11
BY
12
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SSCE0001841
2
3
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Right.
we have certain offices that we kind of are
attentive to,
8
9
10
11
12
I mean, there are just some that you have
13
14
closer relationships with because you've worked with
15
them on legislative matters, and some of the staff
16
you just know better.
17
Okay.
No, that's a personal relationship. We
18
19
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22
don't get into how offices operate.
23
24
25
That's where we
26
IIINIBSSCE0001842
57
1
2
come in.
Q
so let me just get this down.
Gosh.
3
4
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6
7
Not about -- I mean, not necessarily
8
9
about this issue.

Right.
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Uh-huh, I did.
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SSCE0001843
Golly.
5
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8
9
is in
THE WITNESS: Right, because
10
11
cycle right now, yes.
12
BY
13
14
15
16
Yes.
17
Yeah, yeah.
18
(Exhibitall6 identified.)
19
BY
20
I will put before you and your
21
counsel the next exhibit, which is 111-6, and ask you
22
to take a look at that.

23
24
A Okay.
25
And looking at ExhibitillF6,
it
26
MIMI-SSCE0001844
59
1
2
A
It does.
4
5
6
A Yeah.
Do you remember that? What did that refer
I -- I don't remember it.
8
9
to?
10
11
12
13
14
But I don't
15
16
17
recall specifically.
Q
Okay.
18
19
Talk about that.
20
21
Sure.
22
What did you think about that at the time?
23
Well, it's Friday at 2:20, and a common
24
phrase we have around our office on Friday
25
afternoons is we're not going to make a career out
26
SSCE0001845
of the day. So it's kind of a race to the door,
because most times Thursday night the bosses are in
the air, or Friday morning, and so everyone just
kind of sits around and waits for the opportunity to
go, especially in our office, because we're so
floor-oriented.
7
8
9
mean, we're either on or off when we're up there.
10
There's no just kind of like constant, if you're in
11
a personal office.
So that's what the last part is.
12
13
14
15
16
So you respond and say what?
17
18
19
20
21
By that you mean?
22
23
24
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-SSCE0001846
61
1
2
3
4
So that's what that's about.
5
6
Let me ask you this. There are some
friendships that one has in life where you actually
do feel like talking about work at the end of the
day, because you feel like you need somebody to talk
10
to who would understand what you're saying and
11
understand your frustration, and further would care
12
about that.
13
A Uh-huh.
14
15
And would be there to kind of be a
sounding board and also to be an advisory.
16
17
18
A
Yeah, yeah.
24
Right.
25
19
20
21
22
23
26
11.11111-SSCE0001847
61
1
2
3
4
So that's what that's about.
5
6
Let me ask you this.
7
8
9
10
11
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A Uh-huh.
14
15
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19
Yeah, yeah.
Right.
20
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1111.1-SSCE0001847
1
2
3
4
Not that I --
Q
6
7
8
9
10
All right.
BY
11
12
you
13
14
described how in a personal office people kind of
15
wait for the boss to leave before they can take off.
16
17
18
19
20
21
No, no, no, no.
22
23
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.11.1-SSCE0001848
63
1
2
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5
No, Eldid not.
6
7
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Okay.
13
14
Okay.
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IMSSCE0001849
64
1
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9
Correct.
10
BY
11
Just a follow-up.
12
13
14
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17
18
19
20
I do not recall specifically. It would --
21
the specifics would be who the person is
22
trying to insert
23
was
with.
Again, with the issue set that I have, it
24
would -- even if Undid mention it was related to
25
blank, it would have just rolled right off the top
26
IIMESSCE0001850
65
of my head. I wouldn't know.

But it would have been, you know,
2
3
little world, so that would be it.
playing in
4
5
6
7
8
9
10
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15
: When you say you recall
16
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18
saying, who is
THE WITNESS: I'm sorry,
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26
IIIIM-SSCE0001851
66
1
2
3
4
A
6
Yes, or anyone else in the office.
No.
8
9
10
11
But in terms of specifics, no.
12
13
14
15
Did that ever come up?
16
17
No.
I don't know.
18
BY
19
20
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SSCE0001852
67
1
2
3
4
5
6
7
8
9
10
11
So let's break this down for a minute.
12
Sure.
Yeah, I think it was that Iltwas, again,
13
14
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16
17
getting involved in something, and I brought it
18
up --
19
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IM-SSCE0001853
68
Right.
3
4
5
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17
And to the extent we did have a
18
conversation, that's what it -- I mean, the flavor
19
of what we would have talked about.

BY
20
21
22
I'd like to bring your attention back to
Exhibit 6 here.
23
Of course.
24
And the line,
25
26
SSCE0001854
69
Just ask a couple more questions to probe
1
2
to see if it triggers a recollection.
Sure.
Do you happen to recall around this
time --
6
7
8
Do you seem to recall
9
10
that?
11
I don't. I don't.
12
Okay.
Not -- not to my knowledge.
13
14
15
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23
24
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-SSCE0001855
70
1
2
No, it doesn't bring up any recollection.

BY
3
4
5
6
No, no.
BY
7
8
9
10
11
12
13
14
Is that what happened, if you remember?
15
16
17
That I do not recall. I do not recall
specifically.
18
But you understand my question?
19
No, no, I understand, correct.
20
I will fill you in.
21
Nothing hits my recollection, other than,
22
again, another one of the conversations recounting
23
whatever problem of the day was being caused or
24
tensions between two employees that 111 would have
25
brought up. But I don't recall anything specific.
26
SSCE0001856
71
(Exhibit. 7 identified.)
BY
3
4
Q
Exhibit
I'm now going to show you an exhibit,

7. It's a three-page exhibit,
5
6
(Recess.)
BY
we remind you after the break that you
10
11
12
remain under oath.

A
Yes,
We have placed before you and your counsel
13
14
We're back ready to proceed, then.
a three-page exhibit
marked 11.-7,
15
16
17
18
19
Okay.
20
And what does that refer to, if
22
23
24
you remember?
A
25
26
all-SSCE0001857
72
2
3
4
5
6
7
(Laughter.)
BY
9
correct?
10
11
Exactly, correct.
12
(Laughter.)
13
BY
14
15
16
17
No, unfortunately they ran out.
18
19
Yes.
20
And what was his response?
21
22
23
24
25
And your response?
Okay. And --
26
IIIIII-SSCE0001858
73
2
3
4
5
6
7
8
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10
So tell us about that.
11
12
13
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18
19
20
21
22
23
24
25
Okay. And take us through the remaining
communications, if you would.

A
Sure.
26
-SSCE0001859
0981,00090SS-1.11
TZ
0Z
61
81
LT
91
ST
T7T
ET
ZT
17L
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Sure.
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Mal-SSCE0001861
1
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A .Uh-huh.
Correct?
5
6
Correct.
10
11
12
13
14
15
It wasn't -- it wasn't a protracted thing,
16
17
and there was really no discussion. And I'm sure I
18
inquired further, you know, why. And no one
19
one knew.
no
20
21
22
23
24
25
So you learned it from
26
1.11.-SSCE0001862
77
Yes.
I -- no, I don't believe so. No, I don't.
4
5
6
7
8
9
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11
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I did not.
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1.1.-SSCE0001863
78
79
11
17
But no, i t was a l l a mystery.
A No.
Q
19
Are you f a m i l i a r w i t h the
o r g a n i z a t i o n November Inc.?
A
21
No, okay.
Just what I read i n the news -- what I've
read i n the newspapers.

And what have you read i n t h e newspapers
23
about November Inc.?
26
Okay.
Let me see i f I can get t h i s r i g h t .
81
82
83
84
I b e l i e v e t h a t I read i t i n one of the
a r t i c l e s , but a t the time no one r e a l l y - - n o one
r e a l l y said.
4
I'm j u s t -- f o r the sake of completeness,
5
6
I want the record t o show t h a t we put --
Of course.
9
10
11
12
13
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15
16
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18
19
20
21
I don't r e c a l l which a r t i c l e i t was.
22
23
24
25
26
Was t h a t -- was t h a t The New York
Times or L.A. Times?

Q
That was New York Times.
85
New York Times, okay.
A
That was what you were -- you understood
t o describe t o you?
A
And
A
t e l l you what i t was about?
d i d not.
whatever issues
Again, t h e substance of
I don't r e a l l y know.
88
89
90
94
95
96
97
98
Okay. And what's the basis o f t h a t
12
13
14
15
16
17
18
19
20
Understood.
21
22
So i t would have j u s t been, i f anything,
23
t h a t i t was going t o happen but no substantive
24
discussion whatsoever.
25
26
A
Okay.
Not t h a t I r e c a l l .
That's my r e c o l l e c t i o n .
BY
Let me j u s t f o l l o w up on something you had
17
j u s t s a i d i n terms of
question --
19
quick question as a follow-up t o that?
21
BY
Not -- not t h a t I r e c a l l .
BY
26
4
5
THE
WITNESS:
Thank you.
You're welcome.
I want t o ask you j u s t a h y p o t h e t i c a l very
q u i c k l y and e a s i l y .
A colleague of yours s i x months
a f t e r he leaves your o f f i c e c a l l s you and says,
10
now
employed by such-and-such c o r p o r a t i o n .
11
you help us and c a l l Secretary
12
and arrange f o r me t o b r i n g the CEO
13
them."
14
rules?
15
"I'm
Could
So-and-So's o f f i c e
i n t o meet w i t h
Are you permitted t o do t h a t by the Senate
I don't believe so, and I would not do
16
Again, our o f f i c e takes a -- us personally, we take
17
an o v e r l y cautious -- not o v e r l y cautious.
18
very s t r i c t about not parsing, oh, w e l l , maybe t h i s ,
We
are
maybe
20
21
22
23
Something l i k e t h a t would come i n ,

a b s o l u t e l y not.
fl^^^H^^I:
We're ready t o proceed,
then, I t h i n k , t o 2009.
BY
25
26
I ' l l ask you -- and I can take those.
103
Oh, I'm s o r r y .
No, t h a t ' s okay.
I f o r g o t t h e y were h e r e .
And I ' l l be h a n d i n g you
o t h e r -- you and y o u r counsel a n o t h e r e x h i b i t
shortly.
But I ask you, when d i d you f i r s t
hear
t h a t Senator E n s i g n had had an a f f a i r and f r o m whom
d i d you hear i t ? What were t h e c i r c u m s t a n c e s o f
your l e a r n i n g
that?
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
I t h i n k t h a t ' s -- t h a t was about
because i t was a v e r y b r i e f c o n v e r s a t i o n .
it,
104
Because I t h i n k he f l e w o u t t h a t -- I
c a n ' t remember t h e sequence o f e v e n t s , b u t --
He, Senator
Senator Ensign went t o Nevada t o do t h e
10
press conference
11
I t wasn't f r o m
from t h e r e , i f I r e c a l l
D.C.
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
Ensign?
Correct
correctly.
107
14
On t h e day o f t h e --
That's my r e c o l l e c t i o n .
Q
So I ' l l
ask i f you c o u l d t r y t o r e c o l l e c t .
Okay.
12
13
14
don't
Q
recall.
Do you remember h i s -- I'm s o r r y f o r
interrupting.
Please.
15
No, no.
16
Do you remember, as you s i t h e r e today,
17
when was i t t h a t you d i d l e a r n ?
18
Was i t a c o u p l e o f days a f t e r t h e day t h a t we're
19
t a l k i n g about
20
26
How soon a f t e r ?
here?
I - - gosh.
110
(Exhibit
identified.)
BY
3
4
a two-page e x h i b i t marked
7
8
I'm g o i n g t o now show you and
So t h i s would be w i t h i n -A
I'm s o r r y ,
what day was t h e p u b l i c
14
possible that the time
15
f o r the
16
w h i c h c o u l d make i t June 19 l a t e a t n i g h t .
17
m i g h t r e c a l l whether i t was a t 3:45 i n t h e morning
18
o r not?
19
a t t h e t o p i s Greenwich mean t i m e ,
THE WITNESS:
But you
I'm s o r r y ?
r e c a l l whether i t
21
was a t 3:45 i n t h e m o r n i n g o r
22
23
24
THE WITNESS:
I would be sound
asleep.
Okay.
BY
26
No.
a t t h e bottom?
22
Oh, yes.
C o r r e c t , yes.
113
21
And my sense from y o u r t e s t i m o n y here i s
22
t h a t you've been v e r y c a r e f u l w i t h us t o d a y t o t e l l
23
us i f you're r e c o l l e c t i n g something
24
25
26
--
Correct.
f r o m y o u r r e c o l l e c t i o n on t h e one hand?
114
115
117
119
Yes.
And d i d y o u g i v e t h a t ?
I did.
BY
When was t h a t ?
sorry?
I t was a f t e r
2
3
4
5
-- was i t soon a f t e r
that?
Was i t i n August o r was i t l a t e r ?

A
Golly.
I don't r e c a l l
and I
don't r e c a l l what t h e c a t a l y s t was.
6
7
8
9
10
11
12
13
14
15
16
17
period that
18
of J u l y and August, i t ' s J u l y and August o f 2009?
19
20
21
22
23
24
25
26
J u s t so t h e r e c o r d i s c l e a r , t h e t i m e
BY
Q
t a l k i n g about h e r e when we speak
123
That's what we've h e a r d .
THE WITNESS:
What's t h a t ?
10
T h a t ' s what we hear.
THE
13
much l o n g e r ?
14
f i v e more m i n u t e s .
15
16
l o n g e r , maybe
a n o t h e r hour?
17
Maybe an hour.
18
Could we go f i v e more
19
m i n u t e s t o wrap up t h i s area?
20
a f t e r t h e break.
21
22
23
I'm g o i n g t o show y o u now

Exhibit
9.
(Exhibit
BY
26
And maybe an hour
9 i s a two-page
9
identified.)
exhibit.
124
125
Yeah, yes.
9
10
c o u l d ask i f y o u c o u l d
j u s t g i v e me a b r i e f moment w i t h my
11
co-counsel.
(Discussion o f f t h e record.)
12
I'm g o i n g t o mark a
13
one-page e x h i b i t ,
14
t o t e l l us a l l how many e x h i b i t s
15
go t h r o u g h b e f o r e t h e end o f t h e day.
16
s i n c e I premarked a l l o f t h e o t h e r e x h i b i t s .
17
we're d o i n g okay.
18
and i t ' s g o i n g t o be -- i t ' s g o i n g
THE WITNESS:
19
20
I anticipate
I t ' s 16,
w i l l be 16.
22
What number a r e we on?
So we don't have f a r t o go.
(Exhibit
Okay.
16 i d e n t i f i e d . )
BY
25
26
So
We've j u s t done 9, so t h i s
THE WITNESS:
24
we'll
We don't have f a r t o go.
one-page e x h i b i t ,
And i t ' s a
and I p l a c e i t b e f o r e you.
127
|: Now i s a good t i m e f o r us
2
3
t o break.
4
BY
5
6
7
We're back on t h e r e c o r d ,
we r e m i n d you t h a t y o u remain under
Yes,
So
ready t o p r o c e e d
10
11
12
13
14
15
16
17
18
19
Am I c o r r e c t ?
Yeah.
20
21
22
23
24
25
26
Correct
oath.
129
130
132
f o r more t h a n t h a t w o u l d n o t be p e r m i t t e d ?
I n my v i e w ,
correct.
Correct,
10
Correct.
13
Correct.
15
Correct.
20
I'm sure I d i d .
correct.
There were s e v e r a l --
anymore
23
25
26
mean, anymore c o n t e x t t o w h i c h
specific?
I s t h e r e one t h a t you t h i n k o f as t h e b i g
133
134
135
136
1
2
3
4
5
6
7
10
11
12
13
14
I don't.
15
Sequencing,
right.
BY
16
17
I d o n ' t remember t h e sequencing.
W e l l , I t h i n k we've asked you -- and I
18
won't go over t h i n g s t h a t we've asked you.
19
j u s t ask one q u i c k q u e s t i o n .
20
21
22
23
24
25
26
I ' l l
That i s c o r r e c t
3
4
5
6
7
8
9
10
11
W e l l , t h e t i m e s t h a t I t o l d you t h a t --
12
Other t h a n
13
Other t h a n t h o s e .
14
C o r r e c t , do n o t
L e t me ask f o r a b r i e f
15
16
(Discussion o f f the record.)
17
BY
18
19
20
21
When d i d you f i r s t
22
23
24
25
26
learn
Hold on a second,
m i s i n t e r p r e t e d your question.
move on.
We're n o t ready t o
We're n o t o f f
I a p o l o g i z e and I ' l l
turn
138
1
2
3
t o my c o l l e a g u e s here.
I f we need a b r e a k -need t o mark t h e
139
(Exhibit
as an
11
exhibit f o r the
12
t o y o u and t o y o u r c o u n s e l .
13
Okay.
you
17
t o take a look a t t h a t .
18
(Witness r e v i e w e d t h e document.)
19
I'm happy t o read t h e whole t h i n g b u t --
20
I can t e l l y o u --
21.
- - i s t h e r e a p a r t y o u can p o i n t me t o ?
26
141
I'm s o r r y , what was t h e q u e s t i o n ?
143
145
147
1
2
3
right
Do y o u r e c a l l t h a t ?
7
We
8
9
d e t a i l , b u t you can f l i p t h r o u g h , i f you --
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
want you t o go t h r o u g h them i n
A
them.
Q
Oh, dear.
That's why I d i d n ' t l o o k a t
148
150
151
1
2
3
Could you -- I'm t r y i n g t o -- I'm s o r r y .
And more r e l e v a n t ,
d i d you u n d e r s t a n d a t
t h e t i m e t h a t t h i s --
6
7
8
THE WITNESS:
BY
Oh, oh, oh, oh.
10
11
12
13
14
15
16
17
18
19
20
asked a v e r y
21
22
q u e s t i o n , and I ' d l i k e y o u t o
23
BY
24
25
26
specific
152
153
154
18
W e l l , t h e i n s t a n c e , as we t a l k e d about --
21
The one, and t h e n w i t h t h e o t h e r one,
157
158
161
162
163
164
Not
apologize?
10
11
no.
don't we t a k e a m i n u t e
o r two o f f t h e r e c o r d .
12
(Recess.)
BY
14
We're ready t o proceed.
15
record.
And,
16
you r e m a i n under o a t h .
17
Correct.
21
Correct.
Okay.
26
We're back on t h e
again
that
166
Yes,
10
But I have an e x h i b i t t h a t we have marked.
By t h e Senator?
I t ' s E x h i b i t 14, a c t u a l l y .
12
(Exhibit
14
identified.)
I t ' s a three-page e x h i b i t .
And f o r t h e
15
r e c o r d , I'm g o i n g t o p u t on t h e r e c o r d t h a t we w i l l
16
n o t be showing you E x h i b i t s 10, 1 1 , 12 and 13.
17
18
These a r e two d i f f e r e n t ones

here.
sorry?
20
T h i s i s something --
21
22
24
25
26
THE WITNESS:
Committee o r someone.
This i s i t ,
This i s from t h e E t h i c s
I don't know what t h a t i s .
sorry.
That's i t ,
you have -- you have b e f o r e you
okay.
So
which
167
1
2
i s a three-page e x h i b i t .
A
3
4
5
6
7
8
9
10
11
12
13
Correct, yes.
14
Halfway down t h e f i r s t page?
15
Correct.
16
17
18
19
20
21
22
23
24
25
26
Okay.
Yes, s i r .
168
169
1
2
3
4
5
A
I do n o t r e c a l l t h a t I d i d .
9
10
11
12
No, I do n o t t a k e i t t o mean t h a t ,
13
Thank you.
14
(Exhibit
15
BY
16
I'll
show y o u a one-page e x h i b i t marked
And I t h i n k I have an unmarked copy f o r you,
17
18
19
20
21
Uh-huh.
22
23
24
25
26
identified.)
Uh-huh.
172
10
Okay.
11
12
15
No, no, o f
sure.
I'm n o t -- I'm n o t i m p l y i n g a n y t h i n g by
the question.
A
Absolutely. .
16
17
22
26
t h a t I'm
simply p u t t i n g a question.
13
14
Well, please understand
another
on t h i s document b e f o r e we move on.
Correct.
question
10
11
Yeah, t h e
t h e name d i d -- i t d i d r i n g a
b e l l t h a t t h a t was one i n whatever --
12
Wait a
Per t h e
13
a r t i c l e s t h a t a r e a l r e a d y -- t h e a r t i c l e i s i n
14
October.
T h i s i s --
15
16
a r t i c l e s --
21
22
Yeah, i f I'm -And what I'm. a s k i n g i s --
23
24
I don't t h i n k t h a t was
testimony.
BY
26
No, no, t h e o t h e r
177
180
19
20
21
26
S p e c i f i c a l l y Senator Ensign, I d o n ' t
r e c a l l h i m ever s a y i n g t h a t , no.
Q
Anyone e l s e ?
181
1
2
3
4
5
6
But not -- not specifically the Senator
8
9
that I recall.
Q
Okay.
10
11
12
13
14
15
16
17
18
19
apologize.
20
21
No, that's okay. I'm just confused.

These are kind of just wrap-up questions.
22
23
24
25
26
1.1111SSCE0001967
2
3
A
5
Yeah, yeah, yeah, yeah. No, I do
understand.
6
7
8
Or anything to that general effect?
: In words or substance.
10
THE WITNESS: Yeah. No, no.
11
12
13
14
15
16
17
18
19
But specifically Senator Ensign, no.
20
BY
21
22
23
24
25
26
SSCE0001968
183
1
2
3
4
5
6
8
9
10
11
Not -- not that I recall, no.

BY
12
we prepared for this deposition
13
with an effort to make sure that we covered with you
14
everything that we had reason to believe you would
15
have some knowledge of to be of assistance to the
16
committee.
17
Okay.
18
So we ask you now, is there anything that
19
you would have to offer, anything that you know or
20
any knowledge of any event or of anything that
21
you've -- that we've not covered with you that
22
you've not testified to about this matter?
23
Not -- no, not that I can think of.
24
Okay. Anything that you expected we would
25
ask you about that we have not asked you?
26
MII-SSCE0001969
184
A No.
Okay. We thank you both. We say to you
that the committee inquiry is not done and that in
the event that something were to develop that we
would need to reach out to you again, we would reach
out to
A Okay.
8
9
to your counsel.
And we say to you also that when the

transcript is done, we'll giveIIIIIIIIIIII a call.
10
Okay.
11
And finally, we end with the notion that
12
we started with earlier on, that the rule of
13
confidentiality applies to us, all of us, committee
14
staff and the committee. It doesn't apply to you.
15
But we ask you not to discuss' your testimony here or
16
the fact of your deposition with anyone other than

your counsel.
17
18
Okay.
Thank you.
19
20
THE WITNESS: Thanks.
21
22
was concluded.)
23
24
25
26
-SSCE0001970
185
5
6
7
8
9
10
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12
day of
, 20
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15
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17
Notary Public
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MIII
-SSCE0001971
186
CONTENTS
2
3
WITNESS
EXAMINATION
4
5
by
6
7
8
9
10
11
12
EXHIBITS
EXHIBIT NUMBER
IDENTIFIED
13
14
24
15
24
16
24
17
31
18
58
19
71
20
110
21
123
22
14
166
23
15
169
24
16
126
25
17
140
-SSCE0001972
10
14
42
144
146
179

2
Washington, D.C.
3
4
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Tuesday, June 8, 2010
15
16
17

18
Suite 220
19
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REPORTED BY:
25
26
11111111-SSCE0006082
called for
Deposition of
Monday, June 7, 2010, in Washington, DC, at the


6
8
9
ESQ.
ESQ.
11.11111111111.11 ESQ
ESQ.
13
14
15
16
17
18
19
20

Committee on Ethics
202-224-2981
111111101111/ethics.senate.gov
1111111111111pethics senate.gov
21
22
Committee
On behalf of Senate Ethics
23
24
-- continued --
25
26
11111111-SSCE0006083
APPEARANCES (Continued):
1
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3
Committee on Ethics
202
10
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Mila-SSCE0006084
PROCEEDINGS
: Good morning,
2
3
THE WITNESS: Good morning.
I, as you know, am
5
111111111 and I will be conducting the questioning
for the deposition, along with my colleagues. But I
will take the lead.

Initially, we give you introductory
8
9
warnings that we give every witness who appears in a

10
11
12
13
14
15
deposition before the Committee, and we advise you

that the Senate Select Committee on Ethics has
summoned you here today for this deposition as a
witness in connection with the committee's
preliminary inquiry concerning Senator John Ensign.
17
by
18
counsel,
19
20
and I am joined
My name is
16
on my left, who is our chief

on
left, who is my
colleague and also counsel on the staff,

111111111on my right, who is my colleague and also
who is
and
21
22
our deputy staff director, is with us as well.

All of us have been authorized by the
23
24
25
committee to participate in the questioning in the

deposition.
26
IIIIIIIISSCE0006085
Our questions and your answers will be
taken down by the court reporter, who is with us.
And because it's a deposition before a legislative
branch agency, your statements are subject to the
False Statements Statute, Section 1001 of
Title XVIII.
Additionally, because it's a sworn
deposition, your statements are subject to penalty
of perjury under the rules of the Senate
9
10
11
12
13
specifically set of this committee, section 7B of

the supplementary procedural rules of the Select
Committee on Ethics.
THE WITNESS: Okay.
We've given you a copy of
14
15
16
those rules, and they are in front of you.

THE WITNESS: Okay.
: Your testimony is also
17
18
19
20
21
22
subject to the provisions of Section 1621 of

Title XVIII of the United States Code, which
would -- as well as the obstruction of Congress
statute, which appears in Section 1505 of
Title XVIII.
Thus, if you were to make an intentionally
23
24
25
26
false statement or knowingly mislead the committee

in any way in connection with your testimony about a
material matter in this inquiry, you would subject

1
yourself to the possibility of prosecution under any
2
of those statutes. And you understand that?
THE WITNESS: I understand that.

4
Yeah. At this point,
5
I would ask that the court reporter
6
7
swear you as a witness.
Whereupon,
9
10
11
EXAMINATION
12
BY
so I would ask you, having given you the
13
14
15
Q
warnings that we give to all witnesses, you
understand that your statements today are subject to

16
the statutes and the committee rules concerning
17
false statements, perjury and obstruction of
18
19
20
Congress?
Yes.
A
t--IIIIINIIIIINI I advise you that in
21
connection with your appearance here before the
22
committee to give testimony in deposition, that your
23
right -- you have a right to consult with counsel
24
and have counsel accompany you in connection with
25
26
11111111-SSCE0006 087
your appearance. And you understand that?
I do.
And you've informed us, have you not, that

Q
it's your wish to proceed without counsel today?
3
4
That's correct.
Okay. If at any time during the course of

Q
the questioning you wish to take a break for any
6
7
reason, you just indicate that and let us know, and
that's what we'll do.
9
10
11
12
And so if it's your desire to proceed,
then we'll proceed.
13
14
15
Okay.
Absolutely, I'm ready when you are.

As I mentioned to you, we've given you a
copy of our procedural rules. They govern the

conduct of the work of the committee and committee
16
counsel staff. They govern this deposition and your
17
18
statements and our work as well.

They contain the rule of confidentiality
19
that applies to us essentially. We don't talk about
20
21
22
23
24
25
our work utcide of our work. But the rule of

confidentiality does not apply to you. You're
actually free to discuss your testimony or your
deposition with anyone you wish.
A
Okay.
26
1111111-SSCE0006088
However, to protect the integrity of the
committee process and the integrity of the
investigation, we request that you not discuss your
testimony, particularly with anybody else who you

think might be -- might also be a witness in the
matter.
A Understood.
And the reason for that is so that it

Q
wouldn't interfere with everyone's best recollection
8
9
of the events.
10
11
A Okay.
12
13
I understand that.
14
Thank you.
And you understand that?
Also pursuant to the same supplementary

15
16
rules, you're entitled to inspect a copy of a

transcript of your deposition. And after examining
17
18
it, if you believe there are any errors, you're

entitled to the opportunity to request that errors
19
20
be corrected.
Wc make that available to you in the
21
22
committee spaces here.
23
24
25
Okay.
So what we'll do at the end of the
deposition is we'll wait to hear from the court
26
111111111SSCE0006089
reporter, and when we hear from'
that the
transcript is ready, we'll let you know.
Great.
And then at a time that's convenient to

Q
you and the committee staff, we'll make it available
4
5
to you, you'll come in and review it. Any errors

that you think are there, we can discuss them and go
7
forward.
Okay. Thank you.
I mentioned to you, and I'll mention

Q
again, that if at any time during the deposition
10
11
that you want to take a break, you let us know and

12
13
we'll do it.
14
15
Thank you.
During the course of the deposition, I'll

Q
perhaps be showing you documents. The purpose of
16
17
that is actually to be helpful to you. To the

extent to which a document might help refresh your
18
19
recollection, we can do that.

(Exhibit Ilk identified.)
20
21
22
First, however, I've marked as Exhibit

Q
Ilkl a copy of our deposition, and I would ask you
23
24
25
for the record to identify that document.

A
Yes, this is the summons I received by
26
IIIII-SSCE0006090
10
e-mail and also by Federal Express.
Okay. And the summons to appear here and
to give a deposition?
3
4
That's correct.
Very good, thank you.

what I would like to do
6
would be to start out by asking you to tell us a
little bit about yourself, particularly your
8
9
10
educational background.
A
Sure.
11
12
Q Whereabouts?
13
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MM-SSCE0006091
11
1
2
3
4
5
6
7
Let me get -- I'll get to that in a
Q
minute. Sorry to interrupt you.
8
9
10
11
12
Sure.
just want to make sure that I have a
sense of a number of things here.
13
14
A 1111111
15
16
That's right.
17
18
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11111111-SSCE0006092
12
Okay. And. then after that?
4
A
5
6
Right
9
Q
10
111111111111111111111111111111
11
That's correct.
12
13
111111.111111111111111111111111
14
15
16
17
Ell
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19
20
21
22
MEM
23
Yes.
24
25
NMI.
26
11.111-SSCE0006093
13
Right.
1
2
3
4
5
Right.
A
7
8
9
Okay.
10
11
12
13
14
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16
Not really. Not really.
11111.1111111111111.11.11111111
17
18
That's correct.
Okay.
19
20
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22
That's correct.
23
24
25
26
MitSSCE0006094
14
1
2
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Right.
18
Yes.
19
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23
Right.
24
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aimiSSCE0006095
15
Right.
1
2
3
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8
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10
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15
Yes.
16
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25
Yes.
Okay.
26
MIIIIKSSCE0006096
16
1
A
2
3
4
5
6
7
8
9
10
I see.
11
12
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15
Okay.
16
17
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19
That's correct.
Okay.
20
21
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23
Okay.
24
25
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-SSCE0006097
17
1
2
5
6
7
8
9
10
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Right.
Yes.
23
24
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-SSCE0006098
18
Okay.
1
2
3
4
A
5
6
7
8
Right.
Yes.
13
Yes.
14
Any others?
15
Not that -- not that I can recall. Those
9
10
11
12
16
17
18
would be the principal people.

Q
Okay. So when you came to the Senator's
personal office, you had met with the Senator
19
personally?
20
Oh, yes. Yes.
21
H w w uld you describe your relationship
22
23
24
with Senator Ensign?

A
I think it was a good working
relationship.
25
26
IIIIII-SSCE0006099
19
1
2
3
4
5
7
8
9
10
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12
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Q
Okay.
18
That's correct.
19
20
22
16
17
Well, when I was --
23
24
25
That's correct.
26
SSCE0006100
20
Okay.
1
2
Yes.
Okay.
A
5
6
7
8
9
10
11
I see. Okay.
12
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-SSCE00061 01
ZO 900090SS-
OZ
61
81
LT
91
ST
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OT
6
8
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0,11-6P1
TZ
22
6
7
Q
9
Okay.
10
11
12
That's what I meant, close professionally.
13
Right.
14
Yes.
15
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SSCE00061 03
23
1
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Okay.
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A
Yes.
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Issues?
26
.1111-SSCE00061 04
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Yes.
In issues?
That's correct. In legislative issues,
yeah.
5
No.
No, or energy issues?
A
9
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We did, yes.
23
Who was the person?
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1111111-SSCE00061 05
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1
2
3
4
5
6
7
8
Social contacts would be office-related?
9
10
11
12
That's correct. That's correct.

I want to show you a document and just ask
you to take a look at it.

(Exhibitlig2 identified.)
13
BY
14
15
16
17
18
This is Exhibit 1-2, and sorry that the

Q
Bates number is camouflaged. But I'll ask you to
identify it, and then the record will reflect what
it is.
So you could take a look at that document
19
20
and then identify it for us.

(Witness reviPmed the document.)
21
22
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1
2
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Q
Okay.
Yes, that's correct. That's correct.
That's correct.
15
That's correct.
16
5
6
7
8
9
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18
And it's from you to -- I just want, so
that the record will contain your explanation.

A
Yes.
Yes.
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And if you (lould put on the record --
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24
Right.
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111111illSSCE00061 07
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2
That's correct.
Can I just put on the

4
record that this documpnt has a Bates stamp which is
obscured on that copy, but it's 2368.
Thank you.
THE WITNESS: Can I just inquire what the

8
9
importance of the Bates stamp is?

It's for recordkeeping for
us.
THE WITNESS: Just wanted to know, thank
13
you.
: So we can identify it if we
14
15
lose track of it.

THE WITNESS: Thank you. Fair enough.
16
BY
17
18
19
20
In reviewing a transcript, the record

Q
would contain a reference so that we could go right
to the document if we --
21
22
Okay.
23
24
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SSCE00061 08
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1
Yes.
2
3
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7
was --
10
Yes.
Do you know anything about that, what that
I have no idea what that was about.
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Q
Rigbt 1111111111111111111111111111111111
23
lam.
24
1111111.111.
11111111111111111111111111111111"i
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111.111111111.
111
26
11.IIII-SSCE0006109
29
1
2
Right.
3
4
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7
Uh -huh.
10
11
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Okay.
It was -- it was fine.
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1111111SSCE 0006110
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No.
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No. Why not?
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1.11-SSCE0006111
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I believe so, yes.
Right. And that's your recollection?
2
A
3
4
But in --
5
6
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8
9
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15
Okay. And did you attend the meeting?
16
Yes, I did.
17
BY
18
19
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21
22
Exhibit III-3, which is the Ensign document 1073

Bates stamp. And Tici just ask you to take a look at
that.
23
I'll ask if you could identify that
24
25
I'm going to mark as an exhibit here
document.
26
111111111-SSCE000611 2
32
4
5
6
And then Ensign's office and all
7
8
that.
9
10
11
12
13
14
I -- I don't know. I don't know if this
was, in fact, that meeting. We had all-staff

meetings frequently, so I can't say whether it was.
15
16
17
Right, very good. Okay.
18
19
20
23
24
11111111111111111111111111111111111
1111111111111111
25
-----1
26
SSCE0006113
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1
2
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5
Pardon?
6
7
But that was basically i
8
9
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19
Yeah.
20
22
23
24
25
I think it was interest -- you know, we
talked to, you know, people in the office just to,

you know, kind of get their sense of it. I'm sure
26
-SSCE0006114
34
it came up in several conversations just, you know,
between fellow staff, what people thought of it.
You know, I 'm sure I had a few
conversations like that, yes.
I'm asking --
5
6
7
THE WITNESS:
8
9
10
11
12
13
: Thank you.
14
THE WITNESS: So I think it would have
15
16
17
been pretty hard for me to, you know, have

conversations before that.
BY
18
Okay. So I don't think we had made that

19
20
2
clear.
Ti
22
23
24
I believe that's correct.
25
26
ENM-SSCE0006115
35
Okay.
1
2
3
4
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7
8
We're asking you to share with us the
9
10
11
events that followed.

A
Yeah, yeah, yeah.
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-SSCE0006116
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1
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Q
6
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I may have.
Okay.
I -- I didn't.
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Right.
24
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IIIIII-SSCE 0006117
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Right.
6
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9
Right,
That's correct.
right.
10
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Right.
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About the -- yes.
17
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SSCE0006118
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7
8
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That's correct.
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Okay.
25
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IIIMI-SSCE0006119
0Z1,900090SS
9Z
EZ
V
umimomamma1111g
SGA
TZ
OZ
61
81
LT
91
ST
T7T
ET
ZT
TT
OT
6
8
GE
SA
sax
T7
40
1
2
Okay.
3
4
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7
8
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11
Right.
12
13
14
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16
17
Yes.
18
(Exhibit I1F4 identified.)
19
BY
20
I'm going to show you an exhibit. It's --
22
I have a question.
23
24
25
26
-SSCE0006121
41
1
2
3
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Q
1111111111.111111111011111111111111.1111
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I did not.
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SSCE0006122
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2
3
: Thank you.
THE WITNESS: You're welcome.
BY
I am now showing you Exhibit 111-4, which
is the Ensign Bates number 126, and ask you to take
8
9
a look.
A Okay.
10
Okay. Can you identify Exhibit
11
12
13
for
us?
A
14
15
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-SSCE0006123
43
1
2
3
4
Q Right. Okay. So if we just -- what I
want to do is take it easily step by step.
6
7
8
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10
That's correct, I did not receive it.
11
12
13
That's correct.
14
Right.
15
16
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Correct?
18
19
Uh-huh.
That's correct.
20
21
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25
Okay.
26
11.11-SSCE0006124
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1
2
Not that -- not that I'm aware o
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Right.
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12
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Right.
18
19
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24
25
Now, at or about --
26
-SSCE0006125
45
: I have a question about
that, just to follow up.
: Of course.
3
BY
4
5
6
7
8
9
10
Not that I can recall. Not that I can
recall.
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12
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25
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-SSCE00061 26
46
Honestly, I don't recall. I don't recall.
I'm sure --
That's fine.
That could have happened, but I don't
recall. That's not something I remember being
focused on.
BY
I have a follow-up as well.
8
9
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IMN.SSCE00061 27
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1
BY
2
Q
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I didn't.
17
BY
18
19
Can I ask just kind of a general follow-up
question here?
20
22
23
24
25
Uh-huh, uh-huh.
26
IIIIIII-SSCE0006128
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1
2
3
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13
Can I follow up with that a little bit.
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SSCE00061 30
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I want to ask that.
Q
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-SSCE0006131
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2
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: Thank you.
18
BY
19
20
Let me just ask a couple more follow-up
questi nc n that
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1111111-SSCE 0006132
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1
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Thank you.
22
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BY
So you -- there's handwriting on the
document; right?
26
MI-SSCE0006133
53
Yes.
And do you identify -- do you recognize
the handwriting?
4
5
6
7
A Yeah.
8
9
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Okay. Take us through this, if you would.

Q
Jul. go d wn line by line, if you could tell us what
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we see here.
23
Yeah.
24
25
A Yeah.
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1111111-SSCE 0006134
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1
2
Okay.
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A
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Okay.
7
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Certainly.
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All right.
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SSCE00061 35
56
I think -- yeah, I believe I did.
A
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17,
18
: We'll get there.

19
THE WITNESS: I believe -- yeah, that's
20
: We'll get there.
21
BY
22
23
But I want to first make sure that we -Q

our record is clear here, what your recollection is.
24
25
Yes.
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1001101-SSCE0006137
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1
2
A
Yes, yes.
Yes.
okay.
3
4
8
9
Okay.
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-SSCE00061 38
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1
2
So I think it was something along those
lines, but I don't recall.
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5
6
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8
9
10
That's correct.
Yeah, I -- I don't want to make a judgment
11
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on that.
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Yes.
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IIIIIII-SSCE00061 39
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Yes.
Yes.
Q
A
Yes.
11
Exactly.
12
Yes.
13
9
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15
No.
: Can I follow up with a
16
17
quick question?
BY
18
19
20
22
23
24
25
Not that I can recall.
26
SSCE00061 40
60
1
Thank you, okay.
I don, t want to jump the gun
but I just have a couple of quick questions.
: Go ahead.
5
BY
6
7
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9
A Uh-huh.
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-SSCE0006141
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Yes, I did.
Can you describe what you can recall about
3
4
5
that conversation?
A
6
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21.
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IIIII-SSCE 0006142
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Okay.
16
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z
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-SSCE0006143
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1
2
3
4
: Go ahead.
5
BY
6
7
8
9
10
11
12
13
14
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16
17
I wasn't part of that conversation so at
18
19
20
least that original -Q
21
22
That's correct.
23
24
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1.IIIUSCE0006144
64
4
A
5
6
7
8
9
10
11
12
13
Okay.
14
15
16
17
18
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20
A
You know, I think it was
something like that. That's not a direct quote.
2
22
23
24
25
26
SSCE00061 45
66
: I think we'll get there,

1
okay. That's enough then.
BY
Let me ask you something.
4
5
6
7
8
9
10
11
12
Yes.
13
14
011111111111111111111.11111111111
15
16
Yes.
17
18
19
20
22
Is that correct?
23
24
Uh-huh, yes.
Yes, that's correct.
25
26
11.11-SSCE0006147
67
1
2
3
4
5
6
A
8
9
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11
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BY
14
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17
Yes, yes.
Yes
18
19
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2-1
22
23
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allaSSCE0006148
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Yes, I believe that's correct.
2
3
4
A
5
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Okay.
21
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SSCE00061 50
70
2
3
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5
Yes, I
And who was the person who spoke those
6
7
I believe so, yeah.
words?
11
12
13
14
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16
17
18
19
20
21
22
So you don't know?
23
I don't know, that's correct. I don't
24
know everyone who was there, that's right.
25
26
1.11-SSCE00061 51
71
1
2
A
3
4
5
6
I don't know.
: Was the Senator present?

THE WITNESS:- No.
BY
10
Do you recall when this took place?
11
12
13
: Thank you.
14
BY
15
16
17
And again, if you have to close your eyes
and picture the meeting and all that -: We do have a calendar
18
19
available, too.
BY
20
22
23
24
You know, I think I've conveyed what the
essence of it is.
25
26
IIIIII-SSCE00061 52
72
1
3
4
6
7
8
9
Not that
7-
not to my recollection, no.
10
11
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1111111.SSCE00061 53
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As a --
20
BV
22
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It would -- it would depend.
24
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-SSCE00061 54
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1
2
Right.
Right.
Right.
Right.
3
4
5
6
7
8
9
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11
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13
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15
16
17
Yes.
18
19
20
21
And your recollection is the Senator was
22
23
not there?
24
My recollection was he was not there.
25
Okay.
26
IIMM-SSCE00061 56
76
1
A
2
3
Okay.
4
5
6
7
8
9
10
11
Right.
12
13
14
15
A
But I - Q
16
17
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20
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23
24
Yes, that's right, I believe so.
25
26
-SSCE0006157
77
before you left?

That's correct.
A
3
4
5
Right.
: Go ahead.
7
BY
A few more questions on that matter.

10
11
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IIIIIBSSCE00061 58
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Okay.
5
6
7
8
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20
zl.
22
23
Okay.
24
25
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-SSCE0006160
80
I don't.
Okay.
3
A
4
5
6
7
8
Okay.
Usually, there would be.
10
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SSCE00061 61
81
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No, it depended on the schedule.
8
9
10
11
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14
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16
Okay.
17
18
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24
25
26
ilmBSSCE0006162
82
1
2
: Okay. Thank you.
3
BY
4
5
6
7
8
9
Not that -- no.
10
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SSCE00061 63
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Yeah.
8
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Right.
12
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22
And I had another one.
23
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Yeah.
23
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-SSCE0006165
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1
A
2
3
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BY
20
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23
That's correct,
BY
24
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BY
20
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24
I don't know.
25
Don't know?
26
01111SCE00061 67
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1
2
3
4
5
Yes.
Yes.
6
7
8
9
10
11
Uh-huh.
12
13
14
15
16
Uh-huh.
17
18
19
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2
22
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24
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26
all-SSCE0006168
88
1
2
3
All right.
4
5
6
7
8
9
10
11
12
13
14
15
16
17
I want to show you a document here that
18
19
you've referred to earlier, actually, I think, but
20
I'll ask you to look at the document and identify
22
Okay.
23
But let me ask you this first. We've gone
24
for an hour and a half. Is it okay with you to keep
25
going? I indicated at the start if you ever want to
26
IIII-SSCE0006169
89
take a five- or 10-minute break, you'll tell us
that.
Yeah. If we could just take just a
two-minute break, I just want to just do one thing

5
real quick.
: Of course.
6
(Recess.)
We're back on the record.
8
BY
And
10
11
12
you're still under oath. And you understand that?

I do.
And we'll proceed where we were when we
13
14
took a 10-minute-or-50 break.

(Exhibit 1115A, 5B and 5C identified.)
15
BY
16
I'm showing you a document which has been
17
18
19
marked as an Exhibit II-5A, 5B and SC. Ensign Bates

stamp numbers are 127, 128 and 129.
I ask you to take a look at the document.
20
21
22
23
Th=re are three pages to the exhibit. Examine them

and then tell us, if you would, if you recognize the
document.
24
25
, I'll remind you that
Yes, I do.
26
SSCE0006170
90
to be?
Okay. What do you recognize the document
I recognize the document actually to be

If you could go by order of
4
5
the number so we are clear on the record.

THE WITNESS: Certainly, certainly.
recognizell11-5A
8
9
10
11
And I believe actually that the document
12
13
that you have labeled as 11-5C is also related to
14
that general -- to II[5A, which I believe that that
15
document was part of that discussion or was -- or
16
was written down right after that discussion.

BY
17
18
19
20
Let me ask you to take a look at III-5A.
Is the document dated?.

A
It is.
21
22
23
24
25
Okay. Let me ask you now to take a look
at document 1111-5C.
A
Yes.
26
1111.11-SSCE0006171
91
Is that document dated?
It is not.
Is 5B dated?
3
4
It is.
5
6
Okay.
10
Yes.
11
-- on several occasions during this
8
9
12
period?
13
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Okay.
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right.
BY
22
23
All
Can I just clarify what you're saying
earlier? Are you saying that 5C appears to be the

second page of 5A?
26
-SSCE0006172
92
I think so. I believe that those --
So it's out of order?
Yes, I believe that's correct.
Okay. Thank you.
BY
Q
So that we're clear here, then, SA is
That's correct.
13
14
And the Bates number on that
15
Phone conversation.
16
Q Pardon?
17
A phone -- it was a phone conversation.
18
Right.
19
Yes.
20
21
22
And then 5B, what's the Bates number on
6
7
8
9
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11
12
23
Right. Bates number there is 129; right?
your 5B there?
24
Bates number I have is Ensign-JE-000128.
25
Okay. So that's --
26
-SSCE0006173
93
correct?
That's correct.
Okay.
3
4
6
7
SB is
And then if you go to the next page, it's
IIII5C, and it's Bates number 127?

That's correct.
That's undated?
8
9
10
That's correct.
11
12
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Okay.
17
18
19
Yes.
20
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22721111111111111111111111
24
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111111-SSCE 0006174
94
Okay.
And there is sort of an --
2
3
I'm sorry, if I could interrupt, I believe

that's marked 5C, or do I have that wrong?
For the record, the Bates

6
numbers 127, 128, 129 are the reverse of the -- this
is the order it was provided to the committee
originally, 127 was the first page in the pile, 128
9
10
was the second page.

: And I just want to confirm
11
12
that I've got -: That's exactly what we do
13
14
here.
BY
15
16
May I see the exhibit?
17
You sure can.
18
Thank you.
: Thanks.
19
BY
20
21
Thank you.
22
23
24
25
c we'll hand the exhibit back to you,
Certainly.
As you can see, the production reversed

Q
the order and the Bates numbers, you know what I
26
MIIIIISSCE0006175
95
mean, are not necessarily chronological
1
2
Yes, I understand.
That's okay, though. The important thing
is we be clear and the record be clear.
4
5
A Absolutely.
Take it from there, if you would.

Yes.
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All right.
22
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That's c rrect, that's correct.
24
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Okay. So as you look at the document,
26
SSCE0006I 76
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it's on your right-hand side?

2
That's correct.
Okay. Go ahead.
7
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Okay.
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MIIIISSCE0006177
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1
2
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Would you like me to continue in order of
4
5
the document?
Yes, please. Just so the record will
6
7
8
reflect, if you're reading from a document, what is

marked on the document-.
9
10
11
12
The second document I have is III5B, as in
Right. But read chronologically. In
boy.
other words, 5C, if we were to go to 5C, would we be
13
staying with
14
15
16
17
20
Then that's what we ask you to do. Sorry
to interrupt you.
A
So now I'm on III-5C.

Right.
18
19
I believe -- I believe so. That's
Which has the Bates number 127. For 1 in
parentheses or 2, question mark, end parentheses,
2
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1111111-SSCE0006178
98
1
2
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Okay.
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SSCE00061 79
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I would -- I would expect it to be so. III
15
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17
The record can reflect that
18
19
we have reviewed the original document provided to
20
the committee and that is the cutoff on the original
21
documents. The committee is not in possession of
22
any document with more language on it.

BY
23
24
Okay.
25
26
SSCE0006180
100
Thank you. And if you could read that.
2
3
So this is IlF5B.
6
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Okay.
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I-SSCE00061 81
101
1
A
It doesn't necessarily tell me anything.
Okay. Now, let me ask you this, then.
15
Yes.
16
You did?
17
I believe so, yes. Yeah.
Yes.
21
Yes.
22
Okay.
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SSCE00061 82
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: The witness is referring to
8
9
Exhibit 5C.
BY
10
11
5C?
12
13
Thank you. Just so that we
14
the record
is complete and clear,
15
16
17
Yes.
Yes.
18
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20
And the conversation was by telephone?

22
Yes.
23
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IIIIIII-SSCE00061 83
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Yes, that's right.
Yes.
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Okay. Okay.
8
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Yes.
Okay.
12
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Yes.
Yes, yes.
16
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whirh is it so that the record will be
21
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clear?
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IMMISSCE00061 84
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Could you just repeat, if --
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Okay.
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0.11-SSCE00061 86
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A
Yes, they do.
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111.11-SSCE00061 87
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But I think at some point, that was --
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that was also discussed as well.
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Right.
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SSCE00061 89
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Yes.
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QAnyborly else?
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Yes.
And to Senator Ensign?
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SSCE00061 90
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No, I -- no, no.
BY
Can I follow up?
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Okay. Thank you.
15
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point.
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Not -- not at this point. Not at this
At any point?
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SSCE00061 91
112
3
4
5
6
7
That's correct.
: Thank you.
8
BY
13
14
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16
It would be fair to say I don't recall it
word for word, yes.

Q
Okay.
Can I talk to you all for just a second?
17
Yes, one minute.
18
(Recess.)
19
(Exhibits MI6 and1111- 7 identified.)
20
BY
22
23
24
25
We're back on the record. We're going to

Q
mark two documents and give you both at the same
time.
Ilikand1111-7.
the documents have been marked

will question you about
26
SSCE00061 93
113
these exhibits.
A Okay.
BY
3
4
Have you ever seen these before?
No.
What I'm going to ask you, we won't ask
you to explain what they are, but brief description
on the record,
9
10
That is correct.
11
Okay. And one of those on ExhibitIllF6,

is
12
13
14
that correct?
A
And on
15
-14 -- excuse me, is
16
17
18
That's correct.
That's correct, that's correct.

Thank you.
19
20
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SSCE00061 94
114
2
3
4
5
6
7
Okay. Can I just take a minute to read
A
them?
Take your time. Take as much time as you
Q
need.
Thank you, thank you.
Have you reviewed them?
9
10
I have.
Let's takell1F6 first, and that's the one
11
12
dated May 8; is that correct?

A
That's correct.
16
It is.
17
Is there anything in there that is
13
14
15
18
inconsistent with your recollection?
19
No, there does not appear to be.
20
And does that in any way refresh your
21
22
23
24
25
rec llectinn such that you recall anything further

that you haven't talked about yet?
A
I don't think so. I mean, I think it's
pretty consistent with what we've already discussed.

Q
Okay.
26
-SSCE0006195
115
1
2
That's fine. And then let's take 117.
You've had a chance to review that?
4
5
I have.
Yes, yes, it is.
6
7
8
9
Is there anything in there that is
10
11
12
13
14
15
inconsistent with your recollection?

A
No, I don't think so.
Does that refresh your recollection any

Q
further than what you've already shared with us?
A
16
17
18
19
So -- but nothing -- nothing on here seems
20
21
22
23
24
25
differcnt from what I've indicated.

