IN THE DISTRICT COURT OF THE DISTRICT OF COLUMBIA - - - - - - - - - - - - - - -x : JUDICIAL WATCH, INC. : : Plaintiff, : : v. : Civil Action No. : 95-0133 U.S. DEPARTMENT OF COMMERCE, : : Defendant. : : - - - - - - - - - - - - - - -x Washington, D.C. Friday, July 9, 1999 Deposition of JOHNNY CHUNG a witness of lawful age, taken on behalf of the Plaintiff in the above-entitled action, before Rita M. Hemphill, Notary Public in and for the District of Columbia, in the Chambers of Magistrate Judge John M. Facciola, U.S. District Court, 3rd and Constitution, N.W., Washington, D.C. commencing at 10:11 a.m. 2 APPEARANCES: On Behalf of the Plaintiff: LARRY KLAYMAN, ESQ. Chairman and General Counsel Judicial Watch, Inc. 501 School Street, S.W., Suite 725 Washington, D.C. 20024 On Behalf of the Defendant: MARINA UTGOFF BRASWELL, ESQ. Assistant United States Attorney U.S. Attorney's Office 555 Fourth Street, N.W. 12th Floor Washington, D.C. 20001 ALICE McKENNA, ESQ. Office of the General Counsel U.S. Department of Commerce 14th Street and Constitution Avenue, N.W. Washington, D.C. 20230 On Behalf of the Deponent: BRIAN A. SUN, ESQ. O'Neill, Lysaght & Sun, LLP 100 Wilshire Boulevard, Suite 700 Santa Monica, California 90401-1142 Also present: Thomas Fitton, President, Judicial Watch 3 C O N T E N T S EXAMINATION BY: PAGE Counsel for Plaintiff 5 CHUNG DEPOSITION EXHIBITS: No. 11 Invitations 6 No. 12 Envelope 12 No. 12A Solicitation card 12 No. 12B Return card for contribution 12 No. 12C Campaign registration card 12 No. 13 Envelope 15 No. 13A Return envelope 15 No. 14 Washington Times Article dated July 8, 1999, "FBI Outlines China Attempts to Silence Chung" 131 No. 15 Photograph of Bernard Schwartz and President Clinton 163 No. 16 Fox News report by Carl Cameron dated May 24, 1999 173 No. 17 Washington Times article dated July 9, 1999, "Chung Warned to Shield Loral and Hughes" 178 4 1 P R O C E E D I N G S 2 JUDGE FACCIOLA: Before we begin this morning, 3 I wanted to make a statement just to convey to counsel 4 and to everyone else the terrible news that we just 5 have received, news that Judge Gasch passed away this 6 morning. 7 Judge Gasch was suffering from -- when I last saw 8 him, just about ten days ago, he was in the pink of health 9 and he went in for triple bypass surgery, complications set 10 in and he passed away this morning. 11 He was one of the few men in the history of 12 the District of Columbia who served both as Corporation 13 Council and United States Attorney, rescued the George 14 Washington University Law School night program when it 15 was about to close. 16 Few men in history have done more for this 17 community than Oliver Gasch. We regret his passing and 18 when we adjourn later, we will adjourn, of course, in his 19 honor. 20 It couldn't come at a worse time, his wife has 21 Alzheimer's and is institutionalized. A tough time for the 22 Gasch family. 23 That being said, let's proceed. 24 MR. KLAYMAN: Mr. Chung, his brother passed away 25 and our condolences to him as well. 5 1 THE VIDEOGRAPHER: Good morning. This is 2 the continuing video deposition of Johnny Chung. 3 I am the video specialist. For the record, my name 4 is Steve Garland. I am from Beta Reporting Services. The 5 court reporter today is Rita M. Hemphill. 6 We are rejoining the record on July 9, 1999 at the 7 time and date indicated on the video screen. 8 Would counsel please introduce themselves? 9 MR. KLAYMAN: Larry Klayman, General Counsel and 10 Chairman of Judicial Watch. 11 MR. FITTON: Tom Fitton, President, Judicial Watch. 12 MS. McKENNA: Alice McKenna, Office of General 13 Counsel, Department of Commerce. 14 MS. BRASWELL: Marina Braswell, U.S. Attorney's 15 office, on behalf of the Department of Commerce. 16 MR. SUN: Brian Sun on behalf of the witness, 17 Johnny Chung. 18 Whereupon, 19 JOHNNY CHUNG 20 was recalled as a witness and, after having been previously 21 sworn, was examined and testified further as follows: 22 EXAMINATION BY COUNSEL FOR PLAINTIFF (RESUMED) 23 BY MR. KLAYMAN: 24 Q You realize that you are still under oath, 25 Mr. Chung? 6 1 A Yes, I do. 2 Q I'm sure you're aware that being under oath means 3 that you will tell everything you know. 4 A That's correct. 5 MR. KLAYMAN: I'll show you what I'll ask the court 6 reporter to mark as the next exhibit, which is Exhibit 11. 7 (Chung Deposition Exhibit No. 11 8 was marked for identification.) 9 MR. KLAYMAN: Exhibit 11 are copies of documents 10 which your counsel faxed to us after your last deposition. 11 I'll ask you to identify it, Mr. Sun. 12 MR. SUN: Exhibit 11 appears to be a copy of 13 invitations that Mr. Chung received or has received in 14 connection with political fundraisers or politically-related 15 fundraisers and these documents were forwarded to Judicial 16 Watch in response to a request at the last deposition, I 17 believe, that we look and see if Mr. Chung had any such 18 materials in his possession and this is what was forwarded to 19 you. 20 BY MR. KLAYMAN: 21 Q Before I ask you about these specific documents 22 which are Exhibit 11, we made reference the last time you 23 were here to a Democratic National Committee brochure, a 24 managing trustee brochure, that provided certain benefits for 25 contributing $100,000. 7 1 Did you have a chance to look for that brochure? 2 A I used to have it. 3 Q You testified that you gave it to the FBI, at the 4 last deposition. 5 A Yes. 6 Q Have you seen it otherwise since your last 7 deposition? 8 A No. 9 Q No? You're going to have to talk up a little bit. 10 A Oh, I'm sorry. 11 Q In fact, this is a video deposition as well as a 12 written deposition. 13 A Yes. 14 Q I'm showing you what's been marked as Exhibit 11. 15 The first document, what is that, Mr. Chung? 16 MS. BRASWELL: Your Honor, I would object to 17 questions on these documents that are 1999 documents as to 18 really beyond the scope. 19 JUDGE FACCIOLA: Overruled. He's dealing with this 20 subpoena. Hopefully, we'll move over them quickly. 21 MR. KLAYMAN: I just want to identify them, please. 22 BY MR. KLAYMAN: 23 Q What is this? 24 A This is House Democratic leader Richard Gephardt 25 asking me to go to fundraising party. 8 1 Q Dated May 15, 1999? 2 A Yes. May 15, 1999. Saturday. 3 Q Where was this received? At your business, 4 Automatic Intelligence Systems? 5 A That's correct. In my office. 6 Q Did you decide to go to that fundraiser? 7 A No. 8 Q What's the next document? 9 A It's also the Democratic Congressional Campaign 10 Committee. 11 Q Is this the document that has Honorable Charles 12 Rangel, DCCC Co-Chair? 13 A That's correct. 14 Q And what is that? 15 A That's also a fundraiser letter. I told you that 16 last time. I did not pay too much attention to these any 17 more. 18 Q And this is asking you to attend a fundraiser on 19 June 10, 1999? 20 A That's correct. 21 Q With regard to these first two documents, did 22 anyone contact you orally? Other than your getting this by 23 fax or by mail, did anyone contact you and ask you to go? 24 A No. If they did, I won't answer the phone. 25 Q You don't remember them calling you? 9 1 A You have to understand that sometimes my engineer 2 answered most of the phone. I don't answer the phone by 3 myself after what happened, the incidents of the year. I 4 have so many very weird phone call. 5 Q Well, do you remember anyone leaving a message with 6 regard to these two fundraising solicitations? 7 A No. 8 Q Okay. The third one, what's the third one? It 9 says "Please join Senator Diane Feinstein and Senator Robert 10 Torricelli, the DSCC chairmen, for dinner and discussion in 11 Los Angeles, Wednesday, February 17th." Is that 199? 12 A That's correct. 13 Q Requested contribution $10,000 per couple. Did you 14 decide to go to that? 15 A No. 16 Q Where was this sent to you, at Automated 17 Intelligence Systems? 18 A Yes. Sent to my office. 19 Q Did anyone contact you orally about this 20 solicitation? 21 A No. 22 Q The next document, this is a letter to you, 23 Mr. Johnny Chung, Chairman and CEO, "Dear Johnny," sent 24 on January 25, 1999 from Senator Robert G. Torricelli, 25 U.S. Senator. Was this received at your company, Automatic 10 1 Intelligence Systems? 2 A That's correct. 3 Q Why is there something blacked out on the front? 4 A Because my fax machine had the trouble, like the 5 second pages we got over here? During that period of time, 6 we had a problem with our fax machine. I think I bring an 7 original copy over here, if you want to see it, you can see 8 it. 9 Q Do you have the original? 10 A Yes. 11 MR. SUN: This is the original. It's not much 12 better. 13 MR. KLAYMAN: Can we substitute that? 14 MR. SUN: Yes, or make another copy, a copy of this 15 one. 16 THE WITNESS: The toner is not good. 17 MR. KLAYMAN: Okay. 18 THE WITNESS: That's the only reason. 19 MR. KLAYMAN: The toner is not good. Okay. 20 We'll substitute a copy for that because the 21 original that you came with is readable. 22 THE WITNESS: Yes. 23 MR. KLAYMAN: Is that okay with you and your 24 counsel? 25 THE WITNESS: That would be fine. 11 1 MR. KLAYMAN: All right. Thank you. 2 BY MR. KLAYMAN: 3 Q Were you ever contacted by anyone with regard to 4 this particular letter of January 25, 1999 from Senator 5 Robert Torricelli? 6 A Yes. 7 Q Who contacted you? 8 A Nobody contacted me. 9 Q Do you know whether a message was left at your 10 office with regard to that solicitation? 11 A No. 12 Q Turning to the next document, this is a letter from 13 Al Gore dated February 9, 1999 to Johnny Chung, 2771 Plaza 14 Del Amo, Suite 809, Torrance, California, is that the address 15 of Automatic Intelligence Systems? 16 A That's correct, sir. 17 Q That's your company that's in the fax business. 18 A Yes. 19 Q It consists of three pages and you've testified as 20 to how you received it and where previously, but did anyone 21 ever contact you orally about this solicitation? 22 A No. 23 Q Since the time of your last deposition on July 9th, 24 have you received any more fundraising solicitations? 25 A I do. 12 1 Q When did you receive them? 2 A Approximately two weeks -- two weeks ago. 3 Q And do you have a copy of those with you? 4 A I do. 5 Q Can I get a copy of those? 6 A Yes. 7 MR. KLAYMAN: Thank you. 8 One is an envelope -- can I mark these as exhibits? 9 THE WITNESS: Yes. 10 MR. KLAYMAN: I'll ask this be marked as Exhibit 11 12. 12 THE WITNESS: That's the same one. That's the 13 envelope. I'm sorry. That's the same one. That's the same 14 one. 15 MR. KLAYMAN: I'll mark it anyway. 16 Exhibit 12 is a letter sent June 18, 1999, 33 17 cents U.S. postage to Johnny Chung at Automatic Intelligence 18 Systems, 2771 Plaza Del Amo, Suite 809, Torrance, 19 California. 20 I'll ask that we mark as Exhibit 12A the 21 solicitation card contained therein and Exhibit 12B the 22 return card for the contribution, Attention: Greg Evans, 23 and as 12C a card that says "Federal Election Rules, 24 Democratic Congressional Campaign Committee, Los Angeles, 25 July 6, 1999." 13 1 (Chung Deposition Exhibits No. 12, 2 12A, 12B, and 12C were marked for 3 identification.) 4 BY MR. KLAYMAN: 5 Q Did I correctly identify the envelop as Exhibit 12? 6 A Yes. 7 Q And Exhibit 12A is the invitation card from 8 Honorable Richard A. Gephardt, Democratic House leader, and 9 Honorable Patrick J. Kennedy, DCCC Chair, invite you to a 10 reception at 6 p.m. benefitting the Democratic Congressional 11 Campaign Committee at the home of Michelle and Rob Reiner in 12 Brentwood, asking for various contributions. Have I 13 correctly identified that? 14 A That's correct. 15 Q And Exhibit 12C is a little card that you fill out 16 on the back with the federal election rules where you check 17 off the contribution you want to make. Did I correctly 18 identify that? 19 A That's correct. 20 Q And Exhibit 12B is the return card, Attention: 21 Greg Evans, where you put the money in, correct? 22 A That's correct. 23 Q You've seen documents like this before. 24 A Yes. 25 Q Did anyone contact you with regard to this 14 1 solicitation? 2 A No. 3 Q Did anyone leave a message for you with regard to 4 this solicitation? 5 A No. 6 Q Did you respond to this solicitation from the 7 Democratic Party? 8 A No. If not because of you, I would throw it away. 9 Q Thank you. Have you asked anyone since the date of 10 your last deposition to take you off the mailing list of the 11 Democratic Party? 12 MS. BRASWELL: Objection. Outside the scope. 13 JUDGE FACCIOLA: Sustained. Sustained. 14 You don't have to answer that, Mr. Chung. 15 THE WITNESS: Yes. 16 MR. KLAYMAN: I'll show you what I'll ask the court 17 reporter to mark -- 18 THE WITNESS: I want to answer the question. 19 JUDGE FACCIOLA: No, you don't have to. 20 MR. SUN: Don't answer the question. When the 21 judge rules, you don't answer. 22 THE WITNESS: I'm sorry. 23 JUDGE FACCIOLA: Don't worry about it. Don't worry 24 about it. Nobody listens to me anyway. 25 THE WITNESS: I thought he said I could answer the 15 1 question. I misunderstood. 2 JUDGE FACCIOLA: It's not a problem. Don't worry 3 about it, Mr. Chung. 4 THE WITNESS: I thought he said I could answer the 5 question. 6 MR. KLAYMAN: I'll show you what I'll ask the court 7 reporter to mark as Exhibit 13. This is an envelope from 8 Al Gore to Johnny Chung, hand addressed to Johnny Chung, 9 2771 Plaza Del Amo, Suite 809, Torrance, California, with an 10 contribution return envelope to Al Gore, P.O. Box 18958, 11 Washington, D.C. 20036-8958. We'll mark that as 13 and 13A 12 respectively, the envelope being 13 and the return envelope 13 being 13A. 14 (Chung Deposition Exhibits No. 13 15 and 13A were marked for 16 identification.) 17 BY MR. KLAYMAN: 18 Q Did I correctly identify these two documents, 19 Mr. Chung? 20 A That's correct. 21 Q Did you get a new solicitation since your last 22 deposition or does this relate to the earlier one that you 23 identified? 24 A The earlier one. 25 Q And these are the original hand-addressed envelopes 16 1 to you and the return envelope? 2 A Yes, this is the one. 3 Q So these envelopes relate to the solicitation from 4 Al Gore which is part of Exhibit 11, correct? 5 A That's correct. 6 Q Have you received any solicitations any time in the 7 last two years from the Republican Party? 8 MS. BRASWELL: Objection. Outside the scope. 9 JUDGE FACCIOLA: Overruled. 10 THE WITNESS: My wife is a Republican, of course we 11 received some at home. 12 BY MR. KLAYMAN: 13 Q Are they addressed to you or to your wife? 14 A To my wife. 15 Q But you yourself don't get solicitations from the 16 Republican Party. 17 A I don't. I don't. 18 Q Has your wife contributed to the Republican Party 19 in the last two years? 20 MS. BRASWELL: Objection. 21 JUDGE FACCIOLA: Sustained. 22 BY MR. KLAYMAN: 23 Q Since the date of your last deposition, have you 24 provided documents of any kind relating to your involvement 25 in this whole campaign finance controversy to anybody? And 17 1 when I say you, you or your counsel. 2 A I don't think so. 3 MR. SUN: You have to speak up, Mr. Chung. 4 THE WITNESS: I don't really clearly understand 5 this question, okay? Because it is so wide. If I answer 6 that, I would say the last few weeks I have been talking to 7 the book publisher and then we have been talking a little bit 8 more, but not documentation at all. 9 BY MR. KLAYMAN: 10 Q What book publisher have you been talking to? 11 MS. BRASWELL: Objection. 12 JUDGE FACCIOLA: Sustained. 13 MR. KLAYMAN: Your Honor, that can lead to 14 admissible evidence, what was said. 15 BY MR. KLAYMAN: 16 Q Did you discuss with the book publisher the history 17 of your whole involvement in the campaign finance 18 controversy? 19 MS. BRASWELL: Same objection. 20 MR. SUN: I'm going to object as well, Your Honor. 21 I don't think this line of inquiry leads to anything 22 relevant. 23 JUDGE FACCIOLA: Well, let's see. It might lead to 24 it in the sense that if he discussed with this book publisher 25 writing his memoirs. His intention to memorialize what 18 1 occurred in reference in these matters might have some 2 peripheral relevance. 3 Are you going to write a book about this, 4 Mr. Chung? 5 THE WITNESS: Yes, I've been saying all day long, 6 I mean, since I was under government protection. Everybody 7 encouraged me to do so. A part of American history. 8 JUDGE FACCIOLA: Thank you. 9 BY MR. KLAYMAN: 10 Q Did you convey to the book publisher some of the 11 things that you were going to write? 12 A Not that much. Not that much. I was writing a 13 contribution in terms of feeling about my whole family and 14 then what has been reported on the news. 15 Q And who did you talk to? 16 MS. BRASWELL: Objection. 17 JUDGE FACCIOLA: Overruled. 18 THE WITNESS: I remember there's two. One is 19 New York, Sun Martin Press, the company who published 20 Monica Lewinsky's book, and the other one is here in 21 Washington, D.C., I wish my pronunciation is correct, 22 Regnoire. 23 BY MR. KLAYMAN: 24 Q Regnoire? 25 A Yes. Regnoire. 19 1 Q And who did you talk to at both places? 2 A One is -- I don't remember the name of the one is 3 in Sun Martin Press in New York. I personally talked to Mr. 4 Regnoire. 5 Q Did he contact you or did you contact him? 6 A Oh, my book agent. 7 Q Who is your book agent? 8 MS. BRASWELL: Objection. 9 JUDGE FACCIOLA: Sustained. 10 BY MR. KLAYMAN: 11 Q What information did you give to Mr. Regnoire about 12 your experience? 13 A Basically, I didn't talk too much. The book agent 14 talked about it. That's the way it should be. And then -- 15 Q Did this conversation occur in person? 16 A I only talked to Mr. Regnoire once. 17 Q In person? 18 A In person, yes. In his office. 19 Q In the last day or so? 20 A No. Last ten day or two weeks. Two weeks ago. 21 Q So you were here in Washington two weeks ago? 22 A I was here in Washington, D.C. one week ago. 23 Q Why didn't you contact Judicial Watch or the Court 24 so we could have deposed you at that time, so we wouldn't 25 have to go to this expense? 20 1 A Nobody told me I should contact you. If you want 2 to save the money for Judicial Watch, I will tell you that I 3 don't even cash your first check. I tried to save you money. 4 Q You are aware, are you not, that we have through 5 credit cards and checks paid over $4000 to bring you here 6 today. 7 A Yes, I do. I really -- and I also want you to know 8 I tried to shop around for the cheap a ticket as I can, but I 9 cannot save any money for your organization, but I do really 10 want to save money. 11 Q Well, my question is why didn't you let us know -- 12 MR. SUN: Your Honor, I don't think this is 13 productive. We have limited time. Mr. Klayman said he had 14 two hours left to do this depo, I'd like to move on to 15 substantive matters. 16 JUDGE FACCIOLA: Okay. Well, let's just finish 17 this thing. 18 As I understand, Mr. Klayman, the witness did come 19 to Washington. 20 And his question, Mr. Chung, is a simple one. Did 21 it occur to you to call Mr. Klayman and have your deposition 22 done when you were here for another reason? 23 THE WITNESS: Well, first of all, I don't know I 24 should call you guys every time when I come to Washington, 25 D.C. or not. Two, I never know the date and the time until a 21 1 few days earlier when I have the meeting with the publisher 2 over here. 3 JUDGE FACCIOLA: All right. 4 THE WITNESS: And -- 5 MR. SUN: That's enough, Mr. Chung. 6 MR. KLAYMAN: It isn't enough. The judge -- 7 Your Honor, I don't think that's right. I mean, we 8 spent $42,000 to bring him here, so we're going to ask the 9 Court for some relief on that. 10 JUDGE FACCIOLA: That's fine. 11 MR. KLAYMAN: We paid by credit card -- 12 JUDGE FACCIOLA: I'll be glad to look at that. 13 MR. KLAYMAN: Okay. Thank you. 14 BY MR. KLAYMAN: 15 Q Now, did you meet with Mr. Regnoire on any other 16 occasion and talk to him? 17 A No. 18 Q What did you tell him? You said you told him some 19 things. 20 A I speak more -- I think I speak somewhere around 21 five minutes. Most of the time is the agent talk for me and 22 that was it. 23 Q Well, just tell me what you said. 24 A What happened to the newspaper and recently what 25 happened to the Chinese intelligent director as to the report 22 1 even before the English newspaper come out, he has been 2 assigned -- I mean -- how do you say in English -- he been 3 pulled away to teach because I read it from the Internet 4 Chinese newspaper and I feel vindicated. And also surviving 5 the scandal, what kind of impact to my family. How I feel 6 deep inside my heart about all of this. 7 And I supposed to go to the Congress for two days 8 deposition -- I mean hearing, they questioned for hours, and 9 I did the best I can, answered all of the questions and laid 10 out all of the fact on the table. That's all I can remember 11 now. 12 At that time when they come down to the money, how 13 much it was going to be, I don't really want to talk about, 14 but we didn't even make a deal. 15 Q And how long was the entire meeting? 16 A One hours, one hour and a half. It's a lunch 17 meeting at his office. 18 Q And who else was present? 19 A A bunch of his company's people. 20 Q Do you know who they were? 21 A They didn't give me the business card, but they are 22 all his company's. 23 Q Aside from your agent, was anyone else present 24 other then Regnoire's people and your agent and your you? 25 MS. BRASWELL: Objection to this continued line of 23 1 questioning. 2 MR. SUN: Joined. 3 JUDGE FACCIOLA: Sustained. 