Okay. In particular, I want to call your
Q
attention towards the bottom, there is a line I
believe, and I'll ask you to read it precisely, it's
to the effect of some questions may -- some
26
NIBSSCE0006196
116
questions that -- thank you. I'll read it.
2
3
4
Do you see that?
5
6
Yes, I do.
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allISSCE00061 97
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Yes, yes, it is.
3
4
Okay.
5
6
7
Which I think is sort of a -- is similar
on that same topic.
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MINI-SSCE0006198
118
Okay. Thank you.
we're at a
4
5
point where it would be -- it would be convenient to
break, if you want to take a break, and we'll be
glad to do that. You can get a bite to eat or
whatever.
What do you propose?
THE WITNESS: What's your sense of how
10
11
much longer, do you think? I mean, are we
12
another -- I know it's hard to tell, but an hour?

: I would say another hour.
13
THE WITNESS: Okay.
14
: My colleagues agree, is
15
16
that a fair statement?

I think so, I think so.
17
: Sure.
18
THE WITNESS: I might -- I might maybe
19
20
just try to grab something quickly to eat, if that's

ay
: Want to break for half an
22
23
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25
hour?
THE WITNESS: Happy to break for half an
hour. Can I come back here to eat?
26
-SSCE0006199
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: Of course, of course.
THE WITNESS: Great.

was recessed, to be reconvened at 1:30 p.m. this
same day.)
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-SSCE0006200
120
1
2
AFTERNOON SESSION
(1:30 p.m.)
Whereupon,
3
4
resumed the stand and, having been previously duly
sworn, was examined and testified further as
follows:
BY
We're back on the record,
I just remind you that you're still under oath.
10
Yes, I understand.
11
Let me ask you to address a question.
12
13
14
15
16
Is there anything that you recollect about
17
18
the events that we covered here that we've not
19
covered with you?
20
No, not -- not at this point, no.
21
Okay. All right. If something should
22
come to mind at the end of the day, after the
23
deposition, that you think that you recall,
24
recollection is refreshed, please let us know.
25
I will.
26
=111111-SSCE0006201
121
Just give me a call.
I will.
We're going to move on now into one brief
area. So I'm going to show you two exhibits that
I've marked -- one exhibit I've marked, it's III-8A
and 8B, just a two-page document. And it's Senator
Ensign's production 000653 and 654.
(Exhibit 1118A and IIF8B identified.)
BY
10
Il
I'd just ask you to take a look at the
two-page exhibit, 1118A and B.

12
13
Okay. I have reviewed both documents.
14
And to what do the documents pertain
15
16
there, the exhibit?

A
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IIMIIII-SSCE0006202
123
1
2
3
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8
9
On this issue, I don't recall meeting with
them.
10
11
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13
They are associated with the same firm?
14
That's correct.
17
And what do they do?
18
19
15
16
Right.
20
21
22
23
All right.
Yes, I did.
24
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SSCE0006204
124
1
2
I see.
3
4
A
6
7
8
9
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11
I understand.
12
13
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A
Of
15
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That's correct.
17
18
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It did not.
24
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MMIIIIM-SSCE0006205
125
Not at all when -- no.
Right.
10
1
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No.
BY
15
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20
Not -- not specifically that I can recall.
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-SSCE0006206
126
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I may have been in -- I mean, there may
19
have been other meetings where there were, I know,
20
several staff in a meeting. I don't recall
21
specifically, you know-, when they were or who they
22
were with.
23
24
25
26
-SSCE0006207
127
Okay.
No.
3
4
5
6
7
(Exhibit II-9A and-9B identified.)
BY
I'm going to show you another exhibit,

It's marked
10
and 9B, and it's
11
Senator Ensign's production documents Bates 679 and
12
677.
13
Thanks.
14
You're welcome.
15
16
Okay.
17
Could you identify the Exhibit 1119A and
19
Yes.
20
Thank you.
21
A II-9A
18
9B?
22
23
24
25
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-SSCE0006208
128
3
4
5
6
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9
10
11
That ' s 9A?
12
13
And 9B
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IM-SSCE0006209
129
4
5
6
7
8
9
10
11
12
So to your best recollection, you didn't
attend the meeting?
13
That's correct, I don't recall attending.
14
And the meeting was with whom from outside
15
the Senate?
16
17
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.111.-SSCE000621 0
1
2
3
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I don't specifically have that much more
17
18
knowledge other than that.
19
20
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23
No, no.
24
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SSCE0006211
131
1
2
BY
I show you now the Exhibit III-10, which is
a one-page exhibit. I'd just ask you to take a look
at it. If you could read into the record, since I
forgot to check it, what the Bates number is.
Thank you.
9
10
Yes. The number is 000682.
11
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-SSCE0006212
1
2
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16
Did you attend a meeting about this matter
to the best of your recollection?

A
To the best of my recollection, I did not.
17
18
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IMSSCE000621 3
133
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A
Not in Senator Ensign's office.
20
Pardon?
21
6
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-SSCE000621 4
134
I don't know -- no, it didn't.
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Thank you.
17
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-SSCE000621 5
Take a look at the calendar.
3
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How did you learn about that?
15
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And, you know --
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MIII-SSCE0006216
136
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Okay.
15
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It is, it is.
Yes.
17
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Yeah.
19
20
21
Okay.
22
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IMSSCE0006217
4
5
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7
8
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BY
12
13
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What about
15
BY
16
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BY
19
20
No.
21
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-SSCE000621 8
138
BY
1
2
3
4
5
6
7
That ' s correct.

Okay.
8
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1.111-SSCE000621 9
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A
If he said.
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SSCE0006220
140
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Okay.
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111.1111-SSCE0006221
141
2
3
4
5
6
7
9
A
10
11
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14
I am going to mark an
15
16
exhibit that I'll show you. I think it's Exhibit
17
11.
(Exhibit I1[11A through-11C
18
19
identified.)
20
BY
Q
21
So this is going to be 11A, 11B and 11C.
22
And the Bates numbers are 409, 410 and 411. So I'm
23
showing you,
24
11C.
25
Exhibit 11111A, 11B and
Okay. Thank you.
26
11111111.-SSCE0006222
142
Okay.
3
4
5
And I would ask you if you could identify
the Exhibit I1111A, 11B and 11C.

A
Okay.
7
8
9
10
11
12
Okay.
13
14
15
16
Yes, yes.
17
Okay.
18
19
20
21
22
23
Let me interrupt you, if I may.
24
25
A Yeah.
26
-SSCE0006223
143
Am I correct that the Exhibit 11A, 11B and
That's correct, you are correct.
Certainly.
Thank you very much. I think it might be
1
2
11C
3
4
5
6
9
10
11
easier for you and easier for us to talk about it

that way.
A Okay.
12
13
14
15
16
17
18
19
20
21
22
Okay.
23
24
25
No, no, I'm sorry. Right above that.
26
IIIII.-SSCE0006224
144
Oh.
That's correct.
I do.
Okay.
1
2
3
4
5
6
7
10
Who did you understand "JE" to be?
11
12
John Ensign.
Okay.
13
14
15
16
17
18
19
Who did the typing?
20
Yeah.
23
I believe so, from the letter, yeah.
24
Okay. I want to invite your attention
21
22
25
here to a passage that's part of this statement,
26
M-S8CE0006225
145
okay?
2
A Yeah.
And I'm going to read
I'm going to read
aloud, it's about -- it's about two-thirds of the
way down in the paragraph.
Okay.
Right.
7
8
9
10
11
12
13
14
Are we correct?
15
16
17
Are we reading it correctly?

A
18
19
20
All right.
21
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EMSSCE0006226
146
1
2
3
4
5
All right.
6
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26
SCE0006227
yes, it does. Yes, it does.

So it refers to Senator Ensign?
2
3
It does, yes.
That's correct.
4
5
6
Thank you. All right.
7
8
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13
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20
Okay.
21
BY
22
23
Let me just interrupt.
24
Certainly.
25
: I don't know that we need
26
-SSCE0006228
148
1
: No, we don't, actually.
3
Thank you, though, for being precise about that.
THE WITNESS: Certainly, certainly.
BY
6
7
8
Okay.
9
10
11
12
13
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19
Yes.
20
All right.
Yes.
Yes.
21
22
IIIII-SSCE0006229
I did.
2
3
And did anybody respond to you?
6
7
8
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19
All right. That's good.
That's correct.
That's correct.
20
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-SSCE0006230
150
2
3
In Washington.
In the office?
In the office.
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And Senator Ensign, you know, told -- sort
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The Senator took -- gave people
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a chance to ask him questions?

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He -- he did -- he did on certain points.
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expressed their -- you know, their concern and
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frustration with the situation and with what had
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You know, and I think -- and he -- you
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those -- and to those expressions.
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whole conversation.
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Have you ever had occasion to speak to
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since that night?
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Yes, yes.
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to talk with him -- was it -- on how many occasions,
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one or more than one?
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Probably more than one.
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And I know those meetings took place.
Let me ask you something.
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Right.
Right, right.
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Right.
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May I?
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But I --
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I certainly had that impression, yes.

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Tell us, what words are there?
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It's
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document I1[11C.
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There's more, but I think that gets to
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I did not. I did not really have -Thank you.
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Yes.
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Yes.
Yes, yes.
I didn't.
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Yes.
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That's correct.
Several did, yeah.
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A Absolutely.
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Correct.
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Let me ask you one other question.
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No.
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Yeah, I don ' t .
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Right.
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A Yeah. Yes.
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so 1 just want to get some background
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No.
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I do have a follow-up.
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Take a second to think about
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Including
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Let's be clear.
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That would
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help us.
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: Thank you.
THE WITNESS: Yeah.
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Any other members of the Senate there?
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No other members of the Senate.
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Do you know where Senator Ensign was
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coming from?
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I don't know.
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Just one question, on another point.
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Okay. Thank you.
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(Exhibit 11112A and 1.1-12B identified.)
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I will show you now what's been marked as
Exhibit I1[12A and 12B, and they are Bates numbers
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.11111-SSCE0006257
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from Senator Ensign 699 and 700. And I'll ask you
to take a look at the document, and then I'll ask
you a couple of specific questions about it.
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A Okay.
Q Okay?
Yes.
Have you had a chance to read it?
I have mostly, yes.
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Okay. Then referring to Government
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Exhibit II-12A, on the top of that page,
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It is.
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It is.
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That's correct.
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That is correct.
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That's correct.
Right. What I'd like to do now, if I may,
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is to just take a several-minute break, if I could,
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no more than about five minutes, and you could --
just stay comfortably where you are, and maybe
counsel can leave and confer and we'll be right
back.
A Okay.
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(Recess.)
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we're back on the record.
You understand you're still under oath?
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Yes, I do.
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And we just have kind of a final group of
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questions and then we'll be done for the day.

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Okay.
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That's correct.
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Yes.
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Yes.
And you talked to us about that.
Yes.
Yeah, yeah. Not that I can think of off
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Some of -- yes, some of them were, yes.
After.
Some of them.
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And how many?
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Boy--
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Okay.
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No.
I don ' t know.
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Okay.
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Okay.
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Yeah, yeah.
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Am I correct?
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Yeah, I think that that was -- that that
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Not -- I mean, no.
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I believe that's correct.
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Right.
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Yes.
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I don't recall.
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Okay.
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I don't
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And I think -- I think --
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How so? Let's take it step by step. How
so?
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Let me probe that a little bit.
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Right.
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We'll go
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through
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I think some might --
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Oh, yes.
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Yes, yes. Yes.

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We'll get to other stuff.
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On?
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I don't
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recall that coming up.
Let me just finish up on this.
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Yes.
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Absolutely.
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Yeah, I don't -- I do not -- I don't
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recall that coming up. I do not recall that coming
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Well, I mean, I think the -- not that I'm
aware of. I mean, not that I'm aware of.
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I just have another question first.
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Okay.
Fundamentally, no.
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Excuse me, I'm going to interrupt.
Okay.
And just a follow-up.
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Yeah, I mean, I don't think so. 1111111
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Uh- huh .
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Not that I ' m aware of, no.
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Okay.
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Right, right.
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What do you recall about any of that?
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I -- no.
Yes, yes.
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That's right.
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It seems to me -- was that generally in
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this time frame that we're talking about?

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That -- I think that's right.
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A I don't -- I don't know. =NM
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I'm familiar with it. I don't -- honestly
I don't remember it all.

Q
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I was -- I was not aware of any of that.
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No.
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That's correct, yeah.
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Let me just ask a question first. I just
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I believe so.
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Okay.
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I -- I think I did. I think I did. I
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Okay.
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111111111111111111111111=
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: Okay. Thank you.
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1111111-SSCE0006289
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And did you have any conversations as a
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result of that?
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As a result of?
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I don't -- I don't recall saying that,
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but, I mean, I wouldn't -- I don't recall saying
that.
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To whom would you have said that?
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Yeah.
Yeah, I think that's right. I mean, I
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think that that is likely.
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Right.
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That's correct.
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I don't -- I don't recall --
Okay.
I don't know, I --
Yeah, I -- I don't know -- I don't recall
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whether -- I mean, I don't recall if that happened
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or when that happened.
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So you don't recall ever being aware of
it?
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I don't recall being aware of
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BY
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Just a couple of more questions.
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Yes.
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No.
No, no.
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Right.
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I don't think so.
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Let me just follow up right there. 111111
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Anyone else? Anyone else?
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That's about it.
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No.
I don't -- I don't recall.
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III1=-SSCE0006299
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Not that -- not that I'm aware of. I
mean, not that I'm aware of.
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Not that -- no, I mean, not that I can
recall.
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No. I mean, I -- no.
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Of course.
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I don't know.
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No.
I just have two very quick

questions.
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Right, right.
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Yeah.
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EMIISSCE0006304
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No.
We have endeavored today to cover
everything that we think you would be in a position
to cover with us in your testimony that would be
helpful to the committee and the committee's
10
inquiry.
11
Uh-huh.
12
And we -- I think you'd probably concede
13
that we have reviewed a lot of documents so that
14
we'd be in a position to present documents to you,
15
to the extent to which they would be helpful.
16
Right.
17
So as we conclude now, we believe that we
18
have covered everything. We really should ask you
19
that.
20
Is there anything that you know, that you
21
have knowledge of, that you're aware of, pertaining
22
to this matter that the committee is looking into
23
that we have not covered with you?
24
25
No, not -- to the best of my knowledge,
no.
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SSCE0006305
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Okay. We may -- there may come a day when
we come upon other information or other documents
that we didn't have with us or access to on the
occasion of your deposition today. So it could be
that we might ask you to return.
I'm happy to -- would be more than happy
to return at any point.

8
9
Okay. And finally, we appreciate your

coming today to appear for your deposition. As we
10
said at the start of the day, the rule of
11
confidentiality applies to us and it does not apply
12
to you, but that we strongly request that you not
13
discuss your testimony with anybody else who might
14
be -- or with anybody else or with anybody
15
particularly who could be a witness in the matter.
16
17
advisement.
Okay. I will take your position under
18
: Thanks. Okay.
19
: One last thing,
20
did mention that we can make an
21
opportunity available for you to come at some point
22
and review a transcript of today's testimony. If
23
it's something you think you might be interested in
24
doing at some point, if you'd let me know in the
25
next week or so, and we can try to arrange a time
26
11111=-SSCE0006306
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for that.
THE WITNESS: That would be great. I
would definitely like to just review the transcript.
It's always something I would do. So would love to

do that, you know, when it's convenient for your
office.
7
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11
We'll follow up with you on

that.
THE WITNESS: Great, thank you.
was concluded.)
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X
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day of
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Notary Public
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-SSCE0006308
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CONTENTS
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WITNESS
EXAMINATION
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by
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EXHIBITS
EXHIBIT NUMBER
IDENTIFIED
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5A through III-5C
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6 and 111 7
112
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8A and M- 8B
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9A and IN- 9B
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11A through 111- 11C
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12A and 11- 12B
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BY
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eAA IP;
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EMI-SSCE0006256
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TP
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IMSSCE0006300
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1
Washington, D.C.
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Monday, June 7, 2010
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Suite 220
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REPORTED BY:
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MM-SSCE000631 0
called
Deposition of
for examination pursuant to notice of deposition, on
Monday, June 7, 2010, in Washington, DC, at the
a Notary. Public within and for the
9
ESQ.
10
ESQ.
11
ESQ.
12
ESQ.
13
14
15

Committee on Ethics
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202-224-2981
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cethics. senate. gov
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IIIIIIIIIIIIIkethics.senate.gov
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11111111MINgethics . senate. gov
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-- continued --
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SSCE0006311
APPEARANCES (Continued):
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Committee on Ethics
202-
10
ESQ.
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McKenna Long & Aldridge LLP
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303 Peachtree Street NE, Suite 5300
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Atlanta, Georgia 30308
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.11111111mckenna1ong . corn
On behalf of Witness
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.1111.1-SSCE0006312
PROCEEDINGS
: Thanks for coming.

What we do at the beginning is we're going
to read you some warnings that we do with all
witnesses. So this is standard.
We'll start by letting you know that the
Senate Select Committee on Ethics has summoned you
here for the deposition today as a witness in
connection with the committee's preliminary inquiry
10
concerning Senator Ensign. My name is 1111111111111
11
and I am joined by Chief Counsel
12
as counsel,
as Counsel
as the Deputy Staff
13
to the Committee,
14
Director to the Committee, and we also have a court
15
reporter in the room.
16
We've been authorized by the Chairman and
17
the Vice Chairman of the Committee to conduct this
18
questioning. Our questions and your answers will be
19
20
21
your statements today are subject to the False
22
Statements Statute, Section 1001 of Title xvIli of
23
the United States Code.
24
25

26
11111111111SSCE000631 3
of perjury under Section 7B of the Supplementary
Procedural Rules of the Select Committee on Ethics,
and Section 1621 of Title XVIII of the United States
Code, as well as the obstruction of Congress
statute, Section 1505.

Thus, you may not intentionally make any
6
7
false statements or intentionally mislead the
committee through your answers today. Do you
understand?
At this point, I am going to ask that the
10
11
court reporter swear you in.
12
Whereupon,
13
14
15

EXAMINATION
16
BY
17
18
And do you understand that your statements
19
today are subject to the statutes and committee
20
rules concerning false statements, perjury and
21
obstruction of Congress?
22
i do.
23
I'm going to start off --
24
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26
: Counsel, I'm sorry to

interrupt you. Do you need me to enter an
appearance or do anything with regard to appearance?
I am going to put your name
on the record in just a moment. And I can do that
before we go forward, so that will be fine.

BY
5
6
7
And the record will reflect that,
you are represented here today by

is that correct?
8
9
Yes.
10
Andllis in the room with you. We are
11
confident that -- well, let me put this on the
12
record and then I'll continue with these.

And for the record, why don't you state
13
14
your full name, please.
15
16
17
Okay.
I'm going to show you
a document that I'm going to mark Exhibit Number 1.
18
(.1Exhibit 1 identified.)
19
BY
20
Do you recognize this?
21
Yes.
22
And is this a copy of the notice of
23
deposition pursuant to which you're here before us
24
today?
25
Yes.
26
IIIM-SSCE000631 5
Okay. Thank you.

Now, were confident that
has explained all the issues related to your
representation here today. We are aware, however,
that some witnesses attorneys fees are being paid
by Senator Ensign and therefore we must ask you
whether you understand that your attorney represents
you and owes his or her full duty of loyalty to you
and you alone in this deposition, no matter who may
10
be paying Illifee?
Is that your understanding?
11
12
Yes.
13
Okay. Furthermore, I must ask whether you
14
understand that you do not owe any duty of loyalty
15
to any other person merely because they may be
16
paying your attorney fees. Do you understand that?
17
Yes.
18
Do you also understand that your duty
19
today is to answer the questions truthfully and
20
completely to the best of your ability?
21
Yes.
22
NOW, you both have been provided with a
23
copy of our procedural rules. As a general matter,
24
25
26
-SSCE0006316
this deposition and all statements today. These
rules do not govern your own discussions ,of this
interview.
However, its the Committee's expectation
that no witness will tailor or coordinate his or her
testimony based on an earlier deposition, and
therefore we request that you refrain from
discussing our questions and your answers with
anyone other than your attorney.
10
Pursuant to Supplementary Procedural Rule
11
6, you are entitled to the opportunity to inspect
12
the transcript of your deposition in the Committee's
13
offices and request that any transcription errors be
14
corrected. Any errors of fact must be brought to
15
the Committee's attention through submission of a
16
sworn statement.
17
If you do wish to inspect the transcript
18
after the deposition, please let us know in the next
19
week or two and we'll be happy to arrange a time as
20
soon as the transcript is available.

And that is something
21
22
we're going to want to do, but well get in touch
23
with you afterward.

: Timing is totally flexible.
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BY
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-SSCE000631 7
And finally, if you need any time at all
during this deposition to take a break or to speak
privately with
either of you can let us know, and we'll be happy to
give you all the time, okay?

Do you have any questions for us at this
6
7
just let us know,
time?
: I do not.
THE WITNESS: No.
I'm sorry, if I could add
10
11
one other instruction. Because we have a court
12
reporter, one or two times you said uh-huh or
13
uh-huh. Try to use verbal words so it will make it
14
easier for the court reporter to understand what
15
you're saying.
16
THE WITNESS: No problem.
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BY
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All right. So we've asked you to place
your name on the record.
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SSCE000631 8
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Okay.
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Okay.
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Okay.
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Sure.
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1111M-SSCE000631 9
11
That's a pretty good memory. Feel free,
if you remember any as we talk, just remind us if
there's an issue that you did cover that you don't
remember at this time.
Okay.
7
8
Correct.
Where do you currently work?
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Okay.
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IIIMM-SSCE0006320
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4
Okay.
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Okay.
13
But, again, it's a very fluid dynamic.
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SSCE0006321
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Okay. Very good. 111111111111111=
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And when exactly did that happen?

-- what's the question?
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A
Okay.
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SSCE0006322
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1
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I don't believe so.
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And you had already agreed to that?
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Yes.
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A Correct. 111111M11111111
1111111111.
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Okay.
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: I'm sorry to interrupt,
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-SSCE0006323
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1
2
: Correct. Yes, thank you.
THE WITNESS: Two to five times a week.
BY IIIIIIIIIIII:
.1111111.
1111.=11
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And when was that?
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I don ' t recall.
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IIIIIIIII-SSCE0006324
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1
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Okay. 1
..1.111.1111=
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No.
Okay.
Yes.
9
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I don't believe so, no.
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Okay. And how often does that happen?
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Once or twice a year perhaps.
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Okay. Thank you.
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IMESSCE0006325
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111111111111111111111111111111111
A
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Yes.
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Okay.
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A 111.111111111111.11
1.11111.1
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In
the
past?
Correct.
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No.
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Okay.
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1.1111111-SSCE0006326
Yes.
Okay.
111111 Sorry for asking two questions at once.
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Probably not.
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A Yes.
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A
ElII
Q
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No, no particular reason.
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: I'm sorry to interrupt.
19
Try to let
20
your answer. Again, it will make it easier for our
21
court reporter.
finish
22
11-ih W1l1hb5:
23
BY
24
question before you start
okay.
Thank you.
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111M-SSCE0006327
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1
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3
Which transition?
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IM-SSCE0006328
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2
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Okay. Before we go on, I just wanted to
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note that I'll be doing the principal questioning
today, but any of my colleagues here may join in at
any point and ask a question if something occurs to
them, okay?
9
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It varied.
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-SSCE0006329
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I mean fairly regularly.
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Okay.
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Again, occasionally. It would depend on
the circumstances.
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Let me explore this just briefly.
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IIIIIIFSSCE0006330
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2
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7
Okay. I was just going to ask for a list
of what those issues are. You gave us a few
examples. Can you just try and be as specific as
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you can with what were the principal ones?

A
Those would be the ones that I recall.
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Q Okay. All right. M111111111.1111111M
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II-SSCE0006331
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1
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No.
Not to my recollection.
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Okay.
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Okay.
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HOW occasionally-'
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I mean, I don't recall. I mean, less
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often than, say, once a week. More often than once
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a quarter. Perhaps.
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1111-SSCE0006332
24
1
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Tell us what that issue was, when that

occurred.
A
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SSCE0006333
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I don't.
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I don't recall. I don't recall.
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Okay.
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THE WITNESS: Not in that conversation, I

don't recall that, no.
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11111.-SSCE0006335
1
2
3
THE WITNESS:
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BY 111111111111111111:
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Not this issue.
Yes.
I believe it was before that.
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M.1111-SSCE0006336
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2
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BY
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Yes.
Q Right. 111111
11.11
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Okay.
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Okay. 1.1111111111.1111=MINE
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Yes.
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-SSCE0006337
29
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Perhaps.
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BY
Q
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A Uh-huh.
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Not typically, no.
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-SSCE0006338
30
1
2
3
4
5
We're going to follow up on

what happens after this meeting.
BY
6
7
Before that, in part to try and nail down
the timing. For the record, that first exhibit, the
notice of deposition, I marked 1.
10
(II1Exhi1Dit 2 identified.)
11
BY
12
I'm going to show you a document which I
13
have marked Exhibit 1112 and ask you if you
14
recognize that document. And this is -- the
15
document number on this, everybody, is 632.

Have you seen that before?
16
17
Yes.
18
Okay. And just describe what that is
19
20
briefly for the record.

A
21
Q
Okay.
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SSCE0006339
31
1
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6
Yes.
Yes.
=M1111111111111111111111111111111111111
I don't recall. There may be. I
7
8
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10
11
12
13
may be other ones.
14
15
there
Q
the
But are you specifically aware of any at

right now?
: Are you talking about
16
17
subsequent --
1111111111111:
18
19
20
21
: Okay.
Ihh WIINhSS: I believe this is the only
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23
one I can recall at this time.
24
25
BY
Q
So you're not aware that there are others
26
=11111-SSCE0006340
32
that you've seen recently or anything like that, to
the best of your knowledge? That's all I'm asking.
I -- I don't believe so, no.
Okay.
Yes.
Yes.
5
6
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8
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11
Okay.
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16
I can't say with certainty.
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IIIIIMSSCE0006341
33
Yes.
Yes.
Yes.
2
3
4
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10
11
(Exhibit 3A and 3B identified.)
12
BY
13
I'm going to show you a two-page document
14
I'm marking III 3A and 3B, and these are pages 633
15
and 634. Can you describe for the record what this
16
is?
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GL
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SSCE0006342
34
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Correct.
Okay.
How do you mean? I'm sorry.
10.
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SSCE0006343
35
1
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Okay.
It did, yes.
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2
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Okay.
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miniSSCE0006344
36
2
3
No, after.
Okay.
A Yeah.
Okay.
It struck me as a bit odd.
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12
Okay.
13
14
No, I don't recall.
15
Okay.
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A Uh-huh.
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23
Thank you. Do you recall?
24
I don't recall.
25
but I don't recall.
26
SSCE0006345
37
That's fine, appreciate it.
I don't recall. I may have.
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11111111111111111111111111111111111
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I'm going to go through these one at a
time.
A
Sure.
20
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=11111111111111111111111111111111111111111
A
I don't recall.
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24
25
26
Thank you.
38
I don't recall.
Do not recall.
Do not recall.
2
3
4
5
6
For the record, can you spell both that

8
9
first and last name.

A
10
A
111111111111111
I don't recall.
16
I don't recall.
17
Do you recall if you discussed these
11
12
13
14
15
18
concerns with anyone outside of the office?
19
At the time?
20
At the time.
21
I don't recall.
22
Okiy . By L1i wcty,,
ctL ily LLLLt L1LW clb
23
you a question, we never intend to ask you about
24
your conversations with your counsel.
25
BY
26
IIIIIIISSCE0006347
39
Clearly, we intend to cover all the bases
here. We try to make some questions more specific
than others.
5
6
Sure.
That's actually to be helpful to you, so
that it's clear to you what the question is.
7
8
9
10
11
12
13
A
Uh -huh.
In reference to -- again, which issue?
23
Sure.
24
14
15
16
17
18
19
20
21
2
25
26
111111111.-SSCE0006348
41
2
3
4
5
6
: We'll get there.
THE WITNESS:
8
9
10
11
I couldn't tell you a specific

conversation.
12
: Okay.
13
14
BY
Q
Okay.
Yes.
15
16
17
18
19
20
21
Is triat. rig te
23
24
It is.
THE WITNESS:
25
26
-SSCE0006350
42
1
2
3
BY
Q
Okay. These aren't quizzes. These are
just to make the record a little more clear.
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
23
24
25
26
1.11111111.-SSCE0006351
43
1
2
3
4
7
8
9
10
11
12
13
14
15
16
17
A
Okay.
18
19
20
There may have been. I don't recall.

Okay.
21
22
23
24
25
26
SSCE0006352
44
1
2
3
Okay.
4
5
Yes.
In--
6
7
8
9
10
I'm sorry, let me clarify that.

Q
Everything is work-related. 111111.1111.11111.
11
12
13
14
Yes.
Okay.
15
16
17
18
Probably.
I do not believe so, no.
19
20
21
22
23
Okay.
24
25
26
SSCE0006353
45
I do not believe so.
Okay.
3
4
5
6
7
8
Let me try and phrase it more
9
10
particularly, without the ambiguity in there.
11
12
13
14
I do not believe so, no.
15
16
17
18
19
20
21
22
23
U you/ queb 1011 lb
WIC,
Okay. So let me try and be more specific.
24
25
26
SCE0006354
46
1
2
3
Sure.
I do not recall. And I do not believe so,
4
5
6
7
8
9
10
11
12
13
14
15
16
but I could not say for certainty.

Q
Okay. That's fine. All right. Mill
17
18
19
20
21
22
23
24
25
26
-SSCE0006355
47
1
2
3
4
5
6
7
8
9
10
Okay. Let me ask a little background on

this issue, then.
11
12
No.
Not on this issue.
No.
13
14
15
16
17
18
19
20
21
2
23
24
25
26
SSCE0006356
48
1
2
3
No.
Were you involved -- actually, it comes a
little bit after this.
May I?
Yes, please go ahead.
BY
9
10
11
12
13
14
15
16
17
18
19
20
21
2
23
24
25
Okay.
26
-SSCE0006357
49
1
2
I don't
recall anything directly personally.
BY
4
5
6
7
Yes.
What do you recall about that?
9
10
11
12
Part of the process of how we show you
13
documents is we try to get your recollection without
14
showing you first and then we'll show them to you so
15
I'm just going to push a little more.
16
17
18
I do not.
19
And do you recall whether it happened or
20
not?
21
22
11111111111
23
24
Okay.
25
26
-SSCE0006358
50
To my
3
recollection, I mean.
4
5
Do you recall why that was?

A
No.
I don't recall.
-- at that time?
10
I don't know, I should say.
6
7
11
12
13
14
15
16
17
18
19
20
21
No.
22
X 1_L 1
23
24
25
1UiI1L1LJ
U.
BY
Q
I'm going to show you a document I'm going
to mark III 4. This is 1759.
26
-SSCE0006359
51
1
2
3
I believe so, yes.
Correct.
And I will show you the document that I
4
5
will mark'. 5. And this is document number 1761.
Exhibit 5 identified.)
10
BY
11
Do you recall this document?
12
Yes.
13
14
15
16
17
18
19
Do you -- does this document refresh your
20
recollection such that you now remember, at the
21
time, being told? Or are you just saying you're
22
aware now necause
23
24
25
26
IIIIIII
SSCE0006360
52
2
3
Okay. Was that unusual at all?
It didn't strike me as such.
Okay.
I don't -- I don't recall following up on
6
7
8
9
10
it. It didn't strike me as something I necessarily

needed to do.
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
-SSCE0006361
53
2
3
Q
Okay.
No.
All right. A little bit of background
4
5
there. Let's move on.
9
10
11
12
13
14
15
16
17
I'm going to show you a document that I
will mark II 6.
18
ill Exhibit 6 identified.)
19
BY
20
21
I'm going to use 1767.

Do you recall that document?
22
Yes.
23
Could you describe what it is?
24
25
26
SSCE0006362
54
2
3
Okay.
Yes.
Yes.
4
5
6
7
8
9
10
11
: Can I take one moment

with
12
Please do.
13
(Witness conferred with counsel.)
14
THE WITNESS:
15
16
17
18
BY
19
20
21
Okay.
Okay.
23
24
25
26
..11-SSCE0006363
55
1
2
3
4
5
Oh, yes, okay.
illExhibit 7 identified.)
BY
Q
I'll show you what I will mark as 1117.
11
Yes.
12
Okay. And that one is -- what's the
9
10
13
number next to that exhibit sticker?
14
1117 number 1766.
15
1766, thank you. Okay.
16
17
18
19
20
21
23
24
25
Okay.
26
IIIM-SSCE0006364
56
1
2
3
4
5
No, I believe they're the same function.
Okay.
9
10
11
12
13
14
15
16
17
18
19
Okay.
20
21
22
23
24
25
26
=III-SSCE0006365
57
Okay.
Yes.
3
4
5
- - 111117?
Yes.
Okay.
8
9
10
11
12
13
14
15
16
17
18
19
20
21
2
23
Okay. Let me go through a little bit of
e inormacion in cnac.
A
Sure.
24
25
26
-SSCE0006366
58
Yes.
Don't recall.
Okay.
6
7
Okay. You say you don't recall.
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Okay' 11111
11111=1111
26
-SSCE0006367
59
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Okay.
26
-SSCE0006368
60
1
2
No.
3
4
5
6
7
I don't
know.
Okay.
10
11
Q Okay.
1111111
1111111=
12
13
No.
14
Okay.
Okay.
15
16
17
18
19
20
21
22
23
24
25
26
-SSCE0006369
61
2
3
Yes.
4
5
6
7
8
10
11
12
13
14
15
16
17
18
19
20
21
THE WITNESS:- Okay.
22
BY
23
Actually, sometimes its appropriate to
24
speculate and to be perfectly clear that's what
25
you're doing, because that can -- that can refresh
26
-SSCE0006370
62
one's recollection.
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
Okay.
17
18
19
Okay.
20
21
zz
Okay.
23
24
25
26
M-SSCE0006371
63
1
2
3
4
5
6
7
8
9
10
11
12
13
14
Okay.
15
16
17
18
19
20
21
Sure.
11111111.1111111111.1111111111111111.
Sure.
Tell us, to the best of your recollection,
when that came up.

A
22
23
24
25
26
IIIIIIFSSCE0006372
64
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
Since I can remember the specific
23
conversation, no. I mean, it doesn't
24
strike me one way or the other as being memorable.
25
it doesn't
Okay. I'm asking you to go beyond your
26
MIIIIISSCE0006373
65
recollection of the specific words to your
recollection of how you felt about that
conversation, if you can recall.
I don't recall the specific conversation.
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
z
23
24
25
26
-SSCE0006374
66
1
2
3
4
5
6
7
8
9
10
11
12
13
14
That was my thinking at the time.
I don't
15
have -- that's speculation, though. That was what I
16
speculated at the time.
17
Okay. And that is what we were asking, if
18
your speculation reflects what you were thinking at
19
the time.
20
Exactly.
21
23
24
25
26
SSCE0006375
67
1
2
3
4
5
6
7
We'll come back to that.
But I'll say very quickly.
Sure, go ahead.
10
11
12
Don't know.
13
Okay. I think we'll come back to that.
14
: Go ahead.
15
16
BY
I have a couple of quick follow-ups.
I don't recall that, no.
23
Sure, yes.
24
So you mentioned it to others?
25
Yes.
17
18
19
20
21
26
-SSCE0006376
68
1
2
And who?
A
3
4
5
6
7
8
9
BY
10
11
How about
12
13
14
BY
15
16
17
18
19
20
21
2
23
24
25
26
No 111111
69
1
2
3
Okay.
4
5
6
7
8
9
No.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
I don't recall.
24
25
111111111111111.1111.11111.11.11=
26
-SSCE0006378
70
1
2
No.
al Exhibit 8 identified.)
BY
5
6
I 'm going to show you what I've marked MI

8, and that's number 126.
7
8
BY
Q
9
10
11
Yeah.
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
MilIMSSCE0006379
71
1
2
3
BY
Q
Let's turn to II 8. 1118 appears to be
another version of. 7; is that right?
4
5
6
7
8
Yes.
Okay. And do you recognize it,
8?
9
10
11
12
13
Okay.
14
15
16
"Q
17
No.
18
Do you know whose handwriting that is?
19
No.
20
Do you recognize it at all?
21
No.
I'll j ust ask you to kind of picture a few
23
24
Yes.
Is that your handwriting?
people's hand writings.

A
25
26
MillISSCE0006380
72
2
3
Probably not.
I don't think so.
6
7
8
9
10
11
Okay. And obviously, of course, it could
be anybody's.
12
Yes.
13
We're not holding you to that being the
14
finite number of people who it could be.

Do me a favor, do your best to read that
15
16
handwriting for us, since you might be more familiar
17
with it than we are.
18
19
20
21
2
23
24
It could be, yes.
25
Do these words refresh your recollection
26
1=1.-SSCE0006381
73
that anybody had this specific conversation with you
or reported these comments to you or their
substance?
5
6
No, doesn't refresh my memory to that
effect.
Q
Okay. So going through this and reading
through this, you still -- do you have any stronger
belief as to whose handwriting this may be?
10
11
12
13
Okay.
14
15
16
Okay. All right. We'll move on from
17
18
Not to my recollection, no.
these.
19
20
21
22
23
24
No.
25
26
.1111-SSCE0006382
74
1
2
3
Normally, yes.
Under the -- under normal circumstances,
4
5
6
7
8
9
generally yes, that would have been the process.

Q
Okay.
13
Generally, yes.
14
Okay.
18
Generally, yes.
19
Okay.
10
11
12
15
16
17
20
21
22
NO.
23
24
25
26
Mill-SSCE0006383
75
1
2
3
4
5
Okay. To the best of your ability,

describe that information.
A
6
7
8
9
10
11
12
13
14
To my recollection, yes.
15
We'll come back to that in a moment.
16
17
18
19
20
21
22
23
24
25
26
111111M-SSCE0006384
76
1
2
3
4
5
Yes.
Q
All right.
No.
6
7
8
9
10
11
12
13
Not that I recall, no.

Q
Okay.
14
15
16
17
Not aware.
Q
Okay.
Not to my recollection.
18
19
20
21
22
23
24
25
26
-SSCE0006385
77
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
Probably.
Okay.
19
20
21
22
23
24
25
26
MIIISSCE0006386
78
Well, let me ask you this.
2
3
4
No, no. It was not my impression, no.
5
6
7
8
9
10
11
Honestly, I don't know.
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
-SSCE0006387
79
2
3
5
6
7
8
9
Okay.
11
Or later, to my recollection.
12
Or later?
13
Yes.
To my recollection.
I don't recall. I don't know. I may
10
14
15
16
17
18
19
20
21
have; i may not have at that time. its hard to

23
24
25
recall at that specific time.

Q
Let me kind of propose something, the way
something is coming across, and ask you to think
26
111.-SSCE0006388
80
about this, comment and help us understand this.
2
3
It would seem to be that -- well, let me

ask this, foundation here.
4
5
6
7
8
9
10
BY
11
Yes, I'm referring to III 6, 7 and 8.
12
13
14
15
16
Right.
That would have been my understanding at
17
18
19
20
the time.
Okay.
21
22
23
24
25
26
IIM-SSCE0006389
81
1
2
3
4
5
6
Yeah.
Okay.
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
MIIIIIIIIII-SSCE0006390
83
1
2
3
4
Definitely not.
10
Not completely, correct.
11
7
8
9
12
13
14
I hoped not. I didn't know.
15
16
17
18
19
20
All right.
21
22
23
24
25
26
-SSCE0006392
84
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
Okay. I want to explore a little bit what
23
you were just talking about. We're going to go to a
24
document that I will mark --
25
Do you need a break?
26
SSCE0006393
85
1
2
: Good time to take a

break?
: Absolutely.
(Recess.)
BY
7
8
9
10
11
12
13
Uh-huh, yes.
Okay.
14
15
16
17
18
19
20
21
ZG
23
24
25
26
IIIMSSCE0006394
86
1
2
3
4
5
6
7
8
9
10
Correct.
No.
I don't recall. I mean, I don't recall
11
12
13
14
15
16
having received an explanation. I never asked for
17
one, so --
18
But was it talked about?
19
20
21
22
23
24
25
26
1.11M-SSCE0006395
87
All right.
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
I just want to show you one document and
18
19
see if this refreshes your recollection or if you
20
have any thoughts about it.
21
"'Exhibits 9A through 9H identified.)
22
BY
23
I've marked this. 9A through H. I'm
24
giving you the whole thing for the context so you
25
can put it in context.: I'm really only referring to
26
88
1
2
9F, as in
Frank. And we don't have the whole package --
3
4
. It's okay. I've got it. We're

fine.
BY
Do you recall that?
.8
Yes.
And just describe it briefly.
10
Documents III9A and B
11
12
9,
13
14
Q Okay. On11119F,
15
is that correct?
16
17
Yes.
18
19
Yes.
20
21
22
23
MEM
24
25
26
1111=-SSCE0006397
89
1
2
8
9
10
11
12
13
14
15
16
Yes.
At that time, yes.
17
18
19
20
Q
Okay.
23
No.
24
21
22
25
26
SSCE0006398
90
1
2
3
4
6
7
I did.
Oh, it is in there. It's on III9A;
correct?
10
11
Correct, yes.
12
13
14
Not at the time, no.
15
Okay. All right. We don't need to go
16
further.
17
18
19
20
21
22
23
24
Yes.
25
26
-SSCE0006399
91
No.
Or present for it?
No.
You were not?
No.
Why was that?
Don't recall. May have been I was in
otherwise disposed doing something else. It may
have been the call didn't occur at the time it was
10
11
scheduled. Don't know.
Okay. All right.
12
13
14
15
16
17
No.
19
No.
20
18
21
23
24
25
Yes.
26
1.111.11111SSCE0006400
92
1
2
3
4
Yes.
I believe so, yeah.
5
6
7
8
9
10
11
12
13
14
15
16
17
When, during what
18
19
Yes, I was aware of that, yes.
20
21
22
23
I don't recall.
24
25
26
SSCE0006401
93
Not particularly, no.
I believe so, yes.
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Okay.
Offhand I don't recall. Oh, I take that
16
17
18
19
back.
20
21
What was your reaction?
23
24
25
26
Mill-SSCE0006402
94
3
4
Did you have any other reactions to it,
any concern?
A
I don't recall at the time.
Yes.
I believe I may have been a little bit
5
6
7
8
9
13
14
15
16
17
18
19
20
21
22
surprised, yes.
23
24
What was the basis for that surprise?
25
26
-SSCE0006403
95
1
2
3
4
And did you talk about that with anybody?
Probably not, no.
Why not?
No reason to.
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
-SSCE0006404
96
Okay.
2
3
4
I don't think so, but I don't recall.
8
9
10
11
12
And do you recall --
13
But I may have also simply said, hey, can
14
you do this?
15
16
17
It would have been perfunctory, sure,
okay.
18
19
20
21
No.
22
23
24
25
26
11111=1I-SSCE0006405
97
1
2
3
4
5
I was not, given any indication one way or
the other.
Q
Okay.
6
7
8
9
10
11
12
13
No -- I'm sorry, can you restate the
question?
Q
Sure.
No, I don't believe so.
14
15
16
17
18
19
20
21
22
23
24
25
26
SSCE0006406
98
1
2
3
4
5
6
7
8
A
Describe those to the best of your
9
10
11
recollection.
A =1111111111
11111.11.111
12
I couldn't recall a single one with more
13
14
specificity.
15
16
17
18
19
Let me run through some specific questions
20
21
just to see if they refresh your recollection.
22
23
24
25
26
-SSCE0006407
99
2
3
4
5
What is your best recollection of any
other details included in that conversation or about
that topic?
I don't recall.
Do you recall -- do you have any
10
recollection about when that conversation supposedly
11
occurred?
12
No.
No, on either account, no.
13
14
15
16
All right. Back to this.
17
18
19
20
No.
21
22
23
24
25
26
IIII=SSCE0006408
2
3
Okay.
I don't recall.
4
5
6
7
: Quick question.
8
BY
13
14
15
In this case, no.
I don't know.
16
17
18
19
20
BY
Q
Okay.
I don't know that it did.
Wait.
21
22
23
24
25
26
11-SSCE0006409
101
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
So I was misremembering that one.
18
Okay.
19
A
20
21
ill Exhibits 10 and 11 identified.)
22
I will mark these two 10
23
11 and let you compare them to help you with
24
and
25
your recollection. III 10 will be document 682 and
26
SSCE000641 0
102
11 will be 1751.
BY
3
4
5
Yes.
Okay. And briefly describe.' 10. What
7
8
does that reflect?

A
M10
9
10
11
12
13
14
15
16
And briefly describe 11111.
17
18
19
20
21
And for the first one, 11110, does that
refresh your recollection about whether or not you

were on this call or who was on it?
23
It does.
24
25
26
IIM
SSCE0006411
103
1
2 .
I don't recall, but I have no reason to
believe that it did.
that call?
Okay. In fact, what's the subject line of
6
7
8
9
10
11
12
Yes.
13
14
15
I may have. I don't recall.
16
Okay. III 11, what does that reflect?
17
18
What's the subject line?

A
19
20
21
22
23
24
25
26
-SSCE000641 2
Okay.
I was n o t on t h i s
10
Okay.
call?
11
happening?
12
13
24
26
And do y o u r e c a l l t h i s
call
I don't know i f i t happened o r n o t .
think i t did.
16
25
And do y o u b e l i e v e you were on t h i s
Yes.
There p r o b a b l y wasn't a s i n g l e
conversation.
There was p r o b a b l y a h a n d f u l , and
105
t h e r e were p r o b a b l y p e o p l e p r e s e n t a t t h o s e v a r i o u s
conversations.
I don't r e c a l l any s p e c i f i c one
3
4
5
6
No, I don't b e l i e v e so.
8
9
10
11
A
the
Or I don't know why.
At
t i m e I d i d n o t know why.
Q
12
13
14
15
16
17
18
19
20
21
-2223
24
25
26
Okay.
Do y o u have any r e c o l l e c t i o n why
you were n o t on t h i s c a l l ,
A
i f i t happened?
109
110
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
1
D i d anybody ever a p o l o g i z e t o y o u f o r
k e e p i n g y o u away o r n o t i n f o r m i n g y o u o f what was

g o i n g on?
A
Okay.
think
I'm g o i n g t o mark, I t h i n k we're up
t o 12; c o r r e c t ?
|: Yes.
12 i d e n t i f i e d . )
BY ~
Q
I'll
show you a document marked
12,
t h i s i s 1741. T e l l us what t h a t appears t o be.