4 MR. KLAYMAN: Your Honor, it's the same relevancy, 5 I just want to see -- 6 JUDGE FACCIOLA: We know he spoke to these people. 7 Go ahead. 8 MR. KLAYMAN: Well, there's an incentive when 9 you're talking in this context to actually come forward with 10 some unique information because you're trying to sell it, so 11 there may be something very relevant here. 12 JUDGE FACCIOLA: Can you remember who was at the 13 meeting besides the people you mentioned, the names? 14 THE WITNESS: No. The only person I know is -- 15 it's very difficult to pronounce his last name. 16 JUDGE FACCIOLA: Regnoire. 17 THE WITNESS: Regnoire. I call him 18 "Mr. Publisher." 19 JUDGE FACCIOLA: There were other people in the 20 room, but -- 21 THE WITNESS: And then the other one sat next to me 22 and at the other end of the table is the president of the 23 company. And the rest of them, ladies and gentlemen I don't 24 really remember their name. They all belong to their 25 company. 24 1 BY MR. KLAYMAN: 2 Q Was your counsel present, Mr. Sun? 3 A No. 4 Q No lawyers present. 5 A No. 6 Q Now, you gave me the subject matter of what you 7 talked about, but what specifically did you say about General 8 Ji? 9 A Not that much. 10 Q Tell me what you said. 11 A Not that much. What happened to -- what happened 12 to my testimony I just repeated to them. My 30 pages where I 13 say what -- this is what happened and then they got a 14 newspaper, they can read. And that is not a part of the 15 issue they asked me. That's not -- they are not too much 16 interested with the already reported article, the story. 17 Q Well, just tell me what you said. That's all. 18 A I said as I know I am the only one out of 121 19 witness come up and tell the whole truth, that it's not easy, 20 but I think it's the right way to do it and the right thing 21 to do. I told them again like what I said to the Congress. 22 My daughter asked me, Dad, whether you like it or 23 not, it's a part of American history, what you want to do 24 with it? And I told them that I answered the question to my 25 daughters I want to set the record straight, I want to tell 25 1 them the whole truth, and then I mentioned to them about -- 2 they asked me -- yes, they asked me why you want to write 3 this book. 4 I say I have a responsibility to my family, to 5 my children, they are very, very young, three and five 6 years old and one coming up Christmas, and I have a 7 responsibility to them, to let them know what happened. 8 I have a responsibility to my community and to my country. 9 And that's why I want to write a book. He specifically 10 asked me why you wanting to write this book. 11 Q And he asked you what do you have that's new that 12 we don't already know, correct? 13 MR. SUN: Objection. No foundation. 14 JUDGE FACCIOLA: Overruled. Overruled. 15 THE WITNESS: Answer the question? 16 MR. KLAYMAN: Yes. 17 BY MR. KLAYMAN: 18 Q He asked you that, didn't he? 19 A Yes, he did. Not he asked me, somebody else. 20 Q Okay. And what did you tell them? 21 A I tell them that I told whole truth to the 22 government already, but according to the news report, this 23 still did not come out to the light yet. I said everything I 24 know already and then they are still not reporting in the 25 newspaper yet some of it. 26 1 Q And you then told them at Regnoire Publishing what 2 that was, correct? 3 MR. SUN: Objection. Leading. No foundation. 4 MR. KLAYMAN: You can respond. 5 MR. SUN: Mr. Chung did not say that and that's not 6 what they asked him. 7 MR. KLAYMAN: Wait a second here. You know, he 8 wants to come in here and he wants to tell the truth. You're 9 acting as an advocate on behalf of a political interest here. 10 Let him tell the truth. 11 MR. SUN: I don't appreciate your leading my client 12 into -- 13 MR. KLAYMAN: He's an adverse witness. 14 MR. SUN: -- evidentiary conclusions where you've 15 laid no foundation. You can ask the witness did so and so 16 ask you something. 17 MR. KLAYMAN: Please, there's a judge here, 18 Mr. Sun. 19 JUDGE FACCIOLA: Let's see if we can figure this 20 out. 21 Now, when they were talking to you about this book, 22 okay? Did they ask you, as Mr. Klayman said, that you knew 23 something that no one else did, that there was something new 24 that your book would say that not all the other books about 25 this controversy hadn't said? Did they ask you that? 27 1 THE WITNESS: One of the -- I don't remember, 2 gentleman or lady, asked me that question. 3 JUDGE FACCIOLA: And what did you say? 4 THE WITNESS: I said I told the whole truth to the 5 government, but a lot of things still didn't come out to the 6 newspaper yet. 7 MR. KLAYMAN: Your Honor, I'm entitled to ask a 8 leading question. He is adverse. 9 JUDGE FACCIOLA: All right. Go ahead. Ask your 10 question. 11 MR. KLAYMAN: So my question is, and I ask the 12 Mr. Sun be instructed not to interrupt -- 13 JUDGE FACCIOLA: All right. Well, he can object if 14 he wants to. You ask your question. 15 MR. KLAYMAN: Not with a speaking objection. 16 MR. SUN: I will object if I think it's 17 appropriate, Mr. Klayman. 18 JUDGE FACCIOLA: All right. Let's see if we can -- 19 MR. KLAYMAN: The judge makes that decision. 20 JUDGE FACCIOLA: Go ahead, Mr. Klayman. Ask your 21 question. 22 BY MR. KLAYMAN: 23 Q You then told them what it was that you had told 24 the government that hadn't come out yet, correct? 25 A I said, well, the newspaper haven't come out yet. 28 1 I didn't say the government didn't come out yet. 2 Q All right. And then what did you tell them that 3 didn't come out yet? 4 A Larry, I haven't make a deal with them at that 5 time. Why should I tell them? I mean, it's -- 6 Q I don't understand what you just said. 7 A They haven't tell me they want a book or not, why 8 should I tell them everything I know? 9 MR. SUN: He's asking you what did you tell them. 10 BY MR. KLAYMAN: 11 Q You did tell them what it is that hasn't come out 12 yet in your testimony. 13 A Yes. 14 Q And what did you tell them? 15 A I only said, well, most of them, it didn't come out 16 yet. I tell the whole truth. 17 Q I'm trying to -- let me just preface this -- 18 A I give them -- 19 Q Let me just preface this. I know Al Regnoire, I 20 can ask Al Regnoire, but I want to get it from you under 21 oath, so tell me now what you told them because I'm going to 22 ask Al Regnoire. Please answer. 23 A I tell them that I tell the whole truth to the 24 government, which is Department of Justice and the FBI. And 25 obviously so many detail in there is not coming out yet. And 29 1 didn't see it on the news report. And some of the question 2 during my question and answer by the FBI and Department of 3 Justice -- as you know, I want to tell the whole truth to set 4 the record straight, but sometimes I also want to give them 5 the information during that two years, the last two years, 6 and sometimes the question has been stopped, so my answer 7 didn't continue to go on. 8 Q Well -- 9 A I'm telling you what I said to him, okay? And he 10 asked me what is that. I say in my point, I think they don't 11 want to know the truth. 12 Q Who is they? 13 A The government. 14 Q The government? 15 A Yes. 16 Q And you then told him what the truth was? 17 A To -- 18 Q To Regnoire and his people. 19 A No. No. No. No. No. The question was stopped 20 right there. 21 Q Why didn't you tell them? 22 A You mean in detail? 23 Q Mm-hmm. 24 A I've been questioned and answered by the government 25 for two years. How could I have detailed -- even you cannot 30 1 give me questions -- 2 Q Well, I'll ask you a question -- 3 MR. SUN: For the record, Your Honor, I believe 4 that Mr. Chung is maybe not quite understanding Mr. Klayman's 5 questions. 6 JUDGE FACCIOLA: That's a possibility. Go ahead. 7 MR. KLAYMAN: He understands it quite well, 8 Your Honor. 9 BY MR. KLAYMAN: 10 Q I'll ask you now, what is it that hasn't come out? 11 Tell us right now. 12 A Your Honor, answer the question? 13 JUDGE FACCIOLA: Please. If you can. 14 THE WITNESS: Okay. I'm going to do the best I 15 can. What happened, the detail, when I give the $50,000 to 16 Maggie Williams' staff at the White House, basically the 17 general information is there, but the detail, it didn't come 18 out. 19 What happened to the question to the Secretary 20 Energy, Hazel O'Leary, I give them the best memory I squeeze 21 myself, as detailed as I can, and the detail didn't come out 22 yet. The detail of how it happened. 23 And then what happened with the detail of under the 24 government protection, the 21-day for my family, not easy, 25 and when I been learned, there's two group of people coming 31 1 out after me. It doesn't come out. 2 And what happened -- another one, which is an 3 Asian-American female two weeks before my sentencing tried to 4 contact me even one hour before my sentencing date, still 5 call me and try to -- I don't know how to use the words -- 6 try to ask me for money and I am a witness before the Court 7 right now, Your Honor, if I don't have to say it, I don't 8 want to say it because there is a legal pursuit. 9 MR. SUN: For the record, Your Honor, Mr. Chung has 10 been advised by law enforcement authorities that they are 11 conducting an investigation of a woman who contacted 12 Mr. Chung prior to his sentencing and appeared to engage 13 in conversations with him that might have suggested she was 14 in a position to solicit him or perhaps extort money from 15 Mr. Chung. That matter is under investigation and he's 16 a potential witness in that matter. That's what he's 17 referring to. 18 JUDGE FACCIOLA: Thank you, Mr. Sun. 19 BY MR. KLAYMAN: 20 Q Let's go back to your listing certain things and 21 give us the information that has not been provided. Let's 22 start with the issue of the $50,000 check and Maggie 23 Williams. What is it that hasn't come out yet, the details? 24 A Larry, I will try to give you the best I can. 25 Q Yes. Give us all the information. 32 1 A The best I can. 2 Q Take your time. 3 A It's 1995. 4 MR. SUN: Your Honor, I have to interpose this 5 objection for the record, if I could, just for the line of 6 questioning. I don't see the connection or the nexus between 7 this line of inquiry and anything related to the Department 8 of Commerce. 9 Mr. Chung is making reference to, I believe, a 10 March 1995 visit of some business representatives -- business 11 officials from the People's Republic of China. I believe 12 he's also making reference to a situation where he and his 13 family were under temporary relocation and protective custody 14 by the FBI. 15 And also I do believe, actually, the Hazel O'Leary 16 matter might have some tangential reference -- actually, I'm 17 wrong. She's Department of Energy, so I don't think that has 18 anything to do with the Department of Commerce. So I just 19 want to state my objection to this line of inquiry for the 20 record. 21 JUDGE FACCIOLA: Thank you. Overruled. 22 BY MR. KLAYMAN: 23 Q Continue. Tell us everything you know. 24 A There's one more. On May -- May -- no, there's one 25 more. On May 20, 1999, there is one Italian-American come to 33 1 my office, the kind instant -- 2 Q The kind of what? 3 A Instant. The kind of situation. Make me feel very 4 nervous and I happen to have FBI agent right there in my 5 office, I call them up and ask them to come over, but that 6 don't come out yet, okay? And then -- 7 Q The FBI -- 8 A The FBI almost pull out a gun to protect me inside 9 my own office and that's why, Larry, I don't answer the phone 10 by myself any more. 11 Q Let's back up to the Maggie Williams and the check. 12 Tell me everything you know about that. 13 A The day when I decided to invite those people to go 14 to which I call my wish list for them, I contact with Richard 15 Sullivan. He is kind of -- the best way I can say it, to 16 pretty hard to get in the DNC. 17 I went to the OEOB 100, which is White House, and I 18 asked Evan Ryan, Maggie Williams' assistant, and I showed to 19 her my wish list and then I said I would be very happy to do 20 whatever I can, the best memory I can remember. 21 Then I showed her all of the business cards of my 22 guests and my wish list. I remember she walked out of her 23 office and she talked to Maggie Williams and that's what she 24 said to me. 25 Then come back and said to me during 1994 Christmas 34 1 party, First Lady had a lot of debt to the DNC, Democratic 2 National Committee, and Christmas party expense. I remember 3 the best recollection I can get is $80,000. I stay with what 4 I say to Tom Brokaw last time when he give me the interview, 5 that I am going to give the best recollection I can have. 6 And Evan Ryan said to me Maggie Williams said it 7 will be nice if you can help for that debt to the DNC. My 8 light bulb goes on at that time. I say, yes, I would be very 9 happy to help for $50,000. And then that was the 10 conversation. 11 And I went back next day with the check and with 12 the envelope in my hand. The envelope I remember said Dear 13 Ms. Maggie or Dear Ms. Williams, this is the best I can help. 14 And thank you. Sincerely, Johnny Chung. That's what I 15 remember I said in there. 16 Again, I want to stand behind whatever I said to 17 Tom Brokaw at that interview. 18 And then when I handed over the check with the 19 envelope, it did not seal, to Evan Ryan and she asked me, 20 well, you can hand it to her. 21 Q Who is her? 22 A Maggie Williams. Then Maggie Williams come in and 23 then I hand it over to her. She took me back to her office 24 on the corner, OEOB 100. She picked up the phone and called 25 White House mess, make a reservation for me immediately. My 35 1 wish list was part of the -- part of my wish list is to have 2 lunch at the White House mess. 3 And that day when we have everybody come in to have 4 lunch at the White House mess, we also have a tour at the 5 White House, but since then the First Lady was in Europe 6 somewhere is coming back, so what we did is everybody had to 7 go back to the hotel to rest after the tour and lunch and 8 then we come back somewhere around 3:00, my best 9 recollection, you can find out from White House records. 10 I remember clearly that was the day to honor 11 national teacher. They want to give a reward to the national 12 teacher. When we passing by -- and they set it up the First 13 Lady is going to receive us -- when we passing by in the 14 White House, Maggie Williams give me the kind of eye which 15 mean everything is already set up. 16 I was inside -- now I know that's Map Room -- 17 Map Room -- and then I asked Evan Ryan the First Lady know 18 I give the contribution. She say she definitely know. When 19 she come in, handshake, I remember she said, "Welcome to the 20 White House, my good friend." 21 Q Who said that? 22 A The First Lady. 23 Q When she came into the Map Room. 24 A Yes. 25 Q And what did she say? 36 1 A We handshake, and then she said, "Welcome to the 2 White House, my good friend." And obviously they got their 3 own interpreter, which is the group, Chinese businessmen, so 4 they introduced one by one. She invite us to join her to the 5 national teacher's reward inside the White House. This is 6 kind of detail. 7 MR. SUN: Your Honor, could I make this observation 8 now that Mr. Chung has answered this question? 9 I thought that Mr. Klayman's inquiry was on the 10 issue of whether there was something startling or new that 11 had been brought out. Hearing Mr. Chung, I can say for the 12 record, Your Honor, I believe all this is not new to the 13 extent this is information that was given to the government. 14 We run the danger here if this line of inquiry is 15 pursued of listening to Mr. Chung orally write his book and I 16 don't think that's the purpose of this deposition. 17 I have no objection to Mr. Klayman going into 18 aspects of how the Department of Commerce had contacts with 19 Mr. Chung and possibly any connections that folks from the 20 Department of Commerce might have that are finance-related 21 activities, which I believe and understand to be the purpose 22 of the deposition. 23 And so I would make that observation and ask that 24 this line of inquiry be curtailed and focused in that 25 direction. 37 1 JUDGE FACCIOLA: I understand. 2 (Interruption to the proceedings.) 3 THE WITNESS: Can I have some more hot water, if I 4 can? 5 JUDGE FACCIOLA: Well, why don't we take -- 6 MR. KLAYMAN: Your Honor, can I respond to that? 7 JUDGE FACCIOLA: Let's take five minutes. 8 (A brief recess was taken.) 9 THE VIDEOGRAPHER: We're going off record at 10:57. 10 JUDGE FACCIOLA: We'll take five minutes. 11:05, 11 please, everybody. 12 (A brief recess was taken.) 13 THE VIDEOGRAPHER: We're back on record at 11:06. 14 MR. KLAYMAN: Initially, Your Honor, we have 15 already actually gotten testimony in this area before, Your 16 Honor made rulings at the last deposition. 17 Secondly, part of Mr. Chung's wish list, which is 18 directly relevant to this, deals with a desire to meet with 19 Secretary Ron Brown at the Commerce Department. 20 Thirdly, this is part of a continuing course of 21 conduct in terms of his activities which led to his 22 participation in trade missions. So it's clearly relevant 23 and I'm sure Your Honor will recognize that. 24 JUDGE FACCIOLA: Go ahead and pursue it. 25 MR. KLAYMAN: Thank you. 38 1 MR. KLAYMAN: Where were we when we left off before 2 the objection? 3 What was the last response by Mr. Chung, if you can 4 read that back to help refresh his recollection as to where 5 he was? 6 MR. SUN: Not the whole response, just the last 7 few -- 8 MR. KLAYMAN: No, we don't want the whole response. 9 JUDGE FACCIOLA: Not the whole 10 (The record was read back by the court reporter.) 11 BY MR. KLAYMAN: 12 Q What happened after that? 13 A After everybody took pictures and then she said I'm 14 going to address to the National Teachers Association is at 15 the White House, the first floor, and you guys are welcome to 16 join us. So I took all of my guests, listened to her speech, 17 standing in the back. And then we come out. 18 Q What was on the wish list that you gave to Maggie 19 Williams? 20 A The best recollection I got is White House mess for 21 lunch, tour of the White House, meeting with the First Lady, 22 meeting with the President of United States, and I remember 23 also a meeting with Secretary Ron Brown. One of the reason 24 is the head of this delegation, he is the chairman of chamber 25 of commerce of China and he met late Secretary Ron Brown back 39 1 there in China. And he came to United States, invited Mr. 2 Chin, Chin Hu Yi, the former chairman of chamber of commerce 3 of Commerce. 4 He was invited by the United States Chamber of 5 Commerce and he asked me to be a host, joint host, tour them 6 around in Washington, D.C. area. I did. My wish list, one 7 of them is to meet with the late Secretary Ron Brown. 8 Q Did you get your meeting with the President? 9 A I do. 10 Q You did? 11 A I did. 12 Q And when did you have that meeting or meetings? 13 Did you have more than one? 14 A That specific meeting, up to today, I told the FBI 15 and the Department of Justice, is still very confusing 16 because I get all my wish list during that time except 17 meeting with the President and Secretary Ron Brown, all the 18 others are fulfilled. 19 MR. SUN: Mr. Chung, I believe the question was -- 20 MR. KLAYMAN: Let him answer. Just let him answer. 21 MR. SUN: -- how many meetings did you have with 22 the President -- 23 JUDGE FACCIOLA: Gentlemen, please -- 24 MR. KLAYMAN: Just let him answer. 25 JUDGE FACCIOLA: Well, let's -- 40 1 MR. KLAYMAN: He can answer in his own way, 2 Your Honor. 3 JUDGE FACCIOLA: Okay. 4 The question, Madam Reporter, was what, please? 5 (The record was read back by the court reporter.) 6 THE WITNESS: With the President? With this group 7 or myself? 8 MR. KLAYMAN: Either. 9 THE WITNESS: With this group, one. 10 BY MR. KLAYMAN: 11 Q And when did that occur? 12 A It is on the -- Your Honor, I don't remember the 13 date, but there is two day later after we met with the First 14 Lady. I think March 11, March 12. 15 Q Where did that meeting take place? 16 A Radio address at Saturday in the Oval Office. 17 Q That's the famous radio address. 18 A That's correct. 19 Q Was there a meeting after that or meetings after 20 that? 21 A No, just a handshake. They present to the 22 President a stone, jade stone, they say wish you long life. 23 And then also they said, Mr. President, we hope you can come 24 to visit China some day. And that was the whole entire 25 conversation. Pictures and then we walk out. 41 1 Q You considered the pictures to be part of your wish 2 list? 3 A Oh, very important. As I said to the Congress, the 4 picture with the President is the weight of the gold. 5 Q Now, you said the issue was a little confused, you 6 started to explain that, as to whether the meetings with the 7 President were part of your wish list. Do you want to expand 8 on that? 9 A Yes. When I give that $50,000 to Maggie Williams 10 and then nobody set up the meeting with the President. And I 11 asked her, she said, well, that's a different line, I only 12 take care of the First Lady part. For meeting with the 13 President, is a different issue. I cannot help. 14 And I said, well, I already donated 50,000 and this 15 is my wish list, how come I cannot get it? And I have guests 16 over here. I was a little bit confused so back and forth, I 17 been calling DNC and I been talking to the people inside the 18 White House, Maggie Williams' office. 