A
Are these calendars accessible t o a l l

staff?
A
19
20
21
23
24
25
26
G e n e r a l l y , yes.
What does t h a t r e f l e c t ?
Do you r e c a l l i t ,
Not p a r t i c u l a r l y , n o t w i t h o u t g o i n g back
10
11
12
13
t h a t meeting?
t h r o u g h my n o t e s .
Q
I f you r e a d down towards t h e bottom,
t h e r e ' s an a t t e n d e e s
14
18
19
Yes.
21
Yes.
line.
Yes.
Does JE r e f e r t o Senator
Ensign?
t h e next entry?
25
Okay.
What t i m e i s t h a t a t ?
26
S
SCE0006420
113
I t ' s p o s s i b l e --
- - i n the office?
9
10
11
12
13
14
15
16
17
18
19
20
21
So I ' l l p u l l o u t a copy
of
I'm
23
g o i n g t o mark
Exhibit
12B i d e n t i f i e d . )
24
25
Go on from t h e b o t t o m o f 12A t o r e a d t o
26
SSCE0006423
115
t h e t o p o f 12B.
Does i t s u r p r i s e me now o r d i d i t s u r p r i s e
S
SCE0006424
116
1
is
that
3
4
5
6
7
8
9
10
11
12
13
14.
15
16
17
18
I don't
19
recall.
But you
20
I don't
21
Okay.
23
No.
24
All
25
recall?
recall.
So t h i s document does n o t r e f r e s h
right.
26
SSCE0006425
S
SCE0006426
10
Uh-huh.
11
Am I r e c a l l i n g y o u r t e s t i m o n y c o r r e c t l y ?
12
I b e l i e v e t h a t i s an a c c u r a t e
13
14
recollection
o f my t e s t i m o n y .
Q
What I want t o a s k y o u i s t h i s .
15
16
17
1
19
20
21
JMot t o my r e c o l l e c t i o n .
23
24
25
26
S
SCE0006427
119
121
15
I don't b e l i e v e so.
16
I mean s i n c e and up t o t h i s day?
17
I don't b e l i e v e so, no.
18
19
20
21
23
I don't b e l i e v e so, no.
24
I'm n o t g o i n g t o be w r a p p i n g up t h a t
25
quickly.
I don't know what we want t o do i n terms
26
S
SCE0006431
123
o f -- I t h i n k we m i g h t have a n o t h e r hour.
2
3
don't want y o u t o be
l o s i n g focus here.
4
5
THE WITNESS:
I f n o t , we can r e a d d r e s s i t i n 45 m i n u t e s .
6
7
I f i t ' s an hour, I'm
L e t ' s do t h a t .
Let's take
a break.
8
9
E x h i b i t s . 13 and 14 i d e n t i f i e d . )
BY
11
12
W e ' l l s t a r t b y g i v i n g you what I ' v e marked
13
and t h e n I'm g o i n g t o ask y o u --
13
ask you some q u e s t i o n s about those two.
16
What a r e t h e Bates
17
Thank you.
numbers?
Those Bates
a r e -19
THE WITNESS:
20
1510 and 1468.
Thank you.
'
you r e c a l l
23
Yes.
24
And v e r y b r i e f l y ,
25
j u s t d e s c r i b e what t h o s e
are.
26
S
SCE0006432
124
SSCE0006433
.125
126
place?
Do you r e c a l l
i f those meetings
took
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
I'm g o i n g t o show you what

mark
15
E x h i b i t 15 i d e n t i f i e d .
21
23
24
25
26
SSCE0006435
127
12$
1
2
I'm g o i n g t o show you a document

marked 1613.
from
And t h i s i s g o i n g t o be 16A
t h r o u g h G.
And I ' d ask y o u t o f l i p t h r o u g h t h i s t o
f i n d -- I ' l l pass i t t o y o u -- v e r y b r i e f l y d e s c r i b e
t h a t whole package, 16A t h r o u g h G.
6
7
8
9
10
11
12
13
14
15
Yes.
16
17
No.
18
19
No.
20
21
23
24
25
26
-SSCE0006437
Yeah.
Because t h i s i s --
Oh, i s t h i s -- I'm s o r r y , I'm l o o k i n g a t
t h e wrong ones, I a p o l o g i z e .
s what happens when

10
15
26
you're p u s h i n g t h e t i m e .
I am.
Okay.
130
D i d you
JMot
23
24
l e a r n what t h a t was about?
aerinitiveiy,
Have you e v e r h e a r d a s u g g e s t i o n o f what
t h a t was about?
26
;SCE0006439
SSCE0006440
SSCE0006442
134
135
136
137
Do you have any i d e a what t h a t was

I
only i n context t o t h e
i o n I ' v e s i n c e gone t h r o u g h , and a l l t h i s
-SSCE0006449
E x h i b i t 17 i d e n t i f i e d . )
I'm g o i n g t o show you what I ' v e marked

you r e c o g n i z e t h a t ?
I do.
Uh-huh, y e s .
SSCE0006450
142
iSCE0006453
g h t n o t q u i t e be
-SSCE0006454
You
d i d ask me t h a t , y e s .
And
you s a i d
i s that
correct:
8
9
10
11
12
13
14
15
16
17
18
19
20
21
23
24
25
think
E x h i b i t 18 i d e n t i f i e d .
26
SSCE0006456
SSCE0006457
Yes, i t
is.
SSCE0006458
150
151
SSCE0006461
153
SSCE0006462
SSCE0006463
155
158
159
5
6
Q
First
And t e l l
us about t h a t
o f a l l , was a n y b o d y e l s e
No.
So t e l l
us about t h a t
conversation.
there?
conversation.
BY
When was
this?
11
What's t h e d a t e r i g h t
12
The 7 t h .
now?
June
THE
26
S SCE0006469
161
A
9
10
11
something l i k e
13
14
15
18
19
20
21
23
24
25
26
o f anyone b e s i d e s y o u ,
t h a t y o u ' r e aware o f ?
A
17
that.
12
16
Or t h e y d i d t h i n g s t h e r i g h t way,
Speaking
No.
o f --
163
18
Okay.
19
No.
20
Any o t h e r
23
24
25
Anything
else i n that
conversation?
conversations?
For t h a t conversation, a f t e r t h e meeting,

d i d y o u make a n y n o t e s ?
A
26
SSCE0006472
164
1
2
the
D i d y o u -- d i d y o u i n f o r m a n y o n e o f
conversation?
No.
O t h e r t h a n -- o t h e r t h a n
conversations
w i t h your
Yes.
So who d i d
10
Yes.
11
And
12
Probably
13
inform?
how s o o n a f t e r
t h e meeting?
immediately
after.
14
15
16
17
18
19
20
21
22
23
24
25
26
S SCE0006473
166
167
168
169
S SCE0006478
I couldn't t e l l
you e x a c t l y
who o r when o r
how much I t a l k e d a b o u t
S SCE0006479
172
Occasionally.
No
But
specifics?
nothing
specific.
Q
specifics
I'm
going
t o . t r y and
w r a p up,
only
talking
here.
Yes.
I'm
trying
to recall
specific
I was
10
Not a t t h e t i m e , no.
11
Since then,
about
13
14
have y o u t a l k e d t o anyone
that?
A
No, n o t t a l k e d t o a n y o n e , j u s t a g a i n i n
public reference
people c a l l i n g
i t that.
18
I'm n o t a w a r e t h a t
21
I d o n ' t b e l i e v e so, no.
that.
22
26
S SCE0006484
S SCE0006485
B u t t h a t may w e l l h a v e h a p p e n e d , I c o u l d
2
3
be m i s r e m e m b e r i n g
fit.
say
i t , b u t i t c e r t a i n l y w o u l d seem t o
B u t t h a t ' s somewhat s p e c u l a t i o n .
couldn't
7
8
I recall,
no.
BY
9
10
Not t h a t
There's
a g e n e r a l wrap-up q u e s t i o n t h a t
11
ask everybody.
12
i s s u e s we've b e e n a s k i n g y o u a b o u t f o r f o u r h o u r s
13
now, I a p o l o g i z e f o r t h a t ,
we
You o b v i o u s l y know now a b o u t t h e
a n d we a p p r e c i a t e
your
14
What we n e e d t o a s k y o u now i s w h a t
15
16
we've
missed.
17
18
19
20
Is
22
there anything
23
relevant t o a l l of
24
n o t asked
25
-- a n y i n f o r m a t i o n
t h a t y o u h a v e t h a t we h a v e
about?
I d o n ' t b e l i e v e so, no.
26
-SSCE0006487
179
1
2
I t h i n k w e ' r e done f o r t h i s
afternoon.
3
4
:
y o u r t i m e , we a p o l o g i z e
There might
Thank y o u v e r y much
t h a t i t went
forward.
come a t i m e , b e c a u s e we h a v e
n o t r e c e i v e d a l l d o c u m e n t s y e t , t h a t we may n e e d t o
continue t h i s .
we w o u l d n e e d t o h a v e y o u b a c k .
that being
And so t h e r e m i g h t
Wouldn't
We'll
anticipate
give you p l e n t y o f
notice.
:
14
Again,
And do i t t h r o u g h
I remind
you t h a t our rules
However, t h e y d o n ' t
govern
15
our
16
you.
17
v e r y i m p o r t a n t , a n d a s y o u ' v e s e e n , we a l w a y s
18
initially
19
from anything t h a t might
seek t o g e t y o u r r e c o l l e c t i o n
refresh
We a s k t h a t y o u r e s p e c t
from
sharing these
questions,
23
and two,
24
be a f f e c t e d b y y o u r s .
separate
it.
t h a t and r e f r a i n
these
topics,
because t h e y w i l l
25
govern
However, t h e i n t e g r i t y o f t h e i n v e s t i g a t i o n i s
20
21
that
i n t h e immediate
10
11
come a t i m e
with
be d i f f e r e n t
b e c a u s e we n e e d t h e i r r e c o l l e c t i o n t o n o t
THE WITNESS:
Okay.
26
SSCE0006488
And
be
communicating w i t h your o f f i c e about
t r a n s c r i p t when i t ' s
convenient.
4
5
Absolutely.
know when i t ' s
We'll
But you
w r i t t e n r e q u e s t f r o m u s , o r do you?
t need a
No, we d o n ' t .
just
arrange
I f we c o u l d
i n t h e n e x t week o r t w o , i f y o u w a n t t o
10
g i v e u s some t i m e s when y o u ' r e
11
come i n f o r a f e w h o u r s
available,
want t o
i n an a f t e r n o o n .
12
A n d why d o n ' t
I l e t you
13
know when t h e t r a n s c r i p t becomes a v a i l a b l e ,
14
w e ' l l d o some s c h e d u l i n g .
16
17
l e t you
available.
reviewingt h e
and then
(Whereupon, a t 3:08 p.m., t h e d e p o s i t i o n

was
concluded.)
18
19
20
21
~22
23
24
25
-SSCE0006489
181
I HEREBY CERTIFY t h a t I h a v e r e a d
t r a n s c r i p t o f my d e p o s i t i o n a n d t h a t t h i s
accurately
t h e c h a n g e s o r c o r r e c t i o n s , i f a n y , as n o t e d .
states the testimony
this
transcript
g i v e n b y me,
with
5
6
7
8
9
10
11
S u b s c r i b e d and sworn t o b e f o r e
12
me t h i s
day o f
, 20
13
14
15
16
17
Notary
Public
18
19
20
21
My c o m m i s s i o n
expires:
"22
23
24
25
S SCE0006490
182
11
E X H I B I T NUMBER
IDENTIFIED
12
1 identified
13
2 identified
30
14
3A a n d 3B i d e n t i f i e d
33
15
4 identified
50
16
5 identified
51
17
6 identified
53
18
identified
55
19
8 identified
70
20
9A
21
10 a n d 1 1 i d e n t i f i e d
23
24
25
9H i d e n t i f i e d
87
101
12 i d e n t i f i e d
110
12B i d e n t i f i e d
114
13 and 14 i d e n t i f i e d
123
-- c o n t i n u e d --
26
S SCE0006491
183
1
2
EXHIBITS (Continued)
EXHIBIT NUMBER
IDENTIFIED
Exhibit 15 identified
126
Exhibits 16A through 16G identified
127
141
147
148
149
10
11
12
13
14
15
16
17
18
19
20
21
23'
24
MIIIIIESSCE0006492
25
40
82
138
139
157
165
UNITED STATES SENATE'

1
S e l e c t Committee on E t h i c s
2
3
4
5
6
7
Washington,
I N RE: ENSIGN INQUIRY
9
10
11
12
13
14
T h u r s d a y , J u n e 10, 2010
15
16
- 17
H a r t Senate O f f i c e B u i l d i n g
18
S u i t e 220
19
21
22
23
24
25
26
REPORTED BY:
Deposition of
examination pursuant
o f d e p o s i t i o n , on
T h u r s d a y , J u n e 10, 2 0 1 0 , i n W a s h i n g t o n , DC, a t t h e
Senate S e l e c t
on E t h i c s , Hart
Office Building,
Senate
S u i t e 220, a t
before
a N o t a r y P u b l i c w i t h i n and f o r t h e
D i s t r i c t o f C o l u m b i a , when w e r e p r e s e n t o n b e h a l f o f
the respective p a r t i e s :
ESQ.
ESQ.
ESQ.
ESQ.
U n i t e d S t a t e s Senate S e l e c t
Committee on E t h i c s
220 H a r t S e n a t e O f f i c e
W a s h i n g t o n , DC 20510
202-224-2981
Building
APPEARANCES
(Continued):
2
3
United States
Senate
Select
4
on E t h i c s
5
.220 H a r t S e n a t e O f f i c e B u i l d i n g
6
W a s h i n g t o n , DC 20510
7
8
On b e h a l f o f S e n a t e E t h i c s
9
10
11
12
W a s h i n g t o n , DC
14 '
15
On b e h a l f o f t h e W i t n e s s
16
17
18
19
Committee
P R O C E E D I N G S
1
Welcome.
2
3
4
What w e ' r e
going
t o s t a r t w i t h i s some s t a n d a r d m a t t e r s we r e a d t o
a l l witnesses.
the
Select
C o m m i t t e e o n E t h i c s h a s summoned y o u a t a d e p o s i t i o n
as a w i t n e s s i n c o n n e c t i o n w i t h t h e Senate's
p r e l i m i n a r y i n q u i r y concerning Senator
Ensign.
My name
with
8
9
10
also have
11
12
a court reporter
t a k i n g down t h e t e s t i m o n y a n d t h e q u e s t i o n s
14
15
16
17
18
19
20
21
22
23
24
25
26
be
today.
We h a v e b e e n a u t h o r i z e d b y t h e C h a i r m a n
and V i c e C h a i r m a n o f t h e C o m m i t t e e t o c o n d u c t
questioning i n this
Our q u e s t i o n s a n d y o u r
answers w i l l be r e c o r d e d b y t h e c o u r t r e p o r t e r , a n d
because t h i s
branch
the
i sa deposition before a
agency, your
False
Statements
statements
today a r e subject t o
S t a t u t e , Section 1001
T i t l e X V I I I o f t h e U.S. Code.
because t h i s
legislative
And a d d i t i o n a l l y ,
i s a sworn d e p o s i t i o n , your
are s u b j e c t t o t h e p e n a l t y o f p e r j u r y under S e c t i o n
7B o f t h e S u p p l e m e n t a r y P r o c e d u r a l R u l e s o f t h e
S e l e c t Committee o n E t h i c s , and S e c t i o n 1621 o f
T i t l e X V I I I o f t h e U n i t e d S t a t e s Code, a s w e l l a s
the
S e c t i o n 1505.
O b s t r u c t i o n o f Congress
Thus, y o u may n o t make a n y i n t e n t i o n a l l y

2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
f a l s e statements
o r k n o w i n g l y m i s l e a d t h e Committee
t h r o u g h your answers
today.
Do y o u u n d e r s t a n d
THE WITNESS:
that?
Yes, I do.
MR. SCHWAGER:
I n t h a t c a s e , I'm g o i n g t o
ask t h a t you be sworn i n .

Whereupon,
was
c a l l e d as a w i t n e s s and, h a v i n g f i r s t b e e n d u l y
s w o r n , was e x a m i n e d a n d t e s t i f i e d
as f o l l o w s :
EXAMINATION
I want t o be t e l l i n g
you t h e t r u t h
n e x t s e c t i o n s o I'm g i v i n g y o u some r u l e s
i n this
books.
A g a i n , now t h a t y o u ' v e b e e n s w o r n i n , I
need t o ask, do y o u u n d e r s t a n d t h a t y o u r
today are subject t ot h e statutes
rules
21
22
23
andcommittee
concerning false statements, p e r j u r y and
obstruction
o f Congress?
Y e s , I do,
The r e c o r d s h o u l d r e f l e c t
that
24
represented here today b y
25
s i t t i n g w i t h you today; i s t h a t c o r r e c t ?
26
statements
you're
Okay.
explained a l l
representation.
witnesses'
Ensign
issues r e l a t e d t o your
However, w e ' r e a w a r e t h a t some
attorneys fees are being p a i d by
o r o t h e r s and t h e r e f o r e ,
whether you
Senator
t o ask you
t h a t your
y o u a n d owes h i s o r h e r f u l l
has
We're c o n f i d e n t t h a t
represents
d u t y o f l o y a l t y t o you
and y o u a l o n e i n t h i s d e p o s i t i o n , no m a t t e r who
10
be p a y i n g h i s f e e .
11
A
12
Yes, I
understand.
14
understand
15
to
16
paying your a t t o r n e y fees.
20
21
t h a t y o u do n o t
any d u t y o f l o y a l t y
any o t h e r p e r s o n m e r e l y b e c a u s e t h e y may
17
19
that?
And f u r t h e r m o r e , I m u s t a s k w h e t h e r y o u -
13
18
may
be
that?
Yes, I d o .
And do y o u a l s o u n d e r s t a n d
t h a t your
duty
t o d a y i s t o answer t h e q u e s t i o n s t r u t h f u l l y a n d
completely t o t h e best o f your
22
Yes, I d o .
23
Okay.
Now
ability?
y o u have been p r o v i d e d w i t h
24
c o p y o f o u r p r o c e d u r a l r u l e s , a n d as a g e n e r a l
25
m a t t e r , Supplementary P r o c e d u r a l Rule 8 d i c t a t e s
26
strict
c o n f i d e n t i a l i t y on o u r p a r t r e g a r d i n g t h e
1
f a c t o f t h i s d e p o s i t i o n and a l l s t a t e m e n t s
today.
2
These r u l e s do n o t g o v e r n
y o u r own
3
discussions of t h i s
interview.
However, i t ' s t h e
4
committee's
e x p e c t a t i o n t h a t no w i t n e s s
tailor
5
o r c o o r d i n a t e h i s o r h e r t e s t i m o n y b a s e d on a n
6
earlier
And
t h e r e f o r e , we're a s k i n g t h a t you
r e f r a i n from d i s c u s s i n g our q u e s t i o n s and your
answers w i t h anyone
10
than your
attorney.
Do y o u u n d e r s t a n d ?
11
A
12
Uh-huh.
Yes, I do.
t o Supplementary Procedural Rule
13
14
6, y o u ' r e e n t i t l e d t o t h e o p p o r t u n i t y t o i n s p e c t t h e
15
t r a n s c r i p t o f your d e p o s i t i o n i n . t h e
16
o f f i c e s and r e q u e s t t h a t any t r a n s c r i p t i o n e r r o r s b e
17
corrected.
18
t h e committee's
19
Any e r r o r s o f f a c t
committee's
be brought t o
a t t e n t i o n through t h e submission o f
sworn statement, and i f y o u w i s h t o i n s p e c t t h e

transcript,
y o u c a n j u s t l e t u s know
next
c o u p l e o f weeks a n d w e ' l l b e h a p p y t o a r r a n g e a
21
i n o u r o f f i c e s t o make i t a v a i l a b l e t o t h e t w o
22
23
24
o f y o u a n d a l l e x h i b i t s b e made a v a i l a b l e a t t h a t
t i m e as w e l l , o k a y , i f a n y .
i f
25
26
need any t i m e a t a l l
d u r i n g t h e d e p o s i t i o n t o d a y t o speak t o y o u r
counsel
o r t o t a k e a b r e a k f o r any r e a s o n , j u s t l e t us
and w e ' l l g i v e y o u w h a t e v e r
time
okay?
Y o u r c o u n s e l i s f r e e t o a s k f o r t h a t as
|:
Thank
know
well.
you.
I
understand
t h a t y o u w a n t t o make a r e c o r d as w e l l .
I
do.
Just at the outset,
want t o r e q u e s t t h a t t h e committee,
ultimately
should i t
r e l e a s e any m a t e r i a l
from
t e s t i m o n y o u t s i d e o f t h e Senate,
c o n s i d e r t h e p r i v i l e g e and
consult with
that i t
Senator
c o u n s e l on t h a t i s s u e .
We'll take t h a t
into
consideration.
Thank you.
Do
questions,
e i t h e r o f you,
THE
WITNESS:
you have any
o r concerns
other
a t t h i s time?
I do n o t .
Do
not.
All
right.
T h e n I'm
going
I'll
show t h i s t o y o u
and
ask
you
i f this
1
looks
t o you.
Do
you
recognize i t ?
2
A
Yes,
I do
recognize
3
And
do
you
t h e subpoena -
t h a t you
e x c u s e me,
received
deposition
r e c o g n i z e t h a t t o be
the n o t i c e of
summoning y o u
here t o
a copy
of
deposition
this
today?
Yes.
A l t h o u g h t h i s wasn't f i l l e d
out
on
8
my
copy.
Q
10
" t h i s , " you're r e f e r r i n g
11
page of E x h i b i t
12
correct?
A
13
which
to the
a return
of
back
service;
Yes.
Great.
Thank you v e r y much.
14
All
right.
We're g o i n g
t o s t a r t w i t h some
15
basic background questions,
g e t t o know a l i t t l e b i t
16
17
18
19
a b o u t you.
Why
d o n ' t you
educational
background.
s t a r t w i t h your
20T h a t w o u l d be
great
21
22
23
24
Q
25
26
And
w h e r e d i d you
go
after
that?
10
12
13
15
17
18
Thank y o u .
Okay.
23
25
26
11
Do y o u r e c a l l any
responses?
I do n o t r e c a l l
responses.
not r e c a l l .
any
27
28
1
2
3
4
5
6
8
10
11
12
13
14
15
16
17
18
19
20
11111111111.1 1111111.11.
11111111
11111111111.11111111111 I don't
A 11111111111111.1
Right.
No.
A
Okay. Okay.
A 111111111111111111.111.
111.1111111111111.
MEN11.111111.1111111111111" I don't recall
anything.
111.11011111111111111111111111.1111111
A 1111111.11.
111111.1111.111111
22
23
24
25
26
SSCE0002179
29
1
2
3
4
5
6
7
8
9
10
11
12
13
14
All right.
15
16
17
NUISMININIIIMIMM11.111111.11.111.1111.1111.1111111
A
I don't. I just -That's fine.
18
21
22
Right.
23
Yes.
24
Describe that to us.
25
26
11111111-SSCE00021 80
30
1
A
2
3
Did you want

4
me to --
5
6
Go ahead and describe that.
Okay.
8
9
10
11
12
13
Let me go back and explore that kind of
14
15
16
piece by piece.
A
Okay.
17
18
19
20
21
22
23
I don't remember. I don't remember when
this was. I just can't recall.
24
25
26
EIMM-SSCE0002181
31
1
2
3
IIIIIIIIIIIIIIIIIII
4
5
about that.
But again, I'm not certain
That's fine, that's fine.
7
A
I do not recall the specific -- specific
way that I found out about
9
10
11
12
13
14
15
16
17
18
19
21
22
23
24
I do not remember when that was. I can't
25
26
INIMSSCE00021 82
32
recall.
1
2
3
Okay.
4
5
6
7
1MMEIMMEIMM
II
11.
1
9
10
11
12
13
14
15
16
17
18
111111111111111"
111.111.1"
19
20
-SSCE00021 83
33
2
3
4
5
7
8
9
10
11
12
13
14
15
16
17
18
Okay.
19
20
21
22
I don't recall.
23
24
Okay.
25
26
111111-SSCE00021 84
34
4
5
Were you -- right.
6
A
Was I aware of that?

Right, right. You obviously can't know
8
9
Right, right, right.
10
11
12
Okay.
13
14
15
16
17
18
19
71)
21
22
23
24
25
26
11.I.SSCE00021 85
35
1
2
Right.
A
That's assumed.
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Sure.
25
26
SSCE00021 86
36
1
No, it would not have.
2
3
4
A 1111111111111111111
: Please.
Yes.
BY111111111111
9.
111111111111111
10
11
12
111
13
14
Q Okay.
15
16
17'
18
19
20
21
A
IIIIIIIIIIIII 1111111111111111.11"
1111111111111111111111111111111111
22
23
24
25
26
SSCEOOO2 187
37
1
2
3
4
5
6
7
8
9
10
11
: Anything else on this?
12
:
13
No.
14
15
16
17
18
19
20
21
22
23
24
25
26
M-SSCE0002188
38
1
2
3
4
5
8
9
Okay.
10
11
12
13
14
15
16
17
18
19
20
-SSCE0002189
39
Okay.
1.111111111111.
1111111111111111111111111111111.11111
3
4
5
A 11111111111.1111111111111.111
7
111111.""1.111
Q Okay - 1111.111.
1111111111
10
11
A 11111111111111111111111111111111111
12
13
14
15
MINN
A
16
17
18
19
20
21
22
23
24
25
You know, I don't -- I don't recall
26
SSCE00021 90
40
specifically.
1
2
4
5
6
9
10
I cannot recall any sort of conversation.
11
12
13
14
15
16
17
18
19
Is that your
20
111111111111111/111111111111
recollection?
21
2
23
That's my recollectiOn.
24
25
26
-SSCE00021 91
41
That I can't recall.
1
2
3
4
5
6
7
I actually don't -- I don't ever recall
8
9
10
knowing that.
Okay.
11
12
13
No, I do not recall -- I do not recall
A
that.
14
15
16
17
18
19
20
21
22
23
24
25
26
11M-SSCE0002192
42
1
2
3
A
4
5
6
8
9
10
11,
12
If you can
13
14
15
16
17.
1111111111111111111111111111111111111
I'd be happy to take a
refresh my recollection,
look.
Q
I will do my best.
(ExhibitIII-2 identified.)
: I'm going to show you a
18
19
20
21
22
23
24
25
document that I will mark III-2A, B and C. It's

actually --111111111111111111111111111111111111111111111111111111
111111 I'm going to show it to you as one exhibit.
just for the purpose of refreshing your
recollection. III2A is a document with the number
679 on it. II1[2B has a document number 677 on it.
Give an extra copy to counsel to review
26
-SSCE00021 93
43
while I'm marking these as well..

Andll1-2C has document number 678 on it.
1
2
Just take a look through those and see if

they refresh your recollection in any way.
THE WITNESS: Okay.

5
6
I'm sorry, your question?
BY
Q 1111111111111111.1111111111111111111111
9
10
11
12
13
14
1111111111111111111111111111.1"1
111111111 I would also like to point out for the
A
record --
15
16
Please.
-- that in looking at Exhibit .2C,
17
18
I was going to ask you about that, to
19
20
explain.
21
11.11.1M1111.
1111111
1
22
23
24
25
.1.11
26
IMOSSCE0002194
44
Okay.
Q
A
2
3
4
5
6
8
9
10
11
12
13
This would suggest -- this would indeed
14
15
16
suggest that.
Q 111111111111111111.1111111"
111111
17
18
19
This -- this particular meeting?

Right.
21
22
23
24
25
26
SSCE00021 95
45
1
Okay.
2
3
Uh -huh.
4
5
6
9
10
11
12
I would say it was after this.
Okay.
13
14
15
16
17
18
19
20
Okay.
21
22
23
Because for whatever reason, I wasn't
there to write it.

Do you have any independent recollection
24
25
of that as you sit here today?
26
-SSCE0002196
46
I don't.
1
2
3
4
. (Laughter.)
5
6
Okay.
8
9
10
11
12
Just offhand or after having refreshed my
recollection?
After having refreshed your recollection.
13
14
Could I have a Minute to --
15
Please do, take all the time you need.
16
17
18
19
20
21
22
23
24
25
26
111.11-SSCE00021 97
47
3
4
5
6
7
8
Okay.
9
A
10
11
12
13
14
15
16
17
18
19
21
22
23
24
25
26
IIIIIISSCE00021 98
48
1
2
4
Okay. All right.
5
6
A
9
10
11
12
(Exhibit-1113 identified.)
13
14
15
16
17
18
19
20
21
BY
I'm going to show you a document that I'll
ask you to describe. I'll give you a copy while I

mark it 111-3A through D.
This does not have any Bates stamp numbers
on it,
111111111111111111111111111111
: Might be cut off.
Is the copy on the bottom
22
23
24
25
cut off? Sorry about that. The'original will have

that and you'll see it. Top of each page, page 1 of
4, 2 of 4, 3 of 4 and 4 of 4.
26
11111SSCE0002199
49
BY
I'm going to be referring, obviously, to
Q
the text on II-3B and C, pages 2 and 3 of this
2
3
document, not all the Web site stuff. At the top of
the page, you'll see page 2 of 4 and page 3 of 4 is

what I'm referring to.
After you've taken as much time as you
6
7
need, I'll ask you if this refers to the letter that
you were just testifying about.
. (Witness reviewed the document.)

10
11
1111111111111111111111111111111111111111
12
13
17
Yes, that is correct.
Okay.
18
19
20
21
22
23
24
1111111111111111111111111111111111
Yes.
A
Q
Okay.
1111111.11111111111111111111111.11.1111111
25
26
111111111-SSCE 0002200
50
Okay.
2
3
4
A
5
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
111.11-SSCE0002201
51
1
2
1111111.1111111111111111111111111111111
3
4
A
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
I'm I'm guessing.
1111.111111111111.11
21
Okay.
22
23
24
25
26
SSCE0002202
52
1
2
8
9
10
11
12
Okay.
13
14
15
16
17
18
19
20
21
Zr
23
24
I did not know Lna
d 't
surprise me, though.

Q ' Would that have surprised you then?
A
25
26
-SSCE0002203
53
2
Let me correct what I said.
3
4
5
6
7
8
9
10
11
12
13
14 15
16
17
18
19
Maybe I'm not setting the timeframe right.
20
21
A Okay.
22
23
24
25
26
IIIIII-SSCE0002204
54
1
Okay.
2
3
4
5
6
Q 111111111111111111111.
1111111.1"
8
9
11,
111
1
1
11111-111111
10
11
12
13
14
15
Q Okay. 111111111111111111.111111111
16
18
17
19
1111111111
A 1.11111111111.111111111.1111111111111
20
21
22
23
24
25
26
SSCE0002205
55
3
4
A
5
6
8
9
10
11
Okay.
12
13
14
15
Okay. Thank you.
16
17
18
19
21
22
23
24
25
26
EllitSSCE0002206
56
3
4
5
6
7
Okay.
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
Okay.
23
24
25
26
SSCE0002207
57
2
3
clear.
Okay. Thank you. We're just trying to be
5
6
I don't, but If you
A
can refresh my recollection, I could certainly take
7
8
a look.
(ExhibitII1[4 identified.)
10
11
12
13
14
15
16
BY 11111111111111:
Show you what I will mark as 4A and B,
give you a copy while I'm marking it. These are

documents with numbers at the bottom 1652 and 1653.
A 11111111111111111111111111.11111111
17
18
19
20
21
22
23
24
25
26
11111111-SSCE0002208
58
3
4
5
6
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
I don' t recall.
24
25
26
111111-SSCE0002209
59
1
Yes, that is
2
Q
that is correct.
All right.
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
Okay. Thank you.
20
21
22
23
24
25
26
-SSCE000221 0
60
2
3
4
5
6
8
9
10
Okay.
11
12
13
14
15
16
17
18
19
20
21
22
23
I understand you said you Have very little

recollection, don't recall the details. I'm going
to ask you those questions anyway, just to see if
they trigger some recollection.
A Okay,
24
25
26
1111111
-SSCE0002211
61
1
2
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
11111-SSCE0002212
62
3
4
5
6
10
11
12
13
14
15
16
17
18
19
20
21
2.2
23
Okay.
24
25
So I --
26
11111-SSCE000221 3
63
1
2
A
3
4
5
6
7
Okay.
8
9
10
11
12
13
14
15
Okay.
16
17
11111.11.11111.1111.111
But --
18
19
20
21
22
23
24
25
26
IIMMISSCE0002214
64
11111111111111111111
This whole matter?
The entire matter in which the committee
is looking at.
How about Senator Ensign?

A'discussion with SenatOr Ensign
regarding?
7
8
9
10
11
12
13
14
15
16
17
18
19.
20
21
Yes, absolutely.
Yes, I did.
22
23
24
25
26
1111.11111-SSCE000221 5
65
3
4
5
6
7
8
Did you take that opportunity?
10
11
I did end up taking that opportunity.

We're going to come back to that.
12
13
14
15
16
17
Okay.
18
19
To the best of my recollection, it didn't.
21
22
Okay. And we'll come back to it kind of
23
24
in a chronological sense in just a moment.

: Can we go ahead and take a
25
26
-SSCE0002216
66
break?
Absolutely.
2
3
(Recess.)
BY
5
6
We're back on the record. Remind you for
the record that you're still under oath.

A
Okay.
: May I interrupt --
10
Please.
11
12
13
14
15
16
17
I do have a question.
lp
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BY
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11.111.-SSCE0002217
67
That's correct.
Okay.
6
7
8
9
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18
19
So wait, I'm confused on the time. So
this would have been the time period after --
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Oh, I see what you're saying.
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IIIIIBSSCE0002218
68
A Right.
1
2
4
5
6
Right, no, I understand your question.
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z2
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Do you remember with whom?
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-SSCE000221 9
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I do not remember with whom.
111111111111: Okay. Thank you.

BY
One last question.
Sure.
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No.
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SSCE0002220
70
1
2
3
Thank you.
4
5
BY
We're trying, obviously, to be very
thorough and ask youabout this matter in all .
different ways to help refresh your recollection.
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10
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71
So I'm pretty certain that there was
general discussions of that. I don't remember
specific instances, but I would say yes.
4
5
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7
No, absolutely not.
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9
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13
Okay. All right.
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11111111-SSCE0002222
72
1
2
.3
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8
(Exhibit -5A throu44111-5C identified.)
14
BY
15
16
17
18
19
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21
22
I'm going to show you....5A through C,
documents with Bates numbers on them 121, 122 and

123. And here's an extra copy.
Thank you.
THE WITNESS: Right. So in this I am
referring to ExhibitIIII-5A, 111-5B and-5C.
23
24
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26
111111-SSCE0002223
73
1
2
'Excuse me,
3
4
5
THE WITNESS: There you go. Thank you, I
appreciate that.
7
8
9
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THE WITNESS:
14
And the date is actually

15
16
on the page before Exhibit 111,5B.
17
BYNUM.:
And what's the subject line?
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19
70
11111111111
Do you understand what that refers to?
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22
23
1111111111111.111111111111111111111111111"11
111111111.
11111111111111111
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25
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1111111-SSCE 0002224
74
I did.
1
2
3
4
Okay.
A
8
9
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12
A Okay.
13
14
15
Yes.
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22 .
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SSCE0002225
75
1
I don't think I did.
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A
I don't.
That name rings a bell.
Okay.
22
At the time?
23
At the time.
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25
13
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I don't recall being aware.

Okay.
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SSCE0002226
76
1
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5
Oh, absolutely.
8
9
10
Okay. We'll go into that in a minute.
11
12
Okay.
13
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11111111111111.
1111.
1111111111
A
Okay.
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11111111-SSCE0002227
77
1
2
3
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A
5
6
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Oh, absolutely, I absolutely was, yes.
13
Okay.
14
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20
Well --
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111111SSCE0002228
78
1
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That was not.
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-SSCE0002229
79
2
1
111111111111111111111111
What would you have done?
Q
4
5
Who was?
A 111111111111M
All right.
INIIIIIIMINIIIIIIIIIIII"""
10
11
12
Q Okay. 1111111111111111111111111.1111
13
NMI
14
15
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17
I believe it was.
IIIIIIIIIIIIIII"Mil"I
correct?
A
1111111111111111.1111.11"
18
19
Okay, right. Thank you.
20
21
22
23
24
25
A 11111111111111111111111111111111111
1111111111111111111111
All right.
MOM
26
-SSCE0002230
80
1
BY 11.111.1:
Do you -- yeah, so if you go to 111-5A, the
top of the page,
4
5
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A
10
11
12
11111111.
111111111111.111111111.111.1
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Okay.
26
mimSSCE0002231
81
2
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7
Okay.
8
9
But that's the extent of it.
Okay.
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11
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17
Okay.
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19
70
1.11.1.
111111111111111111111.1111111
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1111111111111
A
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-SSCE0002232
82
Okay.
4
5
6
Along which line?
8
9
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.16 .
That I don't recall. That I don't recall.

Okay.
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11111111SSCE0002233
83
2
3
4
A
6
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9
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No, I don't. I don't.

BY
18
So that I'm clear as to what we have here.
19
20
A Okay.
We have a document, what's the exhibit
21
22
nuMber?
23
24
III5C.
The exhibit numbers are II-5A, 111-5B and
25
26
11.1.-SSCE0002234
84
1
2
Yes.
Yes.
Yes.
3
4
5
6
7
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A
Right.
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Okay.
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11.1111-SSCE 0002235
85
1
2
3
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8
That's what this is, isn't it?
9
10
Yes.
: May we just have a moment?
11
: Absolutely.
12
13
(Recess.)
14
BY
15
We're back on the record.
16
17
And just one clarification, in terms of
your question.
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11.11-SSCE0002236
86
2
3
4
5
6
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8
9
Thank you.
10
11
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23
Okay.
BY
I want to ask 1Tc:it' a question, and I do not

Q
want to ask you anything about conversations you've
had with your counsel, okay?
24
25
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SSCE0002237
87
1
2
3
4
Yes, to the best I can recall, yes.

Okay.
6
7
8
9
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12
A
recall.
So this would be the only instance?
13
14
Not that I can recall. Not that I can
15
16
17
Okay.
18
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1=111-SSCE0002238
88
3
4
6
7.
8
9
10
BY
11
12
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A
20
21
At what point in time we're talking about
now?
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11.1.111-SSCE0002239
89
1
2
3
4
5
Okay.
6
7
8
9
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11
12
13
That I don't recall.
Okay.
14
15
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17
18
19
Okay.
20
21
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A
Do you have any information yourself that
23
24
25
would suggest that?

A
No, I -- not that I have that would
26
MESSCE0002240
90
suggest that, no.

BY
3
4
5
6
7
: Yeah.
9
10
BY
11
12
13
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15
That I don't remember.
16
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20
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BY
Let me ask a different question, then. So
witndraw Llie
J_1/.4 )
23
24
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26
11.1111-SSCE0002241
91
Right.
To the best of my recollection, no.

BY
3
4
5
6
7
Any of these --
8
9
10
11
12
13
14
15
Okay.
16
17
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19
2n
22
All right.
23
24
25
26
111111111-SSCE0002242
92
1
2
3
4
5
6
7
8
9
10
.11
12
Okay.
13
14
15
16
17
A
don't recall that.
18
19
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22
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24
25
26
Mil-SSCE0002243
93
1
I do, actually.
2
3
4
5
6
IIIIIIIIIIIIIIIIIII
Some months later. I don't remember
exactly when that was.
10
111.11111111111111111111111"
11
12
13
14
I could have been.
I -- I don't remember.
15
16
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18
11111111111111111111111111111111111
don't recall.
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20
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26
A Okay.
I just -- I
94
A
3
4
5
8
9
10
11
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13
14
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18
No, no, that would not have gone through
me, and I don't recall that.
19
20
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23
I don ' t . I don't remember.
24
25
I don't remember.
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11..-SSCE000245
95
1
Okay.
4
5
That I don't recall.

Okay.
6
7
8
9
10
Yes, we know it's difficult. Do your
11
12
13
best.
A
14
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17
But again, this is a very vague
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23
recollection.
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MIN-SSCE0002246
96
1
2
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A
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=NM
22
Right, right.
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THE WITNESS:
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-SSCE0002247
97
BY
1
2
3
A
4
5
Okay.
6
7
8
9
10
11
12
13
That's correct, that's correct.
Well --
14
15
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17
First of all, about when was it?
18
That I don't remember.
19
21
22
Okay. All right.
23
24
25
26
-SSCE0002248
99
1
2
That I just don't remember.
3
4
You do or you don't?
5
6
7
Okay.
8
9
10
11
12
13
14
15
16
17
18
Okay.
19
20
21
It would have been more of -- I just
don't -- I don't remember.
22
23
24
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SSCE0002250
100
1
2
A
3
4
5
6
Okay.
9
10
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20
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22
23
Okay.
24
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1111111SSCE0002251
101
1
2
3
4
Okay.
5
6
A
7
8
9
10
Okay.
11
12
13
14
15
16
17
A.
18
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llISSCE0002252
102
1
2
3
4
5
6
Q
Okay.
Yes.
8
9
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11
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SSCE0002253
103
Do what?
1
A
2
3
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6
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8
11111111111111"
1111111111111
9
A
10
11
12
13
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0
MEN
A
1111111111111111111111111.111"1"1"1111
21
Okay.
22
23
24
25
26
1111111.1-SSCE0002254
104
1
2
3
Yes.
No. And as a matter of fact, I think it
would have been the opposite.
Okay.
BY
8
9
10
11
12
13
14
15
16
17
Q . Okay. Not approving?

A
18
19
20
21
22
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24
Let's be clear -25
26
11111-SSCE0002255
105
BY
Just so that I want to be clear with you,
2
3
when we put questions to you, we're not suggesting
an answer or suggesting words. And it's my way
simply of asking what your best recollection is.
A Okay.
7
8
And'we appreciate that.

BY
9
10
11
12
13
14
15
16
17
18
Okay.
19
20
21
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IIIIIMSSCE0002256
106
6
A
8
9
10
11
12
13
14
15
16
17
18
19
No.
20
Okay.
21
To the best of my recollection.
To the best of my recollection --
22
23
24
25
26
111111-SSCE0002257
107
1
2
3

Okay.
5
6
7
A
10
11
12
13
14
15
16
17
18
19
20
21
22
Right.
23
24
25
26
IMSSCE0002258
108
2
A
3
4
5
6
Not that I can -- not that I can recall.

Okay. We're just going to step out for a
minute and make sure that we're ready to wrap.

(Recess.)
10
BY
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Andrew, we really appreciate all of your
efforts here to share with us, you know, whatever

exists in your recollection about these matters and
to be clear about the nature of those recollections,
and we definitely appreciate it.
We ask a general wrap-up question at the
end of all of these, and that's this. You know,
we've gone on at length about various issues, and
you understand, I believe, now the scope of what it
is we've been asking you about.
What we ask is do you have any other
infoLmation or knowledge regarding the matters that
we've been asking about that we haven't touched
that's related to this that you can share with us?
26
11111
-SSCE0002259
109
In other words, what did we miss?
You know, I think these questions pretty
much cover it. They have covered things that I
didn't remember, so there's nothing that I could --
4
5
6

1111111111111: All right. Anything else
8
for the record?
No. We just want to thank the

10
11
12
13
14
15
16
Committee for its time, and obviously,

intends to continue to cooperate with this
investigation as it proceeds. And we just want to
reserve the right to supplement the record with any
information that should come to light subsequent to
this deposition.
: We welcome it. And, in
17
18
19
fact, we have not yet received all the documents

that we'll be receiving in this matter so there
might come a time that we need to ask you additional
20
21
questions. But with that, for today -: We will suspend.
22
Thank you.
23
24
25
was concluded.)
26
IM-SSCE0002260
110
5
6
X
7
8
9
10
11
12
day of
, 20
13
14
15
16
X
Notary Public
17
18
19
20
21 .
22
23
24
25
MIESSCE0002261
111
CONTENTS
2
3
EXAMINATION
WITNESS
4
by
5
6
7
8
9
EXHIBITS
10
IDENTIFIED
11
EXHIBIT NUMBER
12
Exhibit
1 identified
13
Exhibit
2 identified
42
14,
Exhibit
3 identified
48
15
Exhibit
4 identified
57
16
Exhibit
5A through-5C identified
72
17
18
19
20
21
22
23
24
IIIMI-SSCE0002262
4
5
6
9
10
11
12
13
14
15
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21
22
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25
v\I
26
SSCE0002171
22
3
4
5
6
7
8
9
10
11
12
13
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19
20
21
22
23
SCE0002173
98
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
QO
16
17
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19
20
21
23
24
25
.Q
26
1111111-SSCE0002249
SELECT COMMITTEE ON ETHICS
3
4
5
I n the matter
. SENATOR JOHN ENSIGN
June 29, 2010
Washington,
8
9
Deposition
11
a Witness, c a l l e d f o r examination pursuant t o n o t i c e of
12
deposition, on Tuesday, June 29, 2010, i n Room 220 of t h e
13
Hart Senate O f f i c e B u i l d i n g , Washington, D.C, a t 10:30
14
a.m., before
15
f o r the D i s t r i c t of Columbia, when were present on behalf o f
16
the respective p a r t i e s :
17
18
19
20
26
a Notary Public w i t h i n and
1
2
For the Witness:

pro se
3
4
For the Ethics Committee:
Counsel
Chief Counsel
Counsel
8
9
Counsel
United States Senate
10
11
22 0 Hart Senate O f f i c e B u i l d i n g
12
Washington, D.C. 20-510
13
T 202.224.2981
14
F 202.224.7410
15
16
17
18
19
20
21
-33-
23
24
25
26
Also present:
Deputy S t a f f D i r e c t o r
CONTENTS
2
3
Examination by:
4
5
6
7
8
9
10
E X H I B I T S
11
12
Deposition E x h i b i t
Marked
13
14
15
17
16
18
17
18
18
20
19
20
20
36
21
7A, B, C
42
23
(Exhibits
retained.
24
25
26
SSCE0003212
1
2
C E E D I N G S
(Discussion o f f the record.)
Thank you, I am, and we're on the record.

Good morning,
: Good
As the Chief Counsel advised you, I'm
going t o go through some matters here p r e l i m i n a r i l y t h a t we
go through w i t h a l l witnesses, and f i r s t we advised you t h a t
the Senate Select Committee on Ethigs has subpoenaed you
10
here today f o r t h i s d e p o s i t i o n as a witness, i n connection
11
w i t h the Committee's p r e l i m i n a r y i n q u i r y concerning Senator
12
John Ensign.
13
As you know,
and I serve as one of
14
the counsel t o the Committee.
15
who i s Chief Counsel, and on h i s l e f t i s
16
on my r i g h t
17
my r i g h t i s
19
On my l e f t i s
they are also counsel.
Also on
our Deputy S t a f f D i r e c t o r .
We've been authorized by the Chairman and
20
Vice Chairman of the Committee t o conduct t h i s d e p o s i t i o n .
21
We also
you t h a t our questions and your answers w i l l
recorded by the court r e p o r t e r s i t t i n g next t o you there.

23
Because
a d e p o s i t i o n before a L e g i s l a t i v e Branch
24
agency, your statements today are subject t o the p r o v i s i o n s
25
of Section 1001 of T i t l e 18 of the United States Code, which
26
creates the c r i m i n a l offense of a f a l s e statement.
understand that?
You
A d d i t i o n a l l y , because i t ' s a sworn
d e p o s i t i o n , your statements are also subject t o the penalty
o f p e r j u r y under Section 7(b) of t h e Supplementary
Procedural Rules of t h e Select Committee on E t h i c s , and
Section 1621 of T i t l e 18 of the United States Code, as w e l l
as t h e s t a t u t e c r i m i n a l i z i n g o b s t r u c t i o n of Congress a t
10
Section 1505 of T i t l e 18. You understand t h a t as well?
12
Thus, you may not make any i n t e n t i o n a l l y
13
false
o r knowingly mislead the Committee through
14
your answers today, and you understand that?
16
Okay.
17
t h e court reporter t o administer the oath.
18
Thereupon,
20
a Witness, c a l l e d f o r examination by counsel f o r the Senate
21
E t h i c s Committee and, a f t e r having been f i r s t duly sworn,

was
At t h i s p o i n t , I'm going t o ask
and t e s t i f i e d as
EXAMINATION
BY
25
And I ask you t o s t a t e again under oath t h a t you
26
SSCE0003214
do understand t h a t today i n your testimony you're subject t o
the s t a t u t e s and Committee r u l e s concerning f a l s e
statements, p e r j u r y and o b s t r u c t i o n of Congress?
Yes.
Okay.
when I spoke w i t h you t o
inform you t h a t
Committee had a u t h o r i z e d your subpoena,
I advised you t h a t you had a r i g h t t o be accompanied by
counsel i n connection w i t h the d e p o s i t i o n ; i s t h a t correct?
Right, yes.
10
And are you represented by counsel today i n
11
connection w i t h t h i s matter?
12
No, I'm not.
13
But you do f u l l y understand t h a t i f you were t o
14
request counsel t h a t we would accommodate your request, and
15
schedule your appearance here t o accommodate also the
16
appearance of your counsel?
17
Yes.
18
And i s i t your wish t o proceed w i t h o u t counsel?
19
Yes, I ' d l i k e t o proceed.
20
Very good.
I a l s o advised you
- - d o you
21
understand t h a t you do not owe any duty of l o y a l t y t o any
22
other
23
pay your a t t o r n e y fees i n connection w i t h t h i s matter?
event t h a t t h a t other
offered t o
24
Yes.
25
And you understand t h a t your duty today i s t o
26
answer your questions t r u t h f u l l y and completely t o the best
of your a b i l i t y ?
Absolutely.
I n f r o n t of you a t your seat there, we provided
you w i t h a blue book, which i s a copy o f our supplementary
procedural r u l e s , and you can take t h a t w i t h you or consult
i t as we go through the d e p o s i t i o n , i f you wish.
We mentioned t o you t h a t Supplementary Procedural
10
Rule 8 d i c t a t e s s t r i c t
11
regarding the f a c t of t h i s d e p o s i t i o n , and a l l of your
12
statements.
13
t h i s d e p o s i t i o n , however.
14
15
t h a t a p p l i e s t o us
The r u l e s do not govern your own discussions of
By t h a t , I mean we're not free t o discuss our work here

outside of work, but you are free t o do so.
16
Okay.
17
However, i t ' s the Committee's expectation and the
18
Committee's request t h a t no witness w i l l t a i l o r o r
19
coordinate h i s or her testimony based on an e a r l i e r
20
d e p o s i t i o n , and t h a t t h e r e f o r e we request t h a t you r e f r a i n
21
from discussions our questions or your answers w i t h anyone

who might also be a witness i n Lh i s
23
a t t o r n e y t o advise you i n connection w i t h i t .
24
understand that?
25
26
Yes.
Do you
Okay, and we also informed you t h a t pursuant t o
t h e Committee's procedural r u l e s , t h a t a f t e r the deposition,
you're e n t i t l e d t o inspect the t r a n s c r i p t of your deposition
here, and t h a t would take place i n our Committee o f f i c e s
5
6
You'd have the opportunity t o request t h a t any matter
contained i n the t r a n s c r i p t t h a t you deemed t o be an e r r o r
be corrected and t h a t would be brought t o the a t t e n t i o n of
t h e Committee through the submission of a sworn statement
10
11
f o r the Committee t o decide.

So i f you wish, what w e ' l l do i s a f t e r the d e p o s i t i o n i s
12
completed today, a t some p o i n t I ' l l inform you t h a t the
13
t r a n s c r i p t i s ready, and e n t i r e l y a t your convenience, w e ' l l
14
arrange f o r you t o come up t o t h e Committee spaces here t o
15
inspect i t .
16
Okay.
17
You understand t h a t , okay.
And as our chief
18.
counsel has i n d i c a t e d t o you a t t h e s t a r t , a t any p o i n t
19
d u r i n g the d e p o s i t i o n t h i s morning, i f you need t o take a
20
break j u s t t o -- f o r any reason a t a l l , j u s t i n d i c a t e and
21
w e ' l l be glad t o accommodate you.
23
F i r s t , I've marked a one-page document as
24
an e x h i b i t and I place i t before you, and ask you t o take a
25
look a t the document and t e l l me i f you recognize i t ?
26
(Exhibit
1
2
THE WITNESS:
1 was marked f o r
Yes. I t ' s a document I received i n the
3
4
5
6
Okay, and i s i t a copy of t h e subpoena
you t o appear today f o r t h i s deposition?
Yes.
Very good, thank you.
directing
could you give
us your f u l l name please f o r t h e record?
10
11
12
13
14
Very good, and what i s your address please?
15
16
17
Yes.
18
And by whom are you employed?
19
20
21
23
24
25
26
Thank you, and are you p r e s e n t l y employed?
10
1
Yes.
2
3
4
5
6
7
8
9
11
12
13
14
15
16
17
18
19
20
21
23
24
25
26
Where i s that?
Very good, and what do you f o r them?
We wish you a l l the best.
Thank you.
And
a l l r i g h t , and what i s your educational
Uh-huh.
What d i d you do a f t e r that?
11
SSCE0003220
12
S
SCE0003221
13
SSCE0003222
15
16
17
Thank you.
1
document which we've marked as
4
5
t o show you a
e x h i b i t , and i t ' s Document
I ' d ask you t o take a look a t the document and t e l l

us i f you recognize i t .
(Exhibit
was marked f o r
BY
10
11
15
Did you sign i t ?
Yes.
Yes.
Yes.
23
Okay, very good.
24
I t ' s Exhibit
25
I s i t signed by -- I'm sorry.
f o r the record.
26
S
SCE0003226
Yes.
Oh, okay
4
5
6
7
8
9
Okay.
which I've marked as
I'm going t o show you a document

i t ' s not the next one i n order, b u t
10
i t ' s the one beyond t h a t .
11
I ask you i f you can t e l l me, do you recognize t h a t
12
document?
13
14
(Exhibit
I t ' s a document marked
and
was marked f o r
THE WITNESS:
15
16
17
18
19
20
21
Yes.
we l e a r n then from
23
24
document ?
A
25
26
S
SCE0003227
Yes.
Yes.
7
8
I show you
look a t that as w e l l .
9
10
(Exhibit
was marked f o r
THE WITNESS: Yes.
11
12
Of course.
a l l three?
Yes, yes, go ahead.

THE
21
Do you want me t o go through
Yes, go ahead.
15
18
5 and ask you t o take a
Okay.
BY MR. CORCORAN:
Okay, and what's the date of that?
26
SSCE0003228
20
5
6
11
Yes.
(Exhibit
was marked f o r
I show you E x h i b i t
and ask i f you recognize
t h a t document as well?
Okay, and d i d you sign i t as well?

Yes.
17
18
Yes
: Very good.
I have one more document of
19
t h i s type t o show you, and then my colleagues may have some
20
questions.
21
Exhibit
I have a one-page document I've marked as

I ' d ask you t o take a look a t t h a t .
marked f o r
THE
26
S
SCE0003229
21
SSCE0003230
22
S
SCE0003231
2
3
to
BY
I'm coming back
I j u s t want t o put on the record, and then I'm
going t o ask my colleagues t o chime i n here.
7
8
9
10
11
But I'm
not sure
12
Okay.
13
I don't t h i n k I d i d .
14
Okay, okay.
15
BY
16
I have a few questions, okay
17
18
19
20
21
23
24
25
26
-SSCE0003232
-SSCE0003234
26
3
4
BY
6
7
8
9
10
11
12
13
14
15
16
17
18
19
Okay.
20
21
22
Okay.
We've given you a calendar there, and I'm
going to give you back hX lblt
23
24
Yes.
25
26
MIIIIMI-SSCE0003235
27
2
3
Okay, great.
4
5
Yes.
Okay.
9
10
11
12
13
14
15
16
No.
17
Okay. I also want you to take a look atIIII-5,
Yes.
18
is that
19
right?
20
21
Q
A
23
Yes.
Yes, u -hun.
24
25
26
SSCE0003236
28
A
2
Okay.
Okay.
5
6
Right.
8
9
It's similar.
10
11
12
13
14
15
Not that I know of.
16
Okay.
19
No.
20
17
18
21
es, ic cloes.
GG
23
24
25
26
IIIIII-SSCE0003237
29
1
2
3
No, I don't -- no. I'm pretty sure I did not.
okay.
No, I don't remember anything like that.
10
Yes, yes.
11
Okay.
12
BY
5
6
7
8
9
13
14
15
16
17
No.
18
19
20
21
A
or_ LIie Luc,o.r. , W
22
23
24
25
Lctlk iiy d ULI
Exhibit 1114.
: Thank you.
I'm going to ask more questions about these
26
-SSCE0003238
unless you --
want to look at, I guess it's maybe MI6,

Do you want to ask about those or
3
4
5
: You go ahead.
BY
6
7
8
No.
Okay.
No.
14
Yes.
15
Okay.
9
10
11
12
13
16
17
BY 111111111111
you were asked, I think, about 1114,
18
19
20
21
2
23
24
25
26
SSCE0003239
31
1
2
3
4
Yes.
5
A
6
7
8
No more questions about these documents.
No.
16
Thank you.
17
BY
Let me
ask:
10
11
12
13
14
15
18
19
20
21
2
Yes, u - u .
23
24
25
26
MISSSCE0003240
32
1
2
5
6
7
8
9
10
11
12
13
Okay.
14
Yes.
15
16
17
18
Not that I know of.
19
20
21
24
23
24
Okay, and we'll get to that.
25
26
MillISSCE0003241
33
Yes.
2
3
4
5
6
I believe
so.
7
8
BY
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
-SSCE0003242
34
1
2
BY
3
4
5
6
7
8
9
10
11
12
13
14
15
Go ahead,
11111111111111 Do we want to do some refreshing?
16
BY
17
18
At the time -- what was your last answer?
19
20
21
22
23
24
Okay, well go ahead.

: Yes, I think so. We've jumped around and
I think it would be good to do that, yes, yes.

BY
25
26
111111111-SSCE0003243
35
1
2
3
4
5
Yes.
So that's where we are.
Okay.
Yes.
No.
19
Yes.
20
Okay, and how did you learn that?
21
I don't remember how.
All right, and what did you learn from either of
8
9
10
11
12
13
14
15
16
17
18
22
23
24
25
them, if you remember?

A
26
Mill-SSCE0003244
36
1
2
3
Okay.
4
5
6
I think so.
IIIIIIIIIIIII: Let me show you a document. It's not the

next document in order. I've already marked that. It's the
one after that, and it's document Exhibit II-8. It's a one-
page document. I'll ask you to take a look at that and tell
10
us, if you can, what is the document.
11
12
(Exhibit III-8 was marked for identification.)

THE WITNESS:
13
14
15
BY
16
17
18
Okay, and do you recognize that or does it
refresh your recollection on any events?

A
19
20
21
22
Yes.
23
24
25
26
MI-SSCE0003245
37
Yes.
Okay.
I think so.
okay.
2
3
4
5
6
7
It should be.
10
11
12
13
14
15
16
17
18
19
20
21
Okay.
Okay.
22
23
24
25
26
11111=1-SSCE0003246
38
Okay.
2
3
4
5
Not necessarily.
6
7
8
9
10
11
Okay. 1111111111111111111.1.111111
12
13
14
Yes.
15
16
17
18
19
20
Q
A
Okay.
But I'm sorry.
21
22
23
24
25
Q
A
Okay.
Yes.
26
111=-SSCE0003247
39
1
2
Yes.
I don't really remember.
Yes.
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
EIMSSCE0003248
40
Yes.
Yes.
Uh-huh, yes.
Not that I remember, no.
Yes.
20
No.
21
Okay.
23
Not that I remember, no.
24
Okay.
2
3
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
22
I don't think so.
25
26
SSCE0003249
2
3
4
5
6
7
No.
No.
10
Okay, back home?
11
I think so.
12
Okay.
13
14
15
16
I'm sorry?
I don't know.
17
18
19
20
21
ay, cind you donr recd
23
w et er It. was before
or after?
24
I don't.
25
26
11111M-SSCE0003250
42
1
2
3
No.
No.
5
6
7
No.
No.
10
No, I don't think so.
11
I've marked a document that I will show
12
you, and it's Exhibit II-7A, 7B and 7C, ask you to take a
13
look at it, and for the record, the Bates numbers are 001,
14
002 and 003,
15
and
16
that non-pertinent information unrelated to today's
17
deposition has been deleted from the document, okay.
18
(Exhibit II-7A, -7B and -7C were marked for
19
identification.)
20
THE WITNESS: Okay.
21
zz
: And I show you the document and ask you
o caice a iooic.
23
(Witness reviewing document.)
24
BY
25
Now on 7B, is there a date on Exhibit --
26
IIIMSSCE0003251
43
A
2
3
Uh -huh.
Okay.
4
5
6
7
And then on
, what appears on
1113 on the bottom of the page there?
On this?
Yes.
10
Okay.
Okay.
I don't.
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
IIIIMIgSSCE0003252
44
2
3
4
5
6
7
Later.
Later.
Yes.
Right.
Yes.
Right.
I don't.
8
9
10
11
12
13
14
15
16
17
18
19
20
21
But I don't know who.
22
23
Okay.
BY
24
25
Doubtful.
26
IIIII
-SSCE0003253
45
1
2
Why is that?
A
3
4
5
6
BY IIIIIIIIIIIII
7
8
9
10
11
No, and I'll tell you why.
22
I don't -- it I ald, I don't remember.
23
Okay.
12
13
14
15
16
17
18
19
20
21
24
25
26
46
BY
No.
That sounds, I mean, possible.
4
5
6
No.
Oh, you did.
7
8
9
10
I just wanted to have it for the
record.
11
12
13
BY
Okay, okay.
14 15
16
Okay.
17
Any questions?
Yes.
I don't remember tor sure.
Okay.
So here we are.
18
19
20
21
22
23
24
25
Yes, go ahead.
26
.1111-SS0E0003255
47
BY
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
Occasionally, but not I mean a lot.
17
18
19
20
21
22
23
24
25
26
111111.-SSCE0003256
48
1
2
3
A
5
sorry.
6
7
Not that I can remember, no. Oh, oh, no. Okay,
This is how this works. This is why we keep

asking the same question.
: That's good, yes.
THE WITNESS:
10
11
12
That sounds like very correct.

BY
13
14
15
16
17
18
No.
19
20
21
22
23
BY
24
If I could follow up briefly here.
25
26
11.1-SSCE0003257
49
1
2
3
4
5
6
No.
7
8
9
10
11
BY
12
13
14
15
16
BY
No.
17
18
19
20
21
22
23
24
25
26
MIIIMISSCE0003258
50
1
2
3
4
5
6
7
8
9
10
11
12
Uh-huh.
No.
20
Okay, thank you.
21
BY
13
14
15
16
17
18
19
22
23
24
25
26
IIIIMII-SSCE0003259
51
1
2
Okay.
If it happened, I wasn't around. I don't
3
4
5
6
7
remember.
8
9
10
Thank you.
11
12
I don't remember anything about that.
BY
13
Okay.
14
15
16
17
Yes.
18
19
20
21
22
Okay.
23
Yes.
Yes.
24
25
26
-SSCE0003260
52
1
2
No.
Okay.
4
5
All right.
Yes.
7
8
9
10
11
12
13
Yes.
14
15
16
17
18
19
20
I don't know.
No.
Yes.
21
22
23
24
25
26
MESSCE0003261
53
1
2
3
Yes.
Right.
Yes, I've heard of it.
4
5
7
8
9
Okay, and how have you heard of that?
10
11
12
13
14
15
Okay.
16
17
18
19
20
21
22
23
Okay.
24
25
No.
26
SSCE0003262
54
Probably.
3
A
5
6
If you know.
A
8
9
10
11
12
13
14
15
16
BY
I see.
Go ahead.
17
18
19
Is that -A
Yes.
No.
20
21
22
23
24
BY
25
Okay.
26
IM
SSCE0003263
55
3
4
5
Okay.
But other than that, no.
Okay.
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
No.
26
=II-SSCE0003264
56
3
4
5
6
7
A
I think so.
Okay.
9
10
11
I don't remember.
12
I don't know.
13
14
15
16
17
18
19
20
Okay.
: Can I ask a question?
21
Yes.
23
BY
24
25
26
SSCE0003265
57
2
3
BY
5
6
7
8
9
10
conversation about it later, you know, about like who

it with, like if it was -- like ifillIshould have had it
11
12
I don't remember.
But I don't remember specifics.

BY
13
14
15
16
17
18
But I don't -BY
19
20
21
BY
That's the one.
23
24
25
26
IMIIII-SSCE0003266
had
58
BY
No.
3
4
A
I remember talk, again this was later.
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
Ibcussion between counsel.)
23
: What I'm going to propose,
24
we take a five minute break, if it would be a convenient
25
time. We're off the record.
26
MI-SSCE0003267
is
59
(Brief recess.)
1111111111111: Back on the record.
NEM Did you get to walk around a bit?
THE WITNESS: Yes.
BY
we remind you as we remind every
witness after a break that you remain under oath.

A
Okay.
14
I don't remember any discussion about it.
15
No.
17
No, not that I remember. No
18
No.
20
No, not that I remember. No
21
Okay.
Yes.
8
9
10
11
12
13
16
19
22
23
24
25
26
IIIIIBSSCE0003268
60
1
A
Yes.
No.
No.
17
No, not that I know of.
18
Okay.
No, not that I -- I don't remember anything about
Okay.
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
19
20
21
22
23
ttiat.
24
25
26
IIIIIMI-SSCE0003269
No, I don't remember.

Okay.
3
4
5
No. I don't remember anything being told. III
6
7
8
9
10
Okay.
No, I did not.
No
11
12
13
14
Okay.
15
16
17
18
19
20
21
22
Ail right. Thank you very much.
23
24
25
26
.11111-SSCE0003270
62
2
3
I know I didn't say that.
No.
A
4
5
Oh no.
No.
Why not?
6
7
9
10
11
Yes.
No.
12
13
14
15
Okay.
16
17
18
19
20
Okay.
21
zz
Right, okay.
Yes.
23
24
25
26
IIINIIIMSCE0003271
63
1
2
Yes.
Yes.
Yes.
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
I'm
not sure.
23
24
Yes.
25
26
11.11M-SSCE0003272
64
Okay.
3
4
5
6
But I don't remember what.
7
8
9
10
11
I see.
12
13
14
15
Okay.
16
17
18
19
20
21
22
23
24
25
26
MIIIII-SSCE0003273
65
1
2
3
4
A
Yes, yes.
Right.
10
Right.
6
7
8
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
MIII
SSCE0003274
2
3
Right.
5
6
7
9
10
11
12
13
14
BY
Yes.
15
16
17
18
No.
19
20
21
2
23
24
25
26
11.1-SSCE0003275
67
1
2
3
4
6
7
8
9
10
11
12
13
14
15
16
No, no.
17
18
19
20
21
22
okay.
23
24
Oh no.
25
26
IMM
-SSCE0003276
68
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6
Looking back, yeah.
7
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BY
Okay.
22
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No.
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illinSSCE0003277
BY
Okay.
3
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16
Yes.
17
Okay.
18
BY
19
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24
25
26
MIIIII-SSCE0003278
70
I think so, but I'm not 100 percent sure.

Okay. Thank you.
BY 11111111.111111:
5
6
7
Let's see. What day was that?
NO.
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9
10
11
12
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IIIIMI..SSCE0003279
71
2
3
4
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6
Uh-huh.
7
8
9
10
11
12
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14
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16
1.1111
A
No.
17
18
19
20
21
Okay.
Well, there was --
22
23
24
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26
1111111.-SSCE0003280
72
Yeah.
14
No, I don't remember coming until later.
15
No.
No.
I see.
1
2
3
4
5
6
7
8
9
10
11
12
13
16
17
18
I don't remember anything on that day.
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ElliSSCE0003281
73
Yeah.
Yes.
Uh-huh.
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3
4
5
7
8
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10
11
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13
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Uh-huh, yes.
24
And did you?
25
Yes.
26
-SSCE0003282
74
And who else was present, if anyone?
3
4
5
6
That's a good question. I don't really remember.
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8
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111.1-SSCE0003283
75
1
2
3
4
Okay.
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6
7
8
9
10
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12
I'm sure I did, but I don't remember.
All right. Let me ask you this. IIIIIIIIIIIIIII
No.
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SSCE0003284
76
2
3
All right.
Yes.
It was somewhere, I mean, in that area.
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5
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7
8
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10
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12
13
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16
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18
A
I don't remember when it was.
Q
A
All right. Did you read it?
Yes. .11.11111111
Yeah. Let me ask you this.
19
20
21
11111.
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IIIIISSCE0003285
77
Uh -huh.
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8
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19
Have you talked with anybody who's been deposed
20
in this matter, who has testified in the matter about
21
questions put to them or answers that they gave prior to
22
your coming?
23
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25
Right.
26
-SSCE0003286
78
2
3
4
5
6
7
8
9
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And for the record, tell us who you mean there?

A
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18
No, I did not.
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20
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BY
25
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.111-SSCE0003287
2
A
I didn't.
Just that, I mean, I don't really remember
specifics.
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4
5
8
9
10
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18
Okay.
I don't
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20
know, no. I'm not sure. 1111111111111,11

But I don't know that for sure.
21
22
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24
That I don't know.
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26
SSCE0003288
80
1
2
3
4
Okay.
No.
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1111
-SSCE0003289
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I think so.
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A
I'm not sure.
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11111111-SSCE0003290
82
Not specifically, no.
2
3
4
5
Okay.
I'm sorry, one other thing.IIIIIIIIIIIII
7
8
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11
BY
No.
12
13
14
Let's see.
Right.
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THE WITNESS: Okay.
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-SSCE0003291
83
BY
2
3
4
5
No, no.
6
7
Thank you.
10
BY
11
I have a few follow-ups.
No.
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18
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25
was going to ask that.

A
I don't remember.
Okay, and then
andIIIII have asked you about
26
11.111-SSCE0003292
84
this, but I'm going to just ask again, and it may lead to
something, it may not.
Okay.
4
5
6
7
8
9
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EMI-SSCE0003293
85
2
3
Hmmm.
Or that night. I don't remember.
6
7
8
9
BY
10
11
A
I don't remember.
14
Okay.
15
BY
12
13
16
17
Yes.
18
(Discussion between counsel.)
19
BY
20
21
23
Oh, no
24
Okay.
25
No.
26
MIII-SSCE0003294
You didn't discuss it with anybody?
No.
No. Done. We have tried to cover everything
with you that we think you might have knowledge of, to be
helpful to the Committee in this matter. We thank you for
your efforts to give us your best recollection. Is there
anything that you can think of that you have knowledge of,
that we have not covered with you?
I can't think of anything.
10
All right. Well, let me say a number of things
11
here. Number one, as we mentioned at the start, the rule of
12
confidentiality applies to us, and we're not permitted to
13
discuss your deposition outside of our work here.
14
It doesn't apply to you. You're free to do so, but we
15
ask that you not do so, and not discuss it with anybody who
16
might be a witness in the matter, because
17
has been a witness.
18
or anybody who
Secondly, we also remind you that you're entitled to
19
come up to the Committee offices here at a time that would
20
be convenient for you to review your transcript, and you
21
know, I'll call you to let you know when it's ready. Then
ctL
23
24
25
yout
LU11V1LLti1
yuu Lan uuut up
ct.LIU LUV.LW 1 .
Finally, we thank you for your testimony, and I hope, as

Andrew Shaw predicted, it wasn't so bad for you either.
A
No, it wasn't bad. I just wish I could remember
26
-SSCE0003295
87
1
2
3
more.
Q
Well, if you do, please give me a call, and then
we'll make arrangements for you to go back on the record.
Okay.
Okay. We thank you and you have our best wishes.
Thank you.
7
8
: Thank you.
Thank you very much.
9
10
(Whereupon, at 12:31 p.m., the deposition concluded.)
11
12
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16
17
18
19
20
21
23
24
25
26
MRSSCE0003296
88
I HEREBY CERTIFY that I have read this transcript of my
deposition and that this transcript accurately states the
testimony given by me, with the changes or corrections, if
any, as noted.
5
6
7
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12
day of
20 .
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17
Notary Public
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-SSCE0003297
1
1
Washington, D.C.
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Thursday, January 20, 2011
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Suite 220
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REPORTED BY:
25
26
(40
'
111111ISSCE0003298
.03
called for
Deposition of
Thursday, January 20, 2011, in Washington, DC, at
the Senate Select Committee on Ethics, Hart Senate
ESQ.
10
ESQ.
ESQ.
11
ESQ.
12
ESQ.
13
14
15

Committee on Ethics
16
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18
202-224-2981
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@ethics.senate.gov
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ethics. senate . gov

ethics senate .gov
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1111.ethics.senate.gov
22
11111111111
23
IIIIIIIIIIkethics.senate.gov
24
25

ALSO PRESENT:
26
.1111.-SSCE0003299
PROCEEDINGS
: The Senate Select Committee
2
3
on Ethics has summoned you here today for this
deposition as a witness in connection with the
committee's preliminary inquiry concerning Senator
John Ensign.
I'm
counsel to the
chief
Committee. I'm joined by

9
10
counsel to the Committee. To my right,

is deputy staff director for the Committee,
11
and I'm also joined with my co-counsel on the
12
Committee,
and
13
14
We have collectively been authorized by
15
the chairman and vice chairman of the Committee to
16
conduct questioning of you here today.
17
The questions and your answers will be
18
19
20
your statements today are subject to the False
21
Statements Statutes, which is Section 1001 of
22
Title XVIII of the U.S. Code.
23
24
25
of perjury under Section 7(b) of the Supplementary
26
MIIIM-SSCE0003300
Procedural Rules of the Select Committee on Ethics

2
and Section 1621 of Title XVIII of the United States
Code, as well as the Obstruction of Congress
Statute, Section 1505.

5
6
through your testimony today.

At this point, I will ask the court
8
9
10
reporter to administer the oath.

Whereupon,
11
12
13

EXAMINATION
14
15
16
BY
Q
do you understand that your
17
statements today are subject to statutes and
18
committee rules concerning false statements, perjury
19
and obstruction of Congress?
20
Correct. And also under the immunity?
21
We'll get to that.
22
We'll get to that, okay.
23
Okay. Now, the record will reflect that
24
you are not represented by counsel today; is that
25
correct?
26
EMI-SSCE0003301
Correct.
And do you understand that you are
2
3
entitled to have a counsel at your expense with you
if you wish?
Correct.
Okay. Now, before we get -- begin, I'm
7
8
going to place Exhibit 1, I've marked this Exhibit

11111, in front of you.
BY
10
11
Addressing Exhibit 1, does that appear to
12
be a copy of the subpoena pursuant to which you are
13
appearing today?
14
It does.
15
Okay. Thank you.
16
Now, before we move to Exhibit 2, I'm
17
going to put on the record that your counsel or
18
previous counsel, we don't know the status at this
19
point, has previously informed us that were we to
20
issue such a subpoena, it was your intention to
21
invoke your Fifth Amendment privileges and refuse to
22
testify; is that correct?
23
That is correct.
24
And is it your intent that, absent an
25
order of immunity, you would invoke your Fifth
26
-SSCE0003302
Amendment privilege to testify here today?

A
That would be -- yes.
BY
Okay. In that case, we're going to move
to Exhibit 1112. Have you seen a copy of this
previously?
Yes, I have.
Okay. And have you had a chance to review
11
Yes.
12
Okay. I'm going to read a portion of it
10
it?
13
into the record. It states in part "ordered that
14
may not refuse either to testify or
15
provide other information at proceedings before or
16
ancillary to the United States Select Committee on
17
Ethics on the basis of his privilege against
18
self-incrimination, and it is further ordered that
19
no testimony or other information compelled under
20
this order or any information directly or indirectly
21
derived from such testimony or other information may
22
be used against
23
except a prosecution for perjury, giving a false
24
statement or otherwise failing to comply with this
25
order."
in any criminal case,
26
III.11-SSCE0003303
It's signed by United States District
is that correct?
Court Judge
That's correct.
Do you understand this document and what
5
6
7
it means?
A
your -- your reinterpretation.

So to be clear, while this document
8
9
I believe so, but I'd be glad to listen to
conveys immunity for your testimony from use against
10
you in most criminal proceedings, it is not a
11
license to lie or to mislead the Committee here
12
today.
Do you understand that?
13
14
I do understand that.
15
Okay. And that means that if you lie to
16
or mislead us here today in any material way, you
17
may still be prosecuted for the criminal violations
18
I cited a few minutes ago despite this order. Do
19
you understand that as well?
20
I do understand that.
21
22
BY
23
Then I'm going to show you Exhibit III-3.
24
This is simply a sealing order. We put that on the
25
record to notify you that the court has sealed the
26
-SSCE0003304
matter of your immunity order. That certainly
applies to us, and we do not make that public in the
normal course without following proper. procedures.
And whether this order has any application or not to
you is something that we leave to you to determine
and to seek counsel on if you wish. But we -A
Could somebody get this under a FOIA?
I'm sorry?
Could somebody access this under a FOIA?
10
We can't give you any advice on FOIA or
11
any information about how it would apply to the
12
courts. This Committee is not subject to FOIA under
13
the normal course of that law.
14
That's a good answer.
15
Okay. All right.
16
In addition, you've been provided with a
17
copy of our procedural rules. As a general matter,
18
19
20
this deposition and all statements today. Separate
21
and apart from the sealing order, Exhibit 3, which
22
you may seek advice about, these rules do not govern
23
your own discussions of this interview.
24
25
However, it's the Committee's expectation

that no witness will tailor or coordinate his or her
26
-SSCE0003305
testimony based on an earlier deposition, and thus
we would request that you refrain from discussing
our questions and your answers with anyone other
than an attorney, should you choose to seek one.
That's not a problem.
Finally, pursuant to Supplementary
Procedural Rule 6, you are entitled to the
opportunity to inspect the transcript of your
deposition in the Committee's offices here in
10
Washington.
11
Okay.
12
And you can request that any transcription
13
errors be corrected. Any errors of fact or changes
14
of testimony would be brought to the Committee's
15
attention through a submission of a sworn statement.

If you wish to inspect the transcript, if
16
17
you happen to be back in Washington, just let us
18
know and we'll arrange that opportunity.
19
And when would that be available?
20
It's generally available within
21
approximately a week or a little bit less.
22
Okay.
23
But just let us know and we'll tell you if
24
25
it's available.
A
Okay.
26
1=-SSCE0003306
10
Finally, if you need any time during the
deposition to take a break for any reason, should
you wish to make a phone call to an attorney or
should you wish to get some water or some food or
anything, just let us know and we will certainly
accommodate any such reasonable requests.

Before we get to the substance, do you
7
8
have any questions for us?
No, sir.
10
Okay.
11
12
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MIII-SSCE0003307
How do you spell it?
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MIM-SSCE0003308
14
It was really that kind of decision
1
2
process.
When was that?
3
4
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MINII-SSCE0003311
16
2
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7
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: Who is your new employer?
21
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THE WITNESS:
23
BY
24
25
Where are you located with
26
1111.1111-SSCE000331 3
17
1
A
It is, okay.
3
4
No, no, no, it's in
Do you want me to give you the address? I
mean, you have it. You delivered so I figured you
have it somewhere.
7
8
9
10
11
12
All right.
13
Does that answer your question? I'm
14
15
trying to do this quickly for you.

Q
That's correct. We appreciate it.
16
17
18
A Never.
19
20
21
22
23
Yes, it has, one time.
24
25
26
SSCE0003314
18
2
3
4
5
6
9
10
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12
13
14
How do you spell
last name?
15
16
17
Okay. Other' than the contacts you've had
18
with Senator Ensign that we'll talk about a little
19
bit later, any other contacts in your professional
20
capacity with legislators, either state or federal
21
level?
22
23
24
25
Or their offices.
26
-SSCE000331 5
19
1
2
3
4
6
7
8
9
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Just give us your best, you know,
13
14
thumbnail -- right now we're talking about your
15
thumbnail sketch of your experience.
16
17
18
19
20
21
22
23
No. That's an easy one.
24
All right. Well, let's get a little more
25
directly to the point here.
26
MESSCE0003316
20
2
3
Absolutely. I'll give you that, because I
think that's -- all right.
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-SSCE0003317
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1
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3
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5
Are we okay on your time?
6
7
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9
Absolutely. I'm looking out for your
time.
A
Well -: By the way, this is not too
10
11
much detail. So keep going.

BY
12
Keep going. Don't worry about it. Just
13
14
keep going.
15
So I'm going to just give you the facts
16
and then you all weed through it. Is that a fair
17
way to do it? So I'll give you the truth and the
18
whole truth.
19
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.1111.11-SSCE0003323
28
1
2
3
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8
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10
The person who was with Senator --
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12
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18
thank you. I'm here trying
to think too fast. Yes, absolutely was.
19
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-SSCE0003325
30
1
2
So we all said good-bye, right.
Let me just follow up.
6
7
Yeah, for some reason.
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-SSCE0003327
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22
Let me just ask you one more thing about
that meeting before we move on from it.
23
24
Okay.
25
26
MIIIIISSCE0003328
32
2
3
4
5
6
7
8
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20
No, there was no -: Just to clarify,
21
also present for this meeting at the --
22
THE WITNESS: Yes.
23
24
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26
-SSCE0003329
33
1
BY
2
3
4
That's not -- I don't remember that name.
7
8
A
Is that who it was?
9
10
11
A
don't
12
13
THE WITNESS:
14
BY
15
Okay. So moving on from there.
16
All right.
17
18
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22
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-SSCE0003330
36
So walk out the door, I don't hear
anything. I get a call --
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-SSCE0003333
45
2
3
You did, thank you. That was helpful.
Now I'm going to go back and take you through, get a
few more details, look at some timing.
Let's see what we can do.

See if we remember anything else.
7
8
9
10
11
12
13
14
15
No, nothing -- it's just I'm not going to
help those people.
16
17
18
19
THE WITNESS:* No, another III showed up.

: I mean the topic of
20
21
THE WITNESS:
22
23
But no.
24
25
26
SSCE0003342
46
THE WITNESS:
BY
Let me show you a document, I ' l l mark t h i s
4
5
6
(Exhibit
BY MR. SCHWAGER:
8
9
identified.)
This i s
For the record, i t ' s got a
Bates stamp of 143. Ask you t o take a look a t t h a t ,
10
Oh, okay.
11
So i f you look down k i n d of i n the middle
12
That would be about r i g h t .
of t h a t , f i r s t of a l l ,
13
14
15
16
17
18
19
I mean, t h a t ' s what t h a t says.
I can't
20
I can't v e r i f y t h a t was the date, but t h a t ' s what
21
t h a t says, yes.
22
23
A
25
26
Okay.
No, I t h i n k i t was probably about t h a t
6
Okay.
12
Then I r e c a l l
differently.
13
That's f i n e .
14
So i t would be --
We show you t h i s i n f o r m a t i o n -- t h i s i s
16
how human memory works.
We show you t h i s
17
i n f o r m a t i o n -- i t ' s f a r from
18
you t h i s i n f o r m a t i o n t o see i f i t refreshes your
19
r e c o l l e c t i o n . That's p e r f e c t l y f i n e .
20
works w i t h a l l witnesses..
So we show
That's how i t
26
SSCE0003344
48
22
23
24
25
That's f i n e .
We show you these documents
t o t r y and help you.

A
Yeah, glad you got these.
Let's get t o
the r i g h t
26
SSCE0003345
49
I ' l l show you a document marked
(Exhibit
THE WITNESS:
113,
I j u s t appreciate you can
show me a document and we can put i t i n the context
of the appropriate date.
By t h a t you're r e f e r r i n g t o
10
Okay.
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
Okay.
Let me j u s t ask you what kind -
k i n d of a side note
2
3
4
5
Could have.
So you're asking me -- I'm
going t o say -Q
F i r s t I'm asking you i f you r e c a l l before
we show you some documents.
51
3
4
That probably would be -- t h a t would sound
good.
(Exhibit
BY
7 identified.
marking
i f you can help us understand t h a t
10
I'm going t o show you an e x h i b i t I'm

w i t h a Bates stamp of 96 on i t .
See
11
12
13
Well, i f you look a t the date on t h a t .
14
Oh, then i t was probably the same as -
15
16
17
18
19
Oh, no, no, no. No, no.
20
21
22
23
24
25
26
A l l r i g h t , no problem.
I ' l l take these
53
documents back.
That we j u s t needed t o s t r a i g h t e n
2
3
I'm glad you d i d .
And I s t i l l get those.
11
That's the one I t o l d you about.
SSCE0003350
54
Doesn't mean
Uh-huh.
11
13
14
(Exhibit
Q
t o mark
I'm going t o show you a document I'm going

8.
17
That's how we're t r a i n e d .
18
That's f i n e .
19
This i s a Bates stamp of 199.
20
As long as you appreciate t h a t I'm here t o
21
t e l l you what happened t o the best of my -- I have
22
no s k i n i n t h i s one.
23
We d e f i n i t e l y appreciate i t .
And again,
24
we're not showing these documents f o r any purpose
25
other than t o help you r e c a l l the time l i n e .
No
26
SSCE0003351
55
human being can r e c a l l -- very few r e c a l l
dates and don't get t i m e l i n e s confused now and then,
specific
4
5
9
10
11
12
13
A l l right.
document I ' l l
Now I'm going t o show you a

Bates stamp of 176.
14
(Exhibit
identified.)
15
THE WITNESS: A l l r i g h t .
16
17
18
19
20
21
22
23
24
25
26
SSCE0003352
But t h i s i s more accurate, so I t h i n k I
would r a t h e r go w i t h t h i s i n f o r m a t i o n .
So yes.
That's no problem.
That's j u s t t o help you k i n d of put your
mind back a t t h a t time frame.
going
The next document I'm
you i s 10.
10
(Exhibit
identified.)
11
12
13
10, Bates stamp of
those
14
15
(Witness reviewed the
16
Okay.
17
Okay.
18
19
20
21
22
23
24
25
26
13, read
58
15
Very few people do.
16
You know, so I'm -- w i t h t h a t .
17
So I don't
know t h a t I r e a l l y thought about the document.
-SSCE0003356
60
61
62
11
12
13
14
15
I don't --
So i t ' s possible t h a t t h a t ' s what the
Senator could have been t a l k i n g about as w e l l , i s n ' t

it?
A
I t ' s certainly possible.
But I have no
r e c o l l e c t i o n whatsoever of t h e
SSCE0003359
SSCE0003360
20
21
The problem w i t h t h i s i s these date stamps
were never accurate.
22
Which date stamps are you t a l k i n g
23
This date.
24
25
26
You're h o l d i n g up
A
On
about?
The dates were never accurate,
Got i t .
4
5
9
10
11
12
13
I t was t h e biggest mess-up we had, t h e
dates were never --
14
15
16
17
18
20
21
22
23
24
25
26
That does not, t h a t i s correct,
66
All
I want t o get t o t h a t i n a
minute, but f i r s t I want t o see i f you r e c a l l what
t h i s was about, and i f not, t h a t ' s f i n e , w e ' l l move

on.
68
1
2
3
4
Q
U n t i l you got dragged i n t o these kinds of
Oh, I have a whole new view now.
5
6
(Exhibit
identified.)
10
11
I want t o show you
12
13
14
15
16
17
18
(Witness reviewed the document,
19
20
21
22
23
24
25
26
And so they said no, a l l
stamp of
i s that?
You know, you sometimes go o f f your gut.
I t h i n k -- how you read i n d i v i d u a l s , read
SSCE0003366
71
72
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
BY
24
25
All right. I want to talk a little bit
26
-SSCE0003369
about your meeting with
2
3
4
A
And do you recall Senator Ensign ever
6
7
No.
discussing with you anything about
A Never.
10
11
12
-- I don't recall it.
13
14
(Exhibitill115 identified.)
15
BY
Q
16
17
138.
18
19
It's marked." 15, got a Bates stamp of
20
21
22
23
Was in October, correct.
24
25
26
-SSCE0003370
74
Okay.
All right.
Okay.
All right.
10
Yes.
11
6
7
8
9
12
13
14
15
All right.
16
17
18
Okay. Now, so keeping in mind the date
19
there on III 15, even if that meeting didn't happen,
20
kind of --
21
22
23
Okay.
24
25
BY
26
MIIIIISSCE0003371
75
I want to show you'll 16, which is Bates
stamped 56. And it -- hopefully, it puts a relative
time frame on your discussion with
4
5
I have no recollection of the time, so
this is probably sometime in June.

Okay.
6
7
8
9
10
11
12
13
Relative to me?
No.
14
15
16
17
18
19
20
21
22
23
24
25
26
11111.11-SSCE0003372
77
Did you ever have a meeting with
1
2
3
You know, I don't recall -- who is he?
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
11111111-SSCE0003374
78
1
2
4
: Let's go off the record.
5
6
BY
Back on the record.

We remind all witnesses whenever we come
9
10
back on the record that you're still under oath,
11
okay?
12
A Uh-huh.
13
14
BY
15
I'm going to show you one last -- we were
16
17
18
and I'm going to show you a document marked. 17,
19
with a Bates stamp of 68 on it, and see if that
20
refreshes your recollection.

21
22
23
24
25
26
111=111-SSCE0003375
79
1
2
3
4
5
6
7
8
9
10
11
I truly don't remember. I mean, if we
12
did, it is lost in -- it could have been. I have no
13
recollection of that.
14
15
wrap-up, unless anybody else has anything.

In wrapping up, we try and make sure that
16
17
All right. We're going to move into
we kind of are expansive and we don't miss anything.
18
19
20
21
22
23
24
25
26
11111=-SSCE0003376
80
1
2
3
4
5
6
7
8
9
10
11
12
13
Oh, it may have been. I didn't --
Oh, no. I don't even remember -- if
14
15
16
17
18
somebody did contact on our behalf, I don't really
19
remember anything happening on it.
20
Okay.
21
22
23
24
25
26
1-SSCE0003377
81
2
3
4
5
6
7
I can recall that piece.
And we don't want to suggest to you -- we
8
9
10
11
12
13
14
15
16
17
18
don't want you to take away from this that there's
19
anything wrong with those conversations that you
20
had. We're not trying, to suggest that. So I know
21
once you said not good or bad. So we're not
22
suggesting anything is wrong with any of these
23
communications.
24
25
We're just trying to determine if you

recall any contact from them.
26
-SSCE0003378
82
Oh, I understand.
Which is perfectly appropriate.
And that's what -- that's kind of what
1
2
3
4
7
8
makes my world go around, kind of thing.

Q
Right.
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
-SSCE0003379
84
1
2
3
4
5
6
Right.
7
8
9
10
11
12
13
14
15
16
17
18
Other than that one. Okay.

Our final question of all witnesses is
19
again to ensure that we're not missing anything. Is
20
there anything else that you know that's clear in
21
your mind, is relevant to what we've been asking
22
about that we haven't covered, anything you're
23
surprised we haven't asked you about, any other
24
conversations that you -- that are clear in your
25
mind as relevant to this that we haven't discussed?
26
-SSCE0003381
85
No. You've asked more than I thought you
would. I mean, your breadth of knowledge is greater
than I anticipated.
No, you've covered everything that I can
recall.
6
7
8
9
10
11
12
13
14
15
16
: We'd appreciate it if you'd
17
18
let us know.
19
BY
20
Then we've done our best to cover
21
everything. You never know if something else comes
22
up. We'll reach out to you, but we don't anticipate
23
that happening. We hope this is all the time we
24
need from you.
25
I do have one request, and I've -- I've
26
11.111-SSCE0003382
86
got two requests.

: We'll talk about that off
2
3
the record.
BY
4
5
What's the other?
Second one is that if you need to subpoena
me or if you're going to send me a document, would

8
you just call me and say I'm going to send you
something so I don't have --
10
I'll e-mail you first.
11
: We'll talk about that off
12
the record.
THE WITNESS: Let's go off the record,
13
14
then.
Okay. Thank you very much.
15
16
17
(Whereupon, at 11:43 a.m., the deposition

was concluded.)
18
19
20
21
22
23
SSCE0003383
87

5
6
X
7
8
9
10
11
12
day of
, 20
13
14
15
16
17
Notary Public
18
19
20
21
22
23
Mill-SSCE0003384
88
CONTENTS
2
3
WITNESS
EXAMINATION
4
5
and
by
8
9
10
EXHIBITS
11
12
13
EXHIBIT NUMBER
IDENTIFIED
14
15
Exhibit
16
Exhibit
17
Exhibit
18
Exhibit
46
19
Exhibit
49
20
Exhibit
50
21
Exhibit
52
22
Exhibit
54
23
Exhibit
55
24
Exhibit
10
56
25
-- continued --
26
IIIMIIIIISSCE0003385
89
EXHIBITS (Continued)
2
3
EXHIBIT NUMBER
IDENTIFIED
4
5
Exhibit
11
62
Exhibit
12
64
Exhibit
13
64
Exhibit
14
68
Exhibit
15
73
10
Exhibit
16
74
11
Exhibit
17
78
12
13
14
15
16
17
18
19
20
21
22
23
24
SSCE0003386
12
13
15
21
22
23
24
25
27
34
35
37
SSCE0003334
38
39
40
41
42
43
44
70
76
83
S e l e c t Committee on
Ethics
3
4
5
6
I N RE: ENSIGN INQUIRY .
7
8
9
10
11
CONFIDENTIAL DEPOSITION
OF
12
13
14
15
Wednesday, S e p t e m b e r
8, 2 010
H a r t Senate O f f i c e
Building
16
17
18
19
20
21
P
REPORTED BY:
Deposition of
called
f o r examination pursuant t o notice of deposition,
Wednesday,
t h e Senate S e l e c t Committee on E t h i c s ,
Office Building,
on
8, 2 0 1 0 , i n W a s h i n g t o n , DC, a t
Hart
Room 640A, a t 2:02 p.m.,
Senate
before
a N o t a r y P u b l i c w i t h i n and f o r t h e
District
o f C o l u m b i a , when w e r e p r e s e n t o n b e h a l f o f

ESQ.
ESQ.
ESQ.
ESQ.
14
United States Select
15
Committee on E t h i c s
16
220 H a r t S e n a t e O f f i c e
17
W a s h i n g t o n , DC 2 0510
18
Building
202-224-2981
gov
gov
21
3
24
25
26
. senate . gov
gov
On b e h a l f o f S e n a t e E t h i c s C o m m i t t e e
-- c o n t i n u e d --
APPEARANCES
ESQ.
4
C r a v a t h , S w a i n e & Moore LLP
Worldwide
Plaza
825 E i g h t h A v e n u e
7
New Y o r k , New Y o r k
10019-7475
com
10
On b e h a l f o f W i t n e s s
11
12
13
14
15
16
17
18
19
20
21
33
23
24
25
P R O C E E D I N G S
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
EXAMINATION
C o u l d y o u p l e a s e s t a t e y o u r name f o r t h e
r e p o r t e r and s p e l l i t .
A
My o f f i c i a l
name i s
Could you g i v e us your
background,
e d u c a t i o n and experience k i n d o f l e a d i n g
up t o y o u r
p o s i t i o n here a t
A
Do y o u g u y s know w h a t
23
24
25
26
No, i f y o u c o u l d
explain
that.
Perhaps y o u want t o e x p l a i n ,
3
4
t h o u g h , w h a t y o u w e r e a s s i g n e d t o do d u r i n g t h e
t r a n s i t i o n t o t h e new -- b e c a u s e I t h i n k w h a t
g e t t i n g a t i s w h a t was y o u r j o b d u r i n g
time
you're
the relevant
period.
BY
8
9
10
11
12
13
14
15
16
17
18
19
20
21
would
23
24
25
26
those
10
11
11
12
Uh-huh.
And t h o s e - - d o t h o s e t y p e s o f r e q u e s t s
come i n r e g u l a r l y t o meet?
13
Yes.
17
Absolutely,
yeah.
Do t h a t w o u l d be common?
23
24
25
26
Even t o d a y .
Could I i n j e c t
a b i t of
background i n f o r m a t i o n that I t h i n k would
help
15
general
8
questions
b e f o r e we move on?
BY
15
O n l y now.
16
O n l y now.
17
So a t t h e t i m e y o u w e r e n o t
familiar with i t ?
18
No.
19
So a n y i n f o r m a t i o n t h a t y o u h a v e w o u l d be
20
something t h a t you've
21
period?
25
26
No.
acquired since that
time
17
1
2
3
4
5
6
7
8
You d i d n ' t a t a l l ?
10
Huh-uh, n o .
11
12
Makes t h i n g s e a s y on t h a t
13
14
15
All
And
that
provided t o
17
(Exhibit
18
20
right
I j u s t w a n t t o c o n f i r m some o f t h e m a t e r i a l s
16
19
didn't.
identified.)
BY
Q
I ' l l g i v e y o u a document
m a r k e d i t as E x h i b i t
1.
and have
just
The B a t e s number i s 1 2 1 a t
21
23
correct?
24
25
26
Okay.
And what I want t o have y o u t a k e
18
I don't s p e c i f i c a l l y
Okay.
and
memory a
maybe t h a t
will
just
--
see
i f that
something
can
else
j o g your
A
(Exhibit
Q
Exhibit
I'll
2.
identified.)
j u s t g i v e you
what's been marked
I t ' s B a t e s numbers 116
12
13
show y o u
request.
little.
10
I'll
to this
do y o u
as
to
as
117.
want t o t a k e a
look
well?
on
15
thanks.
16
I t ' s pretty
17
(Witness
reviewed
the
short.
document.)
BY
19
Can
you
tell
us who
was?
re a l l t r y i n g
23
24
25
26
that
out.
(Laughter.)
THE
WITNESS:
I h a v e no
idea.
to
So y o u
No.
Tried
Yeah.
I know why.
t know who - -
And I ' v e t r i e d
t o --
t o f i g u r e i t out?
Just recently.
B u t now
this
now
8
9
10
11
12
13
14
15
16
17
18
19
20
21
I
do w h a t I c a n t o f i g u r e o u t who
24
25
likely
i s t h i s p e r s o n who j u s t
may h a v e b e e n d e t a i l e d
I've
tried
i s . I think i t
d o e s n ' t remember t h a t
a day o r two t o
26
S SCE0002126
21
a n s w e r some p h o n e s a n d
But t h a t ' s
i t on.
speculation.
3
4
she j u s t p a s s e d
I don't t h i n k
we n e e d t o
pursue
No, I d o n ' t e i t h e r .
I just
wanted
t e r m s o f how t h e c a l l was s e t u p , b u t i t d o e s n ' t
seem l i k e i t d i d .
9
10
BY
11
12
13
14
15
16
17
18
19
20
21
23
24
25
26
t o s e e i f t h i s w o u l d j o g t h e memory a t a l l i n
Yes, t h a t ' s
standard.
S SCE0002128
23
24
1
2
3
Oh, y e a h ,
yeah.
9
10
11
12
13
14
15
16
17
18
19
20
21
No.
we have t o
we
23
24
Do y o u remember how l o n g t h e c a l l
was?
25
I don't.
very
26
These c a l l s ,
typically,
25
1
2
Five minutes
I f that.
I fthat,
Yeah.
to
this call,
short?
okay.
I mean, I c a n ' t
speak s p e c i f i c a l l y
b u t t y p i c a l l y , these
a r e q u i c k phone
7
8
BY
9
10
11
Do y o u h a v e a n y r e c o l l e c t i o n
of that?
12
13
14
15
17
18
19
20
21
23
24
25
26
S SCE0002131
23
24
25
26
So y o u j u s t d o n ' t remember how t h i n g s
s e t up?
A
I don't.
Well,
how t h i n g s w e r e s e t u p
were
1
2
but
Q
3
4
Oh, n o .
5
6
I'm
sorry,
d i d y o u have
something?
Just t o c l a r i f y
8
9
10
11
12
13
14
15
16
17
18
19
THE WITNESS:
To g e t - - n o , I d o n ' t .
20
mean, o n l y f r o m w h a t I ' v e b e e n p i c k e d u p -- o r a s
21
documents were p r o d u c e d f r o m p u l l i n g them.
22
I d o n ' t know how i t
23
24
25
26
B u t no,
O n l y b a s e d on p u l l i n g t h e
Okay
the
30
1
2
3
4
Can I j u s t
clarify
one
thing?
5
6
7
8
9
10
11
THE WITNESS:
12
Thanks
BY
13
14
15
16
I'll
(Exhibit 4
18
BY
19
21
Uh-huh.
Q
24
26
identified.)
you want t o j u s t
20
25
m a r k t h i s as E x h i b i t 4, B a t e s
number 107.
17
23
Uh-huh, y e s ,
take a look a t t h a t ,
31
And y o u w e r e n ' t
16
B u t y o u d o n ' t r e c a l l who i t m i g h t h a v e
Okay.
17
been?
19
21
23
And I ' l l
number
show y o u E x h i b i t 5.
24
Bates
25
i n f o r m a t i o n on here.
26
involved with that at all?
I j u s t wanted t o
This i s
the
is
that
correct?
5
6
7
8
9
10
12
13
I don't
recall.
14
15
I j u s t w a n t t o make s u r e
you're a c c u r a t e on t h e r e c o r d .
16
THE WITNESS:
17
BY
18
I appreciate
that.
19
20
21
j u s t don't
23
24
25
26
Do y o u w a n t me t o p r o f f e r ?
34
And n e x t ,
fire
department issue.
Do y o u
remember w h a t t h a t was?
-SSCE0002141
13
14
Moving on, j u s t g o i n g
-- I d o n ' t
t h i n k we n e e d t o g o t h r o u g h
18
J u s t o u t s i d e o f what's
19
Yes.
20
21
make
you could just

what t h a t
25
line
listed?
A n d t h e r e a r e some t h i n g s a t t h e b o t t o m
I
23
through.
The
last
few
s e e i f y o u c a n -- i f y o u c a n make o u t
says.
Do y o u h a v e t h e o r i g i n a l ?
26
-SSCE0002142
37
We do, a n d I d o n ' t
I s i t any
2
3
No.
|:
think
looked l i k e
i t was k i n d
i t ' s much more

better?
I t h o u g h t I h a d some t h a t
of colorish.
THE WITNESS:
7
8
Yeah, t h a t ' s
BY
10
Can y o u j u s t
11
Yeah.
16
What a b o u t
17
more
clear.
r e a d what i t i s t o us?
So -- I d o n ' t
know.
12
13
14
15
on t h e o t h e r s i d e ?
18
19
20
21
23
24
25
26
Okay.
I s t h a t a t t h e bottom?
I f y o u know.
I don't
11
Uh-huh, y e s .
14
I don't.
know.
Okay.
17
18
I'm s u r e e a c h o f t h e m s p o k e .
r e c o l l e c t w h a t was s a i d .
I j u s t don't
I just
don't
recall.
19
Do y o u r e c a l l
'20
21
A n d do y o u know i f t h e r e was a n y f o l l o w - u p
from the m e e t i n g ?
26
how l o n g t h e m e e t i n g l a s t e d ?
That's the only t h a t
I don't
9
10
Okay.
I can r e c a l l .
recall.
Do y o u r e c a l l
anything else
about
t h e meeting?
11
I don't.
BY
15
I don't
recall.
BY
20
21
A
can't
I -- i t w o u l d b e s p e c u l a t i o n .
just
recall.
it's
23
a g o so we a p p r e c i a t e y o u s e a r c h i n g y o u r
24
recollection,
25
we're h o p i n g t o t r i g g e r
26
and by a s k i n g a l i n e
of questions,
something, i f t h e r e ' s
40
something t h e r e .
well.
I f there's not, that's fine
as
BY
5
6
7
8
9
10
11
12
13
14
Sad.
15
16
17
Yes,
18
Do y o u remember when t h e s e
N o t o f f t h e t o p o f my h e a d .
19
discussions
were?
20
21
-2223
24
25
26
SSCE0002146
41
I f I d i d , I wouldn't
know
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
Quite ab i t .
So i t d o e s happen?
BY
23
24
Does i t d e p e n d o n t h e o f f i c e ?
25
It
26
depends on v a r i o u s
11
I don't r e c a l l any.
I don't.
13
No.
16
No, I d o n ' t .
20
21
I think that's
it.
Thank y o u
v e r y much.
2:48
23
was
concluded.)
24
25
-SSCE0002149
44
I HEREBY CERTIFY t h a t I h a v e r e a d
this
transcript
o f my d e p o s i t i o n a n d t h a t t h i s
accurately
states the testimony
t h e c h a n g e s o r c o r r e c t i o n s , i f a n y , as n o t e d .
given
transcript
b y me,
with
5
6
7
8
9
10
11
S u b s c r i b e d and sworn t o b e f o r e
12
, 20
me t h i s
13
14
15
16
17
Notary
18
19
20
21
23
24
25
My c o m m i s s i o n
expires:
Public
day o f
45
C O N T E N T S
2
3
WITNESS
EXAMINATION
4
5
6
7
9
10
E X H I B I T S
11
E X H I B I T NUMBER
12
Exhibit
identified
17
13
Exhibit 2
identified
19
14
Exhibit 3
identified
22
15
Exhibit 4
identified
30
16
Exhibit
identified
32
17
Exhibit 6
identified
34
18
19
20
21
23
24
25
IDENTIFIED
Subject to the Procedures for Handling Committee Sensitive Materials Set Forth in
Rule 8 of the Supplementary Procedural Rules
United States Senate Select Committee on Ethics
Memorandum of Interview
Preliminary Inquiry Concerning Senator John Ensign
Date:
2010
Location: Las Vegas, NV
consented to an interview that was authorized by the Chairman and Vice Chairman of the Ethics
Committee.
furnished the following information after being given a warning on false
statements
1001) and obstruction of Congress
This
memorandum reflects the mental impressions of counsel and is not intended to be a verbatim
recitation of the questions and answers from the interview.
After a brief wrap up, the interview concluded.

Documents reviewed with I
ENSIGN
ENSIGN
Citizens for Responsibility and Ethics in Washington v. United States

Department of Justice, Civil Action No. 12-01491 (JDB) (D.D.C)
Criminal Divisions Vaughn Index
Acronyms/Abbreviations Used in this Index:
WIF=Withheld in Full
RIP=Released in Part
LTR=Letter
TC=Telephone Call
DOJ=U.S. Department of Justice
CRM=Criminal Division
PIN=Public Integrity Section
OEO=Office of Enforcement Operations
PSEU=Policy and Statutory Enforcement Unit
OLA=Office of Legislative Affairs
JMD=Justice Management Division
PAO=Public Affairs Office
SMO=Services Management Office
AG=Attorney General
AAG=Assistant Attorney General
DAAG=Deputy Assistant Attorney General
Trial Atty.=Trial Attorney
EOUSA=Executive Office of United States Attorneys
USADC=United States Attorney for the District of Columbia
AUSA=Assistant United States Attorney
USACT=U.S. Court of Appeals
FBI=Federal Bureau of Investigation
SA=Special Agent
DOT=U.S. Department of Transportation
IRS=Internal Revenue Service
SSCE= Senate Select Committee on Ethics
USAM=United States Attorneys Manual
ACTS=Automated Case Tracking System
Individuals/Entities Identified in this Index:
Ensign=U.S. Senator John Ensign of Nevada
JE=John Ensign
Fred Schwartz= (Ensign), a/k/a U.S. Senator John Ensign of Nevada
Elmer Johnson= (Ensign) [[ ]_Ensign@ensign.senate.gov], a/k/a U.S. Senator John Ensign of Nevada
congressnv@[ ]=a/k/a, U.S. Senator John Ensign of Nevada. This email account was also used by other members of the Ensign family.
nvensign@[ ]=a/k/a, U.S. Senator John Ensign of Nevada
[ ]=Name of a Private Third Party Individual Mentioned
FOIA Withholding Exemptions:
(b)(3)=Section 552(b)(3)Fed. R. Crim. P. 6(e), Grand Jury Materials: These documents are being withheld because they would disclose matter
occurring before a grand jury, including the identities of witnesses, the substance of the testimony, or the strategy or direction of the investigation.
(b)(5)=Section 552(b)(5)--Attorney Work Product (AWP): These documents constitute AWP because they were created by PIN attorneys in
anticipation of the criminal prosecution of Ensign and other third parties. They contain legal analysis by the PIN attorneys involved in the
investigation. Release of these documents would reveal the authoring attorneys mental impressions and legal theories.
(b)(5)=Section 552(b)(5)--Deliberative Process Privilege (DPP): These intra-agency documents are deliberative as they include a distillation of
facts and evidence by the PIN attorneys and would reveal pre-decisional deliberations as to whether to prosecute Senator Ensign and other third
parties and which investigative routes would be fruitful in the investigation. The discussions include information related to sufficiency of the
evidence to begin an investigation, what crimes to charge, which witnesses to interview, what records and documents to subpoena, and other
possible avenues of investigation.
(b)(6) and (b)(7)(C)=Section 552(b)(6) and Section 552(b)(7)(C)--Personal Privacy: The documents are being withheld in part to protect the
personal privacy interests of DOJ attorneys, FBI special agents, government employees, and private third party individuals. The release of this
information would not serve any identifiable public interest.
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
Title and/or Document

Description
FOIA
Exemption
CRM 1
[PIN Bankers
Box No. 1]
[ ], PIN
ACTS
Coordinator
To: Files Unit
06/12/2012
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
CRM 2
[PIN Bankers
Box No. 1]
[ ], PIN Trial
Atty.
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Jack Smith,
PIN Section
Chief; [ ], PIN
ACTS
Coordinator
Date Submitted:
5/12/2012
U.S. Department of Justice

Notice of Closed Files
Subject: [Form OBD-25];
Division: Criminal; File Number
186-16-2367; Case Title:
ENSIGN, JOHN ET AL. (ACT #
20100266).
Description: The document
performs the function of a file
cover sheet and further identifies
the underlying Ensign case file as
having been closed.
Basis for Withholding: (b)(6)
and (b)(7)(C). The document has
been withheld in part to protect
the personal privacy interests of
lower-level DOJ employee(s).
Revealing the names and personal
information of DOJ employee(s),
who maintain strong privacy
interests, would not be justified by
any ascertainable public interest.
[1-page]
PIN - ACTS Declination Sheet
for John Ensign 20100266
Subject: [USDOJ/CRM, Form
PI-2, 02/13/08]; ACTS #
20100266; Title: John Ensign.
Description: The document is a
DOJ internal tracking form used
to identify or describe a particular
investigation and/or case, i.e.,
venue; potential criminal
violations and statutes violated;
assigned DOJ attorney(s);
declination analysis; supporting
documents; primary reason(s) for
immediate declination; agency
information; supervisory notes
and routing.
Basis for Withholding: (b)( 5)
(DPP). The information contained
in this document is deliberative
because it includes pre-decisional
material that was compiled to
assist policy-makers in reaching a
decision as to whether to
prosecute Ensign and because it
reflects the give-and-take process
by which the government reached
that decision. The declination
sheet, for example, includes
factual information and subjective
analysis, in the form of the
primary reason for immediate
declination. Disclosure of this
deliberative material could likely
chill the open sharing of thoughts
and impressions of ongoing
criminal prosecutions. Disclosure
is also likely to confuse the public
about the final basis for the
decision not to prosecute Ensign.
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 3 (a) and

(b)
[PIN Bankers
Box No. 1]
See also:
CRM 96
[email sweep]
[DOJ0000154];
[DOJ0000155]
See also:
CRM 173
[email sweep]
[DOJ0001970];
[EOUSA referral
to CRM]
Author(s)
Recipient(s)
[ ], PI
Deputy
Chief
Jack Smith,
PIN Section
Chief.
[ ], [ ],
PIN Trial
Attys.
Jack Smith,
PIN
Section Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ], PIN
Deputy Chief.
Date(s)
May 7, 2012;
March 7, 2011.