19 Finally some time -- that was Friday, I believe, it 20 is a Friday and Saturday. Friday finally somebody call my 21 apartment here in Washington, D.C. and say you can come to 22 White House 10:00 with your guests for radio address. 23 I remember I received two phone calls, one is from 24 White House, I don't remember the name, a female. And the 25 other phone call is from DNC, a female. Could be Carol 42 1 Khare. 2 Q How is that spelled? 3 MR. SUN: Khare. I think it's K-h-a-r-e. 4 MR. KLAYMAN: Okay. 5 THE WITNESS: Yes. I only remember she is the 6 special assistant to Don Fowler, then the chairman. 7 BY MR. KLAYMAN: 8 Q And what did this woman tell you from the DNC? 9 A That's why I tried to explain to you it's very 10 confused. 11 Q As best you can. 12 A At that time -- up to today, I still don't know who 13 set it up, the meeting for me, okay? But I received one 14 phone call from White House, one phone call from DNC. And 15 then they ask me to bring my guests 10:00 in the morning. 16 That's the best -- that's the best I gave it to the FBI. 17 Q What did the person from the White House tell you, 18 the woman whose name you don't remember? 19 A I don't remember. 20 Q From the First Lady's office, what did that person 21 tell you? 22 A No, it's not a First Lady office. I think it is 23 someone who in charge of all the radio address. 24 Q What did she tell you? 25 A Bring your guests to the Pennsylvania Avenue 43 1 entrance at 10:00. 2 Q So you took that to mean that your wish list was 3 being honored. 4 A That's correct. 5 Q That you were getting your meeting with the 6 President for your $50,000. 7 A That's correct. 8 Q When you first contacted the Democratic National 9 Committee to register your complaint that you had paid 10 $50,000 and weren't getting the meeting with the President, 11 did you speak with anyone at that time? 12 MR. SUN: Objection. Misstates the testimony. 13 JUDGE FACCIOLA: Overruled. 14 THE WITNESS: My best recollection, I did speak 15 with Richard Sullivan of the DNC. I did speak with Carol 16 Khare of the DNC. I speak with the DNC -- one of the 17 gentlemen named Eric Suldon. 18 MR. SUN: I think it's Selden, S-e-l-d-e-n. 19 THE WITNESS: Selden. 20 MR. KLAYMAN: Silden, S-i-l-d-e-n. 21 THE WITNESS: Silden. 22 BY MR. KLAYMAN: 23 Q Okay. We all know him. Go on. And what did you 24 tell him? 25 A I paid $50,000 and this is my wish list, how come 44 1 the last one is so important and I cannot get it. I give the 2 money already, I gave the money already, and then I -- it is 3 important for this group of people, my guests, I want to do 4 business because this is chairman of chamber of commerce. 5 They promise me some day when I go back to China I can have a 6 good business. 7 One thing I did not know, I make a record here, 8 after the radio address, their visit over here in the United 9 States, within 45 days, that chairman of chamber of commerce 10 resigned, retired. 11 All my investment and everything is gone, okay? 12 And then he is very tricky, he didn't tell me he is going to 13 be retired and he just have his final wish list to be 14 granted. And up to today, I am still taking a lot of heat 15 for asking nothing. 16 Q Taking heat from the Chinese? 17 A Newspaper, the United States government, including 18 Judicial Watch ask me after four years, same old story over 19 and over, and that guy just retired like old man in the 20 countryside and doing nothing. He hanging the pictures over 21 there in his house and he did not tell me 45 days after that 22 visit in the White House he is going to retire. He already 23 knew it, but he didn't tell me. 24 Q So what you're basically saying is you went to 25 all this trouble, you paid the $50,000, you created a 45 1 controversy, and then the guy wasn't even there to take 2 advantage of. 3 A No. 4 Q Right? 5 A Yes. And I cannot even ask him for any help for my 6 business in the future because he retired. Retired 45 days 7 after that visit in the White House. But I did learn 8 something, when I tried to rescue Harry Wu, the other people 9 did help me. That's the only thing I can say. But after 10 today, Harry Wu still think I got nothing to do with it. 11 Q What other people are you talking about? 12 A The other group of people who came to the White 13 House. The other businessmen with this delegation. 14 Q That delegation? 15 A Yes. They did help me to rescue Harry Wu. 16 Q What did Sullivan and Ms. Khare and Mr. Silden tell 17 you when you said you wanted to get the value of your 18 $50,000? Did they say anything back? 19 A Before or after? 20 Q When you contacted them and said I paid $50,000, I 21 want my meeting with the President, can I get it. What did 22 they say to you in response? The first time you contacted 23 them. 24 A The first time, before we visit, they pretty hard 25 to get and now they even pretty harder to get. That's what I 46 1 can remember. 2 Q Well, but you told them what you wanted, right? 3 A Yes. 4 Q Okay. And what did they? They said we'll take 5 care of it? 6 A I don't remember exactly conversation, but the 7 attitude is a played harder to get. 8 Q What? 9 A Played harder -- harder to get. 10 Q What do you mean? 11 A It is more difficult to get my wish list to be 12 granted. Than even before I give it to them the $50,000. 13 Q But when you contacted them, when you were told 14 your $50,000 wasn't going to the President, it was going to 15 the First Lady, when you contacted the DNC to complain, what 16 did these people say to you at that time? 17 A I don't remember exactly language they said to me, 18 but their attitude to me I remember, it's even pretty harder 19 to get than before I give it the $50,000 to them because I 20 told you that I asked them -- I showed to them my wish list 21 and Richard Sullivan said to me at the very beginning it's 22 very difficult to get, pretty hard to get. And now it's 23 pretty more harder to get. 24 Q But they told you that they would try to get it for 25 you. 47 1 A Not Richard Sullivan. Not Eric Silden. Maybe 2 Carol Khare. 3 Q And ultimately you were notified by Carol Khare 4 that you had gotten it. 5 A Yes. Her and the other person in the White House. 6 That's why I up to today, this question, Larry, has been 7 asked to me by FBI and the Department of Justice and I been 8 answer that over and over again. 9 Very confused because it's in the Friday night, 10 finally I am in the very, very -- I was really -- I use the 11 word panic, I want to grant all my wish list to be granted, 12 but it happened to be the last one is very difficult. And 13 until late Friday night, finally somebody called me. I don't 14 care who told me that, the only thing I really cared is 10:00 15 at the gate, bring your guests, and I remember two phone 16 call. But very confused. Up to today, I still searching who 17 did the job for us. I cannot answer your question. 18 Q You were very happy when you found that out. 19 A Yes. 20 Q Relieved. 21 A Big relief. 22 Q You were able to save face with your colleagues. 23 A Yes. That's what I said is putting powder on my 24 face. 25 Q You had paid the money into the turnstile and you 48 1 got something back. 2 A Yes. 3 Q Now, the other part of your wish list, a meeting 4 with Ron Brown. 5 A That's correct. 6 Q You got your meeting with Ron Brown eventually? 7 A No. What happened is I tried to call people who I 8 know, this is one of very few instance I have contact with 9 John Huang. As I told you, contact with him. I remember 10 what he said to me is Ron Brown is under Independent Counsel 11 investigation during that time and it's very inconvenient to 12 meet any foreign guests. 13 Be honest with you, I do not know what Independent 14 Counsel during that time. I take it some kind of serious 15 situation, but I don't care, I want to have a meeting. It 16 not happen. So we have two phone call, one from when I call, 17 one when he called me regarding setting up the meeting. 18 Finally, he said I will stop at the J.W. Marriott 19 Hotel which is your guests all stay there. I will stop by 20 and explain to them this is not appropriate time to meet with 21 the late Secretary Ron Brown. And he came in and he 22 explained to everybody and they took a picture with him 23 inside the hotel room and goodbye. 24 Q When you say he came by, Secretary Brown? 25 A No. No. No. No. 49 1 Q Huang? 2 A Huang. John Huang. 3 Q So the whole delegation got a picture with John 4 Huang. 5 A Yes. 6 JUDGE FACCIOLA: Excuse me. In that sentence, did 7 Brown come to the Marriott? 8 THE WITNESS: No. 9 JUDGE FACCIOLA: I see. 10 THE WITNESS: No. The only reason why John Huang 11 come in is under my request and I say would you please 12 explain to this delegation it's not appropriate time to meet 13 with the late Secretary Ron Brown and then he did the job and 14 then he come in and explain to all of those people. And 15 obviously I can see that he know them, they know him. 16 BY MR. KLAYMAN: 17 Q Do you know how they knew him? 18 A I don't know, but I think it is when he was there 19 in China, maybe that's the reason -- I told you he was the 20 chairman of the chamber of commerce of China. 21 Q When you were there in China on the trade mission. 22 A Yes. I don't know how they know each other, but I 23 take the idea is Mr. Chin, the chairman of chamber of 24 commerce, that he is very famous in world business circle. 25 Q At the time that Mr. Huang came over to the J.W. 50 1 Marriott to explain that Secretary Brown couldn't meet 2 because he was under Independent Counsel investigation, 3 Mr. Huang worked for the Department of Commerce, correct? 4 A Yes. Yes. But did he mention Independent Counsel, 5 those words, that I don't know. It is very difficult. He is 6 under investigation. 7 Q Now, what did Mr. Huang tell you why being under 8 investigation, Secretary Brown, would make it impossible to 9 meet? 10 A No, and I don't care. That's not my wish list to 11 know. 12 Q But some of the people in that room asked, didn't 13 they? 14 A No. No. The people didn't really care. Pictures. 15 Larry, pictures. 16 Q Pictures are worth gold. 17 A Pictures are worth a ton of gold. Worth a ton of 18 gold. 19 Q Now, was that the second time you had seen John 20 Huang or had you seen him more than one other time? You 21 testified the first time, on July 9th, you saw him when you 22 went over to the White House so you could try to get 23 Taiwanese put on your passport, right? 24 A Yes. 25 Q You testified that -- 51 1 A That's one time. 2 Q -- that you didn't feel that close to him because 3 he's native Chinese and you're Taiwanese. 4 A Yes. 5 Q You didn't think he had any business being there. 6 A You asked me the question, am I Houka. I tried to 7 ask my father, he said maybe our ancestors but you are not. 8 Q Well, I meant that positively. Houkas are very 9 hard working people. 10 A Yes. Yes. But I think maybe ten generation before 11 me is Houka. I don't know. I am not. 12 Q Okay. 13 A That's a good question. I asked my father. 14 Q Okay. But had you ever talked to Huang before you 15 had contact over getting in to meet Ron Brown, between the 16 time you saw him at the White House to have your passport and 17 other people's passports changed to country of origin Taiwan, 18 as opposed to China, had you talked to him between that time 19 and the time you talked to him about getting you and the 20 delegation in to see Ron Brown? 21 A I don't remember I had contacted him about that, 22 but it could be. The end of '95, I had one phone call asked 23 me to join them -- I'm sorry, correction. Summertime of '95, 24 I had one phone call from John Huang asking me to join them 25 for the fundraising party, but I always talked to my former 52 1 general manager. 2 I don't like to go to the group -- a big group of 3 Asian-American together because with my experience it will 4 always create a lot of trouble, so I don't even bother to 5 make a phone call, to answer the phone call, or to call him 6 back. Which I have made a right decision, up to today, I 7 still save my own skin, I don't get involved too much. 8 Q In fact, you had a number of telephone 9 conversations with Mr. Huang between the time that you first 10 met him at the White House over the passport matter and the 11 time that you talked to him about getting the delegation and 12 yourself in to see the President. 13 MR. SUN: Objection. Misstates the testimony. 14 Argumentative. 15 JUDGE FACCIOLA: Overruled. He can correct it if 16 he wishes. 17 MR. KLAYMAN: Correct? 18 THE WITNESS: Answer? 19 MR. KLAYMAN: Yes. 20 MR. SUN: And objection as to the term number of 21 times. 22 MR. KLAYMAN: I can show the telephone records, 23 Your Honor. We have them. 24 JUDGE FACCIOLA: Let me -- 25 MR. KLAYMAN: I'm making it easy, to move it along. 53 1 JUDGE FACCIOLA: Madam Reporter, would you please 2 read back the last question? 3 (The record was read back by the court reporter.) 4 THE WITNESS: Maybe I did, one phone call, maybe I 5 don't. I don't remember. That's the best answer I have. 6 BY MR. KLAYMAN: 7 Q Who contacted who? 8 A I think -- I think it is John Huang contacted my 9 office and normally I don't answer the phone calls and then 10 my general manager tell me -- I only remember he called me 11 and left a message. 12 Q And he called you, trying to refresh your 13 recollection -- 14 A Okay. Please. 15 Q To solicit political contributions. 16 A Join them to the fundraising party. That's the 17 word I want to use, join them to the fundraising party. 18 Q And he called you during the day, because you were 19 at work. 20 A I did not answer the phone. I did not know when he 21 called me, but obviously my former general manager, told me 22 that in the daytime. 23 Q And at the time he called you, you knew he was 24 working for the Commerce Department. 25 A That's correct. 54 1 Q And did you decide to give Mr. Huang -- did you 2 decide to give him what he asked for? 3 A No. 4 Q The solicitation for the money? 5 A No. The answer to this I want to say it again is 6 join me to the fundraising party, join them, okay? Them. 7 That mean Asian American. And then I said to you I don't 8 want to be there with that group of people. I know how it 9 happens, chaos. 10 Q Why didn't you want to be there? You said you 11 don't want to be there with a group of people. Why? 12 A Well, it kind of -- sometimes it will be kind of 13 marketplace. Larry, have you been Chinese restaurant? 14 Q Sure. 15 A Very noisy. Very noisy. 16 Q So you wanted individual attention, right? You 17 didn't want to be there with a lot of other people. 18 A Exactly. 19 Q For the money you were giving, you wanted 20 individual attention, right? 21 A That's correct. That's what I pay for. 22 Q Now, when you had this discussion with Mr. Huang 23 when he came over to the J.W. Marriott, he said he had come 24 on behalf of Ron Brown to give you the message, correct? 25 MR. SUN: Objection. 55 1 THE WITNESS: No. 2 MR. SUN: No foundation. 3 MR. KLAYMAN: He can respond. 4 JUDGE FACCIOLA: Overruled. 5 THE WITNESS: No. No. That is not the words. 6 That is the situation, I asked him to come over and explain 7 to this group of people. They are my guests. And then one 8 of the wish list, I wished them to do it and I asked John 9 Huang to explain to them why is not appropriate time for Ron 10 Brown to meet them. 11 BY MR. KLAYMAN: 12 Q But you understood -- 13 A I asked. 14 Q Okay. At that time, you understood that John 15 Huang, working at the Commerce Department, was in a position 16 to speak for Ron Brown. That's why you asked him to come 17 over. 18 MR. SUN: Objection. Calls for speculation. 19 Argumentative. 20 JUDGE FACCIOLA: Overruled. 21 THE WITNESS: I think he worked in Department of 22 Commerce and someone with that position to explain would be 23 appropriate to save my face. 24 BY MR. KLAYMAN: 25 Q But you knew -- the question was that John Huang by 56 1 virtue of his position at the Commerce Department could come 2 over and speak on behalf of Ron Brown on this matter. 3 MS. BRASWELL: Same objection. 4 MR. KLAYMAN: That's why you contacted him. 5 MS. BRASWELL: Speculative. 6 MR. KLAYMAN: You can respond. 7 MR. SUN: I join, Your Honor. 8 JUDGE FACCIOLA: Overruled. Overruled. 9 THE WITNESS: No, I did not say that. Because I 10 asked him to come over on behalf of me to save my own face, 11 to talk to those people, that is the purpose I asked him to 12 come over. I can't say that. 13 BY MR. KLAYMAN: 14 Q Let me back up a little bit. You know that John 15 Huang had a high position at the Commerce Department, 16 correct? 17 A That's correct. 18 Q You knew that he worked with Ron Brown. 19 A That's correct. 20 Q You knew that John Huang was involved in issues 21 involving international trade. 22 A That I understand, yes. 23 Q And you knew he was involved in matters concerning 24 international trade in China at the Commerce Department. 25 A That I don't know at that time. 57 1 Q You found that out later. 2 A Later, after the campaign finance scandal. 3 Q Yes. 4 A Yes. Then, I don't know, okay? But I do know -- 5 Q But you thought he was in a position to be able to 6 relay information to this delegation that Ron Brown was not 7 available. 8 MR. SUN: Objection. Calls for speculation. 9 MR. KLAYMAN: Correct? 10 JUDGE FACCIOLA: Overruled. 11 THE WITNESS: Your Honor, can I say fifty-fifty? 12 JUDGE FACCIOLA: If that's your best answer. 13 BY MR. KLAYMAN: 14 Q Okay. What do you mean by fifty-fifty? 15 A He come over under my request and he's also 16 Asian-American. And then I met him once or twice and this is 17 what I call an important delegation, VIP, and for me it's 18 easier to ask him as Asian-American to Asian-American, would 19 you please do me a favor for this. And why I want to do 20 that, because I also -- the other 50 percent, he working for 21 Department of Commerce, so, yes, what he said is more 22 powerful than anybody in the street or any department 23 official. That's why I said fifty-fifty. 24 Q You wouldn't have called someone over to say 25 something to this Chinese delegation that wasn't true, 58 1 correct? 2 A That's correct. 3 Q You didn't intend to lie to them, just to have 4 anybody come in and give them nonsense, correct? 5 A That's correct. 6 Q So you believed that Huang could speak for Brown, 7 correct? 8 MS. BRASWELL: Objection. 9 JUDGE FACCIOLA: Overruled. 10 MR. SUN: Same objection, Your Honor. 11 JUDGE FACCIOLA: Overruled. 12 THE WITNESS: I believed he is a Department of 13 Commerce official and when he explained to them it was more 14 powerful than the people in the different department or 15 people in the street. 16 BY MR. KLAYMAN: 17 Q But you also believed that he would have the 18 authority to talk to the delegation, he being Huang. 19 MR. SUN: Objection. Asked and answered. 20 JUDGE FACCIOLA: Overruled. 21 THE WITNESS: Again, I want to repeat my answer. 22 I think that he got the power to explain to those people 23 better than other department official. And also can save my 24 face. 25 MR. KLAYMAN: So the answer is yes. 59 1 MS. BRASWELL: Objection. 2 JUDGE FACCIOLA: The answer is the answer. 3 MS. BRASWELL: Yes. 4 MR. KLAYMAN: Well, it sounds like yes to me. 5 MR. SUN: Your Honor -- 6 MR. KLAYMAN: That is what he said. 7 MS. BRASWELL: I didn't hear a yes in it. 8 JUDGE FACCIOLA: Please, don't quibble. Let's go 9 on. Move on, please. 10 MR. KLAYMAN: There's one thing I don't understand 11 here, Your Honor, just for the record, okay? We seem to be 12 having an advocate's role being played by these counsel here, 13 okay? I just want to get the facts out. 14 JUDGE FACCIOLA: Well, they're lawyers. 15 MS. BRASWELL: What a novel idea. 16 MR. SUN: I'll take that as a compliment, 17 Your Honor. 18 MR. KLAYMAN: Given the nature of this case, we 19 should get the information out. I don't understand why 20 they're taking an advocate's role in this issue, just let him 21 answer. 22 JUDGE FACCIOLA: What can you do? I mean, bears 23 sleep in the woods, lawyers make objections. It just comes 24 with the territory. 25 MR. KLAYMAN: I know objections, but I just want to 60 1 get the truth out. 2 JUDGE FACCIOLA: I understand. 3 MR. KLAYMAN: I think he's willing to give the full 4 truth. 5 JUDGE FACCIOLA: I think he's very refreshingly 6 candid, frankly. 7 THE WITNESS: Always. 8 BY MR. KLAYMAN: 9 Q You understood when Mr. Huang came over to speak to 10 the delegation that he was a Democratic fundraiser. 11 A No, I don't. No, I don't. At that time, I don't. 12 Q You did later. 13 A Yes. 14 Q At what point later did you understand that? 15 A When he called my office for that join them to the 16 fundraising party. 17 Q Then you knew what he really was. 18 MS. BRASWELL: Objection. Vague. 19 JUDGE FACCIOLA: Overruled. Overruled. 20 THE WITNESS: After what incident happened to me, 21 inside the White House with that radio address, I became to 22 know a little bit more better in this time. And I begin to 23 understand a little more clearly. But during that time, at 24 that meeting at the J.W. Marriott, I don't know he is a 25 fundraiser. 61 1 BY MR. KLAYMAN: 2 Q Yes, but, again, I'm going back to when it finally 3 hit you, that you knew that he really was a Democratic 4 fundraiser when he called you and solicited you for that 5 event. 6 A That's correct. 7 Q Now, there did come a point in time when you did 8 meet with Ron Brown eventually. You did meet him in China, 9 right? 