Description
and (b)(7)(C). The document is
also being withheld in part to
protect the personal privacy
interests of lower-level DOJ
employee(s). Revealing the
names and personal information
of the DOJ employee(s), who
maintain strong privacy interests,
would not be justified by any
ascertainable public interest.
[3-pages]
MEMORANDUM [Declination
Memo]
Subject: Recommendation to
Decline Prosecution of Former
Senator John Ensign [Footnote
1].
Declination Memo setting forth
the detailed reasoning behind
DOJs decision to non-prosecute
Sen. John Ensign.
(AWP). The document
constitutes AWP because it was
created in anticipation of
supervisory approval by DOJ
managers of a recommendation to
decline to prosecute Ensign. The
document discusses legal theories
and factual information that was
compiled by PIN Trial
Attorney(s) during the
investigation and possible
criminal prosecution of Ensign
and its release would reveal the
mental impressions and legal
strategies of the DOJ attorney(s)
involved in the case. For
example, the document contains a
detailed legal analysis behind
DOJs recommendation not to
charge or prosecute Ensign, and
revelation of that information
would improperly disclose the
DOJ attorneys legal strategy.
(DPP). The information
contained in this document is
deliberative because it includes
pre-decisional material that was
compiled to assist policy-makers
in reaching a decision as to
whether to prosecute Sen. Ensign
and because it reflects the giveand-take process by which the
government made that decision.
The Declination Memo, for
example, includes factual
information and subjective
primary reasons for immediate
FOIA
Exemption
(b)(3)
(Grand Jury
Material),
(b) (5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)

Description
decision not to prosecute Sen.
Ensign.
also being withheld in full to
employee(s) and private third
party individual(s). Revealing the
of DOJ employee(s) and private
third party individual(s), who
[6-pages]
PROSECUTION
MEMORANDUM
Subject: Memorandum
Recommending Prosecution as to
[ ] and [ ], Declination as to John
Ensign.
Prosecution Memo setting forth
DOJs decision recommending
the prosecution/indictment of [ ]
and [ ], and further declining the
prosecution of Ensign.
(Grand Jury Material).
(AWP). The document
indict several individuals, as well
as the approval by DOJ managers
to decline to prosecute Ensign.
The document contains legal
theories and factual information
that was compiled by PIN Trial
list of the statutes that may be
used in any possible criminal
prosecution, and revelation of that
information would improperly
disclose the DOJ attorneys legal
strategy.
FOIA
Exemption
WIF
RIP
Document
Reference
Number
CRM 4
[PIN Bankers
Box No. 1]
See also:
CRM 93
Author(s)
Unknown
Recipient(s)
Unknown
Date(s)
10/23/2009

Description
whether to prosecute Ensign and
because it reflects the give-andtake process by which the
government reached that decision.
The declination memo, for
also been withheld in full to
Page one of the PROSECUTION
MEMORANDUM contains a
banner reading:
CONFIDENTIAL []
ATTORNEY WORK
PRODUCT [] CONTAINS 6(e)
MATERIAL.
[48-pages]
ACTS OPENING SHEET
PI-1, 4/8//2009]; TITLE: U.S. v.
Ensign.
Description: The document is an
internal DOJ tracking form used
to identify a particular case, i.e.,
criminal allegations and federal
statutes that may have been
violated; case responsibility;
statute of limitations expiration
date; attorney(s) assigned;
subject(s); case synopsis; agency
information and attorney conflict
of interest form.
(AWP). The document
created in anticipation of litigation
involving Ensign. The document
contains factual information that
was compiled by PIN Trial
Attorney(s) for the investigation
and possible criminal prosecution
FOIA
Exemption
WIF
RIP
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Document
Reference
Number
CRM 5
[PIN Bankers
Box No. 1]
Author(s)
[ ], PIN Trial
Atty.; [ ],
AUSA-DC.
Recipient(s)
[ ], Esq.,
Federal Public
Defender for
DC
Date(s)
April 4, 2011

Description
strategies of the attorneys
strategy.
(DPP). The information in this
document is deliberative because
it includes pre-decisional material
that was compiled to assist
government attorneys in reaching
a decision of whether to prosecute
Ensign and because it reflects the
give-and-take by which the
The document contains factual
analysis intended to inform a final
prosecute Ensign. Disclosure of
this material is likely to
discourage government
employees from keeping records
of conversations or mental
impressions related to evidence or
witnesses. Disclosure would also
likely confuse the public as to the
final basis for the decision not to
prosecute, as some of the
evidence described in the notes
may have served as a basis for
that decision.
also being withheld to protect the
personal privacy interests of
lower-level DOJ employee(s) and
private third party individual(s).
information of DOJ employee(s)
and private third party
individual(s), who maintain strong
privacy interests, would not be
justified by any ascertainable
public interest.
[4-pages; 2 copies]
LTR
Subject: Re: United States v.
[ ] Criminal Number: 11085(BAH).
references documents produced
by Ensign to the government
during the criminal investigation.
being withheld in part to protect
FOIA
Exemption
(b)(3) (Grand
Jury
Material)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
WIF
RIP
Document
Reference
Number
CRM 6
[PIN Bankers
Box No. 1]
Author(s)
Unidentified
PIN Trial
Atty.
Recipient(s)
Unidentified
PIN Trial
Atty.
Date(s)
10/14/--;
11/6/--.

Description
FOIA
Exemption

public interest.
[3-pages]
Notes
Subject: Untitled.
Description: The notes are
unattributed however they are
consistent with records prepared
by an unidentified PIN Trial
Attorney in connection with the
Ensign investigation. The notes
contain multiple references to
Ensign. The notes also contain
information involving case legal
strategy as well as case specific
references to certain evidence and
witnesses.
Basis for Withholding: (b) 5
(AWP). The document
created in anticipation of the
possible criminal prosecution of
Ensign. The document contains
subjective legal analysis by an
unidentified PIN Trial Atty.
involved in the investigation.
Release of this document would
reveal the authoring attorneys
theories. For example, the
document discusses strategies for
obtaining possible evidence
related to the investigation.
The handwritten notes contain
redacted
under (b)(6)
and (b)(7)(C)
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 7 (a), (b)

and (c)
[PIN Bankers
Box No. 1]
CRM 8 (a), (b)

and (c)
[PIN Bankers
Box No. 1; CD
marked: [ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
Author(s)
Recipient(s)
[ ], PIN Trial
Atty.
[ ], PIN
Employee
[ ], Private
Legal
Counsel
[ ], PIN Trial
Atty.
[ ], Private
person
[ ], Private
Legal Counsel
[ ], Private
Individual
[ ], Private
Individual
[ ] (Ensign
employee),
Private
Individual
[ ], Private
Individual
[ ], Private
Individual
[ ] (Ensign
employee),
Private
Individual
Date(s)
December 14,
2009;
December 2, 2009;
December 1, 2009
December 5, 2008.

Description
that decision.
also being withheld to protect the
information of private third party
public interest.
[3-pages]
Email
Subject: The document consists
of three emails with a subject line:
FW: Emailing:
NRSC, [ ], [ ], Email Addresses,
Allegiant Air, [ ], [ ], Ensign
Home, [ ], John Ensign, John
Ensign Fictitious,
[ ], [ ] [ ] NRSC, November Inc.
Description: The emails
reference Ensign and include an
email from private legal counsel
representing an individual with
information pertaining to the
Ensign investigation.
public interest.
[2-pages]
Email
Update EIS; RE: Ely Energy
Center Draft EIS and Re: Ely
Energy Center Draft EIS.
Description: The document was
obtained by the government from
a witness to the criminal
investigation. The emails contain
address information referencing
[ ] (Ensign employee) and [ ]
@ensign.sen.gov.
public interest.
FOIA
Exemption
WIF
RIP
The name(s)
and personal
information
of lowerlevel DOJ
Employees
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 8 are
deemed nonresponsive.
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)

Description
[1-page; 2 copies]
Email
Update EIS; RE: Ely Energy
Center Draft EIS and Re: Ely
Energy Center Draft EIS.
@ensign.sen.gov.
This document is identical to the
previous email chain (CRM 8(a),
however, NV Energy
correspondence has been
handwritten on this email chain
by an unidentified individual].
public interest.
[1-page]
Email
of three email messages with a
subject line: Update EIS; RE:
Ely Energy Center Draft EIS and
Re: Ely Energy Center Draft
EIS.
@ensign.sen.gov.
This document is identical to the
previous email chain CRM 8(b),
however, NV Energy
correspondence and Ensign
office has been handwritten on
this email chain by an
unidentified private individual/
third party].
FOIA
Exemption
WIF
RIP
Document
Reference
Number
CRM 9
[PIN Bankers
Box No. 1]
CRM 10 (a), (b)

and (c)
[PIN Bankers
Box No. 1; CD
marked: [ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
CRM 11 (a) and

(b)
[PIN Bankers
Box No. 1; CD
marked: [ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
Author(s)
Unknown
Recipient(s)
Unknown
[ ], Private
Individual
[ ] (Ensign
employee),
Private
Individual
[ ] (Ensign
employee),
Private
Individual
[ ], Private
Individual
[ ], Private
Individual
[ ] (Ensign
employee),
Private
Individual
nvensign@
[ ], a/k/a
Ensign
[ ], Private
Individual
[ ], Private
Individual
Ensign [ ]
Date(s)
Undated
December 12,
2008
May 23, 2008

Description
public interest.
[1-page]
Email Addresses
Subject: The document contains
a list of email addresses for
Ensign and other private third
party individuals.
Description: The document lists
other private third party
individuals email addresses,
including that of Ensign.
public interest.
[1-page; 2 copies]
Email
or three email messages with the
subject line: RE: Draft EIS and
Draft EIS.
(Ensign employee) and
@ensign.senate.gov.
public interest.
[1-page; 4 copies]
Email
of two emails with a subject line:
Fw.
investigation. The emails
reference nvensign@[ ] and
Ensign [ ], John. The email chain
also contains handwritten notes
from an unidentified individual/
private third party.
FOIA
Exemption
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Portions of
CRM 9 are
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)( 6)
and (b)(7)(C)
Portions of
CRM 10 are
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 11 are
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)

Description
FOIA
Exemption
WIF
RIP

public interest.
[1-page; 3 copies]
CRM 12 (a) and

(b)
[PIN Bankers
Box No. 1]
[ ], Private
Individual
[ ], Private
Individual,
(Ensign
Employee)
[ ], Private
Individual
[ ], Private
Individual
February 26, 2008
Email
of two emails with a subject line:
Fw.
investigation. The emails
reference nvensign@[ ] and
Ensign [ ], John. The email chain
also contains additional
handwritten notes from an
unidentified individual/ private
third party re: Never seen
document! and Ensign to [ ].
public interest.
[1-page]
Email
of two emails with the subject
line: Fw: November Inc. 2008.
Description: The To line of
first email references (Ensign).
The email contains handwritten
notes from an unidentified
individual/ private third party.
private third party individuals.
public interest.
[1-page]
Email
of two emails with the subject
line: Fw: November Inc. 2008.
Description: The To line of
the email references (Ensign).
The email contains additional
unidentified individual.
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 12 are
Document
Reference
Number
CRM 13 (a), (b)

and (c)
[PIN Bankers
Box No. 1; CD
marked: [ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
CRM 14 (a) and

(b)
[PIN Bankers
Box No. 1]
CRM 15
[PIN Bankers
Box No. 1]
Author(s)
Recipient(s)
[ ], Private
Individual
[ ], Private
Individual
[ ], Private
Individual
[ ], Private
Individual
[ ], Private
Individual
[ ], Private
Individual
[ ], Private
Individual
[ ], Private
Individual
[ ], Private
Individual
[ ], [ ],
[ ], Private
Individuals
[ ], Private
Legal
Counsel
[ ], PIN Trial
Atty.
Date(s)
May 28, 2008
December 14,
2008
August 9, 2010;
Stamped
RECEIVED Aug
24 2010 PI

Description
third party individual(s).
information of third parties, who
[1-page]
Email
of three emails with the subject
line: RE: Hey man.
investigation. CRM 13(a) email
references JE.
public interest.
[1-page; 3 copies]
Email
of two email messages with the
subject line: Fw: Our Next
Venture.
Description: The emails contain
several references to Ensign.
individual(s) who maintain strong
public interest.
[1-page; 2 copies]
LTR
Subject: Ensign Investigation
[ ] & [ ].
consists of correspondence
between [ ], Private Legal
Counsel and [ ], PI Trial Attorney
related to a privilege issue for a
potential witness to the criminal
investigation.
FOIA
Exemption
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Portions of
CRM 13 are
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 14 are
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Document
Reference
Number
CRM 16 (a), (b),

(c) and (d)
[PIN Bankers
Box No. 1; CD
marked: [ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
Author(s)
Recipient(s)
[ ], Private
Individual
[ ], Private
Individual
Fred
Schwartz
(Ensign),
a/k/a Ensign
[ ], Private
Individual
Date(s)
December 09,
2009;
April 16, 2008

Description
public interest.
[1-page]
Email
subject line: FW: did you call?
Im sorry.
a witness in the criminal
investigation. The first email
forwards a second email from.
Ensign to a witness in the criminal
investigation.
public interest.
[1-page; 2 copies]
Email
Subject: The subject line of this
email states: FW: did you call?
Im sorry.
investigation. The original email
from Ensign was sent to a witness
to the criminal investigation.
public interest.
[1-page; 2 copies]
Email
email states: FW: did you call?
Im sorry.
forwards a second email. The
document contains a handwritten
note from an unidentified
individual/ private third party
FOIA
Exemption
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 16 are
WIF
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)

Description
reading: One of John (sic)
fictitious email addresses.
public interest.
[1-page; 2 copies]
Email
email states did you call? Im
sorry.
forwards a second email from
Ensign to a witness to the criminal
investigation. The document
contains the handwritten note of
an unidentified individual/ private
third party that reads: fictitious
email address.
public interest.
[1-page; 2 copies]
Email
Subject: did you call? Im
sorry.
investigation. The email is from
Ensign to a witness to the
investigation. This particular
version of the document does not
contain a handwritten note.
public interest.
[1-page]
FOIA
Exemption
WIF
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)

Description
FOIA
Exemption
CRM 17
[PIN Bankers
Box No. 1; CD
marked: [ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
Unknown
Unknown
November 2007June 2009
Senator Ensign Phone List

contains the following
information: personal names,
telephone numbers and email
addresses for Ensign and other
private third party individuals
who were either associated with
and/or employed on behalf of
Ensign.
public interest.
[1-page; 2 copies]
[ ] Private Individual, Senator
Ensigns Office
Subject: Miscellaneous notes (2pages), see CRM 18 (a) and CRM
18 (b), the notes were then
combined together on a single
page, see CRM 18(c); Notes on
talks with John [Ensign] (1-page)
(CRM 18(d) and Record of
discussions with John Ensign (1page) (CRM 18(e).
Description: The notes were
consists of handwritten notes from
investigation. The notes reference
JE and John. Portions of
page 3 of the handwritten notes
also appear to contain legal advice
from [ ], private legal counsel.
public interest.
[4-pages]
Untitled and Miscellaneous
Subject: The document
references Chief of Staff Duties
([ ]) and Administrative Duties
(Position TBD by JE).
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
CRM 18 (a), (b),

(c), (d) and (e)
[PIN Bankers
Box No. 1; CD
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
CRM 19
[PIN Bankers
Box No. 1; CD
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
Unknown
Unknown
Unknown
Unknown
4/2/08
Undated
WIF
RIP
Portions of
CRM 17 are
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 18 are
The name(s)
and personal
information
of private
third party
individual(s)
have been
Document
Reference
Number
CRM 20 (a) and

(b)
[PIN Bankers
Box No. 1; CD
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
Author(s)
[ ], Private
Individual
Recipient(s)
[ ], Private
Individual
Date(s)
July 10, 2008
CRM 21
[PIN Bankers
Box No. 1; CD
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
congressnv
@_, a/k/a
Ensign
[ ], Private
Individual
(Ensign
Employee)
March 28, 2008
CRM 22(a), (b),

(c) and (d)
[PIN Bankers
Box No. 1; CD
congressnv
@_ a/k/a
Ensign
[ ], Private
Individual
(Ensign
Employee)
March 28, 2008

Description
FOIA
Exemption

contains references to Ensign
and JE.
public interest.
[3-pages; 2 copies]
Email
subject line: RE: hey man and
hey man.
investigation. The email
references John and Ensign
Inc.
public interest.
[2-pages]
Email
Subject: The subject line of the
email message states: I havent
spoken to you about anything but
as a person who cares for you,
you might want to talk to [ ].
investigation. There is no text or
message body to the email.
public interest.
[1-page]
Email
of three email messages with the
subject line: Re: [ ]
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Portions of
CRM 19 are
The name(s)
and personal
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 20 are
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of private
Document
Reference
Number
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
CRM 23 (a) and

(b)
[PIN Bankers
Box No. 1; CD
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
CRM 24
[PIN Bankers
Box No. 1; CD
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
Author(s)
Recipient(s)
[ ], Private
Individual
(Ensign
Employee)
congressnv@_
a/k/a Ensign
congressnv
@_ a/k/a
Ensign
[ ], Private
Individual
(Ensign
Employee)
[ ] Private
Individual
[ ] Private
Individual
[ ] Private
Individual
[ ] Private
Individual
Date(s)
February 23, 2008
6/30/2009

Description
FOIA
Exemption

investigation.
public interest.
[2-pages]
Email
Subject: None.
investigation. The email contains
references to John.
public interest.
[1-page]
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Email
Subject: None.
references to John. The
document contains a handwritten
individual on the face of the
email.
public interest.
[1-page]
Email
Subject: Ensign.
references to John and
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Portions of
CRM 23 are
The name(s)
and personal
information
of private
third party
individual(s)
have been
Document
Reference
Number
CRM 25 (a), (b),

(c), (d), (e), (f), (g)
and (h)
[PIN Bankers
Box No. 1; CD
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
CRM 26 (a) and

(b)
[PIN Bankers
Box No. 1; CD
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
CRM 27
[PIN Bankers
Box No. 1; CD
marked:[ ] Docs
Author(s)
Recipient(s)
Elmer
Johnson
(Ensign)
[[ ]
_Ensign@
ensign.senate
.gov], a/k/a
Ensign
congressnv@_
a/k/a Ensign;
[ ], Private
Individual,
(Ensign
Employee);
[ ] Private
Individual
[ ] Private
Individual
Elmer
Johnson
(Ensign), a/k/a
Ensign
[ ] Private
Individual
[ ] Private
Individual
[ ] Private
Individual.
[ ] Private
Individual
[ ] Private
Individual
[ ] Private
Individual
(Ensign
Employee)
Date(s)
December 10,
2007;
December 3, 2010
July 10, 2008
December 12,
2008

Description
FOIA
Exemption
Ensign.
and (b) 7(C). The document is
public interest.
[1-page]
Email
of eight email messages with a
subject line: Fw: [ ] at Cisco.
investigation. The emails are
between Ensign and other private
third party individuals.
public interest.
[3-pages]
Email
of two email messages with a
subject line: RE: hey man.
references John and Ensign
Inc. There is a handwritten note
from an unidentified individual /
private third party on CRM 26(a)
blocking out a portion of the
email text. CRM 26(b) is nearly
identical to CRM 20.
public interest.
[2-pages]
Email
Subject: Draft EIS.
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Portions of
CRM 24 are
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 25 are
The name(s)
and personal
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 26 are
The name(s)
and personal
information
of private
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
& Open Source;

[ ], PIN Trial
Atty. [copy]]
CRM 28 (a), (b)

and (c)
[PIN Bankers
Box no. 1; CD
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
CRM 29
[PIN Bankers
Box No. 1; CD
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
CRM 30
[PIN Bankers
Box No. 1; CD
[ ] Private
Individual
.
[ ] Private
Individual
(Ensign
Employee)
[ ] Private
Individual
[ ] Private
Individual
[ ] Private
Individual
(Ensign
Employee)
[ ] Private
Individual
[ ] Private
Individual
December 12,
2008
[ ] Private
Individual
nvensign@[ ],
a/k/a Ensign
nvensign@[ ],
a/k/a Ensign
Unidentified
person/ private
third party
handwriting on
document re:
Sent 5/27/08 @
10:40 am.
Unidentified
person/ private
third party

Description
FOIA
Exemption

investigation. There is a
handwritten note from an
third party on CRM 28
referencing Ensign Staff.
information of third party
public interest.
[1-page]
Email
of three emails with the subject
line: FW: Draft EIS.
investigation. The emails are to
and from an Ensign employee;
one email references: @sign up
for Ensigns weekly update.
There is a handwritten note from
an unidentified individual/ private
third party on CRM 28(b).
public interest.
[1-page]
Email
Subject: Untitled.
references to John.
public interest.
[1-page; 2 copies]
Email
Subject: Voice Message.
hird party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Portions of
CRM 27 are
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 28 are
The name(s)
and personal
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 29 are
The name(s)
and personal
information
Document
Reference
Number
Author(s)
Recipient(s)
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
CRM 31
[PIN Bankers
Box No. 1; CD
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
CRM 32
[PI Bankers Box
No. 1; CD
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
CRM 33 (a), (b),

(c) and (d)
[PIN Bankers
Box No. 1; CD
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
[ ] Private
Individual
Elmer
Johnson
(Ensign)
[[ ]
_Ensign@
ensign.senate
.gov], a/k/a
Ensign
Elmer
Johnson
(Ensign)
[[ ]
_Ensign@
ensign.senate
.gov], a/k/a
nvensign@[ ],
a/k/a Ensign
[ ] Private
Individual
[ ] Private
Individual
Date(s)

Description
FOIA
Exemption
handwriting on
document re:
Sent 5/30/08 @
4:40 pm

references to John.
public interest.
[1-page; 2 copies]
Email
Subject: [ ].
investigation. The email is
directed to Ensign and contains
references to John.
public interest.
[1-page; 2 copies]
Email
Subject: [ ]
references John. There is a
handwritten note on the document
private third party re: John to
[ ].
public interest.
[1-page]
Email
of four email messages with the
subject line: Fw: [ ].
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
July 14, 2008
November 20,
2007
January 28, 2008.
WIF
RIP
Portions of
CRM 30 are
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 31 are
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 32 are
The name(s)
and personal
information
of private
third party
individual(s)
have been
Document
Reference
Number
Author(s)
Atty. [copy]]
Ensign
[ ] Private
Individual
CRM 34
[PIN Bankers
Box No. 1; CD
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
CRM 35 (a) and

(b)
[PIN Bankers
Box No. 1; CD
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
Recipient(s)
Elmer
Johnson
(Ensign), a/k/a
Ensign
Elmer
Johnson
(Ensign),
a/k/a Ensign
[ ] Private
Individual
[ ] Private
Individual
Elmer
Johnson
(Ensign), a/k/a
Ensign
[ ] Private
Individual
[ ] Private
Individual
Ensign
Date(s)
[ ] Private
Individual
06/15/2009
Feb. 2008;
2/14/08

Description
FOIA
Exemption
handwritten note on the document
third party re: John.
public interest.
[1-page]
redacted
under (b)(6)
and (b)(7)(C)
Email
Subject: John Ensign [ ] to: [ ].
references to John. There is a
handwritten note on this
document from an unidentified
individual/private third party.
public interest.
[1-page]
LTR
Subject: None.
investigation. The document is a
handwritten letter from Ensign
(signed John) to a private third
party individual. This version of
the document does not contain a
unidentified individual/private
third party on the lower left hand
corner of the letter.
public interest.
[1-page]
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Portions of
CRM 33 are
Portions of
CRM 34 are
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 35 are
Document
Reference
Number
CRM 36
[PIN Bankers
Box No. 1; CD
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
CRM 37 (a) and

(b)
[PIN Bankers
Box No. 1; CD
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
Author(s)
[ ] Private
Individual
Recipient(s)
[ ] Private
Individual
[ ] Private
Individual
[ ] Private
Individual
[ ] Private
Individual
[ ], [ ], [ ],
[ ] Private
Individual;
Ensign
Date(s)
06/11/2009
December 09,
2009;
February 17, 2008

Description
LTR
Subject: None.
investigation. The document is a
handwritten letter from Ensign
(signed John) to a private third
party individual. This version of
the document does contain a
third party on the lower left hand
corner of the letter.
public interest.
[1-page]
Email
Subject: US Senator [ ] to:
americasnewsroom.
a reference to Senator John
Ensign. There is a handwritten
individual/ private third party on
the bottom of the email.
public interest.
[1-page]
Email
subject line: FW: [ ].
third party on the bottom of the
email re: John.
FOIA
Exemption
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Portions of
CRM 36 are
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b) (6)
and (b)(7)(C)
Portions of
CRM 37 are
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)

Description
FOIA
Exemption
WIF
RIP

public interest.
[1-page; 2 copies]
CRM 38 (a), (b)

and (c)
[PIN Bankers
Box No. 1; CD
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
[ ] Private
Individual
[ ] Private
Individual
[ ] Private
Individual
[ ], [ ] Private
Individual
[ ] Private
Individual
[ ], [ ] Private
Individual
December 09,
2009;
February 18, 2008
Email
investigation. This version of the
document does not contain a
handwritten note.
public interest.
[1-page]
Email
subject line: FW: John [ ].
email that reads: John moving
out.
public interest.
[1-page; 2 copies]
Email
subject line:FW: John [ ].
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 38 are
Document
Reference
Number
CRM 39 (a) and

(b)
[PIN Bankers
Box No. 1; CD
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
Author(s)
Recipient(s)
[ ] Private
Individual
[ ] Private
Individual
[ ] Private
Individual
[ ], [ ] Private
Individual;
Ensign
Date(s)
December 09,
2009;
February 18, 2008

Description
handwritten note.
public interest.
[1-page]
Email
subject line:FW: [ ].
investigation. The second email
references John. There is a
second email.
public interest.
[1-page; 2 copies]
FOIA
Exemption
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Portions of
CRM 39 are
Email
references John. This version
of the document does not contain
a handwritten note.
public interest.
[1-page]
CRM 40 (a) and
(b)
[PIN Bankers
[ ] Private
Individual
[ ] Private
Individual
December 09,
2009;
February 21, 2008
Email
The name(s)
and personal
information
Document
Reference
Number
Author(s)
Recipient(s)
Box No. 1; CD
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
[ ] Private
Individual
[ ] Private
Individual
CRM 41 (a) and

(b)
[PIN Bankers
Box No. 1; CD
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
[ ] Private
Individual
[ ] Private
Individual
Ensign
[ ] Private
Individual
Date(s)
December 09,
2009;
April 1, 2008

Description
FOIA
Exemption
subject line: FW: A few things.

references Ensign. There is a
second email.
[1-page]
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Email
subject line: FW: A few things.
references Ensign. This version
of the document does not contain
a handwritten note.
public interest.
[1-page; 2 copies]
Email
subject line: FW: is it possible to
talk.
second email re: John.
WIF
RIP
Portions of
CRM 40 are
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 41 are
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)

Description
FOIA
Exemption
WIF
RIP

public interest.
[1-page; 2 copies]
CRM 42 (a) and

(b)
[PIN Bankers
Box No. 1; CD
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
[ ] Private
Individual
[ ] Private
Individual
Ensign
[ ] Private
Individual
December 09,
2009;
April 1, 2008
Email
talk.
handwritten note.
public interest.
[1-page]
Email
subject line: FW: can you call
me on campaign vonage phone.
second email re: John.
public interest.
[1-page; 2 copies]
Email
subject line: FW: can you call
me on campaign vonage phone.
handwritten note.
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 42 are
Document
Reference
Number
CRM 43 (a), (b),

(c) and (d)
[PIN Bankers
Box No. 1; CD
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
CRM 44 (a), (b),

(c) , (d) and (e)
[PIN Bankers
Box No. 1; CD
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
CRM 45
PIN Bankers
Box No. 1; CD
marked: [ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
Author(s)
Recipient(s)
[ ] Private
Individual
[ ] Private
Individual
Ensign
[ ] Private
Individual
[ ] Private
Individual
Ensign
Ensign
[ ] Private
Individual
[ ] Private
Individual
[ ] Private
Individual
[ ] Private
Individual
Fred Schwartz
(Ensign), a/k/a
Ensign
Fred
Schwartz
(Ensign),
a/k/a Ensign.
Fred
Schwartz
(Ensign),
a/k/a Ensign
[ ] Private
Individual
Fred
Schwartz
(Ensign),
a/k/a Ensign
[ ] Private
Individual
[ ] Private
Legal
Counsel
[ ] (FBI-SA)
Date(s)
December 09,
2009;
April 1, 2008;
April 2, 2008
December 09,
2009;
April 10, 2008
[ ] Private
Individual
December 18,
2009

Description
the personal privacy interest of
public interest.
[1-page]
Email
of four email messages with the
talk.
consists of emails between Ensign
and a witness to the criminal
investigation.
public interest.
[1-page; 3copies]
Email
of five email messages with the
subject line: FW: t.
consists of emails between Ensign
and a witness to the criminal
investigation.
public interest.
[1-page; 3 copies]
LTR
Subject: Ensign Investigation.
consists of correspondence
between [ ], Private Legal
Counsel and [ ], SA (FBI) and
relates to a witness/subject to the
criminal investigation. The
FOIA
Exemption
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Portions of
CRM 43 are
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
& (b)(7)(C)
Portions of
CRM 44 are
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
Document
Reference
Number
CRM 46 (a) and

(b)
[PIN Bankers
Box No. 1; CD
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
Author(s)
Ensign
Recipient(s)
Unknown
Date(s)
04/09/2008

Description
FOIA
Exemption
document also contains a

reference to [ ], a PIN Trial Atty.
information of lower-level DOJ
party individual(s), who maintain
strong privacy interests, would
not be justified by any
[1-page]
Wachovia Bank
Subject: Non-Personal Signature
Card; Legal Entity Name: Senate
Majority Committee;
Signature: (signed) John E.
Ensign.
third party at the top of the
document re: Bank accounts
Turn Over Removal of my
name, add [ ] &
[ ].
[1-page]
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Wachovia Bank
Subject: Non-Personal Signature
Card; Legal Entity Name: Battle
Born Political Action
Committee; Signature: (signed)
John E. Ensign - President.
investigation.
public interest.
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 46 are
WIF
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
CRM 47 (a) and

(b)
[PIN Bankers
Box No. 1; CD
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
Ensign
Unknown
Date: 04/11/2008;
04/14/08 (Signed
by Ensign) &
Date: ______;
04/14/2008
(signed by Ensign)
CRM 48
[PIN Bankers
Box No. 1; CD
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
[ ] Private
Individual
Bank of
Nevada
Date: April 21,

2008

Description
[1-page]
Bank of Nevada
Subject: Account Agreement;
Account Title: ENSIGN FOR
SENATE CAMPAIGN and
dated at the top of document.
investigation.
Signature: (signed) John
Ensign.
public interest.
[2-pages]
Bank of Nevada
Subject: Account Agreement;
Account Title: ENSIGN FOR
SENATE CAMPAIGN and
undated at the top of document.
investigation. The signature
block is (signed) John E.
Ensign.
Basis for Withholding: (b)(6) &
(b)(7)(C). The document is being
withheld in part to protect the
public interest.
[2-pages]
LTR. JohnENSIGN U.S.
SENATE
Subject: Letter to Bank of
Nevada notifying the bank of
account change re: signer for
Ensign for Senate account.
investigation.
FOIA
Exemption
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Portions of
CRM 47 are
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 48 are
Document
Reference
Number
CRM 49
[PIN Bankers
Box No. 1; CD
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
CRM 50
[PIN Bankers
Box No. 1; CD
marked:[ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
CRM 51
[PIN Bankers
Box No. 1; CD
marked: [ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
Author(s)
[ ] Private
Individual
[ ] Private
Individual
[ ] Private
Individual
Recipient(s)
IRS
[ ], [ ], [ ],
[ ] (Ensign),
[ ] (Ensign),
[ ] (Ensign),
[ ], Private
Individual
[ ] (Ensign),
Private
Individual
.
Date(s)
2008
March 07, 2008
December 12,
2008

Description
public interest.
[1-page]
Miscellaneous Income Form
1099-MISC
Subject: ENSIGN FOR
SENATE.
investigation.
public interest.
[1-page]
Email
Subject: The document subject
line states: CQ: PACs Rush to
Drop NRCC Treasurer.
investigation. The subject article
contains references to Ensign.
public interest.
[3-pages]
Email
Subject: The document subject
line states: Draft EIS.
(Ensign).
public interest.
[1-page]
FOIA
Exemption
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Portions of
CRM 49 are
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 50 are
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 51 are
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)

Description
FOIA
Exemption
CRM 52 (a), (b),

(c), (d), (e) and (f)
[PIN Bankers
Box No. 1; CD
marked: [ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]]
[ ] Private
Individual
[ ] Private
Individual
December 12,
2008
[ ] (Ensign
employee),
Private
Individual
[ ] Private
Individual
[ ] Private
Individual
[ ] (Ensign
employee),
Private
Individual
Email
of six email messages with a
subject line: FW: Draft EIS;
RE: Draft EIS; Draft EIS.
(Ensign) and @ensign.senate.gov.
public interest.
[2-pages]
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Settlement
Subject: Settlement Terms.
investigation. The first version of
the document contains
third party at the bottom of the
page. The document contains a
reference to John [Ensign]. The
document also references
damages, legal fees and other
subjects.
public interest.
[1-page]
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
CRM 53 (a) and

(b)
[PIN Bankers
Box No. 1; CD
marked: [ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]
[ ] Private
Individual
[ ] (Ensign
employee),
Private
Individual
[ ] (Ensign
employee),
Private
Individual
[ ] Private
Individual
[ ] Private
Individual
[ ] (Ensign
employee),
Private
Individual
Unknown
Unknown
May 21 09
Settlement
Subject: Settlement Terms.
investigation. The second version
of this document does not contain
any handwritten notes on the
page. The document contains a
reference to John [Ensign]. The
WIF
Portions of
CRM 52 are
Portions of
CRM 53 are
RIP
Document
Reference
Number
CRM 54
[PIN Bankers
Box No.1; CD
marked: [ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]
CRM 55
[PIN Bankers
Box No. 1; CD
marked: [ ] Docs
& Open Source;
[ ], PIN Trial
Atty. [copy]
CRM 56
[PIN Bankers
Author(s)
[ ] Private
Individual
[ ] Private
Individual
[ ] PIN Trial
Atty.
Recipient(s)
Unknown
Unknown
[ ] PIN Trial
Atty.
Date(s)
2007-2008 (Misc.
Dates)
12/10/2009
Undated

Description
document also references
damages, legal fees and other
subjects.
public interest.
[1-page]
ENSIGN AFFAIR TIME-LINE
of a detailed timeline series of
events related to the Ensign affair.
contains multiple references to
Ensign.
public interest.
[7-pages; Last page is blank]
The Chronology of Senator
Ensign Affair, Cover up,
Ethics, Crime (December
2007- June 2009)
Subject: The document provides
a detailed timeline recounting the
series of events related to the
Ensign affair. CRM 55 also
includes eighteen separate
attachments.
Ensign.
[30-pages; Last page is blank]
Notes
Subject: Untitled.
FOIA
Exemption
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
& (b)(7)(C)
WIF
Portions of
CRM 54 are
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 55 are
(b)(5)
(AWP) and
RIP
Document
Reference
Number
Box No. 1]
Author(s)
Recipient(s)
Date(s)

Description
FOIA
Exemption

unattributed however they appear
by a PIN Trial Attorney in
connection with the Ensign
investigation. The notes contain
multiple references to Ensign.
The notes also contain
information involving case
witnesses.
(AWP). The document
unidentified PIN Trial Attorney.
reveal the authoring DOJ
attorney(s) mental impressions
and legal theories. For example,
the document discusses strategies
for obtaining possible evidence
that was compiled to assist DOJ
attorney(s) in reaching a decision
of whether to prosecute Ensign
and because it reflects the giveand-take by which the
that decision.
interests of private third party
individual(s). Revealing the
of private third party
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employees
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 57
[PIN Bankers
Box No. 2]
Author(s)
Unidentified
PIN Trial
Atty.
Recipient(s)
Unidentified
PIN Trial
Atty.
Date(s)
Undated

Description
public interest.
[3-pages]
Questions for [ ]
Subject: A typed list of questions
covering various subjects.
Description: The document is
unattributed however it is
Ensign and others involved in the
investigation. The notes also
contain information pertaining to
legal case strategy as well as case
specific references to certain
evidence and witnesses.
(AWP). This document
unidentified PIN Trial Attorney
involved in the Ensign
investigation. Release of this
document would reveal the
authoring attorneys mental
impressions and legal theories.
For example, the document
discusses strategies for obtaining
possible evidence related to the
The notes contain factual
that decision.
FOIA
Exemption
WIF
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
Author(s)
CRM 58
[PIN Bankers
Boxes No. 2 and
No. 3]
[ ] PIN Trial
Atty.
CRM 59
[PIN Bankers
Boxes No. 2 and
No. 3]
[ ] PIN Trial
Atty.
Recipient(s)
[ ] Inspector
General DOT
[ ] Inspector
General DOT
Date(s)
January 6, 2010
January 12, 2010

Description
public interest.
[2-pages]
Email
Subject: Request for
documents.
email from [ ], a PIN Trial Atty.
to the DOT Inspector General
requesting the production of
certain documents and evidence
regarding the criminal
investigation involving Ensign.
The email references Ensign and
other individuals.
subjective legal analysis by [ ], a
PIN Trial Attorney involved in
the investigation. Release of this
discusses legal strategies for
related to the Ensign
investigation.
public interest.
[1-page; 2 copies]
Email
Subject: Supplemental
Information.
follow-up email to a previous
email, see CRM 58, from [ ], a
PIN Trial Attorney to the DOT
Inspector General requesting the
production of certain documents
and evidence regarding a criminal
investigation involving Ensign.
(AWP). The document
FOIA
Exemption
(b)(5)
(AWP)
WIF
RIP
The name(s)
and personal
information
of lowerlevel DOJ
employees
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)( 5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
Employees
and private
third party
individual(s)
have been
redacted
under (b)(6)
Document
Reference
Number
CRM 60
[PIN Bankers
Box No. 2]
Author(s)
Unidentified
PIN Trial
Atty.
Recipient(s)
Unknown
Date(s)
Handwritten: As
of 5/11/2010

Description
FOIA
Exemption

subjective legal analysis by [ ], a
PIN Trial Attorney involved in
the investigation. Release of this
public interest.
[1-page; 2 copies]
Initial_DOJ_Search
Terms_5_6_10
Subject: Computer search terms
prepared by an unidentified PIN
Trial Atty.
references Ensign, Inc., as well as
other private named individual(s)
and business entities.
(AWP). The document
discusses computer search terms
to be employed in obtaining
potential evidence related to the
The computer search terms
contain factual information and
subjective analysis intended to
inform a final decision as to
and (b)(7)(C)
(b)( 5)
(AWP),
(b)(5)
(DPP)
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 61
[PIN Bankers
Box No. 2]
Author(s)
Unidentified
PIN Trial
Atty.
Recipient(s)
Unknown
Date(s)
As of 5/17/2010

Description
whether to prosecute Ensign.
Disclosure of this material is
likely to discourage government
evidence described in the
computer search terms may have
served as a basis for that decision.
public interest.
[3-pages]
Initial_DOJ_Search
Terms_5_6_10
Subject: Computer search terms
prepared by an unidentified PIN
Trial Atty.
contains a reference to Ensign,
Inc.
(AWP). The document
The notes contain factual
FOIA
Exemption
(b)(5)
(AWP);
(b)(5) (DPP);
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 62
[PIN Bankers
Box No. 3]
CRM 63
[PIN Bankers
Box No. 3]
Author(s)
Unknown
Unidentified
PIN Trial
Atty.
Recipient(s)
UnknownRecords/
Archives
Unknown
Date(s)
CLOSED DATE
07/18/2012
04-12-10

Description
that decision.
interests of third party
public interest.
[3-pages]
PIN-DOJ-CRM: FILE
MANIFEST, [0001 OF 0002],
Subject/Case Title: ENSIGN,
JOHN ET AL. (ACT #20100266)
contains an inventory of the
contents of PINs Banker Box No.
3 which directly relates to the
being withheld to protect the
public interest.
[1-page]
Notes
Subject: Untitled.
unattributed however they are
Ensign. The notes also contain
information involving case legal
witnesses.
(AWP). The document
FOIA
Exemption
WIF
(b)(3) (Grand
Jury
Material)
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
CRM 64
[PIN Bankers
Box No. 3]
[EOUSA referral
to CRM]
Author(s)
Senator
Barbara
Boxer,
Chairman;
Senator
Johnny
Isakson,
Vice
Chairman
Recipient(s)
Honorable
Eric Holder,
A.G.
Date(s)
May 12, 2011

Description
document discusses strategies for
that decision.
public interest.
[17-pages]
LTR and Attachment
Un-redacted
Subject: Re: Referral of Matters
Arising from the Preliminary
Inquiry of Senator John Ensign.
consists of a Senate referral LTR
and a 2-page attachment to the
AG regarding Ensign.
FOIA
Exemption
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)

Description
FOIA
Exemption
WIF
RIP

public interest.
[(LTR) 1-page; (Attachment) 2pages]
CRM 65
[PIN Bankers
Box No. 2; CD
marked: Ensign
Investigation; 416-2010; DOJ
[ ]]
[ ] PIN Trial
Atty.
Google
(G-mail)
Custodian of
Records
LTR (final)
(signed) dated
March 2, 2010;
LTR (draft) dated
December 3, 2009
[ ] PIN Trial
Atty.
Google
(G-mail)
Custodian of
Records
LTR (final)
(signed) dated
April 2, 2010
[LTR (final)
(signed); LTR
(draft); [EOUSA
referral to CRM]
CRM 66
[PIN
BankersBox No.
2; CD marked:
Ensign
[ ]]
LTR and Attachment

Redacted
Subject: Re: Referral of Matters
consists of a Senate referral LTR
and a 2-page attachment to the
AG regarding Ensign.
public interest.
[(LTR) 1-page; (Attachment) 2pages]
LTR and Fax Cover Sheet
Subject: Re: Preservation
Request.
preservation request related to an
email account for Sen. Ensign
(nvensign@[ ].com).
Revealing the name of lower-level
DOJ employee(s), who maintain
[1-page LTR (final) (signed); 1page Fax Cover Sheet] (1-page
LTR(draft))
LTR and Fax Cover Sheet
Request.
email account of Sen. Ensign
(j.e.ensign@[ ].com).
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)( 6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Document
Reference
Number
CRM 67
[PIN Bankers
Box No. 2; CD
marked: Ensign
[ ]]
Author(s)
Recipient(s)
Date(s)
[ ] PIN Trial
Atty.
Custodian of
Records AOL,
LLC
LTR (final)
(signed) dated
December 4, 2009;
LTR (draft) dated
December 4, 2009
[ ] PIN Trial
Atty.
Custodian of
Records
Yahoo! Inc
LTR (final)
(signed) dated
December 10,
2009; LTR (draft)
dated December
10, 2009; LTR
(draft) dated
December 3, 2009
Unidentified
PIN
Employee
Case File
Closed Date:
07/18/2012
[LTR (final)
(signed); LTR
(draft); [EOUSA
referral to CRM]
CRM 68
[PIN Bankers
Box No. 2; CD
marked: Ensign
[ ]]
[LTR (final)
(signed); LTR
(draft); [EOUSA
referral to CRM]
CRM 69
[PIN Bankers
Box No. 4]

Description
[1-page LTR (final) (signed); 1page fax cover sheet]
LTR and Fax Cover Sheet.
Request.
email account for Ensign and
another private third party
individual ([@aol.com) and
([ ]@aol.com.
Revealing the name of lowerlevel DOJ employee(s) and
private third party individual(s),
[LTR (final) (signed) 1-page; fax
cover sheet 1-page; LTR(draft) 1page]
LTR and Fax Cover Sheet.
Request.
email account of Ensign
(fredschwartz72@[ ].com).
being withheld in full to protect
Revealing the name of lowerlevel DOJ employee(s) who
maintains strong privacy interests,
[LTR (final) (signed) 1-page; fax
cover sheet 1-page; LTR (draft) 1page; LTR (draft) 1-page]
PIN-DOJ-CRM: FILE
MANIFEST, [0001 OF 0001].
JOHN ET AL. (ACT #20100266).
contains a list of the contents of
PINs Banker Box No. 4 which
directly relates to the Ensign
investigation.
FOIA
Exemption
WIF
RIP
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Document
Reference
Number
CRM 70
[PIN Bankers
Box No. 4]
[EOUSA referral
to CRM]
Author(s)
Date(s)
[ ] SSCE
Raymond
Hulser, PIN
Principle
Deputy for
Litigation;
Jack Smith,
PIN Section
Chief
Undated
[ ] PIN Trial
Atty.
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Deputy for
Litigation; [ ]
PIN Trial
Atty.
June 02, 2011
See also:
CRM 287;
[The Inventory
of the Ensign
Investigative
Materials is the
attachment part
of a letter dated
May 24, 2011
from SSCE to
PIN]
CRM 71
[PIN Bankers
Box No. 4]
Recipient(s)
Jack Smith,
PIN Section
Chief
[ ] PIN Trial
Atty.;
Raymond
Hulser, PIN
Principal
Deputy for
Litigation; [ ]
PIN Trial
Atty.