10 A I counted three times. Not in China, three times, 11 in China one time. 12 Q You met him during the trade mission in '94. 13 A Yes. And in 1992 when then governor Bill 14 Clinton -- November 20, 1992. I was doing my fax broadcast 15 business promotion in Little Rock, Arkansas and he come to 16 the hotel, Excelsior, I think the name is. I have a picture 17 taken with him. 18 And the third time is somewhere in Washington, 19 D.C., I believe it's a fundraising party. Fundraising party. 20 I don't remember which one or where is it. I have two 21 pictures, so I remember that. 22 Q Was that in '94 or '95? 23 A Could be '94. Your Honor, I say could be. 24 JUDGE FACCIOLA: I understand. 25 THE WITNESS: At the 48 years old birthday. My 62 1 very first time political contribution. I don't have the 2 pictures. 3 BY MR. KLAYMAN: 4 Q What you talked about last time. 5 A Yes. We talked about that. 6 Q The President's forty-eighth birthday. 7 A That's correct. But I don't have the pictures, so 8 I don't remember. But three times. 9 Q And you may have met him at that time. 10 A Which time? 11 Q The forty-eighth birthday party. 12 A Okay. 13 Q You introduced yourself. 14 A Yes. And also I introduced my friends, they're all 15 Asian-Americans. 16 Q Who was that? 17 A I told you that last time already. The same group 18 of people we went to the passport issue. 19 Q And did you tell Ron Brown I'd like to go on one of 20 your trade missions at that time? 21 A No. No. I don't even know there's a trade mission 22 yet. 23 Q That you found out later from Jude Kearney. 24 A Yes. 25 Q Okay. Now, you testified that -- this is the other 63 1 information that hasn't come out yet, that there's 2 information about Hazel O'Leary. Tell us about that. 3 MR. SUN: Same objection, Your Honor. 4 JUDGE FACCIOLA: All right. Overruled. 5 THE WITNESS: Again, I went back to DNC and asked 6 with my point of contact, Mr. Richard Sullivan, I have the 7 group of people from China which they call SINOPEC, China oil 8 company, they want to meet with the secretary, Hazel O'Leary. 9 And at the third floor of the DNC by the elevator, there's 10 two person introduced me, one is -- two person introduced me 11 to Mr. Wilson Golden. 12 BY MR. KLAYMAN: 13 Q Wilson Golden? 14 A Yes. 15 Q How is that spelled? 16 A Wilson Golden. 17 Q All right. Golden. Okay. 18 A And that two person, one is Carol Khare, one is 19 Richard Sullivan, and asked me to say hi to this gentleman 20 and he is also very active in the DNC. That's what they said 21 to me. And at that time, I already talked to both of them, 22 which is Carol Khare and Richard Sullivan, I would like to 23 set up a meeting for this delegation meeting with then 24 Secretary Hazel O'Leary and also hope we get a chance to meet 25 with the President. 64 1 They set it up for me to meet with this gentleman 2 which is by accident, but later on I find it out maybe could 3 not be the accident, it was in the timing. And then this 4 gentleman immediately invite -- Wilson Golden immediately 5 invite me to have lunch at the Navy-Army Club right here at 6 Washington, D.C. 7 And the whole entire afternoon with that lunch I 8 was not really concentrating with that kind of lunch because 9 I really wanted to get my wish list to be granted again. And 10 then I said what I really want and he begin to tell me he 11 know somebody in the Department of Energy. The lady he 12 called and set up a meeting for me is -- what is the name 13 again -- I have to think a little bit. I can't give you -- 14 again, it's under my interview with Tom Brokaw, it's there. 15 She is the director of some department of the Department of 16 Energy. 17 I called her up and set up the meeting. I went 18 into the office, I told them what I wanted and she said to 19 me, the best recollection I can give -- 20 Q The woman's name is Corlis Moody. 21 A Corlis Moody. Thank you to remind me. And then I 22 went into the room and then talked to tell her what is my 23 wish list. And she said to me we are going to have an 24 Africare party which the President is going to be there and 25 Secretary of Energy she also will be there. It will be nice 65 1 if you can contribute to it. 2 And I said how much it will be and I remember she 3 said $25,000 for the table. And I knew if I pay for it then 4 I will be granted my wish list again. I said, yes, I will. 5 And then the following the next day or two, I been 6 talking to -- 7 Q Let me stop you there. When you talked to Corlis 8 Moody, she said she was relaying this message from Hazel 9 O'Leary. 10 MR. SUN: Objection. Misstates the testimony. 11 JUDGE FACCIOLA: Overruled. 12 THE WITNESS: No. Not at that time. 13 BY MR. KLAYMAN: 14 Q But later she said that? 15 A Not even later at that time because I found it out. 16 Q You found it out yourself? 17 A Yes. 18 Q How did you find that out yourself? 19 A You want to go one, two, three? 20 Q All right. Let's go one, two, three. You'll tell 21 us later. 22 A Otherwise, it will confuse. 23 Q Okay. Go ahead. 24 A And then I been working very hard with the lady, 25 Corlis Moody, Ms. Moody, and asking her to write an 66 1 invitation to invite this group of people. They are over 2 there in Dallas or Houston. They have the corporate jet 3 provided by American oil company, they treat them VIP, they 4 are on their way from Texas to Chicago. 5 If I can set up the meeting with the invitation 6 they will fly with the corporate jet directly from Texas to 7 Washington, D.C. and later on go to Chicago. But in order 8 for them to have that, they want make sure I have invitation 9 from Secretary Hazel O'Leary. 10 So Ms. Moody and I were working over the phone 11 late. I really need it that night and she faxed over to me 12 the version. I asked her that is not a good version, you 13 should say something clearly. And then she faxed to me 14 another copy which is without a signature. She said to me 15 Secretary Hazel O'Leary already went home, the best thing we 16 can do is the next morning when she can she will ask her to 17 sign it and then will fax over to me. The timing is 18 different, so that still give me one extra hour between 19 Washington, D.C. and Texas. I say okay. 20 The next morning, the invitation arrive at my fax 21 machine. Then I immediately fax over to them and ask the 22 group in Texas to come over. And also she said to me there 23 is a gentleman from Department of Energy is coming to pick up 24 the check for $25,000 for Africare. And the gentleman came 25 into my apartment, knock on the door and coming in. I hand 67 1 it over to him, the $25,000 check and he looked at my fax 2 machine and that was the latest, they sent it to me fax. 3 He said to me I had to take those letter back. I 4 said why? He say the general counsel of Department of Energy 5 said that is not the way should write it. It's really 6 appropriate or legal to write it. 7 I said fine, take it, I just wanted to make sure 8 the meeting is granted and we will be there. And he 9 retrieved all of the letters. That's why I do not have a 10 copy. 11 Q The faxes which you received from the Department of 12 Energy came from the Department of Energy, off of their fax 13 machine? 14 A Say that again, your question? 15 Q The faxes that you got -- 16 A Yes. 17 Q -- that he took back were sent from the Department 18 of Energy. 19 A That's correct. 20 Q And the faxes contained the signature of Hazel 21 O'Leary. 22 A The next day. Yes. The one is without and the 23 second one is with. 24 Q And he took back the one without the signature and 25 the one with her signature. 68 1 A That's correct. 2 Q And he told you the general counsel told him to do 3 this. 4 A That's correct. 5 Q And -- 6 A Not general counsel. He said the general counsel 7 said it's not appropriate or legal to write such kind of 8 letter and they had to take it back. 9 Q And who was this man? 10 A This is -- I never know the name, I don't remember, 11 but FBI provided me six pictures of African-American. I give 12 them a description. I think I positively identified him, but 13 I still did not know the name. They showed me six pictures, 14 a photo line up. 15 Q Did you know the name at the time? 16 A I don't know. Up to today, I still don't know. 17 Q But you knew that he worked with Hazel O'Leary. 18 A She said to me and he said to me when he come to 19 pick it up, I work at the Department of Energy. 20 Q And you knew that he worked in Secretary O'Leary's 21 office. 22 MR. SUN: Objection. Misstates the testimony. 23 MR. KLAYMAN: You can respond. 24 JUDGE FACCIOLA: Overruled. 25 THE WITNESS: I don't know, but I did see him 69 1 talking to Ms. Moody at Ms. Moody's office. 2 BY MR. KLAYMAN: 3 Q And what was Ms. Moody's position? 4 A Director of some -- I have her business card, but I 5 don't know. Director at Department of Energy. 6 Q And you knew she worked with Hazel O'Leary. 7 A That's correct. 8 Q And -- 9 A Can I say that she worked for Hazel O'Leary 10 closely, I can feel that. 11 Q You can feel that. 12 A Yes. 13 Q And do you know who the general counsel of the 14 Department of Energy was at the time? 15 A I don't care. 16 Q This whole sequence of events occurred when in 17 time? Approximately. 18 A My memory isn't good, only the time -- the time and 19 the person's name is not good, so if you would help me on the 20 news account. 21 Q Ms. Moody worked as the Director of Economic Impact 22 and Diversity. 23 A That's correct. That's correct. If you would help 24 me on the -- should be on the -- 25 MR. KLAYMAN: I'll show you what has already been 70 1 marked as an exhibit. I'll get you the number. It's the 2 article "Johnny Chung's Tale of Cash and Access." Exhibit 3 10. And ask you if this helps you remember the date. Turn 4 to page 5 of 7. 5 MS. BRASWELL: Could I see what everyone's looking 6 at? 7 MR. FITTON: It's a copy of the exhibit. 8 JUDGE FACCIOLA: Where is the -- 9 MR. FITTON: It's Exhibit 10. It's in the back, 10 Your Honor. 11 MR. KLAYMAN: Look at page 5, where it says October 12 17th. 13 THE WITNESS: October -- page 5? 14 MR. KLAYMAN: Yes. I'm only showing you this -- 15 page 5 -- 16 MS. BRASWELL: Page -- are we looking here or here? 17 MR. KLAYMAN: Page 5. 18 THE WITNESS: That's correct. 19 BY MR. KLAYMAN: 20 Q Of what year? 21 A 1995. 22 Q 1995. Now, you ultimately gave the money -- you 23 presented the $25,000 to Africare, correct? 24 A That's correct. 25 Q The check was made out to Africare, correct? 71 1 A That's correct. 2 Q The check was cashed, correct? 3 A Yes. 4 Q You never got the money back. 5 A Never. 6 Q Okay. And you had a wish list that you wanted for 7 that $25,000, correct? 8 A That's correct. 