Description
[1-page]
Inventory of the Ensign
Investigative Materials
(Attachment)
Subject: An inventory of
relevant SSCE documents in the
Ensign investigation designed to
assist or aid the DOJ prosecutor in
organizing evidentiary material.
Description: This is an SSCE
created document which consists
of a list of depositions,
memoranda of interviews,
document binders and [ ] taint
files.
public interest.
[3-pages]
Email
subject line: RE: ENSIGN and
ENSIGN.
email chain discussing
investigative strategies to be
employed in connection with the
Ensign investigation. There is
also a handwritten word on the
email chain.
(AWP). The document
investigative strategies for
gathering and reviewing evidence.
reveal the authoring PIN Trial
Attorney(s) mental impressions
and legal theories with respect to
the identification of potential
witnesses and evidence related to
the Ensign investigation.
information of lower-level
FOIA
Exemption
WIF
The name(s)
and personal
information
of and
private third
party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
CRM 72
[PIN Bankers
Box No. 4]
Author(s)
Unidentified
PIN Trial
Atty.
Recipient(s)
Unidentified
PIN Trial
Atty.
Date(s)
Undated

Description
government employee(s) and
[2-pages]
Investigative Outline
Subject: None.
broken into three separate
subparts:
[ ] 302 Statements, Corroborating
Evidence & Contradictory
Evidence. The document also
includes four full handwritten
post-it notes.
(AWP). The document
Sen. Ensign. The document
contains a summary of witness
statements and includes evidence
that supports and/or contradicts
such witness statements. Release
of this document would reveal the
authoring PIN Trial Attorney(s)
theories with respect to the
governments analysis of the
witness statements and
supporting/ contradicting
evidence.
compiled to assist DOJ attorney(s)
in reaching a decision of whether
to prosecute Ensign and because it
by which the government made
that decision. The notes contain
legal analysis intended to inform a
final decision as to whether to
that decision.
FOIA
Exemption
(b)(5)
(AWP) and
(b) (5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 73
[PIN Bankers
Box No. 4]
CRM 74
[PIN Bankers
Box No. 4]
Author(s)
Unidentified
PIN Trial
Atty.
Unidentified
PIN Trial
Atty.
Recipient(s)
Unidentified
PIN Trial
Atty.
Unidentified
PIN Trial
Atty.
Date(s)
Undated
Undated

Description
[15-pages]
[ ] Deposition
Subject: Deposition notes.
consists of handwritten notes
summarizing witness testimony
taken during a deposition. The
witness testimony references
Ensign.
Ensign. The document contains a
summary of statements and
evidence offered during a
deposition. Release of this
authoring PIN Trial Attorney(s)
theories with respect to the
governments analysis of
statements and evidence offered
by the witness.
public interest.
[10-pages]
Investigative Outline
Subject: None.
broken into three separate
subparts: Source, New Info &
Impact. The document contains
references Ensign and other
private third parties.
(AWP). The document
reveal the authoring PIN Trial
Attorney(s) mental impressions
and legal theories. For example,
the document discusses legal
FOIA
Exemption
(b)(5)
(AWP)
WIF
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(5)
(AWP).
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
CRM 75
[PIN Bankers
Box No. 4]
Author(s)
[ ], [ ]
PIN Trial
Attys.
Recipient(s)
Jack Smith,
PIN
Section Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty
for Litigation;
[ ] PIN
Deputy Chief
Date(s)
March 7, 2011

Description
strategies for obtaining potential
evidence related to the
investigation.
that decision.
public interest.
[3-pages]
REVISED PROSECUTION
MEMORANDUM
Subject: Memorandum
Ensign.
pros memo setting forth the
detailed reasoning behind DOJs
decision recommending the
prosecution/indictment of [ ] and
[ ], and further declining the
(AWP). The document
CRM managers of a
recommendation to indict several
individuals, as well as the
approval by PIN managers to not
FOIA
Exemption
(b)(3) (Grand
Jury
Material); (b)
5 (AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 76
[PIN Bankers
Box No. 5]
Author(s)
Unknown
Recipient(s)
UnknownRecords/
Archives
Date(s)
CLOSED DATE
07/18/2012

Description
FOIA
Exemption
prosecute Ensign. The document

contains legal theories and factual
information that was compiled by
DOJ attorney(s) during the
disclose the attorneys legal
strategy.
also been withheld in part to
of these lower-level DOJ
Finally, page one of the
Prosecution Memo contains a
banner reading:
CONFIDENTIAL []
ATTORNEY WORK
MATERIAL.
[48-pages]
PIN-DOJ-CRM: FILE
(b)(3) (Grand
Jury
Material)
WIF
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)

Description
contains a list of the contents of
PINs Banker Box No. 5, which
directly relates to the Ensign
investigation.
being withheld to protect the
public interest.
[1-page]
CRM 77
[PIN Bankers
Box No. 5]
[EOUSA referral
to CRM]
Jack Smith,
PIN Section
Chief
[ ] [SSCE]
May 23, 2011
CRM 78
[email sweep];
[Relativity];
[DOJ0000001]
[ ] CRM
Atty.
[ ] PIN Trial
Atty.
June 30, 2011
PIN-DOJ-CRM: FILE
duplicate copy of CRM 62. CRM
62 is an inventory of the contents
of PINs Banker Box No. 3,
which directly relates to the
public interest.
[1-page]
LTR
Subject: Referral of Matters
Description: DOJ is requesting
from the SSCE the complete
evidentiary record as developed
by the SSCE.
[2-pages]
Email
consists of two emails and email
chain with the subject line:RE:
FOIA
Exemption
WIF
RIP
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lower-
Document
Reference
Number
CRM 79
[email sweep];
[Relativity];
[DOJ0000025]
CRM 80
[email sweep];
[Relativity];
[DOJ0000026]
CRM 81
[email sweep];
[Relativity];
[DOJ0000029]
Author(s)
Recipient(s)
Raymond
Hulser, PI N
Principal
Deputy Atty.
for Litigation
[ ] PIN
Employee
[ ] PIN
Employee
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
[ ] PIN
Employee
[ ], [ ], [ ], [ ],
[ ] PIN Trial
Attorneys and
PIN
Employees;
William
Welch, PIN
Former
Section Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
[ ] PIN
Employee;
[ ] PIN Trial
Atty.
[ ] PIN
Employee
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
[ ] PIN
Employee
[ ] PIN Trial
Atty.
Date(s)
June 30, 2011
June 30, 2011
May 20, 2010;

May 19, 2010

Description
FOIA
Exemption
[ ] and [ ]. The document

discusses CRM personnel
assignments related to the Ensign
investigation.
Revealing the name of a lowerlevel DOJ employee(s), who
[1-page]
Email
chains with the subject line:RE:
When did we open the Ensign
matter? and When did we open
the Ensign matter?
Revealing the name of lowerlevel DOJ employee(s), who
[1-page]
Email
consists of three emails and email
PI ACTS Opening Sheet U.S. v.
Ensign ACTS:201000268and PI
ACTS Opening Sheet U.S. v.
Ensign ACTS:201000268
[3-pages]
level DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Email
new matter and new matter.
WIF
RIP
Portions of
CRM 78 are
deemed nonresponsive
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
Document
Reference
Number
CRM 82
[email sweep];
[Relativity];
[DOJ0000031];
[DOJ0000034Duplicative]
CRM 83
[email sweep];
[Relativity];
[DOJ0000036]
CRM 84
[email sweep];
[Relativity];
[DOJ0000037]
Author(s)
Recipient(s)
[ ] PIN
Employee
[ ] PIN Trial
Atty.
[ ] PIN Trial
Atty.
[ ] PIN
Employee
[ ] PIN
Employee
[ ] PIN Trial
Atty.
[ ] PIN Trial
Atty.
[ ] PIN
Employee
[ ] PIN
Employee
[ ] PIN Trial
Atty.
[ ] PIN Trial
Atty.
[ ] PIN
Employee
[ ] PIN
Employee
[ ] PIN Trial
Atty.
[ ] PIN Trial
Atty.
[ ] PIN
Employee
Date(s)
June 9, 2010
June 22, 2010
August 10, 2010

Description
FOIA
Exemption
The emails reference the Ensign

investigation.
[2-pages]
Email
consists of four emails and email
new matter and new matter.
The emails reference the Ensign
investigation.
[3-pages; 2-pages]
Email
matters #s and matters #s. The
emails reference the Ensign
investigation.
Revealing the name of lowerlevel DOJ employee(s), who
[1-page]
Email
matters #s and matters #s. The
emails reference the Ensign
investigation.
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 83 are
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 84 are
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
CRM 85
[email sweep];
[Relativity];
[DOJ0000039]
[ ] PIN
Employee
[ ] PIN Trial
Atty.
August 25, 2010
CRM 86
[email sweep];
[Relativity];
[DOJ0000041]
[ ] PIN
Employee
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
December 2, 2010;
December 1, 2010;
January 18, 2011
Google
Alerts
[ ] PIN
Employee
[ ] PIN
Employee
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
CRM 87
[email sweep];
[Relativity];
[DOJ0000043]
[ ] PIN
Employee
[ ] PIN Trial
Atty.
March 16, 2011
CRM 88
[email sweep];
[Relativity];
[DOJ0000044]
[ ] PIN
Employee
[ ] PIN Trial
Atty.
March 23, 2011
[ ] PIN Trial
Atty.
[ ] PIN
Employee

Description
[2-pages]
Email
consists of single email with the
subject line: [ ] MAIL IN MAIL
BUCKET. The email references
[2-pages]
Email
consists of three emails and email
chains with the subject line:FW:
Google Alert Public Integrity
Section Google Alert Public
Integrity Section and FYI AP
HAS FOIA REQUEST FOR
ENSIGN. The emails reference
[2-pages]
Email
subject line:
PI_All_Open_Cases_Matters_Cr
eated_LANDSCRAPE STYLE.
The email references the Ensign
investigation.
[1-page]
Email
Ensign and Ensign.
FOIA
Exemption
WIF
RIP
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 86 are
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
Document
Reference
Number
CRM 89
[email sweep];
[Relativity];
[DOJ0000045];
[DOJ0000046]
Author(s)
[ ] PIN
Employee
Recipient(s)
[ ] PIN Trial
Atty.
Date(s)
April 15, 2011

Description
FOIA
Exemption

[1-page]
Email
subject line: [ ] pdf. The email
does not reference Ensign
however one page of the nine
page attachment does reference
the Ensign investigation. The
attachment is a PIN survey of
their open cases and matters
report.
(AWP). The document
document contains a synopsis of
the Ensign investigation and it
also includes the names of
subjects, federal crimes, etc.
that decision.
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 89 are
WIF
RIP
Document
Reference
Number
CRM 90
[email sweep];
[Relativity];
[DOJ0000055];
[DOJ0000056]
Author(s)
[ ] PIN
Employee
Recipient(s)
[ ] PIN Trial
Atty.
Date(s)
April 15, 2011

Description
employee(s). Revealing the name
of lower-level DOJ employee(s),
[1-page; 9-pages]
Email
subject line: [ ] pdf. The email
attachment is a PIN section
survey of their open cases and
matters report.
(AWP). The document
document contains a short
synopsis of the Ensign
investigation and includes: the
names of subjects, references to
certain federal crimes, etc.
that decision.
FOIA
Exemption
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 90 are
WIF
RIP
Document
Reference
Number
CRM 91
[email sweep];
[Relativity];
[DOJ0000065];
[DOJ0000067]
Author(s)
[ ] PIN
Employee
Recipient(s)
[ ] PIN Trial
Atty.
Date(s)
April 25, 2011

Description
also being withheld in full to
[1-page; 9-pages]
Email
consists of two emails and an
email chain with the subject line:
[ ] pdf and [ ]. The email
attachment is a PIN survey of
their open cases and matters
report.
(AWP). The document
document contains a short
synopsis of the Ensign
investigation and includes: the
names of subjects, references to
certain federal crimes, etc.
that decision.
FOIA
Exemption
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 91 are
WIF
RIP
Document
Reference
Number
Author(s)
Recipient(s)
CRM 92
[email sweep];
[Relativity];
[DOJ0000078];
[ ] PIN
Employee
[ ] PIN Trial
Atty.
[ ] PIN Trial
Atty.
[ ] PIN
Employee
CRM 93
[email sweep];
[Relativity];
[DOJ0000081];
[DOJ0000082]
[ ] PIN
Employee
[ ] PIN Trial
Atty.
See also:
CRM 4.
[PIN Bankers
Box No. 1]
Date(s)
July 06, 2011
September 12,
2011

Description
[1-page; 10-pages]
Email
Enisign (sic) and Enisign (sic).
Revealing the name of lower level
[3-pages; 2-pages]
Email
subject line: Emailing:
ENSIGN+JOHN+ET+AL+20100
268 and an attachment line:
268.pdf. The attachment consists
of the following document:
ACTS OPENING SHEET.
PI-1, 4/8//2009]; TITLE: U.S. v.
Ensign.
Description: The ACTS
OPENING SHEET is an internal
DOJ tracking form used to
identify a particular case, i.e.,
statutes that might have been
date; DOJ attorney(s) assigned;
of interest form.
(AWP). The document
Attorneys for the investigation
FOIA
Exemption
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
CRM 94
[email sweep];
[Relativity];
[DOJ0000095]
Author(s)
[ ] PIN
Deputy
Chief
Recipient(s)
[ ], [ ] PIN
Trial Attys.
Date(s)
November, 21,
2011

Description
strategy.
that decision.
employee(s), and the names and
personal information of private
information of a lowerlevel
government employee(s) and third
parties, who maintain strong
public interest.
[1-page; 4-pages]
Email
subject line: [ ]. The email
contains a single word reference
to Ensign and a discussion
involving a personnel assignment.
government employee(s), who
FOIA
Exemption
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 94 are
WIF
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
CRM 95
[email sweep];
[Relativity];
[DOJ0000098]
[ ] PIN
Deputy
Chief
[ ] PIN
Employee
April 4, 2012
CRM 96
[email sweep];
[Relativity];
[DOJ0000154];
[DOJ0000155]
See also:
CRM 3 (a) and
(b).
[PIN Bankers
Box No. 1]
[ ] PIN
Employee
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
July 09, 2012;

May 7, 2012

Description
[3-pages]
Email
subject line: Re: [ ] 2nd request
reminder: The email contains a
single word reference to Ensign.
DOJ employee(s), who maintains
[1-page]
Email
subject line: OK to enter into
ACTS in its entirety? Ensign
Declination Memo. The
attachment line: Ensign
Declination Memo.wpd.
MEMORANDUM [Declination
Memo].
Subject: Recommendation to
Decline Prosecution of Former
Senator John Ensign [Footnote
1].
declination memo setting forth the
detailed legal basis behind DOJs
decision not to charge or
prosecute Ensign.
(AWP). The document
decline to prosecute Ensign. The
document discusses legal theories
detailed legal analysis behind
DOJs recommendation not to
charge or prosecute Ensign, and
FOIA
Exemption
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 95 are
(b)(3) (Grand
Jury
Material),
(b) (5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
CRM 97
[email sweep];
[Relativity];
[DOJ0000168];
[DOJ0000169]
See also:
CRM 93
[email sweep];
[Relativity];
[DOJ0000081];
[DOJ0000082]
See also:
CRM 4
[PIN Bankers
Box No. 1]
Author(s)
[ ] PIN
Employee
Recipient(s)
[ ] PIN Trial
Atty.
Date(s)
May 14, 2010

Description
The Declination Memo, for
primary reasons for immediate
decision not to prosecute Sen.
Ensign.
of PIN Attorneys or third parties,
[1-page; 7-pages]
Email
subject line: Emailing:
268. Pdf Case Opening Sheet
and an attachment line:
268.pdf. The attachment consists
of the following document:
ACTS OPENING SHEET.
PI-1, 4/8//2009]; TITLE: U.S. v.
Ensign.
Description: The ACTS
OPENING SHEET is an internal
DOJ tracking form used to
identify a particular case, i.e.,
statutes that may have been
date; DOJ attorney(s) assigned;
of interest form.
(AWP). The document
FOIA
Exemption
WIF
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
CRM 98
[email sweep];
[Relativity];
[DOJ0000173]
Author(s)
[ ] PIN
Employee
Recipient(s)
[ ], [ ] PIN
Trial Atty.
Date(s)
October 23, 2009

Description
strategy.
that decision.
information of a lowerlevel DOJ
[1-page; 4-pages]
Email
subject line: [ ] FOR ENSIGN
CORRECT. The email contains
a single word reference to Ensign
and also refers to a provision of
FOIA
Exemption
(b)(5)(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
WIF
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
CRM 99
[email sweep];
[Relativity];
[DOJ0000175]
[ ] PIN
Employee
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
October 23, 2009
CRM 100
[email sweep];
[Relativity];
[DOJ0000176];
Jack Smith,
PIN
Section
Chief
[ ], [ ] PIN
Trial Atty.
April 1, 2011

Description
FOIA
Exemption
the United States Code.

(AWP). The document
reference to certain statutes that
may be used in any possible
criminal prosecution, and
attorneys legal strategy.
[2-pages]
Email
subject line: PI[N] ACTS
Opening Sheet U.S. v. Ensign
ACTS: 201000268.
the personal privacy interests of a
PIN employee. Revealing the
name of lower-level DOJ
employee(s), who maintain strong
public interest.
[1-page]
Email
subject line: Fw: emergency help
needed. The remainder of the
document contains nonresponsive material.
PIN employee. Revealing the
name of lower-level DOJ
public interest.
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 100
are deemed
nonresponsive.
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
CRM 101
[email sweep];
[Relativity];
[DOJ0000184]
[ ] PIN
Employee
[ ] PIN Trial
Atty.
October 29, 2009
CRM 102
[email sweep];
[Relativity];
[DOJ0000279];
[DOJ0000280]
[ ] PIN
Employee
[ ] PIN Trial
Atty.; [ ] PIN
Employee
[ ], PIN Trial
Atty.
[ ], [ ] PIN
Employee
CRM 103
[email sweep];
[Relativity];
[DOJ0000285]
Unknown
Unknown
April 09, 2010

Description
[1-page]
Email
subject line: financial
disclosures and an attachment
line: Ensign Senate Financial
Disclosure_2006.pdf; Ensign
Senate Financial
Disclosure_2005.pdf. The
attachments are publicly available
documents.
Revealing the names of lowerlevel DOJ employee(s), who
[1-page]
Email
consists of two emails with the
subject line: RE: Credit Bureau
Rider and Credit Bureau
Rider. The attachment line
reads:Subpoena Rider for Credit
Bureau 4-9-10.wpd. The
attachment references John E.
Ensign.
DOJ employee(s) and private
[1-page; 1-page]
Congressional Document
Requests by PIN
consists of a list of PIN requests
for Congressional documents
covering the periods of 2006-10.
The document created in an
outline form references Senator
Ensign
(AWP). The document
FOIA
Exemption
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The
attachment
consists of
publicly
available
documents
(b)(3) (Grand
Jury
Material)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)a
nd private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(3) (Grand
Jury
Material);
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
CRM 104
[email sweep];
[Relativity];
[DOJ0000294];
[DOJ0000295]
Author(s)
Recipient(s)
William
Welch, PIN
Former
Section
Chief
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Raymond
William
Date(s)
October 28, 2009;

October 27, 2009

Description
FOIA
Exemption

involved in the case.
contains a comprehensive list of
cases wherein PIN requested
Congressional documents, the
document reference the method
PIN made the request and whether
production had yet occurred, and
information described in the
document may have served as a
basis for that decision.
information of a lower-level DOJ
[3-pages]
Email
subject line: RE: omnibus list
and omnibus list. The
attachment line reads: cases
(AAG) (102809).mem.wpd. The
Portions of
CRM 103
are deemed
nonresponsive
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
WIF
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Welch, PIN
Former
Section Chief
Date(s)

Description
FOIA
Exemption
attachment at pages 6-7 references

Ensign. The attachment is a
memorandum containing a
detailed synopsis of active CRM
cases prepared on behalf of AAG
Lanny Breuer.
(AWP). The document
was compiled by DOJ attorney(s)
for the investigation and possible
criminal prosecution and its
release would reveal the mental
impressions and legal strategies of
the DOJ attorney(s) involved in
the case. For example, the
document contains a
comprehensive list of cases and
summarizes the status of those
cases and revelation of that
strategy.
interests of a PIN Trial Attorney
and the names and personal
individuals. Revealing the names
and personal information of a
lowerlevel DOJ employee(s) and
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 104
are deemed
nonresponsive
WIF
RIP
Document
Reference
Number
CRM 105
[email sweep];
[Relativity];
[DOJ0000319];
Author(s)
Recipient(s)
William
Welch, PIN
Former
Section
Chief
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
William
Welch, PIN
Former
Section Chief
William
Welch, PIN
Former
Section
Chief
[ ] PIN Trial
Atty.;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] PIN Trial
Atty.
Date(s)
October 23, 2009

Description
[1-page; 23-pages]
Email
consists of three emails with the
subject line: RE: EnsignRe:
Ensign and Ensign. The
document discusses whether to
interview a witness/subject and
further makes reference to
Ensigns legal counsel.
(AWP). The document
was compiled by DOJ Trial
contains a discussion involving
whether to interview a witness/
subject and revelation of that
strategy.
employee (s), and the names and
FOIA
Exemption
WIF
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employees
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
CRM 106
[email sweep];
[Relativity];
[DOJ0000324]
[EOUSA referral
to CRM]
[ ], [ ]
[SSCE]
Jack Smith,
PIN Section
Chief
February 24, 2011
CRM 107
[email sweep];
[Relativity];
[DOJ0000336];
[DOJ0000333Duplicative];
Janet Webb,
OEO,
Deputy
Director
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
September 22,
2011; September
21, 2011
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Janet Webb,
OEO, Deputy
Director; Paul
OBrien,
(DAAG)
Janet Webb,
OEO,
Deputy
Director
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Paul OBrien,
(DAAG)
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Janet Webb,
OEO, Deputy
Director; Paul
OBrien,
(DAAG)
Janet Webb,
OEO,
Deputy
Director
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Paul OBrien,
(DAAG)
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Paul OBrien,
(DAAG);
Janet Webb,
OEO, Deputy
Director

Description
information of a lower-level DOJ
[1-page; 1-page]
LTR.
Subject: Referral of Matters
Description: The SSCE is
requesting access to the evidence
obtained by DOJ during the
investigation of Ensign.
Revealing the name of private
third party person(s) who
[2-pages]
Email
consists of six emails and email
chains with the subject line: RE:
Question. The document
consists of a legal strategy
discussion to determine how to
characterize certain individuals
within the scope of a legal
pleading and relates to the Ensign
investigation. The document also
cites to a relevant section of the
USAM.
(AWP). The document
contains a discussion involving
how to properly characterize
certain persons within the context
of a legal pleading and release of
this information would
improperly disclose the DOJ
FOIA
Exemption
WIF
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
CRM 108
[email sweep];
[Relativity];
[DOJ0000339]
[ ] Private
Legal
Counsel
Unknown PIN
Trial Atty.
June 6, 2011
CRM 109
[email sweep];
[Relativity];
[DOJ0000340]
[ ] PIN
Summer
Volunteer
Intern
[ ] PIN
Deputy Chief
August 03, 2011;

August 02, 2011

Description
interests of several private third
party individuals. Revealing the
of private third parties, who
[3-pages; 3-pages; 2-pages]
Email
subject line: CONF
CALL/Ensign.
third party individual(s) who
[1-page]
Email and MEMORANDUM
subject line: [ ] Memo and with
the attachment line: [ ]
8.2.11.doxc.
MEMORANDUM
Subject: Memorandum
Ensign.
DOJ pros memo setting forth the
detailed legal reasoning behind
the decision recommending the
FOIA
Exemption
WIF
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lower
level DOJ
Employees
and private
third party
individual(s)
have been
redacted
under (b)(6)
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)

Description
FOIA
Exemption
[ ], and further declining the
(AWP). The document
drafted to analyze a certain legal
theory germane to the issue of
whether to prosecute Ensign. The
document contains legal theories
created by a PIN Summer
Volunteer Intern (Law Clerk) for
use by PIN Trial Attorneys during
the investigation and possible
strategy.
The memo, for example, includes
legal analysis, in the form of the
whether the government could
successfully prosecute Ensign
under a certain legal theory.
Disclosure of this deliberative
material could likely chill the
open sharing of thoughts and
impressions of ongoing criminal
prosecutions. Disclosure is also
likely to confuse the public about
the final basis for the decision not
to prosecute Ensign.
interests of several PIN
of these PIN employee(s) and
[1-page; 4-pages]
and (b)(7)(C)
WIF
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)

Description
FOIA
Exemption
WIF
CRM 110
[email sweep];
[Relativity];
[DOJ0000345];
[DOJ0000346]
[ ] PIN
Employee
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] PIN
Employee
June 07, 2012
Email and Attachment

subject line: Update re 2011
Report to Congress with an
attachment line: 2011 Report to
Congress PIN Sheet.pdf.
consists of a list of PIN open
investigations. The document
contains a reference to Senator
Ensign.
Basis for Withholding: (b) (5)
(AWP). The document
contains a comprehensive list of
PIN cases and summarizes the
status of those cases and
of criminal investigations.
Disclosure would also likely
confuse the public as to the final
basis for the decision not to
interests of PIN employee(s), and
the names and personal
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 110
are deemed
nonresponsive
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
CRM 111
[email sweep];
[Relativity];
[DOJ0000349]
[ ] PIN Trial
Atty.
[ ] PIN Trial
Atty.
February 01, 2011
CRM 112
[email sweep];
[Relativity];
[DOJ0000851];
[DOJ0000852];
[DOJ0000856]
[ ] PIN Trial
Atty.
[ ] PIN Trial
Atty.
August 23, 2010

Description
of a lowerlevel government
employee and third parties, who
[1-page; 3-pages]
Email
consists of three emails and the
subject line: Re: [ ] RE: [ ]
and [ ].
several PIN Trial Attorney(s) and
a private third party individual.
[1-page]
Email and Attachments
consists of a single email and the
subject line: 18 Facts Linked To
Object [ ].pdf and 20 Facts
Linked To Object [ ].pdf. The
attachments contain references to
Ensign.
(AWP). The document
was compiled by a PIN Trial
Attorney for the investigation and
possible criminal prosecution and
its release would reveal the
contains an analysis of the
electronic evidence and revelation
of that information would
Each attachment states at the
bottom of the text page Confidential Attorney Work
Product. Do Not Reproduce.
and because it reflects the give-
FOIA
Exemption
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employees
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(3) (Grand
Jury
Material);
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
CRM 113
[email sweep];
[Relativity];
[DOJ0001046]
Author(s)
[ ] PIN Trial
Atty.
Recipient(s)
Patty Stemler,
Chief,
Appellate
Section
Date(s)
January 24, 2011

Description
and-take by which the
several PIN Trial Attorney(s) and
[1-page; 4-pages; 4-pages]
Email
subject line: [ ]. The email
contains a reference to the Ensign
investigation.
(AWP). The document
was compiled by a PIN Trial
Attorney during an investigation
and potential criminal prosecution
example, the document discusses
a legal issue encountered during
the course of the investigation and
FOIA
Exemption
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of DOJ
employees
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 113
are deemed
nonresponsive
WIF
RIP
Document
Reference
Number
CRM 114
[email sweep];
[Relativity];
[DOJ0001047];
See also:
CRM 162
[email sweep];
[Relativity];
[DOJ0001364]
Author(s)
Patty
Stemler,
Chief,
Appellate
Section
Recipient(s)
Mary Patrice
Brown,
(DAAG);
Mythili
Raman,
(DAAG); Jack
Smith, PIN
Section Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Joseph
Wyderko,
Principal
Deputy Chief,
Appellate
Section
Date(s)
January 24, 2011

Description
PIN Trial Attorney(s) and private
[1-page]
Email
subject line: RE: [ ]. The email
contains a reference to the Ensign
investigation.
(AWP). The document
contains factual information and
legal analysis that was compiled
by a DOJ attorney(s) for an
ongoing criminal investigation
and potential prosecution and its
document contains a discussion
about a legal charging issue that
arose during an investigation and
FOIA
Exemption
WIF
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lower
level DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 114
are deemed
nonresponsive
RIP
Document
Reference
Number
CRM 115
[email sweep];
[Relativity];
[DOJ0001049]
Author(s)
Recipient(s)
Patty
Stemler,
Chief,
Appellate
Section
[ ] PIN
Deputy Chief
[ ] PIN
Deputy
Chief
Patty Stemler,
Chief,
Appellate
Section
Patty
Stemler,
Chief,
Appellate
Section
[ ] PIN
Deputy Chief
Date(s)
July 07, 2011

Description
prosecute Ensign and others.
[2-pages]
Email
subject line: RE: Ensign.
(AWP). The document
by DOJ attorney(s) for the
document contains a legal
discussion about a charging issue
and revelation of that information
FOIA
Exemption
WIF
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employees
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 115
are deemed
nonresponsive
RIP
Document
Reference
Number
CRM 116
[email sweep];
[Relativity];
[DOJ0001074]
CRM 117
[email sweep];
[Relativity];
[DOJ0001078]
Author(s)
[ ] PIN Trial
Atty.
Jack Smith,
PIN Section
Chief
Recipient(s)
[ ], [ ], [ ], [ ],
[ ], [ ], [ ] PIN
Trial Atty.
Lanny A.
Breuer
(DAG);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mythili
Raman,
(DAAG);
Mary Patrice
Brown,
(DAAG)
Date(s)
June 21, 2011
March 20, 2011

Description
[1-page]
Email
subject line: I know youre all
busy . . . The message contains a
one line reference to Ensign.
[1-page]
Email
subject line: Talking Points
[ ] + Senate Ethics. The message
references Ensign.
(AWP). The document
legal analysis compiled by a DOJ
attorney(s) for the investigation
of Ensign, and its release would
reveal the mental impressions and
legal strategies of the attorneys
legal discussion about a charging
issue and revelation of that
strategy.
FOIA
Exemption
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 116
are deemed
nonresponsive
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
CRM 118
[email sweep];
[Relativity];
[DOJ0001079]
Jack Smith,
PIN Section
Chief
[ ] PIN
Deputy Chief;
[ ] PIN Trial
Atty.;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mary Patrice
Brown
(DAAG)
July 7, 2011
CRM 119
[email sweep];
[Relativity];
[DOJ0001080]
(PAO)
(SMO)
(PAO) (SMO)
December 01,
2010

Description
Revealing the names of private
[1-page]
Email
subject line: Ensign Update.
[1-page]
Email
subject line: DOJ DAILY NEWS
WRAP. The document contains
a reference to Ensign.
FOIA
Exemption
WIF
RIP
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 119
are deemed
Document
Reference
Number
CRM 120
[email sweep];
[Relativity];
[DOJ0001090]
CRM 121
[email sweep];
[Relativity];
[DOJ0001092]
CRM 122
[email sweep];
[Relativity];
[DOJ0001096]
See also:
CRM 153
[email sweep];
[Relativity];
[DOJ 0001314Duplicative]
See also:
CRM 154
[email sweep];
[Relativity];
Author(s)
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Jack Smith,
PIN Section
Chief
Jack Smith,
PIN Section
Chief
Recipient(s)
Jack Smith,
PIN Section
Chief
Date(s)
June 14, 2010
Jack Smith,
PIN Section
Chief; [ ], [ ]
PIN Trial
Atty.; [ ]
(AUSA-DC);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] PIN
Deputy Chief
September 24,
2010
[ ], [ ] PIN
Trial Atty.;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
December 01,
2010

Description
FOIA
Exemption

[3-pages]
Email
subject line: FW: Meeting. The
document references Ensign.
[1-page]
Email
subject line: ENSIGN
MEETING DISCUSSION OF
DRAFT PROS MEMO.
[1-page]
Email
consists of two emails and the
subject line: Re: Ensign and
Ensign.
(AWP). The document
constitutes AWP because it
consists of a PIN Attorney(s)
recommendation to PIN managers
to decline the prosecution of
Ensign. The document discusses
potential legal theories, evidence
criminal prosecution of Ensign,
detailed summary of the evidence
obtained by PIN and how it might
impact a potential criminal
strategy.
nonresponsive
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 120
are deemed
nonresponsive
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 121
are deemed
nonresponsive
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
CRM 123
[email sweep];
[Relativity];
[DOJ0001097]
CRM 124
[email sweep];
[Relativity];
[DOJ0001098]
Author(s)
Recipient(s)
Jack Smith,
PIN Section
Chief
[ ] Special
Agent (FBI);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
[ ] Special
Agent (FBI)
Jack Smith,
PIN Section
Chief
Jack Smith,
PIN Section
Chief
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] PIN
Deputy Chief;
[ ] PIN Trial
Atty.
Date(s)
December 02,
2010
February 18, 2011

Description
The email message, for example,
includes factual information and
subjective analysis, in the form of
the primary reason for immediate
[1-page]
Email
Ensign.
[1-page]
Email
subject line: Review Ensign GJ
Q+A.
[1-page]
FOIA
Exemption
WIF
RIP
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)

Description
FOIA
Exemption
WIF
CRM 125
[email sweep];
[Relativity];
[DOJ0001099]
Jack Smith,
PIN Section
Chief
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mythili
Raman,
DAAG; Mary
Pat Brown,
DAAG
March 17, 2011;

March 16, 2011
Email
consists of six email and the
subject line: Re: Senate Ethics
Committee re Ensign, et al RE:
Senate Ethic Committee re
Ensign, et al FW: Senate Ethics
Committee re Ensign, et al and
Senate Ethics Committee.
(AWP). The document
summarizes PINs position with
respect to DOJs response to the
SSCE letter and its previous
referral to DOJ. The document
discusses potential legal strategy
and information that was
detailed summary of how DOJ
should respond to the SSCE letter
and its referral to DOJ, its impact
on any potential criminal
strategy.
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
CRM 126
[email sweep];
[Relativity];
[DOJ0001101]
Jack Smith,
PIN Section
Chief
[ ], [ ] PIN
Trial Atty.;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
June 8, 2010
CRM 127
[email sweep];
[Relativity];
[DOJ0001104]
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
[ ] (OLA)
(JMD); [ ]
Mythili
Raman,
(DAAG); Jack
Smith, PIN
Section Chief;
[ ] (CRM); [ ]
(OLA) (JMD);
Mary Patrice
Brown
(DAAG)
May 27, 2012
[ ] (OLA)
(JMD)
Mythili
Raman,
(DAAG); Jack
Smith, PIN
Section Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] (CRM); [ ]
(OLA) (JMD);
Mary Patrice
Brown
(DAAG)
Mythili
Raman
(DAAG)
[ ] (OLA)
(JMD); [ ]
Mythili
Raman
(DAAG); Jack
Smith, PIN
Section Chief;
[ ] (CRM); [ ]
(OLA) (JMD);
Mary Patrice
Brown
(DAAG)

Description
[2-pages]
Email
subject line: ENSIGN weekly
mtg.
[1-page]
Email
subject line: Re: Draft of letter to
OCE.
(AWP). The document
summarizes DOJs posture with
respect to a draft letter to the
OCE. The document discusses
potential legal strategy and
PIN Trial Attorney(s) during the
Ensign investigation and its
the attorneys involved in the case.
contains a discussion of how DOJ
dealt with Congress insofar as the
Ensign investigation and
other individuals because it
that decision. The email message,
for example, includes factual
FOIA
Exemption
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 127
are deemed
nonresponsive
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
CRM 128
[email sweep];
[Relativity];
[DOJ0001113]
Jack Smith,
PIN Section
Chief
Jack Smith,
PIN Section
Chief;[ ], [ ]
PIN Trial
Atty.; [ ]
(AUSA-DC);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
August 8, 2010
CRM 129
[email sweep];
[Relativity];
[DOJ0001114]
Jack Smith,
PIN Section
Chief
[ ], [ ] PIN
Trial Atty.;
[ ] (AUSADC);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Jack Smith,
PIN Section
Chief; [ ] PIN
Deputy Chief
September 14,
2010
CRM 130
[email sweep];
[Relativity];
[DOJ0001118];
[DOJ0001119]
Jack Smith,
PIN Section
Chief
Lanny A.
Breuer
(DAG);
Mythili
Raman,
(DAAG);
Mary Patrice
Brown,
(DAAG);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] PIN Trial
Atty.
May 27, 2012

Description
[3-pages]
Email
subject line: Updated: WEEKLY
ENSIGN MEETING.
[1-page]
Email
subject line: ENSIGN
MEETING DISCUSSION OF
DRAFT PROS MEMO.
[1-page]
Email
subject line: Ensign [ ] Memo
and an attachment line: ensign_
[ ].
(Grand Jury Material). The 4page attachment document is
marked: PRIVILEGED AND
CONFIDENTIAL CONTAINS
6(e) MATERIAL.
(AWP). The document
consists of PIN Trial Attorney(s)
recommendation to DOJ
managers regarding the
prosecution of Ensign and other
individuals. The document
FOIA
Exemption
WIF
RIP
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(3) (Grand
Jury
Material);
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Document
Reference
Number
CRM 131
[email sweep];
[Relativity];
[DOJ0001126]
Author(s)
Recipient(s)
Jack Smith,
PIN Section
Chief
[ ], [ ]
(AUSA-DC);
[ ], [ ] PIN
Trial Atty.;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] PIN
Deputy Chief
Jack Smith,
PIN Section
[ ], [ ], ( [ ],
[ ] PIN Trial
CRM 131
[email sweep];
[Relativity];
[DOJ0001140];
[DOJ0001143]
Date(s)
October 12, 2010;

June 11, 2010

Description
discusses potential legal theories,
evidence and factual information
detailed discussion of grand jury
investigative strategy with regard
to the Ensign investigation, and
[1-page; 4-pages]
Email
subject line: Re: WEEKLY
ENSIGN MEETING.
FOIA
Exemption
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 131
are deemed
WIF
RIP
Document
Reference
Number
CRM 132
[email sweep];
[Relativity];
[DOJ0001145]
Author(s)
Recipient(s)
Chief
Atty.;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Jack Smith,
PIN Section
Chief
Mary Patrice
Brown
(DAAG);
Mythili
Raman,
(DAAG);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ], [ ], PIN
Trial Atty.; [ ]
(AUSA-DC)
Date(s)
February 4 2011

Description
FOIA
Exemption

[1-page]
nonresponsive
Email
subject line: Alabama Weekly
Progress Report. The message
contains a reference to Ensign.
[3-pages; 2-pages]
Email
subject line: Ensign/[ ] Update.
(AWP). The document
consists of PIN Trial Attorneys
recommendation to their DOJ
discusses potential legal theories,
evidence and factual information
Attorneys during the investigation
of Ensign, and its release would
legal strategies of the DOJ
attorney(s) involved in the case.
contains a detailed discussion of
grand jury investigative strategy
with regard to the Ensign
investigation, and revelation of
that information would
(b)(3) (Grand
Jury
Material);
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 133
[email sweep];
[Relativity];
[DOJ0001149]
Author(s)
Jack Smith,
PIN Section
Chief
Recipient(s)
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mythili
Raman
(DAAG);
Mary Patrice
Brown
(DAAG)
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Mythili
Raman
(DAAG);
Jack Smith,
PIN Section
Chief;
Mary Patrice
Brown
(DAAG)
Mythili
Raman
(DAAG)
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mary Patrice
Brown
(DAAG); Jack
Smith, PIN
Section Chief
Mythili
Raman
(DAAG)
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mary Patrice
Brown
(DAAG); Jack
Smith, PIN
Section Chief
Raymond
Hulser, PIN
Mythili
Raman
Date(s)
April 22, 2011;

April 21, 2011

Description
[1-page]
Email
consists of five emails and the
subject line: Re: Senate letter
and Senate letter.
(AWP). The document
summarizes DOJs posture with
respect to a draft letter to the
SSCE. The document discusses
potential legal strategy and
PIN Attorney(s) during the Ensign
investigation and its release would
discussion of how DOJ dealt with
the SSCE insofar as the Ensign
investigation and revelation of
analysis, in the form of a
discussion pertaining to charging
decisions. Disclosure of this
FOIA
Exemption
WIF
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Principal
Deputy Atty.
Litigation
(DAAG);
Jack Smith,
PIN Section
Chief;
Mary Patrice
Brown
(DAAG)
CRM 134
[email sweep];
[Relativity];
[DOJ0001157]
Jack Smith,
PIN Section
Chief
[ ] PIN Trial
Atty.;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
July 29, 2010
CRM 135
[email sweep];
[Relativity];
[DOJ0001160]
Jack Smith,
PIN Section
Chief
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
May 25, 2010
CRM 136
[email sweep];
[Relativity];
[DOJ0001163]
[Duplicative EOUSA referral
to CRM]
CRM 137
[email sweep];
[Relativity];
[DOJ0001164]
Jack Smith,
PIN Section
Chief
Jack Smith,
PIN Section
Chief
[ ], [ ], PIN
Trial Atty.; [ ]
(AUSA-DC);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Raymond
Hulser, PIN
Principal
Deputy Atty.
Date(s)
July 13, 2010
June 07, 2010

Description
[1-page]
Email
consists of three email sand the
subject line: Re: Politico and
Politico.
[1-page]
Email
subject line: RE: Reference
Check Memo-[ ].
[2-pages]
Email
subject line: Ensign.
[1-page]
Email
subject line: Re: Projection for
FOIA
Exemption
WIF
RIP
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and other
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 135
are deemed
nonresponsive
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 135
are deemed
nonresponsive
(b)(5)
(AWP) and
(b)(5) (DPP)
Document
Reference
Number
Author(s)
Date(s)
for Litigation
[Duplicative EOUSA referral

to CRM
CRM 138
[email sweep];
[Relativity];
[DOJ0001166]
Recipient(s)
Jack Smith,
PIN Section
Chief
[ ], [ ], [ ] PIN
Trial Atty.;
Raymond
Hulser, PIN
June 11, 2010

Description
FOIA
Exemption
Document Review -Ensign and

Projection for Document Review
Ensign.
(AWP). The document
consists of PIN Trial Attorneys
prosecution of Sen. Ensign and
other individuals. The document
discusses potential document
review that was compiled by PIN
detailed discussion of document
review strategy with regard to the
Ensign investigation, and
analysis, in the form of document
review strategy. Disclosure of
this deliberative material could
likely chill the open sharing of
thoughts and impressions of
ongoing criminal prosecutions.
Disclosure is also likely to
confuse the public about the final
prosecute Ensign.
[1-page]
Email
subject line: RE: Alabama
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lower-
WIF
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
Principal
Deputy Atty.
for Litigation
CRM 139
[email sweep];
[Relativity];
[DOJ0001178]
Jack Smith,
PIN Section
Chief
[ ] PIN Trial
Atty.;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
June 14, 2010
CRM 140
[email sweep];
[Relativity];
[DOJ0001180]
Jack Smith,
PIN Section
Chief
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
May 27, 2010
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Jack Smith,
PIN Section
Chief

Description
FOIA
Exemption
Weekly Progress Report.

[1-page]
Email
subject line: RE: Filter team
memo. The message contains a
single word reference to Ensign.
[1-page]
Email
subject line: RE: email
question.
(AWP). The document
Trial Attorney(s) during the
detailed discussion of Senate
documents with regard to the
level DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
Portions of
CRM 138
are deemed
nonresponsive
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 140
are deemed
nonresponsive
RIP
Document
Reference
Number
CRM 141
[email sweep];
[Relativity];
[DOJ0001183];
[DOJ0001184]
Author(s)
Jack Smith,
PIN Section
Chief
Recipient(s)
[ ], [ ],
[ ] (CRM);
Mythili
Raman,
(DAAG);
John Keeney,
(DAAG);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Date(s)
August 05, 2010

Description
analysis, in the form of how PIN
should proceed with respect to
Senate documents. Disclosure of
prosecute Ensign.
[2-pages]
Email
subject line: AAGReport(08 05
10).wpd.
(AWP). The document
consists of PIN Attorney(s)
detailed discussion of the Ensign
investigation prepared for the
AAG, and revelation of that
strategy.
FOIA
Exemption
WIF
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 141
are deemed
nonresponsive
RIP
Document
Reference
Number
CRM 142
[email sweep];
[Relativity];
[DOJ0001190];
[DOJ0001191]
Author(s)
Jack Smith,
PIN Section
Chief
Recipient(s)
[ ] PIN
Deputy Chief
Date(s)
August 25, 2010

Description
analysis, in the form of a detailed
summary of the Ensign
investigation prepared for the
AAG. Disclosure of this
Revealing the names of lowerlevel DOJ employee(s) and
[1-page; 2-pages]
Email
subject line: Current Case
Priorities and attachments line:
CURRENT CASE
PRIORITIES.docx. The
attachment is a list of PIN case
priorities and references Ensign.
(AWP). The document
detailed discussion of Ensign
investigation planning and
FOIA
Exemption
WIF
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 142
are deemed
nonresponsive
RIP
Document
Reference
Number
CRM 143
[email sweep];
[Relativity];
[DOJ0001195];
[DOJ0001196]
CRM 144
[email sweep];
[Relativity];
[DOJ0001200];
[DOJ0001201]
Author(s)
Jack Smith,
PIN Section
Chief
Jack Smith,
PIN Section
Chief
Recipient(s)
[ ] PIN
Deputy Chief
Mythili
Raman
(DAAG);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ], PIN
Deputy Chief
Date(s)
August 26, 2010
August 26, 2010

Description
that decision. The attachment
document, for example, includes
analysis, in the form of a detailed
summary of the Ensign
investigative plan. Disclosure of
prosecute Ensign.
[1-page; 3 -pages]
Email
subject line: Case list for next
weeks meeting and attachments:
CURRENT CASE
PRIORITIES1.docx.
[1-page; 4-pages]
Email
subject line: Meeting to Go Over
PIN Priority Cases and
attachments: CURRENT CASE
PRIORITIES01.docx.
FOIA
Exemption
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Portions of
CRM 143
are deemed
nonresponsive
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 144
are deemed
non-
Document
Reference
Number
CRM 145
[email sweep];
[Relativity];
[DOJ0001206];
[DOJ0001207]
Author(s)
Jack Smith,
PIN Section
Chief
Recipient(s)
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
[ ] PIN
Deputy Chief
Date(s)
September 06,
2010

Description
FOIA
Exemption

[1-page; 5-pages]
Email
subject line: Goals and
attachments: SEPTEMBERDECEMBER2010
PRIORITIES.docx.
(AWP). The document
prosecution of Ensign. The
document discusses the use of the
grand jury and charging decisions
by PIN Attorney(s) during the
discussion of the use of the grand
jury and charging decisions, and
document, for example, includes
factual information involving the
use of the grand jury and charging
decisions with respect to the
Ensign investigative. Disclosure
of this deliberative material could
prosecute Ensign.
responsive
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 145
are deemed
nonresponsive
WIF
RIP
Document
Reference
Number
CRM 146
[email sweep];
[Relativity];
[DOJ0001208]
CRM 147
[email sweep];
[Relativity];
[DOJ0001256]
Author(s)
Jack Smith,
PIN Section
Chief
[ ] PIN Trial
Atty.
Recipient(s)
[ ] PIN Trial
Atty.
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Date(s)
September 15,
2010
September 30,
2010

Description
[1-page; 1-page]
Email
subject line: [ ].
(AWP). The document
document discusses an aspect of
example, the document questions
the development of a certain
aspect of the investigation, and
document, for example, includes a
question regarding the status of a
certain aspect of the Ensign
investigative. Disclosure of this
[1-page]
Email
subject line: Draft pros memo.
FOIA
Exemption
WIF
(b)(5)
(AWP) and
(b)(5) (DPP)
RIP
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
Deputy Atty.
for Litigation
[ ] PIN
Deputy Chief;
[ ] PIN Trial
Atty.
CRM 148
[email sweep];
[Relativity];
[DOJ0001257]
Jack Smith,
PIN Section
Chief
[ ] PIN Trial
Atty.
October 4, 2010
CRM 149
[email sweep];
[Relativity];
[DOJ0001258]
Jack Smith,
PIN Section
Chief
[ ], [ ] PIN
Trial Atty.;
[ ] (AUSADC);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
June 15, 2010
CRM 150
[email sweep];
Unspecified
Sender
[ ], [ ] PIN
Trial Atty.;
Undated;
Undated;

Description
FOIA
Exemption

Revealing the names of lowerlevel government employee(s)
public interest.
[1-page]
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Email
subject line: RE: Camp
(AWP). The document
consists of a communication
between PIN managers and a PIN
Trial Attorney regarding
developments in the prosecution
of Ensign. The document
discusses an aspect of
example, the document questions
the investigation developments,
[1-page]
Email
subject line: WEEKLY ENSIGN
MEETING.
[1-page]
Email
Portions of
CRM 147
are deemed
nonresponsive
(b)(5)
(AWP)
WIF
RIP
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
Document
Reference
Number
Author(s)
[Relativity];
[DOJ0001260];
[DOJ0001261];
[DOJ0001262];
[DOJ0001263];
[DOJ0001264]
CRM 151
[email sweep];
[Relativity];
[DOJ0001293];
[DOJ0001294]
CRM 152
[email sweep];
[Relativity];
Jack Smith,
PIN Section
Chief
Jack Smith,
PIN Section
Chief
Recipient(s)
Date(s)

Description
FOIA
Exemption
[ ] (AUSADC); [ ] PIN
Deputy Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Undated;
Undated;
Undated
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] PIN
Deputy Chief
November 19,
2010

subject line: WEEKLY ENSIGN
MEETING Updated: WEEKLY
ENSIGN MEETING and
ENSIGN MEETING
DISCCUSSION OF DRAFT
PROS MEMO.
[1-page; 1-page; 1-page; 1-page;
1-page]
Email
subject line: KeyCase List and
attachments line: KEY CASE
LIST.docx.
(AWP). The document
between PIN managers regarding
and a proposed grand jury
witness, and its release would
reference investigation
developments and makes
reference to a proposed grand jury
witness, and revelation of that
strategy.
[1-page; 5-pages]
Email
consists of eight emails and the
[ ], [ ] PIN
Trial Atty.;
Raymond
December 01,
2010
(b)(3) (Grand
Jury
Material);
(b)(5)
(AWP)
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 151
are deemed
nonresponsive
(b)(3)
(Grand Jury
Material);
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Hulser, PIN
Principal
Deputy Atty.
for Litigation
[DOJ0001307]
[ ] PIN Trial
Atty.
Jack Smith,
PIN Section
Chief; [ ] PIN
Trial Atty. ;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Jack Smith,
PIN Section
Chief
[ ], [ ] PIN
Trial Atty.
Mythili
Raman
(DAAG)
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Jack Smith,
PIN Section
Chief
[ ] (SMO);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mythili
Raman
(DAAG); [ ]
(SMO)
[ ] (SMO)
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mythili
Raman
(DAAG); [ ]
(SMO)
Jack Smith,
PIN Section
Chief
[ ] (SMO);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mythili
Raman
(DAAG); [ ]
(SMO)
[ ] (SMO)
Jack Smith,
PIN Section
Chief;
Date(s)

Description
FOIA
Exemption
subject line: RE: Ensign Re

Ensign and Ensign.
(AWP). The document
discusses a proposed grand jury
witness, and discusses a subject
of the Ensign investigation, and
its release would reveal the
discussion regarding a proposed
grand jury witness, and discusses
a subject of the Ensign
analysis, regarding a grand jury
witness and a subject of the
criminal investigation. Disclosure
prosecute Ensign.
[3-pages]
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)

Description
FOIA
Exemption
WIF
December 02,
2010; December
01, 2010
Email
subject line: Re: Ensign RE:
Ensign and Ensign.
(AWP). The document
consists of a PIN Attorneys
compiled by PIN Attorney(s)
during the investigation and
Ensign, and its release would
contains a detailed summary of
the evidence obtained by PIN and
how it might impact a potential
(b)(5)
(AWP) and
(b)(5) (DPP)
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mythili
Raman
(DAAG); [ ]
(SMO)
CRM 153
[email sweep];
[Relativity];
[DOJ0001311]
See also:
CRM 122
[email sweep];
[Relativity];
DOJ0001096Duplicative]
See also:
CRM 154
[email sweep];
[Relativity];
Jack Smith,
PIN Section
Chief
[ ], [ ] PIN
Trial Atty.;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
CRM 154
[email sweep];
[Relativity];
[DOJ0001316]
See also:
CRM 153
[email sweep];
[Relativity];
[DOJ0001311]
See also:
CRM 122
[email sweep];
[Relativity];
DOJ0001096]
Author(s)
Jack Smith,
PIN Section
Chief
Recipient(s)
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Jack Smith,
PIN Section
Chief
Jack Smith,
PIN Section
Chief
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Jack Smith,
PIN Section
Chief
Jack Smith,
PIN Section
Chief
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ], [ ] PIN
Trial Atty.
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Jack Smith,
PIN Section
Chief; [ ], [ ]
PIN Trial
Atty.
[ ] PIN Trial
Atty.
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] PIN Trial
Atty.
Date(s)
December 02,
2010

Description
[3-pages]
Email
subject line: Re: Ensign RE:
Ensign and Ensign.
(AWP). The document
consists of a PIN Attorneys
compiled by PIN Attorney(s)
Ensign, and its release would
contains a detailed summary of
the evidence obtained by PIN and
how it might impact a potential
Revealing the names of lower-
FOIA
Exemption
WIF
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
CRM 155
[email sweep];
[Relativity];
[DOJ0001324]
CRM 156
[email sweep];
[Relativity];
[DOJ0001325]
Author(s)
Jack Smith,
PIN Section
Chief
Jack Smith,
PIN Section
Chief
Recipient(s)
Date(s)
[ ] (AUSADC); [ ], [ ]
PIN Trial
Atty.;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] PIN
Deputy Chief
December 03,
2010
[ ], [ ]
(AUSA-DC);
[ ], [ ] PIN
Trial Atty.;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] PIN
Deputy Chief ;
Mary Patrice
Brown
(DAAG);
Mythili
Raman
(DAAG)
December 06,
2010

Description
level DOJ employee(s), who
[2-pages]
Email
subject line: Enisgn/[ ]
Schedule.
(AWP). The document
strategy.
[1-page]
Email
subject line: Enisgn/[ ].
(AWP). The document
and an issue involving witness
immunity, and its release would
FOIA
Exemption
(b)(3) (Grand
Jury
Material);
(b)(5)
(AWP)
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
Author(s)
CRM 157
[email sweep];
[Relativity];
[DOJ0001326]
Jack Smith,
PIN Section
Chief
CRM 158
[email sweep];
[Relativity];
[DOJ0001327];
Jack Smith,
PIN Section
Chief
Recipient(s)
Mary Patrice
Brown
(DAAG)
Mary Patrice
Brown
(DAAG)
Date(s)
December 08,
2010
December 09,
2010;
December 10,
2010

Description
reference to a proposed witness
immunity issue, and revelation of
public interest.
[1-page]
Email
consists of four emails and the
subject line: Re and FW. The
email messages reference Ensign.
(AWP). The document
between DOJ management
regarding developments in the
document discusses an aspect of
and a potential subject, and its
document reference investigation
reference to a proposed subject,
[1-page]
Email
consists of a single email with the
subject line: PIN Case List and
FOIA
Exemption
(b)(5)
(AWP)
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(5)
(AWP) and
(b)(5) (DPP)
RIP
Document
Reference
Number
[DOJ0001328]
Author(s)
Recipient(s)
Date(s)

Description
FOIA
Exemption
an attachments line: Omnibus

case list December 2010.wpd.
The attachment at pages 9-10
references Ensign. The
attachment is a Memorandum
containing a detailed synopsis re:
Status of [PIN] Cases as of
December 2010.
(AWP). The document
document contains a
comprehensive list of cases and
summarizes the status of those
cases and revelation of that
strategy.
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 158
are deemed
nonresponsive
WIF
RIP
Document
Reference
Number
CRM 159
[email sweep];
[Relativity];
[DOJ0001348]
CRM 160
[email sweep];
[Relativity];
[DOJ0001349]
CRM 161
[email sweep];
[Relativity];
[DOJ0001354];
[DOJ0001355]
Author(s)
Jack Smith,
PIN Section
Chief
Jack Smith,
PIN Section
Chief
Jack Smith,
PIN Section
Chief
Recipient(s)
[ ], [ ], [ ] PIN
Trial Atty.;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Mythili
Raman
(DAAG)
[ ], [ ] PIN
Trial Atty.; [ ]
PIN Deputy
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
[ ] PIN Trial
Atty.
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] PIN
Deputy Chief;
[ ], [ ], [ ], [ ],
(AUSA-DC);
PIN Trial
Atty.
Jack Smith,
PIN Section
Chief
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Date(s)
December 09,
2010
December 16,
2010
December 23,
2010; December
22, 2010

Description
public interest.
[1-page; 20-pages]
Email
subject line: [ ].
[1-page]
Email
subject line: Re: Lanny did
interview with NYT today on
PIN.
[1-page]
Email
consists of a six emails with the
subject line: RE: Final Pros
Memo and Final Pros Memo.
(AWP). The document
document contains references to
the pros memo related to the
a decision of whether to charge or
FOIA
Exemption
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 159
are deemed
nonresponsive
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 160
are deemed
nonresponsive
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
[ ], [ ] PIN
Trial Atty.; [ ]
PIN Deputy
Chief
CRM 162
[email sweep];
[Relativity];
[DOJ0001364]
See also:
CRM 114
[email sweep];
[Relativity];
[DOJ0001047];
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Jack Smith,
PIN Section
Chief; [ ], [ ]
PIN Trial
Atty.; [ ] PIN
Deputy Chief
Jack Smith,
PIN Section
Chief
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ], [ ] PIN
Trial Atty.; [ ]
PIN Deputy
Chief
[ ] PIN Trial
Atty.
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] PIN
Deputy Chief;
[ ], [ ], [ ], [ ]
(AUSA-DC);
[ ] PIN Trial
Atty.
Jack Smith,
PIN Section
Chief
[ ], [ ] PIN
Trial Atty.
Patty
Stemler,
Chief,
Appellate
Section
Mary Patrice
Brown
(DAAG);
Mythili
Raman
(DAAG); Jack
Smith, PIN
Section Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Joseph
Wyderko,
Principal
Deputy Chief,
Appellate
Section
Mary Patrice
Brown,
DAAG
Patty Stemler,
Chief,
Appellate
Section;
Mythili

Description
FOIA
Exemption
WIF
(b)(5)
(AWP) and
(b)(5) (DPP)
prosecute Ensign and because it

reflects the give-and-take by
which the government made that
decision. The document contains
prosecute individuals related to
of lower-level DOJ employee(s)
public interest.
[3-pages]
January 24, 2011
Email
subject line: Fw: [ ] and [ ].
The email contains a reference to
(AWP). The document
by DOJ attorney(s) for the
document contains a discussion
about a legal charging issue that
arose during an investigation and
The name(s)
and personal
information
of lower
level DOJ
employees
and private
third party
individuals
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
Raman
(DAAG); Jack
Smith, PIN
Section Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
CRM 163
[email sweep];
[Relativity];
[DOJ0001618]
Jack Smith,
PIN Section
Chief
[ ], [ ] PIN
Trial Atty.;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Mary Patrice
Brown
(DAAG)
Lanny A.
Breuer
(AAG);
Mythili
Raman,
(DAAG); Jack
Smith, PIN
Section Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] PIN
Deputy Chief;
[ ] PIN Trial
Atty.
[ ] (AUSADC)
Mary Patrice
Brown
(DAAG);
[ ] (AUSADC)
February 02, 2011

Description
prosecute Ensign and others.
[2-pages]
Email
subject line: FW: Following up
and Following up.
(AWP). The document
between DOJ managers regarding
strategy.
FOIA
Exemption
(b)(3) (Grand
Jury
Material);
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 164
[email sweep];
[Relativity];
[DOJ0001867]
CRM 165
[email sweep];
[Relativity];
[DOJ0001868]
Author(s)
Recipient(s)
Mary Patrice
Brown,
DAAG
[ ], [ ]
(AUSA-DC)
Jack Smith,
PIN Section
Chief
Mary Patrice
Brown
(DAAG)
[ ] PIN Trial
Atty.
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] PIN Trial
Atty.
Jack Smith,
PIN Section
Chief
[ ] PIN Trial
Atty.;
Mary Patrice
Brown
(DAAG)
Date(s)
February 08, 2011
February 10, 2011

Description
[1-page]
Email
subject line: RE: [ ] and [ ].
(AWP). The document
strategy.
[1-page]
Email
(AWP). The document
FOIA
Exemption
(b)(3) (Grand
Jury
Material);
(b)(5)
(AWP)
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(3) (Grand
Jury
Material);
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
RIP
Document
Reference
Number
CRM 166
[email sweep];
[Relativity];
[DOJ0001869];
[DOJ0001870]
Author(s)
Jack Smith,
PIN Section
Chief
Recipient(s)
[ ] PIN Trial
Atty.;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Date(s)
February 11, 2011

Description
FOIA
Exemption
and references a proposed grand
jury witness, and its release would
references investigative
strategy.
[1-page]
Email
subject line: RE: Ensign [ ] and
Ensign and an attachments line:
ensign [ ].wpd.
(Grand Jury Material). The
document attachment contains a
banner headline reading:
PRIVILEGED AND
CONFIDENTIAL CONTAINS
6(e) MATERIAL.
(AWP). The document
strategy.
redacted
under (b)(6)
and (b)(7)(C)
(b)(3) (Grand
Jury
Material);
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 167
[email sweep];
[Relativity];
[DOJ0001874];
[DOJ0001876]
Author(s)
Jack Smith,
PIN Section
Chief
Recipient(s)
Mary Patrice
Brown
(DAAG);
Lanny A.
Breuer
(AAG);
Mythili
Raman,
(DAAG);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] PIN Trial
Atty.
Mary Patrice
Brown
(DAAG)
Lanny A.
Breuer
(AAG); Jack
Smith, PIN
Section Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] PIN Trial
Atty.
Lanny A.
Breuer
(AAG)
Mary Patrice
Brown
(DAAG); Jack
Smith, PIN
Section Chief;
Mythili
Raman
(DAAG);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] PIN Trial
Atty.
Mary Patrice
Brown
(DAAG)
Lanny A.
Breuer
(AAG);
Jack Smith,
PIN Section
Chief; Mythili
Raman
(DAAG);
Raymond
Hulser, PIN
Date(s)
February 14, 2011

Description
[1-page; 4-pages]
Email
consists of six emails with the
subject line: RE: Ensign [ ],
Re: Ensign [ ]and Ensign [ ]
and an attachments line:
BULLET POINTS FOR
DISCUSSION ON [ ] JOHN
ENSIGN.docx.
(AWP). The document
document contains references to
bullet points related to the Ensign
investigation and a proposed
grand jury witness, and revelation
prosecute certain individuals
investigation. Disclosure of this
material is likely to discourage
government employees from
keeping records of conversations
or mental impressions related to
evidence or witnesses. Disclosure
would also likely confuse the
public as to the final basis for the
decision not to prosecute, as some
FOIA
Exemption
(b)(3) (Grand
Jury
Material);
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
Principal
Deputy Atty.
for Litigation;
[ ] PIN Trial
Atty.
CRM 168
[email sweep];
[Relativity];
[DOJ0001878];
[DOJ0001882]
Lanny A.
Breuer
(AAG)
Jack Smith,
PIN Section
Chief; Mary
Patrice Brown
(DAAG);
Mythili
Raman
(DAAG);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] PIN Trial
Atty.
Jack Smith,
PIN Section
Chief
Lanny A.
Breuer
(AAG); Mary
Patrice Brown
(DAAG);
Mythili
Raman
(DAAG);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] PIN Trial
Atty.
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ], [ ] PIN
Trial Atty.;
Mary Patrice
Brown
(DAAG)
Jack Smith,
PIN Section
Chief
[ ] (SMO)
[ ] (JMD); [ ]
(SMO); Jack
Smith, PIN
Section Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mythili
Raman
(DAAG)
[]
legal.senate.
gov
[ ] (SMO)

Description
FOIA
Exemption
WIF
of the information described in

the document may have served as
a basis for that decision.
and private third parties, who
[2-pages; 2-pages]
February 15, 2011
Email
consists of three emails with the
subject line: FW: Immunity
notice from Senate Legal
Counsel, Immunity notice and
an attachments line: doj notify
ensign immunities ltr
021511.pdf.
(AWP). The document
document discusses prosecutorial
immunity issues related to the
Ensign investigation and further
involving a grand jury witness
(b)(3) (Grand
Jury
Material);
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
CRM 169
[email sweep];
[Relativity];
[DOJ0001886];
DOJ0001885Duplicative];
Author(s)
Jack Smith,
PIN Section
Chief
Jack Smith,
PIN Section
Chief
Recipient(s)
[ ] PIN Trial
Atty.;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Mythili
Raman,
(DAAG);
Mary Patrice
Brown,
(DAAG);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ], [ ] PIN
Trial Atty.
Date(s)
February 17, 2011

Description
of whether to prosecute Sen.
public interest.
[1-page; 2-pages]
Email
subject line: Fw: Revised, Re:
Revised and Revised.
(AWP). The document
charging decisions related to the
FOIA
Exemption
(b)(5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
Jack Smith,
PIN Section
Chief
Mary Patrice
Brown
(DAAG);
Mythilia
Raman
(DAAG);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ], [ ], PIN
Trial Atty.
Mary Patrice
Brown
(DAAG)
Mythilia
Raman
(DAAG);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] PIN Trial
Atty.
CRM 170
[email sweep];
[Relativity];
[DOJ0001888]
Jack Smith,
PIN Section
Chief
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] PIN
Deputy Chief;
[ ] PIN Trial
Atty.
February 18, 2011
CRM 171
[email sweep];
[Relativity];
[DOJ0001892];
Jack Smith,
PIN Section
Chief
Mary Patrice
Brown
(DAAG);
Raymond
February 23, 2011

Description
of lower-level government
parties, who maintain strong
public interest.
[1-page]
Email
subject line: Review Ensign GJ
Q+A.
[1-page]
Email
consists of five emails with the
subject line: RE: latest and
FOIA
Exemption
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(5)
(AWP) and
(b)(5) (DPP)
RIP
Document
Reference
Number
Author(s)
Date(s)
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mythilia
Raman
(DAAG)
Jack Smith,
PIN Section
Chief
CRM 172
[email sweep];
[Relativity];
Recipient(s)
Mythilia
Raman,
(DAAG);
Mary Patrice
Brown,
(DAAG); [ ]
PIN Deputy
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Mythilia
Raman
(DAAG)
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mary Patrice
Brown,
(DAAG)
Jack Smith,
PIN Section
Chief
Mary Patrice
Brown,
(DAAG); ; [ ]
PIN Deputy
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Mythilia
Raman
(DAAG)
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mary Patrice
Brown
(DAAG)
Jack Smith,
PIN Section
Chief
[ ], [ ], (SMO);
Raymond
Hulser, PIN
February 23, 2011

Description
FOIA
Exemption
latest.
(AWP). The document
charging decisions related to the
of whether to prosecute
public interest.
[2-pages]
Email
consists of seven emails with the
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
Portions of
CRM 171
are deemed
nonresponsive
(b)(5)
(AWP) and
(b)(5) (DPP)
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Principal
Deputy Atty.
for Litigation;
[ ] (ODAG);
Mythilia
Raman
(DAAG)
[DOJ0001891];
[ ] (SMO)
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] (SMO);
Jack Smith,
PIN Section
Chief; [ ]
(ODAG);
Mythilia
Raman
(DAAG)
Jack Smith,
PIN Section
Chief
Mythilia
Raman,
(DAAG);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mary Patrice
Brown
(DAAG);
Lanny A.
Breuer (AAG)
[ ] (SMO)
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] (SMO);
Mythili
Raman
(DAAG); Jack
Smith, PIN
Section Chief;
[ ] (ODAG)
Date(s)

Description
subject line: RE: Follow up from
[ ] re: [ ] + [ ]-- and Follow up
from [ ] re: [ ] + [ ]--
(AWP). The document
charging and immunization
decisions related to the Ensign
public interest.
[2-pages]
FOIA
Exemption
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)

Description
FOIA
Exemption
CRM 173
[email sweep];
[Relativity];
[DOJ0001897]
Jack Smith,
PIN Section
Chief
[ ], [ ], PIN
Trial Atty.(s);
[ ] PIN
Deputy Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
March 4, 2011
Email
subject line: Re: Additional
Ensign docs and Additional
Ensign docs.
[1-page]
(b)(3) (Grand
Jury
Material)
REVISED PROSECUTION
MEMORANDUM
Subject: Memorandum
Ensign.
DOJ pros memo setting forth the
prosecution/indictment of [ ] and [
], and further declining the
(AWP). The document
as the approval by PIN managers
to decline to prosecute Ensign.
The document contains legal
theories and factual information
Attorneys during the investigation
of Ensign and its release would
contains a list of the statutes that
(b)(3)
(Grand Jury
Material);
(b) (5)
(AWP) and
(b)(5) (DPP)
[ ] PIN Trial
Atty.
CRM 174
[email sweep];
[Relativity];
[DOJ0001970]
See also:
CRM 3 (a) and
(b) [PIN
Bankers Box No.
1]
[ ], [ ] PIN
Trial Atty.
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] PIN
Deputy Chief;
[ ] PIN Trial
Atty.
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] PIN
Deputy Chief.
March 7, 2011
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
CRM 175
[email sweep];
[Relativity];
[DOJ0002063]
Author(s)
Jack Smith,
PIN Section
Chief
Recipient(s)
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Date(s)
March 18, 2011

Description
also been withheld in part to
and third party individual(s), who
Page one of the REVISED
PROSECUTION
MEMORANDUM further
contains a banner reading:
CONFIDENTIAL
ATTORNEY WORK
PRODUCT CONTAINS 6(e)
MATERIAL.
[64-pages]
Email
consists of a single email with the
subject line: Talking Points on
[ ] / Senate Ethics.
(AWP). The document
involving Sen. Ensign. The
document contains factual
DOJ attorney(s) for the
discusses prosecutorial charging
decisions related to the Ensign
FOIA
Exemption
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 175
are deemed
nonresponsive
WIF
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)

Description
FOIA
Exemption
WIF
RIP

public interest.
[1-page]
CRM 176
[email sweep];
[Relativity];
[DOJ0002065]
CRM 177
[email sweep];
[Relativity];
[DOJ0002066]
CRM 178
[email sweep];
[Relativity];
[DOJ0002088]
Jack Smith,
PIN Section
Chief
Jack Smith,
PIN Section
Chief
Jack Smith,
PIN Section
Chief
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] PIN Trial
Atty.; [ ] PIN
Deputy Chief
[ ], [ ] PIN
Trial Atty.
Mythili
Raman
(DAAG);
Raymond
Hulser, PIN
Principal
March 23, 2011
April 01, 2011
April 22, 2011;

April 21, 2011
Email
subject line: FW: If you have
those [ ] cases Lanny wanted to
read, I can get [ ] to stick it in his
reading folder for his flight this
afternoon. The message
references the Ensign
investigation
[1-page]
Email
subject line: Fw: emergency help
needed.
[2-pages]
Email
subject line: Re: Senate letter
RE: Senate letter and Senate
letter.
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 176
are deemed
nonresponsive
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 177
are deemed
nonresponsive
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
Deputy Atty.
for Litigation;
Mary Patrice
Brown
(DAAG)
Mythili
Raman
(DAAG)
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mary Patrice
Brown
(DAAG); Jack
Smith, PIN
Section Chief
Mythili
Raman
(DAAG)
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mary Patrice
Brown
(DAAG)
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Mythili
Raman
(DAAG);
Mary Patrice
Brown
(DAAG); Jack
Smith, PIN
Section Chief
[ ] PIN Trial
Atty.;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
CRM 179
[email sweep];
[Relativity];
[DOJ0002161]
Jack Smith,
PIN Section
Chief
CRM 180
[email sweep];
[Relativity];
[DOJ0002162]
Jack Smith,
PIN Section
Chief
Greg Andres
(Acting
DAAG)
May 24, 2011
May 25, 2011

Description
FOIA
Exemption
WIF
RIP

[1-page]
have been
redacted
under (b)(6)
and (b)(7)(C)
Email
subject line: Ensign Update.
[1-page]
Email
subject line: RE: [ ].
[3-pages]
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 178
are deemed
nonresponsive
Portions of
CRM 180
are deemed
nonresponsive
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)

Description
FOIA
Exemption
WIF
RIP
CRM 181
[email sweep];
[Relativity];
[DOJ0000896]
[ ] (SMO)
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Jack Smith,
PIN Section
Chief; [ ], [ ]
PIN Trial
Atty.; [ ]
(SMO)
May 24, 2011
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
CRM 182
[email sweep];
[Relativity];
[DOJ0000901]
[ ] (SMO)
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] (USACT);
Mythili
Raman
(DAAG);
Mary Patrice
Brown,
(DAAG); [ ]
(SMO)
April 21, 2011
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
CRM 183
[email sweep];
[Relativity];
[DOJ0000902]
[ ] (SMO)
Mythili
Raman,
(DAAG);
Mary Patrice
Brown,
(DAAG); Jack
Smith, PIN
Section Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] (SMO)
May 13, 2011
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
CRM 184
[email sweep];
[Relativity];
[DOJ0000903]
[Duplicative of
CRM 185]
[ ] (SMO)
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] (SMO)
May 13, 2011
Email
subject line: Previous case where
weve charged 18 U.S.C.
207(e)(2).
[1-page]
Email
subject line: FYI Politico on
Ensign.
DOJ Employee(s) and private
[1-page]
Email
[1-page]
Email
subject line: Question from Post
re: Ensign.
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
CRM 185
[email sweep];
[Relativity];
[DOJ0000903]
a[Duplicative of
CRM 184]
[ ] (SMO)
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] (SMO)
May 13, 2011
CRM 186
[email sweep];
[Relativity];
[DOJ0000905];
[DOJ0000904Duplicative of
CRM 188]
[ ] (SMO)
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
May 26, 2011
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
[ ] (SMO);
Lanny A.
Breuer
(AAG);
Mythili
Raman,
(DAAG);
Mary Patrice
Brown
(DAAG); Jack
Smith, PIN
Section Chief
[ ] (SMO)
Lanny A.
Breuer
(AAG);
Mythili
Raman,
(DAAG);
Mary Patrice
Brown,
(DAAG); Jack
Smith, PIN
Section Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
[ ] (SMO)
Lanny A.
Breuer
(AAG);
Mythili
Raman
(DAAG);
Mary Patrice
Brown
(DAAG); Jack
Smith, PIN

Description
[1-page]
Email
subject line: Question from Post
re: Ensign.
[1-page]
Email
subject line: RE: FYI-Ensign
and FYI- Ensign.
[1-page; 1-page]
FOIA
Exemption
WIF
RIP
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Document
Reference
Number
CRM 187
[email sweep];
[Relativity];
[DOJ0000908]
CRM 188
[email sweep];
[Relativity];
[DOJ0000905];
[DOJ0000904Duplicative of
CRM 186]
Author(s)
[ ] (SMO)
Recipient(s)
Section Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Jack Smith,
PIN Section
Chief; [ ]
SMO
[ ]@nytimes.
com
[ ] (SMO)
[ ] (SMO)
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
[ ] (SMO);
Lanny A.
Breuer
(AAG);
Mythili
Raman
(DAAG);
Mary Patrice
Brown
(DAAG); Jack
Smith, PIN
Section Chief
[ ] (SMO)
Lanny A.
Breuer
(AAG);
Mythili
Raman
(DAAG);
Mary Patrice
Brown,
(DAAG); Jack
Smith, PIN
Section Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
[ ] (SMO)
Lanny A.
Breuer
(AAG);
Mythili
Raman
(DAAG);
Date(s)

Description
FOIA
Exemption
November 19,
2010
Email
subject line: FW: Ensign and
Ensign.
third party private individual(s).
Revealing the names of lowerlevel DOJ employee(s) and third
party private individual(s), who
[1-page]
Email
subject line: RE: FYI-Ensign
and FYI- Ensign.
[1-page; 1-page]
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and third
party private
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
May 26, 2011
WIF
RIP
Document
Reference
Number
CRM 189
[email sweep];
[Relativity];
[DOJ0001301];
DOJ0000909]
Author(s)
[ ] (SMO)
Recipient(s)
Date(s)

Description
FOIA
Exemption
Mary Patrice
Brown
(DAAG); Jack
Smith, PIN
Section Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Jack Smith,
PIN Section
Chief; Mythili
Raman
(DAAG);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] (SMO); [ ],
[ ] PIN Trial
Atty.
December 01,
2010; December
02, 2010
Email
subject line: RE: Ensign Re:
Ensign and Ensign.
(AWP). The document
example, the document discusses
the ongoing investigation of a
target and further references a
potential grand jury witness, and
[6-pages]
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Jack Smith,
PIN Section
Chief
[ ] (SMO);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mythili
Raman
(DAAG); [ ]
(SMO)
[ ] (SMO)
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mythili
Raman,
(DAAG); [ ]
(SMO)
Jack Smith,
PIN Section
Chief
[ ] (SMO);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mythili
Raman
(DAAG); [ ]
(SMO)
[ ] (SMO)
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
WIF
RIP
Document
Reference
Number
CRM 190
[email sweep];
[Relativity];
[DOJ00001303]
CRM 191
[email sweep];
[Relativity];
[DOJ00001614]
CRM 192
[email sweep];
[Relativity];
[DOJ00000862];
Author(s)
Jack Smith,
PIN Section
Chief
Recipient(s)
Date(s)

Description
FOIA
Exemption
for Litigation;
Mythili
Raman
(DAAG); [ ]
(SMO)
[ ], [ ] PIN
Trial Atty.
December 01,
2010
Email
subject line: FW: Sen. Ensigns
office says he is no longer target
of DOJ investigation into attempt
to coverup affair with former
aide, Fw: Sen. Ensigns office
says he is no longer target of DOJ
investigation into attempt to
coverup affair with former aide
and Sen. Ensigns office says he
is no longer target of DOJ
investigation into attempt to
coverup affair with former aide.
[2-pages]
Email
subject line: RE: Ensign, FW:
Ensign and Ensign.
[1-page]
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and third
party private
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and third
party private
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
PIN Talking Points Talking

Points 8/9/10
consists of PIN Talking Points
prepared for Jack Smith, PIN
Section Chief. The talking points
reference the Ensign
investigation.
The name(s)
and personal
information
of third party
private
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
[ ] (SMO)
Jack Smith,
PIN Section
Chief; Mythili
Raman
(DAAG)
[]
cbsnews.com
[ ] (SMO)
[ ] press
personality
[ ], [ ], [ ], [ ],
[ ], [ ], [ ], [ ]
misc. press
personalities
Jack Smith,
PIN Section
Chief
[ ] (SMO);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] (SMO)
[ ] (SMO)
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] (SMO)
[ ]@rollcall.
com
[ ] (SMO)
February 01, 2011
8/9/10
Portions of
CRM 192
WIF
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
CRM 193
[email sweep];
[Relativity];
[DOJ0000023]
[ ]@ap.org
[ ] (SMO);
Jack Smith,
PIN Section
Chief
August 28, 2010
CRM 194
[email sweep];
[Relativity];
[DOJ0001099]
Jack Smith,
PIN Section
Chief
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mythili
Raman
(DAAG);
Mary Patrice
Brown
(DAAG)
March 17, 2011;

March 16, 2011
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Jack Smith,
PIN Section
Chief; Mythili
Raman
(DAAG);
Mary Patrice
Brown
(DAAG)
Jack Smith,
PIN Section
Chief
Mythili
Raman
(DAAG);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mary Patrice
Brown
(DAAG)
Mythili
Raman
(DAAG)
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mary Patrice
Brown

Description
FOIA
Exemption

[3-pages; 3-pages]
Email
subject line: Latest.
[2-pages]
Email
consists of six emails and the
subject line: Re: Senate Ethics
Committee re: Ensign, et al,
RE: Senate Ethics Committee re:
Ensign, et al, FW: Senate Ethics
Committee re: Ensign, et al and
Senate Ethics Committee.
(AWP). The document
discusses the ongoing
investigation of target(s) of the
Revealing the names of lowerlevel employee(s), who maintain
[2-pages]
are deemed
nonresponsive
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and third
party private
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)

Description
FOIA
Exemption
March 24, 2011
Email
consists of ten emails and the
subject line: RE: Senate Ethics /
Ensign matter Could someone
please send us the indictment just
before you release it to the press
or make the announcement/,
FW: Senate Ethics / Ensign
matter Could someone please
send us the indictment just before
you release it to the press or make
the announcement/, RE: Senate
Ethics / Ensign matter and
Senate Ethics / Ensign matter --.
DOJ Employee(s) and private
[3-pages]
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and third
party private
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
(DAAG)
CRM 195
[email sweep];
[Relativity];
[DOJ0000886]
[ ] (SMO)
Mythili
Raman
(DAAG);
Lanny A.
Breuer
(AAG);
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Ron Weich
(DAAG);
[ ](SMO);
[ ](JMD)
(SMO);
[]
(OLA)(SMO)
[ ] SSCE
[ ] (SMO); [ ],
SSCE; [ ]
[ ] (SMO);
Mythili
Raman
(DAAG);
[ ] (SMO);
Ron Weich,
(DAAG);
[ ] (OLA)
(SMO);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Jack Smith,
PIN Section
Chief; Mary
Patrice Brown
(DAAG)
[ ] (SMO)
[ ](SMO)
[ ] (SMO);
Mythili
Raman,
(DAAG);
[ ] (SMO);
Ron Weich
(DAAG);
[ ] (OLA);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Jack Smith,
PIN Section
Chief
[ ](SMO)
[ ] (SMO);
Mythili
Raman
Document
Reference
Number
Author(s)
Recipient(s)
(DAAG);
[ ] (SMO);
Ron Weich
(DAAG);
[ ] (OLA);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Jack Smith,
PIN Section
Chief
[ ] (SMO)
[ ] (SMO);
Mythili
Raman
(DAAG);
[ ] (SMO);
Ron Weich
(DAAG);
[ ] (OLA);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Jack Smith,
PIN Section
Chief
[ ] (SMO)
[ ] (SMO);
Mythili
Raman
(DAAG);
[ ] (SMO);
Ron Weich,
(DAAG);
[ ] (OLA);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Jack Smith,
PIN Section
Chief
Mythili
Raman
(DAAG)
[ ] (SMO);
Mythili
Raman,
(DAAG);
[ ] (SMO);
Ron Weich,
(DAAG);
[ ] (OLA);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Jack Smith,
PIN Section
Chief
[ ] (SMO)
[ ] (SMO);
Date(s)

Description
FOIA
Exemption
WIF
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)

Description
FOIA
Exemption
March 24, 2011
Email
subject line: RE: Senate Ethics /
Ensign matter Could someone
please send us the indictment just
before you release it to the press
or make the announcement/,
FW: Senate Ethics / Ensign
matter Could someone please
send us the indictment just before
you release it to the press or make
the announcement/, RE: Senate
Ethics / Ensign matter and
Senate Ethics / Ensign matter --.
lowerlevel DOJ employee(s) and
and third party private
public interest.
[2-pages]
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and third
party private
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Mythili
Raman,
DAAG; [ ]
(SMO); Ron
Weich,
DAAG; [ ]
(OLA)
CRM 196
[email sweep];
[Relativity];
[DOJ0000891];
[DOJ0000897]
[ ] (SMO)
Mythili
Raman,
(DAAG);
[ ] (SMO),
Ron Weich
(DAAG);
[ ] (OLA)
[ ] (SMO)
Ron Weich
(DAAG);
[ ] (OLA)
Ron Weich
(DAAG)
[ ] (SMO)
[ ] (SMO);
[ ] (OLA)
[ ] (SMO);
Mythili
Raman,
(DAAG);
[ ] (SMO);
Ron Weich,
(DAAG);
[ ] (OLA);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Jack Smith,
PIN Section
Chief
[ ] (SMO)
[ ] (SMO);
Mythili
Raman,
(DAAG);
[ ] (SMO);
Ron Weich,
(DAAG);
[ ] (OLA);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Jack Smith,
PIN Section
Chief
[ ] (SMO)
Mythili
Raman
(DAAG);
[ ] (SMO);
Ron Weich,
(DAAG);
[ ] (OLA)
(SMO);
Raymond
Hulser, PIN
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)

Description
FOIA
Exemption
May 12, 2011
Email
consists of seven emails and the
subject line: RE: Senate Ethics
Referral to DOJ re Ensign will
become public at 2:30 pm today,
along with Special Counsels
report on same topic, FW:
Senate Ethics Referral to DOJ re
Ensign will become public at 2:30
pm today, along with Special
Counsels report on same topic
and Senate Ethics Referral to
DOJ re Ensign will become public
at 2:30 pm today, along with
Special Counsels report on same
topic.
lower DOJ employee(s) and third
party private individual(s).
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and third
party private
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Principal
Deputy Atty.
for Litigation;
Jack Smith,
PIN Section
Chief
Mythili
Raman
(DAAG)
[ ], [ ] (SMO);
Ron Weich,
(DAAG);
[ ](OLA);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Jack Smith,
PIN Section
Chief
[ ] (SMO)
[ ](SMO);
[]
(OLA)(SMO);
Ron Weich
(DAAG);
[ ](SMO)
[ ] (SMO)
Mythili
Raman
(DAAG);
[ ] (SMO);
Ron Weich,
(DAAG); [ ]
(OLA)
CRM 197(a)
[email sweep];
[Relativity];
[DOJ0000873]
[ ] (SMO)
Ron Weich
(DAAG); [ ]
(OLA)
Ron Weich
(DAAG)
[ ] (SMO)
[ ] (SMO);
[ ] (OLA)
Mary Patrice
Brown
(DAAG);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Jack Smith,
PIN Section
Chief; Mythili
Raman
(DAAG);
[ ](SMO)
Mary Patrice
Brown
(DAAG)
[ ] (SMO);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Jack Smith,
PIN Section
Chief; Mythili
Raman
CRM 197(b)
This document
was also referred
to CRM by FBI
on a consult
basis.
Document
Reference
Number
Author(s)
Recipient(s)
(DAAG);
[ ](SMO)
[ ] (SMO)
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Jack Smith,
PIN Section
Chief; Mythili
Raman
(DAAG);
[ ](SMO);
Mary Patrice
Brown
(DAAG)
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Mythili
Raman
(DAAG);
[ ] (SMO);
Jack Smith,
PIN Section
Chief; [ ]
(SMO); Mary
Patrice Brown
(DAAG)
Mythili
Raman
(DAAG)
[ ] (SMO);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Jack Smith,
PIN Section
Chief; [ ]
(SMO); Mary
Patrice Brown
(DAAG)
[ ] (SMO)
Mythili
Raman
(DAAG);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Jack Smith,
PIN Section
Chief; [ ]
(SMO)
[ ] (SMO)
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mythili
Raman
(DAAG); [ ]
(SMO); [ ]
(ODAG); Ron
Weich
Date(s)

Description
and third party private
public interest.
[2-pages]
Letter - U.S. Senate Re:
Referral of Matters Arising
from the Preliminary Inquiry of
Senator John Ensign
consists of a letter from the U.S.
Senate to Attorney General Eric
H. Holder. The letter contains a
section entitled: Summary of
Potential Violations.
Revealing the names of third
party private individual(s), who
[3-pages]
FOIA
Exemption
WIF
RIP
Document
Reference
Number
CRM 198
[email sweep];
[Relativity];
[DOJ0000893]
Author(s)
[ ] (SMO)
Recipient(s)
(DAAG); [ ]
(OLA); [ ]
(JMD)
Mary Patrice
Brown
(DAAG); [ ]
(SMO);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Jack Smith,
PIN Section
Chief; Mythili
Raman
(DAAG); [ ]
(CRM)
Mary Patrice
Brown
(DAAG)
[ ] (SMO); [ ]
(SMO);
Mythili
Raman
(DAAG); Jack
Smith, PIN
Section Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] (CRM)
[ ] (SMO)
Mary Patrice
Brown
(DAAG); [ ]
(SMO);
Mythili
Raman
(DAAG); Jack
Smith, PIN
Section Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] (CRM)
Mary Patrice
Brown
(DAAG)
[ ] (SMO); [ ]
(SMO);
Mythili
Raman
(DAAG); Jack
Smith, PIN
Section Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] (CRM)
[ ] (CRM)
Mary Patrice
Brown
(DAAG);
Date(s)

Description
FOIA
Exemption
May 13, 2011
Email
subject line: RE: Ensign, FW:
Ensign and Ensign.
private third party private
names of lower-level DOJ
employee(s) and third party
private individual(s), who
[2-pages]
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and third
party private
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)

Description
FOIA
Exemption
WIF
RIP
June 07, 2011
Email
subject line: Wash Post on PIN.
[1-page]
Email
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
Mythili
Raman
(DAAG)
Mary Patrice
Brown
(DAAG)
[ ] (CRM);
Mythili
Raman
(DAAG)
[ ] (CRM)
Mary Patrice
Brown
(DAAG);
Mythili
Raman
(DAAG)
Mary Patrice
Brown
(DAAG)
[ ] (CRM);
Mythili
Raman
(DAAG)
Mary Patrice
Brown
(DAAG)
[ ](SMO);
Mythili
Raman
(DAAG); Jack
Smith, PIN
Section Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] (SMO)
[ ] (SMO)
Mythili
Raman
(DAAG);
Mary Patrice
Brown
(DAAG); Jack
Smith, PIN
Section Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mary Patrice
Brown
(DAAG);
Mythili
Raman
(DAAG); [ ]
(SMO)
CRM 199
[email sweep];
[Relativity];
[DOJ0000895]
[ ] (SMO)
CRM 200
[email sweep];
[ ] (SMO)
[ ] (SMO);
[ ] (AUSA-
June 02, 2011;

June 01, 2011
Document
Reference
Number
[Relativity];
[DOJ0000907];
CRM 201
[email sweep];
[Relativity];
[DOJ0000910]
Author(s)
Recipient(s)
Date(s)
CT)
[ ] (SMO)
[ ] (AUSACT);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
[ ] (SMO)
[ ] (SMO)
[ ] (SMO)
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mythili
Raman
(DAAG);
[ ] (SMO)
Jack Smith,
PIN Section
Chief
[ ] (SMO);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mythili
Raman
(DAAG); [ ]
(SMO)
[ ] (SMO)
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mythili
Raman
(DAAG);
[ ] (SMO)
Jack Smith,
PIN Section
Chief
[ ] (SMO);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mythili
Raman,
(DAAG);
[ ] (SMO)
December 01,
2010

Description
FOIA
Exemption

subject line: RE: [ ], [ ] and
[ ] freelancer writing for the
Atlantic / 202[ ]/[ ]@gmail.com.
[1-page]
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Email
subject line: RE: Ensign Re:
Ensign and Ensign.
(AWP). The document
document references a potential
grand jury witness, and revelation
[2-pages]
(b) (3)
(Grand Jury
Material);
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 202
[email sweep];
[Relativity];
[DOJ0000912]
CRM 203
[email sweep];
[Relativity];
[DOJ0000914]
Author(s)
Recipient(s)
[ ] (SMO)
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mythili
Raman,
(DAAG);
[ ] (SMO)
Jack Smith,
PIN Section
Chief; Lanny
A. Breuer
(AAG);
Mythili
Raman
(DAAG);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
[ ] (SMO)
Jack Smith,
PIN Section
Chief
Lanny A.
Breuer
(AAG);
Mythili
Raman
(DAAG);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] (SMO)
[ ] CREW
Lanny A.
Breuer (AAG)
Jack Smith,
PIN Section
Chief; Mythili
Raman
(DAAG);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] (SMO); [ ],
[ ] PIN Trial
Atty.
[ ] (SMO)
Jack Smith,
PIN Section
Chief
Mythili
Raman
(DAAG); [ ]
(SMO);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] (SMO); [ ],
[ ] PIN Trial
Date(s)

Description
FOIA
Exemption
December 01,
2010
Email
subject line: Re: Not that it
matters much, Fw: Not that it
matters much, and Not that it
matters much,[.]
[1-page]
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Email
subject line: RE: Ensign, Re:
Ensign and Ensign.
(AWP). The document
document references both a
potential grand jury investigative
target and a grand jury witness,
(b) (3)
(Grand Jury
Material);
(b)(5)
(AWP)
December 02,
2010; December
01, 2010
WIF
Portions of
CRM 202
are deemed
nonresponsive
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
CRM 204
[email sweep];
[Relativity];
[DOJ0000916];
Jack Smith,
PIN Section
Chief; [ ]
(SMO);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] (SMO)
Jack Smith,
PIN Section
Chief
[ ] (SMO);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mythili
Raman
(DAAG);
[ ] (SMO)
[ ] (SMO)
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Mythili
Raman
(DAAG);
[ ] (SMO)
[ ], [ ], PIN
Trial Atty.(s).
[ ] (SMO)
[ ] PIN Trial
Atty.
[ ] (SMO); [ ]
PIN Trial
Atty.
[ ] (SMO)
[ ], [ ], PIN
Trial Atty.
[ ] PIN Trial
Atty.
[ ] (SMO);
[ ] PIN Trial
Atty.
[ ] (SMO)
[ ], [ ], PIN
Trial Atty..
[ ] PIN Trial
Atty.
[ ] (SMO); [ ]
PIN Trial
Atty.
FOIA
Exemption
WIF
(b) (3)
(Grand Jury
Material);
(b)(5)
(AWP)

[1-page]
Atty.
Mythili
Raman
(DAAG)

Description
March 23, 2011
Email
subject line: RE: Indictment
return anticipated tomorrow and
Indictment return anticipated
tomorrow.
(AWP). The document
document references a potential
grand jury investigative target,
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
CRM 205
[email sweep];
[Relativity];
[DOJ0000918]
CRM 206
[email sweep];
[Relativity];
[DOJ0000923]
CRM 207
[email sweep]
[DOJ----------]
[Duplicative of
CRM 212
[DOJ0033578]
Author(s)
Recipient(s)
[ ] (SMO)
[ ], [ ] PIN
Trial Atty.(s);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Jack Smith,
PIN Section
Chief; [ ]
(SMO)
[ ] (SMO)
[ ], [ ] PIN
Trial Atty.;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Jack Smith,
PIN Section
Chief; [ ]
(SMO)
[ ]@alm.com
[ ] (SMO)
[ ] (SMO)
[ ] (SMO)
[ ] (FBI)
[ ] PIN Trial
Atty.; [ ]
(USADC); [ ]
FBI
[ ] PIN Trial
Atty.
[ ] (FBI); [ ],
[ ] (USADC);
[ ] (FBI)
[ ] (FBI)
[ ] PIN Trial
Atty.; [ ]
(AUSA-DC);
[ ] FBI
Date(s)
October 21, 2010
June 01, 2011
February 12, 2010

Description
[2-pages; 1-page]
Email
subject line: RE:[ ], FW: [ ]
and [ ].
[3-pages]
Email
subject line: [ ] / freelancer
writing for the Atlantic / 202[ ] /
[ ]@gmail.com.
[1-page]
Email
subject line: RE: ENSIGN
INVESTIGATION
SCHEDULE and ENSIGN
INVESTIGATION
SCHEDULE.
(AWP). The document
FOIA
Exemption
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Portions of
CRM 205
are deemed
nonresponsive
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 206
are deemed
nonresponsive
(b) (3)
(Grand Jury
Material);
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
CRM 208
[email sweep]
[DOJ0001097]
Jack Smith,
PIN Section
Chief
[ ] (FBI);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
December 02,
2010
CRM 209
[email sweep]
[DOJ0001320]
Jack Smith,
PIN Section
Chief
[ ] (AUSADC);
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] (AUSADC);
[ ], [ ] PIN
Trial Atty.(s).
December 02,
2010; December
01, 2010
[ ] (AUSADC)
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] (AUSADC)
[ ] (FBI)

Description
FOIA
Exemption

document references grand jury
subpoenas, scheduled interviews
of both witnesses and a subject of
the grand jury investigation, and
[2-pages]
Email
Ensign.
[1-page]
Email
subject line: RE: [ ]Flash
Ensigns lawyers say he is no
longer target of DOJ probe,Fw:
[ ]Flash Ensigns lawyers say he
is no longer target of DOJ probe,
FW: [ ]Flash Ensigns lawyers
say he is no longer target of DOJ
probe and [ ]Flash Ensigns
lawyers say he is no longer target
of DOJ probe.
(AWP). The document
under (b)(6)
and (b)(7)(C)
WIF
RIP
Portions of
CRM 207
were referred
by CRM to
the FBI
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
(b) (5) AWP

The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 209
were referred
by CRM to
the FBI and
EOUSA
Document
Reference
Number
CRM 210
[email sweep]
[DOJ0006840]
CRM 211
[email sweep]
[DOJ0033559]
CRM 212
[email sweep]
Author(s)
Recipient(s)
[ ] (FBI)
[ ], [ ] PIN
Trial Atty.; [ ],
[ ] (AUSADC); [ ], [ ], [
], [ ] (FBI
[ ]@
hotmail.com
[ ] (FBI)
[ ]@live.com
[ ]@
hotmail.com
[ ]gmail.com
[]
lyris.greenspu
nmedia.com
[ ] PIN Trial
Atty.
[ ] (FBI)
[ ] PIN Trial
Atty.
[ ] (FBI)
[ ] PIN Trial
Atty.
[ ] (FBI)
[ ] (FBI);
[ ], [ ]
(AUSA-DC)
[ ] PIN Trial
Atty.; [ ]
Date(s)
August 17, 2010
April 5, 2010
February 12, 2010

Description
document references legal
strategy with respect to a subject
of the grand jury investigation,
[3-pages]
Email
DOCUMENT RETURN FROM
[ ].
public interest.
[3-pages]
Email
Status Update.
[3-pages]
Email
FOIA
Exemption
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Portions of
CRM 210
were referred
by CRM to
the FBI
(b)(3) Grand
Jury Material
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 211
were referred
by CRM to
the FBI
(b) (3)
(Grand Jury
Document
Reference
Number
[DOJ0033578]
[Duplicative of
CRM 207]
[DOJ----------]
Author(s)
Recipient(s)
Date(s)
(AUSA-DC);
[ ] FBI
[ ] PIN Trial
Atty.
[ ] (FBI); [ ],
[ ] (AUSADC); [ ] (FBI)
[ ] (FBI)
[ ] PIN Trial
Atty.; [ ]
(AUSA-DC);
[ ] FBI
CRM 213
[email sweep]
[DOJ0032310]
[ ] (FBI)
Jack Smith,
PIN Section
Chief
December 02,
2010
CRM 214
[email sweep]
[DOJ0007084]
[ ] PIN Trial
Atty.
[ ], [ ], [ ], [ ],
(FBI);
[ ] (USADC);
[ ] PIN Trial
Atty.
November 21,
2010

Description
FOIA
Exemption

INVESTIGATION
SCHEDULE and ENSIGN
INVESTIGATION
SCHEDULE.
(AWP). The document
document references grand jury
subpoenas, scheduled interviews
of both witnesses and a subject of
the grand jury investigation, and
[2-pages]
Email
[1-page]
Email
subject line: Re: Google Alert
John Ensign and [ ].
Material);
(b)(5)
(AWP)
WIF
RIP
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 212
were referred
by CRM to
the FBI
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
CRM 215
[EOUSA referral
to CRM]
[ ] (Ensign
Employee)
All
Employees
and Office
Personnel
(Ensign
Senate Office)
October 13, 2009
CRM 216
[EOUSA referral
to CRM]
Raymond
Hulser, PIN
Acting
Chief; [ ]
PIN Trial
Atty.
[ ], Esq.,
Senate Legal
Counsel
December 23,
2009
CRM 217(A) and

(B)
[EOUSA referral
to CRM]
Jack Smith,
PIN Section
Chief; [ ]
PIN Trial
Atty.
Senator [ ]
December 23,
2009
CRM 218(A) and

(B)
[EOUSA referral
to CRM]
Jack Smith,
PIN Section
Chief; [ ]
PIN Trial
Atty.
Senator [ ]
December 23,
2009

Description
FOIA
Exemption

[1-page]
redacted
under (b)(6)
and (b)(7)(C)
MEMORANDUM
Subject: Re: Important Notice
Regarding Document Retention
Procedures.
[1-page]
LTR (draft)
Subject: Re: Request for
Documents from the Office of
U.S. Senator John Ensign.
[2-pages]
LTR (signed) & LTR (draft)
Documents.
Revealing the names of DOJ
[2-pages; 2-pages]
Documents.
Portions of
CRM 214
were referred
by CRM to
the FBI
The name(s)
and personal
information
of private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
CRM 219(A) and

(B)
[EOUSA referral
to CRM]
Jack Smith,
PIN Section
Chief; [ ]
PIN Trial
Atty.
Senator [ ]
December 23,
2009
CRM 220(A) and

(B)
[EOUSA referral
to CRM]
Jack Smith,
PIN Section
Chief; [ ]
PIN Trial
Atty.
Senator [ ]
December 23,
2009
CRM 221
[EOUSA referral
to CRM]
Jack Smith,
PIN Section
Chief; [ ]
PIN Trial
Atty.
Senator [ ]
June 21, 2010
CRM 222
[EOUSA referral
to CRM]
Jack Smith,
PIN Section
Chief
Jack Smith,
PIN Section
Chief
June 8, 2010; June

03, 2010
Jack Smith,
PIN Section
Chief; [ ], [ ]
PIN Trial
Atty.(s);
Raymond

Description
FOIA
Exemption

[2-pages; 2-pages]
Documents.
[2-pages; 2-pages]
LTR (signed)
Documents.
[2-pages]
LTR (draft)
Documents from the Office of
U.S. Senator XX.
[2-pages]
Email
subject line: FW: ENSIGN
weekly mtg and ENSIGN
weekly mtg.
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
Hulser, PIN
Principal
Deputy Atty.
for Litigation
CRM 223
[EOUSA referral
to CRM]
CRM 224
[EOUSA referral
to CRM]
[ ] PIN Trial
Atty.
Trial Atty.
[ ] PIN Trial
Atty.
[ ] PIN Trial
Atty.
[ ] (AUSADC)
[ ], [ ] PIN
Trial Atty.
Google
Alerts
[ ] (AUSADC)
[ ] PIN Trial
Atty.
[ ] (AUSADC); [ ], [ ]
FBI;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ] FBI
Google
Alerts
[ ] PIN Trial
Atty.
August 03, 2010
March 18, 2010

Description
[1-page]
Email
subject line: Fw: Google Alert
Ensign, FW: Google Alert
Ensign and Google Alert
Ensign.
public interest.
[2-pages]
Email
subject line: Fw: Google Alert
john ensign, and Google Alert
john ensign.
public interest.
[2-pages]
FOIA
Exemption
The name(s)
and personal
information
of lowerlevel DOJ
employee(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Portions of
CRM 223
are deemed
nonresponsive
The name(s)
and personal
information
of lowerlevel DOJ
employee(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 224
are deemed
nonresponsive
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)

Description
FOIA
Exemption
CRM 225
[EOUSA referral
to CRM]
[ ] PIN Trial
Atty.
[ ] (AUSADC)
June 22, 2010
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation
[ ] (AUSADC); [ ], [ ]
PIN Trial
Atty.; Jack
Smith, PIN
Section Chief
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
[ ] (AUSADC)
[ ], [ ] PIN
Trial Atty.;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
Jack Smith,
PIN Section
Chief
Email
subject line: FW: Letter
requests, RE: Letter requests
and Letter requests.
(AWP). The document
document references the contents
of request letters sent to certain
U.S. Senators by DOJ seeking
evidence related to the Ensign
investigation, and release of such
information would
improperlydisclose the DOJ
[2-pages]
[ ] PIN Trial
Atty.
Ray Hulser,
PIN Principal
Deputy Atty.
for Litigation;
[ ] (AUSADC)
January 05, 2010
[ ] Private
Legal
Counsel; [ ]
(legal.senate)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
[ ] PIN Trial
Atty.
[ ] PIN Trial
Atty.
[ ] (AUSADC); [ ], [ ]
FBI
[ ], [ ] Private
Legal Counsel
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
[ ] PIN Trial
Atty.
Email
subject line: FW: Request for
Documents and Request for
Documents and attachment line:
Request for Documents from
Senator Ensign 1-5-2010.pdf.
[1-page]
Email
subject line: FW: Senator
Ensign, RE: Senator Ensign
and Senator Ensign.
CRM 226
[EOUSA referral
to CRM]
CRM 227
[EOUSA referral
to CRM]
February 19, 2010
WIF
RIP
Document
Reference
Number
Author(s)
Recipient(s)
[ ] Private
Legal
Counsel
[ ] PIN Trial
Atty.; [ ]
Private Legal
Counsel
[ ] PIN Trial
Atty.
[ ] (AUSADC)
[ ] FBI
[ ] PIN Trial
Atty.
[ ] FBI
[ ] PIN Trial
Atty.
CRM 229
[EOUSA referral
to CRM]
[ ] PIN Trial
Atty.
Trial Atty.
June 07, 2010
CRM 230
[EOUSA referral
to CRM]
[ ] PIN Trial
Atty.
FILE
May 26, 2011
CRM 228
[EOUSA referral
to CRM]
Date(s)
January 06, 2010;

December 07,
2009

Description
FOIA
Exemption

[2-pages]
Email
subject line: FW: SENATOR
ENSIGN INVESTIGATION
Possible Email Hosting
Companies, RE: SENATOR
Companies and SENATOR
Companies.
[2-pages]
Email
subject line: Proposed Final List
of Search Terms -6-7-2010 and
an attachment line: Proposed
Final List of Search Terms -6-72010.docx
[1-page; 10-page attachment]
Memorandum
references: Handling of
Materials Received from SSCE
related to Senator John Ensign.
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(3) (Grand
Jury
Material);
(b)(5)
(AWP)
RIP
Document
Reference
Number
CRM 231
[EOUSA referral
to CRM]
Author(s)
[ ] PIN
Paralegal
Recipient(s)
FILE
Date(s)
May 27, 2011

Description
(AWP). The document
of SSCE investigatory documents
obtained by DOJ, and release of
such information would
Page one of the Memorandum
CONFIDENTIAL [-]
ATTORNEY WORK
PRODUCT [-] CONTAINS 6(e)
MATERIAL.
[3-pages]
Memorandum
references:Receipt of Material
from the Senate Select Committee
on Ethics.
(AWP). The document
of SSCE investigatory documents
obtained by DOJ, and release of
such information would
FOIA
Exemption
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
CRM 232
[EOUSA referral
to CRM]
CRM 233
[EOUSA referral
to CRM]
Author(s)
Unidentified
DOJ attorney
and/or case
agent
Unidentified
DOJ attorney
and/or case
agent
Recipient(s)
Unknown
Unknown
Date(s)
Undated
Undated

Description
CONFIDENTIAL [-]
ATTORNEY WORK
PRODUCT [-] CONTAINS 6(e)
MATERIAL.
[3-pages]
Weekly Meeting Progress
Report week of September 7,
2010
contains a summary of the
governments investigative
strategy related to Ensign and
others.
(AWP). The document
document references documents
reviewed, witnesses interviewed,
grand jury information, etc., and
release of such information would
[2-pages]
Report week of September 7,
2010
contains a summary of the
governments investigative
strategy related to Ensign and
others.
FOIA
Exemption
(b)(3) (Grand
Jury
Material);
(b)(5)
(AWP)
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(3) (Grand
Jury
Material);
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
RIP
Document
Reference
Number
CRM 234 (A)

and (B)
[EOUSA referral
to CRM]
[email sweep];
[Clearwell];
[page 1925-1947
of 7508] (23pages)
[email sweep];
[Clearwell];
[page 1952-1963
of 7508] (12pages)
Author(s)
[ ], [ ], PIN
Trial
Atty.(s); [ ]
(USADC)
Recipient(s)
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ], PIN
Deputy Chief
Date(s)
June 24, 2011;

June 25,2011

Description
FOIA
Exemption
(AWP). The document

was compiled by DOJ atorney(s)
document references documents
reviewed, witnesses interviewed,
grand jury information, etc., and
release of such information would
Note: Page 1 of the Memorandum
[2-pages]
SUPPLEMENTAL
PROSECUTION
MEMORANDUM
Subject: Supplemental
Memorandum Regarding
Prosecution as to [ ] and former
U.S. Senator John Ensign.
supplemental prosecution memo
setting forth the detailed
reasoning behind DOJs decision
recommending the
former U.S. Senator John Ensign.
The document is a draft
instrument and it appears to be
incomplete.
(AWP). The document
to approve the prosecution of [ ]
and former U.S. Senator John
legal theories and factual
PIN attorney(s) and an AUSA
employee(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(3)
(Grand Jury
Material);
(b) (5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)

Description
Ensign and its release would
contains a list of the statutes and
details the evidence that may be
strategy.
The supplemental prosecution
memo, for example, includes
primary justifications for
indictment of [ ] and former U.S.
Senator John Ensign. Disclosure
ascertainable public interest. The
first page of the
SUPPLEMENTAL
PROSECUTION
MEMORANDUM has a banner
headline reading:
CONFIDENTIAL []
ATTORNEY WORK
MATERIAL.
[13-pages]
Excerpt from Supplemental
Memo 6-25-20011.doc. for
Printed Item: 3815 (Attachment
1 of 1)
appears to be an excerpt from the
supplemental prosecution memo
discussed above which sets forth
FOIA
Exemption
WIF
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)

Description
DOJs decision recommending
the prosecution/indictment of [ ]
Ensign. The document is a
draft instrument and it appears
to be incomplete.
(AWP). The document
legal theories and factual
PIN attorney(s) and an AUSA
contains a list of the statutes and
details the evidence that may be
strategy.
FOIA
Exemption
WIF
RIP
Document
Reference
Number
CRM 235
[EOUSA referral
to CRM]
Author(s)
Unidentified
DOJ attorney
and/or case
agent
Recipient(s)
Unknown
Date(s)
Created: 9/16/10

Description
public interest.
[12-pages]
CaseMap Objects Persons
Report
Subject: Case: Stars and Stripes
is a case-tracker software utilized
and designed to identify all
individuals involved in the Ensign
investigation. The document lists
the individual(s) name and their
role in the case, including
documents they may have
authored, documents received
from certain individual(s), etc.
(AWP). The document
factual information that was
compiled by DOJ attorney(s) and
case agent(s) during the
list of the individuals involved in
the investigation, their role and
references documents authored by
the individual(s), etc., and
FOIA
Exemption
WIF
(b) (5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
CRM 236
[EOUSA referral
to CRM]
CRM 237 (A), (B)
Author(s)
Unidentified
DOJ attorney
and/or case
agent
Unidentified
Recipient(s)
Unknown
Unknown
Date(s)
Undated
Undated

Description
[ 6-pages]
TIMELINE
Subject: The document is a
timeline of events related to the
affair involving Ensign.
consistent with something drafted
and created by a DOJ attorney
and/or case agent, and used as a
litigation tool. The document
Ensign.
(AWP). The document
related to the investigation of
case agents during the
detailed timeline of the affair
involving Ensign and would have
been a useful tool for a prosecutor
or investigator as a chronological
device or for summarizing key
events connected to the case, and
public interest.
[10-pages]
241033 Money
FOIA
Exemption
(b) (5)
(AWP)
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
& (b)(7)(C)
(b) (5)
RIP
Document
Reference
Number
Author(s)
and (C)
[EOUSA referral
to CRM]
DOJ attorney
and/or case
agent
Recipient(s)
Date(s)

Description
FOIA
Exemption
Subject: The document tracks

money and salary involving [ ]
and [ ].
litigation tool. The document
Ensign.
(AWP). The document
case agents during the
detailed timeline of the affair
involving Ensign and would have
been a useful tool for a prosecutor
or investigator as a chronological
device or for summarizing key
events connected to the case, and
public interest.
[2-pages]
(AWP)
[ ] and [ ]
Subject: The documents relate to
a subject [ ] and a witness [ ]
investigation.
Description: The documents are
litigation tool. The documents
Ensign.
(AWP). The document
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
& (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 238
[EOUSA referral
to CRM]
Author(s)
Unidentified
DOJ attorney
and/or case
agent
Recipient(s)
AAG
Date(s)
Undated