9 Q Okay. And what was on that wish list? 10 A One is the meeting with the Secretary of Energy, 11 Hazel O'Leary. And then the meeting with the President of 12 the United States to get a photo op. And the third one, I 13 don't really call wish list because we just wanted to have a 14 very short tour. I already got it, which is I don't need to 15 put it on the wish list for that. I asked George 16 Stephanopolous to help me. 17 Q What did you ask him to do? 18 A I was passing by inside the White House and I said 19 this is a group of people -- 20 Q You said what? 21 A I said this is a group of business people and I 22 want to show them around inside the White House, would you 23 help me and he said yes. And he greeted them in the driveway 24 of the White House. 25 Q You had known George Stephanopolous before that? 72 1 A Yes. 2 Q How did you meet him? 3 MS. BRASWELL: Your Honor, I'm going to object to 4 this continued line of questioning, none of which seems to 5 relate to the Department of Commerce. It hasn't even been 6 mentioned -- 7 JUDGE FACCIOLA: Yes. Where are we going with 8 this? 9 MR. KLAYMAN: It's a course of conduct, Your Honor, 10 and we do have -- 11 MS. BRASWELL: That's pretty vague. 12 JUDGE FACCIOLA: Well, the course of what conduct? 13 MR. KLAYMAN: It's the same kind of conduct that's 14 been going on, selling off of government services for 15 campaign contributions. 16 MS. BRASWELL: Your Honor, that has nothing to do 17 with the Department of Commerce. This case is not about the 18 entire campaign finance issue. 19 MR. KLAYMAN: But it's about people that played a 20 role in that and this obviously bears on their general 21 conduct, Your Honor. I just have -- 22 MS. BRASWELL: It must be related to the Department 23 of Commerce and documents to have any relation to this case 24 whatsoever. 25 MR. KLAYMAN: That's not true. 73 1 JUDGE FACCIOLA: Okay. I'm going to give you just 2 a very brief bit of latitude, Mr. Klayman. 3 MR. KLAYMAN: Okay. Thank you, Your Honor. 4 JUDGE FACCIOLA: Close up this inquiry and move on 5 to something else. 6 MR. KLAYMAN: Okay. Thank you. 7 BY MR. KLAYMAN: 8 Q Where had you met Mr. Stephanopolous before? 9 A One time when I was in Indonesia, okay? Which is 10 the only time I was there, it was APEC. Again, it was 11 American businessmen came there. And he speak to the 12 American businessmen. And the second time was one of the 13 fundraisers at home, in Los Angeles, that's why I took one 14 picture with him. 15 Q And when you were at the APEC meeting in Indonesia, 16 that was -- Ron Brown was there, too, right? He was there. 17 A I don't know, but I know the President was there. 18 Q President Clinton? 19 A Yes. President Clinton. Yes. 20 Q And John Huang was there, right? 21 A I didn't know. I didn't know. Again, I am 22 individual to go there, to see it. I don't know. 23 Q You knew that a family called the Riady family was 24 from Indonesia at that time, correct? 25 MR. SUN: Objection. 74 1 THE WITNESS: No. 2 MR. SUN: No foundation. 3 JUDGE FACCIOLA: Sustained. 4 BY MR. KLAYMAN: 5 Q Since you already my question -- 6 A I already answered. No. I knew their name in 7 1997. 8 Q Now, did you get your meeting with the President? 9 A I don't really care at that time because I wanted 10 no business opportunity or anything there. 11 MR. SUN: Are you referring to the Hazel O'Leary -- 12 MR. KLAYMAN: The wish list. The wish list. 13 MR. SUN: He's referring to the Hazel O'Leary 14 matter. 15 MR. KLAYMAN: Yes. 16 THE WITNESS: I thought we were still talking about 17 Indonesia. 18 MR. KLAYMAN: No, we're talking about the President 19 now and your wish list. We're back to the wish list. 20 THE WITNESS: Yes. Yes. Probably a three-minutes 21 meeting. 22 BY MR. KLAYMAN: 23 Q A three what meeting? 24 A Three minutes. 25 Q Three minutes. Okay. When was that? 75 1 A Again, very confused. Seems to be I talked to 2 Ms. Moody, that was I give you $25,000, how come I cannot get 3 a meeting with the President? And then I have to trudge 4 myself all the way through the line of people and I said to 5 the person -- and I also asked Wilson Golden, remember that 6 gentleman -- that he helped me out, I said, hey, I give you 7 guy $25,000, how come I don't get a chance to have a private 8 meeting, just even a couple of minute photo op? And then 9 this is not appropriate with 1000 people over here taking a 10 picture like that, it is not appropriate. 11 And if it wasn't Golden's help or it was myself to 12 go all the way, and I believe I also talked to one of the DNC 13 employee, African-American, I don't remember the name, but I 14 see him -- I remember seeing him also from Arkansas, I 15 believe, and then later on when I see -- when I am face to 16 face with the President, I say I have a group of people, 17 Mr. President, I would like you to meet with them. He say, 18 yes, okay, bring over to the back stage. 19 And then we was escort by -- I don't remember the 20 name, the gentleman who was very close with the President, 21 always carry a suitcase, Goodin? Mr. Goodin or something 22 like that. Young man. And then we were escorted to him and 23 then a handshake and this gentleman from -- the president of 24 SINOPEC explained to the President why he is here, he was 25 invited by major oil company, and they want to do business 76 1 with an American oil company and that it is a pleasure to 2 meet with him and taking the pictures. 3 And we never get the pictures. Handshake and they 4 provided the gentlemen with their own translator. He got his 5 professional official to translate. I don't pay too much 6 attention to that. 7 I remember what the President say to the gentlemen. 8 I also remember, I said, Mr. President, this is the gentleman 9 who helped to rescue Harry Wu back there in China. And he 10 said thank you and he said Johnny is a good friend, Johnny 11 did a lot. 12 And then really what they want is a handshake and 13 take pictures and that was it. I tried to ask for the 14 pictures so many time, I never get them. 15 Q Is there anything else? 16 A No. 17 Q Did you have any other meetings with the President 18 for that $25,000? 19 A No. 20 Q Was the African-American that you've referred to, 21 is his name Ernie Green from the DNC? 22 A No. 23 Q The people that were with you when you met the 24 President, when the President said Johnny's a good friend, 25 they were from China? 77 1 A Yes. Those were only the president of SINOPEC and 2 professional translator and me and the President, surrounded 3 by the Secret Service. 4 Q And did the President say anything directly to the 5 SINOPEC people? 6 A Can I have your question one more time? 7 MR. SUN: Objection. Asked and answered. 8 JUDGE FACCIOLA: Overruled. 9 BY MR. KLAYMAN: 10 Q What did the President say to the SINOPEC people? 11 A I don't remember. The only thing I know is he went 12 to walk away as soon as he can. He just listened and said 13 thank you and then he went to walk away as soon as he can. 14 He had tea or coffee in his hand. 15 Q Now, is there anything else about this Hazel 16 O'Leary story that hasn't come out yet that you haven't had a 17 chance to tell us yet? 18 A Yes. Referring to the first question you asked me, 19 I say one, two, three. 20 Q Right. 21 A This is number three. After the meeting with the 22 President and then everybody getting to the room, sit down, 23 and then my table is pretty much empty because of this group 24 of people already had meeting with Hazel O'Leary, already 25 have meeting with the President, very short, 30-minute tour 78 1 in the White House, they had to go all the way back to D.C. 2 airport to get into their corporate jet headed to Chicago. 3 They have a final meeting the same day with chairman and CEO 4 of the major oil company. 5 So for $25,000 I pay, the table is empty and then 6 very close to the stage, so Mr. Wilson Golden take advantage 7 and invite a few friends to join me with the empty table. 8 And at that time, there are all Secret Service with the ten 9 or twelve, the president of every country is there, there is 10 no way you can get closer to the President during that time 11 or even Secretary Hazel O'Leary. She came down to me. She 12 said that was nice meeting, right? Thank you, Johnny. 13 Q Hazel O'Leary said that? 14 A Yes. 15 Q And you took that to mean that I arranged that 16 meeting for you. 17 A That I -- say your question one more time. 18 Q You took that to mean that Hazel O'Leary was saying 19 that I arranged that meeting for you and thank you for the 20 $25,000. 21 A That's correct. 22 Q Now, have you now told us everything about the 23 Hazel O'Leary story? There's a little more, isn't there? 24 A That was it. 25 Q That's it? Okay. Now, have you been asked to 79 1 provide any testimony to an independent counsel concerning 2 Hazel O'LEary? 3 MS. BRASWELL: Objection. 4 JUDGE FACCIOLA: Sustained. 5 BY MR. KLAYMAN: 6 Q You next said the things that you hadn't talked 7 about before that no one knows yet are about two groups of 8 people that are after you. Who are those two groups of 9 people? 10 MR. SUN: Objection. Relevance, Your Honor. I 11 don't know -- 12 JUDGE FACCIOLA: Well, it might bear on the 13 potential bias of the witness, so I'll allow a brief inquiry. 14 MR. KLAYMAN: Well, it also bears on potential 15 witness tampering, Your Honor. 16 JUDGE FACCIOLA: That's what I meant. Let's go. 17 MR. KLAYMAN: Yes. The ultimate bias. 18 Please answer. 19 MR. SUN: Answer the question. 20 THE WITNESS: During my whole family under 21 government protection, 24 hours a day, the tension is very 22 high, not easy for my children. I want to know why we've 23 been removed from my house. I asked the question, I got the 24 answer from the FBI. 25 There is four people from China that have no 80 1 business here during that time they came. The moment they 2 leave China, Beijing airport, has been monitored by the FBI. 3 They been following these four gentlemen, Los Angeles, Las 4 Vegas, Honolulu, Hawaii, back to Tokyo, Japan. When they see 5 them leave the plane from Tokyo headed to China, they let me 6 know. All the incident. 7 The second group they know that is two gentlemen 8 and one lady. They stopped them at the airport, the Los 9 Angeles International Airport. What they said to me, they 10 send them back on the same airplane. 11 And the third one I just said to you is I am a 12 witness for the ongoing investigation, that Asian-American 13 lady. 14 MR. KLAYMAN: Well, we'll get to that. 15 THE WITNESS: And the fourth one is the 16 Italian-American. 17 BY MR. KLAYMAN: 18 Q Now, these people that were -- that you discussed, 19 the two groups you've just discussed, they were from China. 20 A My best knowledge from the FBI. 21 Q What, if anything, were you told as to why they 22 were sent to the United States? 23 A FBI have the -- okay. I want to make it official.