Description
case agent(s) during the
detailed description of
background information
pertaining to [ ], a subject and [ ],
a witness to the Ensign
investigation and the documents
would be useful tools for a
prosecutor or investigator
summarizing key facts about [ ] a
subject and [ ] a witness
connected to the Ensign
[2-pages]
Briefing for the AAG
(Stars & Stripes)
briefing prepared for the AAG
and overviews the Ensign
investigation.
and created by a DOJ attorney(s)
in preparation for briefing the
AAG about the status of the
Ensign.
(AWP). The document
compiled by DOJ attorney(s)
contains a detailed background of
the affair involving Ensign,
discusses potential criminal
charges and references grand jury
information, and revelation of that
strategy.
FOIA
Exemption
(b) (5)
(AWP)
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
& (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 239
[EOUSA referral
to CRM]
CRM 240
[EOUSA referral
to CRM]
Author(s)
Recipient(s)
Unidentified
DOJ attorney
and/or case
agent
Unidentified
DOJ attorney
and/or case
agent
Date(s)
Undated
DOJ
attorney(s)
and/or case
agent
(As of 1/29/2010)

Description
public interest.
[7-pages]
ENSIGN QUESTIONS
Subject: The document is a list
of interview/proffer questions
prepared for Ensign and which
pertain to the underlying
investigation.
and created by a DOJ attorney(s)
in anticipation of an interview
and/or proffer involving Ensign.
(AWP). The document
contains a detailed list of
questions prepared for Ensign
which relate to the underlying
investigation of Ensign and
others, and revelation of that
strategy.
public interest.
[3-pages]
To Do List Ensign
Investigation
working copy of a list of things or
tasks yet to be done, which was
created for use by attorneys and
agents during the Ensign
investigation.
consistent with something drafted/
created by DOJ attorney(s), which
references specific tasks that
FOIA
Exemption
(b) (5)
(AWP)
WIF
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
& (b)(7)(C)
(b) (5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
RIP
Document
Reference
Number
CRM 241
[EOUSA referral
to CRM]
Author(s)
Unidentified
DOJ attorney
and/or case
agent
Recipient(s)
DOJ
attorney(s)
and/or case
agent
Date(s)
(As of 3/12/2010)

Description
FOIA
Exemption
needed to be completed to keep

the investigation moving forward.
(AWP). The document constitutes
AWP because it was created in
anticipation of litigation related to
the investigation of Ensign. The
document contains factual
DOJ attorney(s) during the
detailed laundry list of tasks that
need to be completed by DOJ
attorney(s) and case agent(s)
involved in the investigation of
Ensign and others, and revelation
public interest.
[3-pages]
To Do List Ensign
Investigation
investigation.
(AWP). The document
have been
redacted
under (b)(6)
& (b)(7)(C)
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
& (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 242
[EOUSA referral
to CRM]
Author(s)
Unidentified
DOJ attorney
and/or case
agent
Recipient(s)
DOJ
attorney(s)
and/or case
agent
Date(s)
(As of 3/19/2010)

Description
contains a detailed laundry list of
tasks that need to be completed by
DOJ attorney(s) and case agent(s)
public interest.
[4-pages]
To Do List Ensign
Investigation
investigation.
(AWP). The document
FOIA
Exemption
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
& (b)(7)(C)
WIF
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
CRM 243(A), (B)

and (C)
[EOUSA referral
to CRM]
Unidentified
DOJ attorney
and/or case
agent
DOJ
attorney(s)
and/or case
agent
(As of 4/2/2010)
CRM 244
[EOUSA referral
to CRM]
Unidentified
DOJ attorney
and/or case
agent
DOJ
attorney(s)
and/or case
agent
(As of 5/14/2010)

Description
public interest.
[4-pages]
To Do List Ensign
Investigation
investigation.
(AWP). The document
public interest.
[5-pages; 5-pages; 6-pages]
To Do List Ensign
Investigation
FOIA
Exemption
(b)(5)
(AWP)
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
& (b)(7)(C)
(b)(5)
(AWP)
The name(s)
and personal
information
RIP
Document
Reference
Number
CRM 245
[EOUSA referral
to CRM]
Author(s)
Unidentified
DOJ attorney
and/or case
agent
Recipient(s)
DOJ
attorney(s)
and/or case
agent
Date(s)
(As of 5/24/2010)

Description
FOIA
Exemption

investigation.
(AWP). The document
public interest.
[5-pages]
To Do List Ensign
Investigation
investigation.
(AWP). The document
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
& (b)(7)(C)
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
& (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 246
[EOUSA referral
to CRM]
Author(s)
Unidentified
DOJ attorney
and/or case
agent
Recipient(s)
DOJ
attorney(s)
and/or case
agent
Date(s)
(As of 8/7/2010)

Description
public interest.
[7-pages]
To Do List Ensign
Investigation
investigation.
(AWP). The document
FOIA
Exemption
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
& (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 247
[EOUSA referral
to CRM]
Author(s)
Unidentified
DOJ attorney
and/or case
agent
Recipient(s)
DOJ
attorney(s)
and/or case
agent
Date(s)
(As of 9/3/2010)

Description
public interest.
[9-pages]
To Do List Ensign
Investigation
investigation.
(AWP). The document
detailed laundry list of tasks that
need to be completed by DOJ
attorney(s) and case agent(s)
improperly disclose the attorneys
legal strategy.
public interest.
[9-pages]
FOIA
Exemption
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
& (b)(7)(C)
WIF
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)

Description
FOIA
Exemption
CRM 248
[EOUSA referral
to CRM]
Unidentified
DOJ attorney
and/or case
agent
DOJ
attorney(s)
and/or case
agent
week of June 14,

2010
(b)(5)
(AWP)
Unidentified
DOJ attorney
and/or case
agent
DOJ
attorney(s)
and/or case
agent
week of June 21,

2010

Report
progress report created for the
and created by a DOJ attorney and
summarizes the investigative
strategy; what needs to be
accomplished; major investigative
steps; issues where supervisory
guidance is needed; issues
slowing down the investigation
and a proposed timetable for
investigative progress.
(AWP). The document
compiled by DOJ Attorney(s)
investigative progress, and
public interest.
[3-pages]
Report
CRM 249
[EOUSA referral
to CRM]
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
& (b)(7)(C)
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
RIP
Document
Reference
Number
CRM 250
[EOUSA referral
to CRM]
Author(s)
Unidentified
DOJ attorney
and/or case
agent
Recipient(s)
DOJ
attorney(s)
and/or case
agent
Date(s)
week of June 28,

2010

Description
FOIA
Exemption

(AWP). The document
public interest.
[3-pages]
Report
(AWP). The document
third party
individual(s)
have been
redacted
under (b)(6)
& (b)(7)(C)
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
& (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 251
[EOUSA referral
to CRM]
Author(s)
Unidentified
DOJ attorney
and/or case
agent
Recipient(s)
DOJ
attorney(s)
and/or case
agent
Date(s)
week of July 5,
2010

Description
public interest.
[3-pages]
Report
(AWP). The document
FOIA
Exemption
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
& (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 252
[EOUSA referral
to CRM]
Author(s)
Unidentified
DOJ attorney
and/or case
agent
Recipient(s)
DOJ
attorney(s)
and/or case
agent
Date(s)
week of July 12,

2010

Description
public interest.
[3-pages]
Report
(AWP). The document
FOIA
Exemption
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
& (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 253
[EOUSA referral
to CRM]
Author(s)
Unidentified
DOJ attorney
and/or case
agent
Recipient(s)
DOJ
attorney(s)
and/or case
agent
Date(s)
week of July 26,

2010

Description
public interest.
[3-pages]
Report
(AWP). The document
FOIA
Exemption
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
& (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 254
[EOUSA referral
to CRM]
CRM 255
[EOUSA referral
to CRM]
Author(s)
Recipient(s)
Date(s)
Unidentified
DOJ attorney
and/or case
agent
DOJ
attorney(s)
and/or case
agent
week of August 2,
2010
Unidentified
DOJ attorney
and/or case
agent
DOJ
attorney(s)
and/or case
agent
week of August 9,
2010

Description
public interest.
[3-pages]
Report
(AWP). The document
public interest.
[3-pages]
Report
FOIA
Exemption
(b)(5)
(AWP)
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
& (b)(7)(C)
(b)(5)
(AWP)
The name(s)
RIP
Document
Reference
Number
CRM 256
[EOUSA referral
to CRM]
Author(s)
Unidentified
DOJ attorney
and/or case
agent
Recipient(s)
DOJ
attorney(s)
and/or case
agent
Date(s)
week of
September 7, 2010

Description
FOIA
Exemption
or created by a DOJ attorney and
(AWP). The document
public interest.
[3-pages]
Report
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
& (b)(7)(C)
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
WIF
RIP
Document
Reference
Number
CRM 257
[EOUSA referral
to CRM]
Author(s)
Unidentified
DOJ attorney
and/or case
agent
Recipient(s)
DOJ
attorney(s)
and/or case
agent
Date(s)
week of July 19,

2010

Description
FOIA
Exemption

(AWP). The document
public interest.
[2-pages]
Report
(AWP). The document
under (b)(6)
& (b)(7)(C)
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
& (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 258
[EOUSA referral
to CRM]
Author(s)
[ ], PIN Trial
Attorney
Recipient(s)
DOJ
attorney(s)
and/or case
agent
Date(s)
Friday, October
29, 2010

Description
public interest.
[3-pages]
Stars and Stripes [-] 39 Facts
Linked To Object: [ ]
Subject: The document is an
(email) date/time, fact text and
source text tool.
summarizes the case evidence
which was obtained pursuant to
grand jury subpoena(s). The
document contains numerous
references to Ensign.
(AWP). The document
FOIA
Exemption
(b)(3)(Grand
Jury
Material);
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
& (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 259
[EOUSA referral
to CRM]
Author(s)
[ ], [ ], PIN
Trial Atty.(s)
Recipient(s)
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ], PIN
Deputy Chief;
[ ], [ ], [ ],
(AUSADC)
Date(s)
December 22,
2010

Description
public interest.
Each page of the document is
marked at the bottom:
Confidential Attorney Work
Product. Do Not Reproduce.
[8-pages]
PROSECUTION
MEMORANDUM
Subject: Memorandum
Ensign.
[ ], and declining the prosecution
of John Ensign.
(AWP). The document
and [ ], and declining the
compiled by PIN attorney(s) and
an AUSA during the investigation
of Ensign and others and its
document contains a list of the
statutes and details the evidence
that may be used in any possible
FOIA
Exemption
WIF
(b)(3)
(Grand Jury
Material);
(b) (5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
CRM 260
[EOUSA referral
to CRM]
Author(s)
[ ], [ ], PIN
Trial
Atty.(s);
[ ], [ ],
(AUSADC)
Recipient(s)
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ], PIN
Deputy Chief;
[ ],
(AUSADC)
Date(s)
December 23,
2010

Description
compiled to assist DOJ policymakers in reaching a decision as
to whether or not to prosecute
Ensign and others, because it
that decision. The pros memo, for
indictment of [ ] and [ ], and the
non-prosecution of Ensign.
prosecutions.
Page one of the
SUPPLEMENTAL
PROSECUTION
banner reading:
CONFIDENTIAL []
ATTORNEY WORK
MATERIAL
[54-pages]
PROSECUTION
MEMORANDUM
Subject: Memorandum
Ensign.
of John Ensign.
(AWP). The document
FOIA
Exemption
WIF
(b)(3)
(Grand Jury
Material);
(b) (5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)

Description
FOIA
Exemption
prosecutions.
Page one of the
SUPPLEMENTAL
PROSECUTION
banner reading:
under (b)(6)
and (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 261
[EOUSA referral
to CRM]
Author(s)
[ ], [ ], PIN
Trial Atty.(s)
Recipient(s)
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principal
Deputy Atty.
for Litigation;
[ ], PIN
Deputy Chief;
[ ], [ ], [ ],
(AUSADC)
Date(s)
January 7, 2011

Description
CONFIDENTIAL []
ATTORNEY WORK
MATERIAL
[50-pages]
REVISED PROSECUTION
MEMORANDUM
Subject: Revised Memorandum
Ensign.
of John Ensign.
(AWP). The document
FOIA
Exemption
WIF
(b)(3)
(Grand Jury
Material);
(b) (5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
CRM 262 (A),

(B), (C), (D), (E),
(F), (G), (H) and
(I)
[EOUSA referral
to CRM]
[email sweep]
[Clearwell];
[pages 1573-1588
of 7508] (16pages)
[email sweep]
[Clearwell];
[pages 1591-1606
of 7508] (16pages)
[email sweep]
[Clearwell];
[pages 1626-1643
of 7508] (18pages)
[email sweep]
[Clearwell];
[pages 1645-1662
of 7508] (18pages)
[email sweep]
[Clearwell];
[pages 1664-1681
of 7508] (18pages)
Author(s)
Unidentified
DOJ attorney
and/or case
agent
Recipient(s)
DOJ
attorney(s)
and/or case
agent
Date(s)
Undated

Description
prosecutions.
Page one of the
SUPPLEMENTAL
PROSECUTION
banner reading:
CONFIDENTIAL []
ATTORNEY WORK
MATERIAL
[57-pages]
[ ] Corroborating/Contradicting
Sheet
corroborating/contradictory
evidence sheet, which was created
for use during the Ensign
investigation.
and/or created by a DOJ attorney
which references
corroborating/contradictory
evidence.
(AWP). The document
references corroborating and/or
contradictory evidence pertaining
to Ensign and others, and
FOIA
Exemption
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
& (b)(7)(C)
WIF
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
FOIA
Exemption
WIF
(b) (5)
(AWP) and
(b)(5) (DPP)

public interest.
[17-pages]
[email sweep]
[Clearwell];
[pages 1784-1801
of 7508] (18pages)
[email sweep]
[Clearwell];
[pages 1529-1543
of 7508] (15pages)
[email sweep]
[Clearwell];
[pages 1546-1560
of 7508] (15pages)
CRM 263
[EOUSA referral
to CRM]

Description
Unidentified
DOJ
attorney/
case agent
Undated
AFFIDAVIT IS SUPPORT OF
AN APPLICATION FOR A
SEARCH WARRANT;
ATTACHMENT A;
ATTACHMENT B AND
CERTIFICATE OF
AUTHENTICITY OF
DOMESTIC BUSINESS
RECORDS PURSUANT TO
FEDERAL RULE OF
EVIDENCE 902(11)
Subject: IN THE MATTER OF
THE SEARCH OF
INFORMATION ASSOCIATED
WITH FREDSCHWARTZ72@
[ ].COM THAT IS STORE AT
PREMISES CONTROLLED BY
[]
draft/unsigned search warrant
with attachments for one of
Ensigns email accounts. The
document itself appears to be
incomplete in format with many
gaps in the text.
(AWP). The document
and is based upon information
obtained by DOJ attorney(s)
and/or case agent(s) during the
and others, and its release would
contains references to information
obtained during the course of a
criminal investigation and which
criminal prosecution and
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 263
are deemed
nonresponsive
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
CRM 264 (A),

(B), (C), (D), (E),
(F) and (G)
[EOUSA
referral to CRM]
Jack Smith,
PIN Section
Chief; [ ]
PIN Trial
Atty.
Senator [ ];
Senator [ ];
Senator [ ];
Senator [ ];
Senator [ ];
Senator [ ];
Senator [ ]
June 22, 2010
CRM 265
[EOUSA referral
to CRM]
Jack Smith,
PIN Section
Chief; [ ]
PIN Trial
Atty.
Senator [ ]
June 22, 2010

Description
that decision. The search warrant,
primary justification (probable
cause) for searching of an Ensign
email account. Disclosure of this
criminal prosecutions.
Page one of the
SUPPLEMENTAL
PROSECUTION
banner reading:
CONFIDENTIAL []
ATTORNEY WORK
MATERIAL
[16-pages]
LTR (drafts)
Documents
[3-pages;2-pages; 3-pages; 3pages; 3-pages; 3-pages]
LTR (draft)
Documents
FOIA
Exemption
WIF
RIP
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
CRM 266
[EOUSA referral
to CRM]
Jack Smith,
PIN Section
Chief; [ ]
PIN Trial
Atty.
Senator [ ]
June 22, 2010
CRM 267
[EOUSA referral
to CRM]
Jack Smith,
PIN Section
Chief; [ ]
PIN Trial
Atty.
Senator [ ]
June 22, 2010
CRM 268
[EOUSA referral
to CRM]
Jack Smith,
PIN Section
Chief; [ ]
PIN Trial
Atty.
Senator [ ]
June 22, 2010
CRM 269
[EOUSA referral
to CRM]
Jack Smith,
PIN Section
Chief; [ ]
PIN Trial
Atty.
Senator [ ]
June 22, 2010

Description
FOIA
Exemption

[2-pages]
LTR (draft)
Documents
[2-pages]
LTR (draft)
Documents
[3-pages]
LTR (draft)
Documents
[3-pages]
LTR (draft)
Documents
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
CRM 270
[EOUSA referral
to CRM]
Jack Smith,
PIN Section
Chief; [ ]
PIN Trial
Atty.
Senator [ ]
June 22, 2010
CRM 271
[EOUSA referral
to CRM]
Jack Smith,
PIN Section
Chief; [ ]
PIN Trial
Atty.
Senator [ ]
June 22, 2010
CRM 272 (A)

and (B)
[EOUSA referral
to CRM]
Jack Smith,
PIN Section
Chief; [ ]
PIN Trial
Atty.
Senator [ ]
June 23, 2010

Description
FOIA
Exemption

[2-pages]
LTR (draft)
Documents
[2-pages]
LTR (draft)
Documents
[2-pages]
LTR (draft)
Documents
[2-pages]
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
LTR (final) (signed)

Documents
WIF
RIP
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
Document
Reference
Number
CRM 273 (A)

and (B)
[EOUSA referral
to CRM]
CRM 274 (A)

and (B)
[EOUSA referral
to CRM]
Author(s)
Jack Smith,
PIN Section
Chief; [ ]
PIN Trial
Atty.
Jack Smith,
PIN Section
Chief; [ ]
PIN Trial
Atty.
Recipient(s)
Senator [ ]
Senator [ ]
Date(s)
June 23, 2010
June 23, 2010

Description
[2-pages]
LTR (draft)
Documents
[3-pages]
Documents
[2-pages]
LTR (draft)
Documents
[3-pages]
Documents
FOIA
Exemption
WIF
RIP
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
Document
Reference
Number
CRM 275 (A)

and (B)
[EOUSA referral
to CRM]
CRM 276 (A)

and (B)
[EOUSA referral
to CRM]
Author(s)
Jack Smith,
PIN Section
Chief; [ ]
PIN Trial
Atty.
Jack Smith,
PIN Section
Chief; [ ]
PIN Trial
Atty.
Recipient(s)
Senator [ ]
Senator [ ]
Date(s)
June 23, 2010
June 23, 2010

Description
[2-pages]
LTR (draft)
Documents
[2-pages]
Documents
[2-pages]
LTR (draft)
Documents
[2-pages]
Documents
FOIA
Exemption
WIF
RIP
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
Document
Reference
Number
CRM 277 (A)

and (B)
[EOUSA referral
to CRM]
CRM 278 (A)

and (B)
[EOUSA referral
to CRM]
Author(s)
Jack Smith,
PIN Section
Chief; [ ]
PIN Trial
Atty.
Jack Smith,
PIN Section
Chief; [ ]
PIN Trial
Atty.
Recipient(s)
Senator [ ]
Senator [ ]
Date(s)
June 23, 2010
June 23, 2010

Description
[2-pages]
LTR (draft)
Documents
[2-pages]
Documents
[2-pages]
LTR (draft)
Documents
[3-pages]
Documents
FOIA
Exemption
WIF
RIP
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
CRM 279
[EOUSA referral
to CRM]
Jack Smith,
PIN Section
Chief; [ ]
PIN Trial
Atty.
Senator [ ]
June 21, 2010
CRM 280
[EOUSA referral
to CRM]
Jack Smith,
PIN Section
Chief; [ ]
PIN Trial
Atty.
[ ], [ ] SSCE
Undated
[ ], [ ], SSCE
Jack Smith,
PIN Section
Chief
CRM 281
[EOUSA referral
to CRM]
April 19, 2011

Description
[2-pages]
LTR (draft)
Documents
[2-pages]
LTR (draft) (unsigned)
Subject: DOJ draft response letter
to SSCE re: letters dated February
24, 2011 and April 19, 2011.
(AWP). The document
[2-pages]
LTR
Subject: The letter relates to a
DOJ request that the SSCE defer
immunization of a witness.
FOIA
Exemption
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(5)
(AWP)
RIP
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of private
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
CRM 282
[EOUSA referral
to CRM]
[ ], SSCE
[ ] PIN Trial
Atty.
April 8, 2011
CRM 283
[EOUSA referral
to CRM]
[ ] Private
Legal
Counsel
Honorable
Barbara
Boxer,
Chairman and
Honorable
Johnny
Isakson, Vice
Chairman
May 28, 2010
CRM 284
[EOUSA referral
to CRM]
May 27, 2010

Description
FOIA
Exemption

public interest.
[2-pages]
LTR and Attachment
Subject: The letter responds to a
DOJ inquiry re: authority of DOJ
to produce to a defendant records
that were produced to DOJ from
various Senate offices. The
attachment is a part of the
Congressional Record Senate,
dated April 7, 2011 and is
releasable in full.
public interest.
[2-pages]
LTR
Subject: Re: Senator John
Ensigns Responses to the
Committees Third Supplemental
Request for Information. The
document also references the
enclosure of the Affidavit of
Senator John Ensign.
public interest.
[(LTR) 1-page;(AFFIDAVIT OF
JOHN ENSIGN) 3-pages, see
also CRM 284 below]
AFFIDAVIT OF JOHN
ENSIGN
Subject: Affidavit of Ensign in
response to questions from the
SSCE posed by letter dated May
21, 2010.
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
CRM 285
[EOUSA referral
to CRM]
April 30, 2010
CRM 286
[EOUSA referral
to CRM]
January 25, 2010
CRM 287
[EOUSA referral
to CRM]
See also:
CRM 70
[PIN Bankers
Box No. 4]
[EOUSA referral
to CRM]
[ ], SSCE
Raymond
Hulser, PIN
Principle
Deputy for
Litigation;
Jack Smith,
PIN Section
Chief
May 24, 2011

Description
public interest.
[3-pages]
Computer Forensic Technical
Report; Case: 20100105-001
Subject: Prepared by the
Information Technology Security
Branch, Office of the Assistant
Sergeant at Arms and Chief
Information Officer. The
document contains multiple
public interest.
[9-pages]
Computer Forensic Technical
Report ; Case: 20100105-001
Subject: Prepared by the
Information Technology Security
Branch, Office of the Assistant
Sergeant at Arms and Chief
Information Officer. The
document contains multiple
public interest.
[9-pages]
LTR and Attachment
[Inventory of the Ensign
Investigative materials]
Subject: The letter is SSCE
response to DOJs request for a
complete inventory of all SSCE
investigative materials concerning
Ensign.
Description: This is an SSCE
created document which consists
of a list of depositions,
memoranda of interviews,
document binders and [ ] taint
files.
asis for Withholding: (b)(6) and
(b)(7)(C). The document is being
FOIA
Exemption
WIF
RIP
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Document
Reference
Number
CRM 288 (A)

and (B)
[EOUSA referral
to CRM]
Author(s)
Unidentified
DOJ attorney
Recipient(s)
Date(s)
October 18, 2010;

October 18, 2010

Description
withheld in part to protect the
public interest.
[1-page; 3-pages]
DRAFT MEMORANDUM
Subject: [ ] Potential Liability as
an Aider and Abettor or Coconspirator.
(AWP). The document
that decision. The draft
memorandum, for example,
subjective legal analysis,
regarding the criminal liability of
an subject related to the Ensign
FOIA
Exemption
WIF
(b) (5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 288
are deemed
nonresponsive
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)

Description
[10-pages]
DRAFT MEMORANDUM
Subject: [ ] Potential Liability as
an Aider and Abettor or Coconspirator.
(AWP). The document
that decision. The draft
memorandum, for example,
subjective legal analysis,
regarding the criminal liability of
an subject related to the Ensign
FOIA
Exemption
WIF
RIP
Document
Reference
Number
CRM 289 (A)

and (B)
[EOUSA referral
to CRM]
Author(s)
Unidentified
DOJ attorney
Recipient(s)
Date(s)
Undated

Description
[14-pages]
[ ] Outline
of an outline of questions or
topics to be covered with a
witness. The document appears to
have been created for use during a
proffer session with a
subject/witness during the Ensign
investigation.
(AWP). The document
public interest.
[18-pages]
[ ] Outline
of an outline of questions or
topics to be covered with a
witness. The document appears to
have been created for use during a
proffer session with a
subject/witness during the Ensign
investigation.
(AWP). The document
FOIA
Exemption
(b) (5)
(AWP)
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 290
[EOUSA referral
to CRM]
Author(s)
[ ] (CRM)
attorney
Recipient(s)
Lanny
Breuer, AAG;
Paul OBrien,
Director, OEO
Date(s)
June 17, 2011

Description
public interest.
[25-pages]
MEMORANDUM
memo involving a witness
immunity request.
(AWP). The document
that decision. The memorandum,
information and subjective legal
FOIA
Exemption
WIF
(b) (5)
(AWP) and
(b)(5) (DPP)
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
CRM 291
[EOUSA referral
to CRM]
[ ], SSCE
[ ], PIN Trial
Attorney
July 16, 2010
CRM 292
[EOUSA referral
to CRM]
[ ], SSCE
[ ], PIN Trial
Attorney
July 12, 2010

Description
analysis, regarding the criminal
liability of an subject related to
prosecutions.
public interest.
[3-pages]
LTR and Attachments
Subject: The document is a letter
and attachments written on behalf
of [ ], a U.S. Senator to [ ], PIN
Trial Attorney in reference to
request dated June 23, 2010, for
certain records related to pending
[Ensign] investigation.
[LTR, 1-page; Attachment, 10pages]
LTR and Attachments
Subject: The document is a letter
and attachments written on behalf
of [ ], a U.S. Senator to [ ], PIN
Trial Attorney in reference to
request dated June 23, 2010, for
certain records related to pending
[Ensign] investigation.
[LTR, 1-page; Attachment, 14-
FOIA
Exemption
WIF
RIP
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s)
have been
redacted
under (b)(6)
and (b)(7)(C)
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
CRM 293 (A),

(B), (C) and (D)
Unidentified
DOJ attorney
DOJ
attorney(s)
and/or case
agent
Undated
DOJ
attorney(s)
and/or case
agent
Undated
[email sweep]
[Clearwell];
[pages 1683-1731
of 7508];
(49-pages)
[email sweep]
[Clearwell];
[pages 1734-1782
of 7508];
(49-pages)
[email sweep]
[Clearwell];
[pages 1821-1869
of 7508];
(49-pages)
[email sweep]
[Clearwell];
[pages 1872-1920
of 7508];
(49-pages)
CRM 294
[email sweep]
[Clearwell];
[pages 1133-1134
of 7508];
(2-pages)
Unidentified
DOJ attorney

Description
pages]
Deposition Spreadsheets
spreadsheet of witness
testimony, persons who were
deposed during the SSCE
investigation. The document was
drafted/ created by DOJ
attorney(s) as a litigation tool to
aid them in analyzing the prior
testimony of each witness as it
investigation.
consistent with a litigation tool
drafted and/or created by a DOJ
attorney(s), which references the
deposition testimony of various
witnesses involved in the Ensign
investigation.
(AWP). The document
compiled and sorted by DOJ
attorney(s) during the
example, the document references
the testimony of various
witness(es), including both
inculpatory and exculpatory
evidence, which relates to Ensign
and others, and revelation of that
strategy.
public interest.
[49-pages]
Deposition Spreadsheets
spreadsheet of witness
testimony, persons who were
deposed during the SSCE
investigation. The document was
drafted/ created by DOJ
attorney(s) as a litigation tool to
FOIA
Exemption
(b)(5)
(AWP)
WIF
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
& (b)(7)(C)
(b)(5)
(AWP)
The name(s)
and personal
information
of private
third party
individual(s)
have been
RIP
Document
Reference
Number
CRM 295
[email sweep]
[Clearwell];
[pages 1124-1126
of 7508];
(3-pages)
email sweep]
[Clearwell];
[pages 1072-1074
of 7508];
(3-pages)
Author(s)
Recipient(s)
[ ] PIN Trial
Atty.
[ ] PIN Trial
Atty.
Jack Smith,
PIN Section
Chief
[ ] PIN Trial
Atty.;
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation;
[ ] PIN Trial
Atty.
Date(s)
June 06, 2011;

June 02, 2011

Description
FOIA
Exemption

investigation.
drafted and/or created by a DOJ
investigation.
(AWP). The document
the testimony of various
witness(es), including both
inculpatory and exculpatory
strategy.
public interest.
[2-pages]
Email
subject line: FW: ENSIGN and
ENSIGN. The emails discuss a
chronological framework for DOJ
investigation of Ensign.
(AWP). The document
redacted
under (b)(6)
& (b)(7)(C)
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 296
[email sweep]
Author(s)
[ ] PIN Legal
Intern
Recipient(s)
Misc.
Unidentified
DOJ Atty.(s)
Date(s)

Description
the review and information
organization of the evidence,
analysis of the evidence, answers
and conclusions, and revelation of
[3-pages]
Summarized Deposition List;
[ ] Corroborating/Contradictory
Sheet
Subject: The documents consist
of a Summarized Deposition
List and [ ]
Corroborating/Contradictory
Sheet of prior testimony of
witnesses related to the
investigation who were deposed
during the SSCE investigation.
The document was drafted/
created by a PIN legal intern at
the direction of DOJ attorney(s),
to be used as a litigation tool to
investigation.
drafted and/or created by a PIN
legal intern at the direction of PIN
investigation.
(AWP). The document
compiled and sorted by a PIN
legal intern for DOJ attorney(s)
during their investigation and
references the testimony of
FOIA
Exemption
(b)(5)
(AWP)
The name(s)
and personal
information
of private
third party
individual(s)
have been
redacted
under (b)(6)
& (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 297
[email sweep]
CRM 298
[email sweep]
Author(s)
[ ] PIN Trial
Atty.
Recipient(s)
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation;
[ ] PIN Trial
Atty.; [ ] PIN
Deputy Chief
Jack Smith,
PIN Section
Chief
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation;
[ ], [ ] PIN
Trial Atty.;
[ ] PIN
Deputy Chief
Raymond
Hulser, PIN
Principle
Deputy
Chief for
Litigation
Jack Smith,
PIN Section
Chief; [ ], [ ]
PIN Trial
Atty.;
[ ] PIN
Deputy Chief
Jack Smith,
PIN Section
Chief
[ ], [ ] PIN
Trial Atty.;
[ ] PIN
Deputy Chief;
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation
[ ] PIN Trial
Atty.
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Date(s)
December 23,
2010
December 01,
2010

Description
various witness(es), including
both inculpatory and exculpatory
strategy.
public interest.
[76-pages; 17-pages; 68-pages;
49-pages; 15-pages; 16-pages; 17pages; 49-pages and 17-pages]
Email
subject line: Re: Final Pros
Memo. The emails discuss
proposed revisions to the Final
Pros Memo.
(AWP). The document
proposed revisions to the final
prosecution memorandum and
[1-page]
Email
subject line: Ensign. The email
discusses the evidence relative to
FOIA
Exemption
(b)(5)
(AWP)
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(5)
(AWP)
The name(s)
and personal
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
Principle
Deputy Chief
for Litigation;
[ ] PIN Trial
Atty.
CRM 299
[email sweep]
[ ] PIN Trial
Atty.
[ ] PIN Trial
Atty.
[ ] PIN Trial
Atty.
[ ] PIN Trial
Atty.
[ ] PIN Trial
Atty.
[ ] PIN Trial
Atty.
[ ] PIN Trial
Atty.
[ ] PIN Trial
Atty.
January 04, 2011

Description
FOIA
Exemption
subjects of the underlying

criminal investigation.
(AWP). The document
the evidence relative to the
criminal investigation and would
[1-page]
Email
subject line: RE: quote from
Shear and quote from Shear.
The email discusses Shear and
other legal decisions insofar as
they relate to criminal liability of
subjects to the investigation.
(AWP). The document
Shear and other legal decisions
insofar as they relate to criminal
liability of subjects to the
investigation, and would
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 300
[email sweep]
CRM 301
[email sweep]
Author(s)
[ ] PIN Trial
Atty.
[ ] PIN Trial
Atty.
Recipient(s)
[ ] PIN Trial
Atty.; [ ]
(AUSA-DC)
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation;
Date(s)
January 06, 2011
January 07, 2011

Description
[3-pages]
Email
subject line: Revised pros
memo and attachments line:
REVISED PROS MEMO
v9.wpd. The email discusses the
relative criminal liability of
investigation.
(AWP). The document
[1-page]
Email
subject line: [ ] / [ ] Revised
pros memo and draft indictment
and an attachment line:
REVISED PROS MEMO v.9.
wpd; [ ] _[ ] _indictment.wpd.
FOIA
Exemption
(b)(5)
(AWP)
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
[ ] PIN
Deputy Chief;
[ ], [ ] PIN
Trial Atty.
CRM 302
[Email sweep]
[ ] PIN Trial
Atty.
[ ] PIN Trial
Atty.
[ ] PIN Trial
Atty.
[ ] PIN Trial
Atty.
[ ] PIN Trial
Atty.
[ ] PIN Trial
Atty.
[ ] PIN Trial
Atty.
[ ], [ ] PIN
Trial Atty.
October 27, 2010

Description
FOIA
Exemption
The email discusses the relative

criminal liability of subjects of the
underlying investigation.
(AWP). The document
[1-page]
Email
subject line: Re: Aiding and
Abetting and Conspiracy
Research, RE: Aiding and
Research and Aiding and
Research. The email discusses
the crimes of conspiracy, aiding
and abetting, insofar as they relate
to potential criminal liability of
subjects to the investigation.
(AWP). The document
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 303
[email sweep]
CRM 304
[email sweep]
Author(s)
Recipient(s)
[ ] PIN Trial
Atty.
[ ] PIN Trial
Atty.
[ ] (AUSADC)
[ ] PIN Trial
Atty.
[ ] PIN Trial
Atty.
[ ] PIN Trial
Atty.; [ ]
(AUSA-DC)
Raymond
Hulser, PIN
Principle
Deputy
[ ] OEOPSEU Atty.;
[ ] Section
Chief OEO-
Date(s)
September 30,
2010
March 17, 2011;

March 16, 2011

Description
example, the emails reference
Shear, as well as other decisions
insofar as they relate to criminal
liability of subjects to the
[3-pages]
Email
subject line: Fw: Very rough
draft pros memo and Very
rough draft pros memo. The
emails discuss proposed revisions
to a draft prosecution
memorandum.
(AWP). The document
proposed revisions to the draft
prosecution memorandum and
[1-page]
Email
subject line: RE: Another
FOIA
Exemption
(b)(5)
(AWP)
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(5)
(AWP)
The name(s)
RIP
Document
Reference
Number
CRM 305
[email sweep]
Author(s)
Recipient(s)
Chief for
Litigation
PSEU
[ ] OEOPSEU Atty.
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation;
[ ] Section
Chief OEOPSEU
[ ] OEOPSEU Atty.
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation
Raymond
Hulser, PIN
Principle
Deputy
Chief for
Litigation
Paul OBrien,
DAAG; [ ]
OEO-PSEU
Atty.; [ ]
Section Chief
OEO-PSEU
Paul
OBrien,
DAAG
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation;
[ ] OEOPSEU Atty.;
[ ] Section
Chief OEOPSEU
Raymond
Hulser, PIN
Principle
Deputy
Chief for
Litigation
Paul OBrien,
DAAG; [ ]
OEO-PSEU
Atty.
[ ] (SMO)
Mythili
Raman,
DAAG;
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation;
Jack Smith,
PIN Section
Chief;
[ ] (OLA)
(SMO); Ron
Weich,
DAAG; [ ]
(SMO); [ ]
(ODAG)
[ ] (Legal)
(U.S. Senate)
[ ] (AUSAEDVA)
[ ] (SMO)
Raymond
Hulser, PIN
Principle
Date(s)
March 04, 2011

Description
FOIA
Exemption
immunity notice re [ ]. The

emails discuss a proposed
immunity notice related to the
(AWP). The document
example, the emails reference a
proposed immunity notice and
[2-pages]
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
Email
(b)(5)
(AWP)
WIF
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
Deputy Chief
for Litigation
CRM 306
[email sweep]
Raymond
Hulser, PIN
Principle
Deputy
Chief for
Litigation
[ ] (AUSAEDVA)
[ ] (AUSAEDVA)
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation
Raymond
Hulser, PIN
Principle
Deputy
Chief for
Litigation
[ ] (AUSAEDVA)
[ ] (AUSAEDVA)
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation
[ ] (AUSAEDVA)
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation
Raymond
Hulser, PIN
Principle
Deputy
Chief for
Litigation
[ ] (AUSADC)
[ ] (AUSAEDVA)
[ ] PIN Trial
Atty.
June 01, 2010

Description
FOIA
Exemption
subject line: RE: do you have the

Ensign FEC opinion? and do
you have the Ensign FEC
opinion? The emails discuss
several FEC cases including
Ensign as they relate to the
(AWP). The document
several FEC cases including
Ensign as they relate to the
criminal investigation, and would
[2-pages]
Email
subject line: revised. The email
discusses the relative criminal
liability of a subject of the
(AWP). The document
evidence relative to a subject of
the underlying criminal
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 307
[email sweep]
CRM 308
[email sweep]
Author(s)
Recipient(s)
Raymond
Hulser, PIN
Principle
Deputy
Chief for
Litigation
[ ], [ ] PIN
Trial Atty.
Raymond
Hulser, PIN
Principle
Deputy
Chief for
Litigation
Mary Patrice
Brown
(DAAG)
Date(s)
June 01, 2010
February 16, 2011

Description
[1-page]
Email
subject line: FW: Follow up
from [ ] re: [ ] + [ ]. The email
discusses the issue of immunity
with respect to subjects of the
(AWP). The document
immunity with respect to subjects
of the underlying criminal
investigation and would
[3-pages]
Email
subject line: RE: Ensign
meeting and Ensign meeting.
The email discusses legal theory
with respect to the subjects of the
FOIA
Exemption
(b)(5)
(AWP)
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
RIP
Document
Reference
Number
CRM 309
[email sweep]
Author(s)
Recipient(s)
Raymond
Hulser, PIN
Principle
Deputy
Chief for
Litigation
Jack Smith,
PIN Section
Chief
Jack Smith,
PIN Section
Chief
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation
Raymond
Hulser, PIN
Principle
Deputy
Chief for
Litigation
Jack Smith,
PIN Section
Chief
Jack Smith,
PIN Section
Chief
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation
Raymond
Hulser, PIN
Principle
Deputy
Chief for
Litigation
Jack Smith,
PIN Section
Chief
Date(s)
February 16, 2011

Description
FOIA
Exemption

(AWP). The document
legal theory with respect to
[1-page]
Email
subject line: RE: Ensign and
Ensign. The email discusses
legal theory with respect to the
investigation.
(AWP). The document
legal theory with respect to
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP
Document
Reference
Number
CRM 310
[email sweep]
Author(s)
Recipient(s)
Jack Smith,
PIN Section
Chief
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation;
[ ], [ ] PIN
Trial Atty.
Raymond
Hulser, PIN
Principle
Deputy
Chief for
Litigation
Jack Smith,
PIN Section
Chief; [ ], [ ]
PIN Trial
Atty.
[ ] PIN Trial
Atty.
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation;
[ ] PIN Trial
Atty.
Raymond
Hulser, PIN
Principle
Deputy
Chief for
Litigation
Jack Smith,
PIN Section
Chief; [ ] PIN
Trial Atty.
Jack Smith,
PIN Section
Chief
[ ] PIN Trial
Atty.;
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation
Jack Smith,
PIN Section
Chief
Mary Patrice
Brown
(DAAG);
Mythilia
Raman
(DAAG);
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation;
[ ], [ ] PIN
Trial Atty.
Mary Patrice
Brown
(DAAG)
Mythilia
Raman
(DAAG);
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation;
Jack Smith,
PIN Section
Date(s)

Description
FOIA
Exemption
WIF

[1-page]
February 17, 2011
Email
subject line: RE: Revised and
Revised. The email discusses
legal theory regarding a subject of
the underlying investigation.
(AWP). The document
legal theory involving a subject
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
CRM 311
[email sweep]
CRM 312
[email sweep]
Author(s)
Recipient(s)
Raymond
Hulser, PIN
Principle
Deputy
Chief for
Litigation
Chief;
[ ] PIN Trial
Atty.
Mythilia
Raman
(DAAG);
Matthew
Axelrod
(DAAG)
Mythilia
Raman
(DAAG)
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation;
Matthew
Axelrod
(DAAG)
Raymond
Hulser, PIN
Principle
Deputy
Chief for
Litigation
Mythilia
Raman
(DAAG);
Matthew
Axelrod
(DAAG)
Mythilia
Raman
(DAAG)
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation;
Matthew
Axelrod
(DAAG)
[ ] (CRM)
Mythili
Raman
(DAAG); [ ]
(JMD)
Date(s)

Description
FOIA
Exemption
WIF

[1-page]
November 02,
2009
March 11, 2010;

March 10, 2010
Email
Ensign. The email discusses
legal theory regarding a subject of
(AWP). The document
legal theory involving a subject
[1-page]
Email
subject line: RE: Ensign
Request for AAG Breuer to
participate in the matter. The
email discusses legal theory
regarding subjects of the
(AWP). The document
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
CRM 313
[email sweep]
CRM 314
[email sweep]
Author(s)
Recipient(s)
Mythilia
Raman
(DAAG)
[ ] (CRM); [ ]
(JMD)
[ ] (JMD)
[ ] (CRM);
Mythilia
Raman
(DAAG)
[ ] (CRM)
[ ] (JMD);
Mythilia
Raman
(DAAG)
[ ] (JMD)
[ ] (CRM);
Mythilia
Raman
(DAAG)
Mythilia
Raman
(DAAG)
Raymond
Hulser, PIN
Principle
Deputy
Chief for
Litigation
[ ] (JMD); [ ]
(CRM)
Patty
Stemler,
ChiefAppellate
Section
Mary Patrice
Brown
(DAAG);
Mythilia
Raman
(DAAG); Jack
Smith, PIN
Section Chief;
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation;
[ ] (CRM)
Mary Patrice
Brown
(DAAG)
Patty Stemler,
ChiefAppellate
Section;
Mythilia
Raman
(DAAG); Jack
Smith, PIN
Section Chief;
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation
Raymond
Hulser, PIN
Mary Patrice
Brown
[ ] PIN Trial
Atty.
Date(s)

Description
FOIA
Exemption
WIF

legal theory involving subjects of
[2-pages]
January 25, 2011
February 16, 2011
Email
subject line: FW: Aiding and
Abetting a 207 violation. The
email discusses legal theory
regarding subjects of the
(AWP). The document
legal theory involving subjects of
[2-pages]
Email
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(5)
(AWP)
RIP
Document
Reference
Number
CRM 315
[email sweep]
Author(s)
Recipient(s)
Principle
Deputy
Chief for
Litigation
(DAAG)
[ ] PIN
Admin
employee
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation;
[ ] PIN Admin
employee
Date(s)
May 18, 2010

Description
subject line: Ensign meeting.
The email discusses the relative
criminal liability of a subject of
(AWP). The document
evidence relative to a subject of
[1-page]
Email
subject line: Matters Sheet. The
email contains a report of
PUBLIC INTEGRITY ALL
OPEN MATTERS WITH
NOTES AND ASSIGNED
ATTYS. The PIN report
contains a reference and
description of he Ensign case.
(AWP). The document
FOIA
Exemption
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 315
are deemed
nonresponsive
RIP
Document
Reference
Number
CRM 316
[email sweep]
CRM 317
[email sweep]
Author(s)
[ ] PIN Trial
Atty.
Recipient(s)
Patty Stemler,
Chief,
Appellate
Section
Patty
Stemler,
Chief,
Appellate
Section
[ ] PIN Trial
Atty.
[ ] PIN Trial
Atty.
Patty Stemler,
Chief,
Appellate
Section
[ ] PIN Trial
Atty.
[ ] PIN Law
Clerk
[ ] PIN Law
Clerk
[ ] PIN Trial
Atty.
Date(s)
July 08, 2011; July

07, 2011
May 28, 2010

Description
and describes the Ensign
[12-pages]
Email
Ensign. The email contains a
discussion re: legal theory
involving the criminal
investigation.
(AWP). The document
legal theories involving the
Ensign investigation, and would
[1-page]
Email
subject line: Re: Questions for
Ensign Research Assignment.
The email contains a discussion
concerning legal research for the
FOIA
Exemption
(b)(5)
(AWP)
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
RIP
Document
Reference
Number
CRM 318
[email sweep]
Author(s)
[ ] PIN Trial
Atty.
Mary Patrice
Brown
(DAAG)
Recipient(s)
Mary Patrice
Brown
(DAAG); Jack
Smith, PIN
Section Chief;
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation
[ ] PIN Trial
Atty.; Jack
Smith, PIN
Section Chief;
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation
[ ] PIN Trial
Atty.
Mary Patrice
Brown
(DAAG); Jack
Smith, PIN
Section Chief;
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation
Mary Patrice
[ ] PIN Trial
Date(s)
May 23, 2011;

May 16, 2011

Description
FOIA
Exemption

(AWP). The document
legal research related to the
Ensign investigation, and would
[2-pages]
Email
Ensign. The email contains a
discussion concerning factual
information and strategy for the
(AWP). The document
factual information and strategy
elated to the Ensign investigation,
and would improperly disclose the
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 315
are deemed
nonresponsive
WIF
RIP
Document
Reference
Number
CRM 319
[email sweep]
CRM 320
[email sweep]
Author(s)
Recipient(s)
Brown
(DAAG)
Atty.
[ ] PIN Trial
Atty.
Mary Patrice
Brown
(DAAG); Jack
Smith, PIN
Section Chief;
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation;
[ ] PIN
Deputy Chief
[ ], PIN
Admin
employee;
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation;
[ ], [ ] PIN
Trial Atty.
[ ] (CRM)
[ ] Lanny A.
Breuer
(DAG)
Jack Smith,
PIN Section
Chief;
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation;
Mary Patrice
Brown
(DAAG);
Mythilia
Date(s)

Description
FOIA
Exemption
WIF

[2-pages]
November 02,
2009
8/4/2011
Email
subject line: Senator Ensign and
attachments line: Ensign.pdf.
(AWP). The document
investigation including potential
criminal violations, and would
[1-page]
Email
subject line: PIN weekly.
(AWP). The document
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
Raman
(DAAG); [ ]
(CRM)
CRM 321
[email sweep]
Unknown
PIN Atty.
and/or Case
Agent
Undated

Description
FOIA
Exemption

investigation including
information about subjects, and
[1-page]
Spreadsheet of Search Terms
spreadsheet containing search
terms; total number of hits and
common false positives and
comments.
Basis for With `holding: (b)(5)
(AWP). The document
and describes computer search
terms related to the Ensign
information about subjects, and
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
Portions of
CRM 320
are deemed
nonresponsive
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
RIP
Document
Reference
Number
Author(s)
Recipient(s)
Date(s)
CRM 322
[email sweep]
Mary Patrice
Brown
(DAAG)
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation
June 29, 2011
CRM 323
[email sweep]
Raymond
Hulser, PIN
Principle
Deputy
Chief for
Litigation
Mary Patrice
Brown
(DAAG)
Mary Patrice
Brown
(DAAG)
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation
Raymond
Hulser, PIN
Principle
Deputy
Chief for
Litigation
Mary Patrice
Brown
(DAAG)
Mary Patrice
Brown
(DAAG)
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation;
[ ], [ ] PIN
Trial Atty.
Matthew
Axelrod
(Acting
DAAG)
[ ] (SMO); [ ],
[ ] (CRM);
Raymond
Hulser, PIN
Principle
Deputy Chief
for Litigation;
William
Welch
(AUSA-MA)
(Former PIN
Section Chief)
[ ] (SMO)
Matthew
Axelrod
(Acting
DAAG); [ ],
[ ] (CRM)
April 05, 2010;

March 22, 2010

Description
[8-pages]
Email
subject line: RE: [ ] depot tr.
(AWP). The document
information about a subject, and
[1-page]
Email
subject line: RE: Congressional
search MOU and attachments
line: Document Requests to
Congress Chart.wpd.
(AWP). The document
and describes document requests
to Congress including information
about the ign investigation, and
FOIA
Exemption
(b)(5)
(AWP)
WIF
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
Portions of
CRM 323
are deemed
nonresponsive
RIP
Document
Reference
Number
CRM 324
[email sweep]
Author(s)
Recipient(s)
[ ] PIN Trial
Atty.
[ ] PIN Trial
Atty.
[ ] (AUSADC)
Hulser, PIN
Principle
Deputy Chief
for Litigation;
Jack Smith,
PIN Section
Chief;[ ], [ ]
PIN Trial
Atty.
Hulser, PIN
Principle
Deputy
Chief for
Litigation
[ ] (AUSADC); Jack
Smith, PIN
Section Chief;
[ ], [ ] PIN
Trial Atty.
[ ] (AUSADC)
Hulser, PIN
Principle
Deputy Chief
for Litigation;
Jack Smith,
PIN Section
Chief; [ ], [ ]
PIN Trial
Atty.
Hulser, PIN
Principle
Deputy
Chief for
Litigation
[ ] (AUSADC); Jack
Smith, PIN
Section Chief;
[ ], [ ] PIN
Trial Atty.
[ ] (AUSADC)
Hulser, PIN
Principle
Deputy Chief
for Litigation;
Jack Smith,
PIN Section
Chief; [ ], [ ]
PIN Trial
Atty.
[ ] (Ensign)
Legal
Counsel
[ ] (AUSADC); ; [ ], [ ]
PIN Trial
Atty.
Date(s)
June 22, 2010;

June 21, 2010

Description
[4-pages]
Email
subject line: FW: Redlined 502
Stipulation.doc and RE:
Redlined 502 Stipulation.doc.
(AWP). The document
and contains a discussion about a
stipulation agreement, and would
[4-pages]
FOIA
Exemption
(b)(5)
(AWP)
The name(s)
and personal
information
of lowerlevel DOJ
employee(s)
and private
third party
individual(s),
have been
redacted
under (b)(6)
and (b)(7)(C)
WIF
RIP

Responsive Documents: CREW: DOJ: Regarding John Ensign: 10-15-14

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Responsive Documents: CREW: DOJ: Regarding John Ensign: 10-15-14

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From:

Wednesday, July 08, 2009 5:26 PM

Here's a quote from

Universal, MSNBC) [mailto:|

If you wouldn't mind sending a

when you have time-

RE; Workflow (Rejected)

believe the writer is referring to the meeting

had lunch the

The same day as the

might have violated

wish to comment on your involvement

money ~ just covering my bases here,

This is kind of unfair? Why do you mention "Ensign and]

Aside from Ensign's admission of payment Thursday,

main stream media. Off the

off the table without

someone else's vomit.

in the Ensign affair.

was not telling the truth, and that there was no

has said that's inaccurate?

Can you help clear that up

Talking Points Memo

Sent: Wed Jul 08 22:30:37 2009

today on the disaster?

Someone in ensigns office thought

Sent from my BlackBerry Wireless Handheld

Leader Tightlipped on Ensign

Do you have a number

October 05, 2009 2:49 PM

Ensign to end and expose, is ridiculous,

CREW Ethics complaint re |

C R E W asserts the article

badly on the Senate.

Or stick by past statements

Ensign's a f f a i r and whether

Wednesday, July 08,

suggested Ensign should give

There was and is no

orchestrating and assisting in any pay-off scheme.

information only and was trying to do

Get Ensign to stop the affair

Help Ensign and|

over the weekend, i anticipate receiving phone calls re: the

Hope you're doing

so sorry you have to slog through

fueling unhelpful speculation

and state the

about the affair and encouraged Senator Ensign to Immediately

says senator should resign

says senator should resign

Here i s the i n f o the guy i s t a l k i n g about

says senator should resign

an exclusive two-part i n t e r v i e w t o a i r over the next two days on

08, 2009 5:02 PM

me based on the questions

w / your boss to pay off the

had caused to his own marriage and

labout actual Senate b i z , l i k e t h e

Thursday. July 09, 2009 6:22 PM

It's the Ensign scandal,,,,

This is unfair. Why do you mention "Ensign

\ didn't trigger this scandal and was trying to

had a bigger role in this