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, : Volume 4 : Defendant. : : - - - - - - - - - - - - - - -x Washington, D.C. Monday, May 3, 1999 Deposition of JOHN HUANG 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 10:08 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 Assistant United States Attorney U.S. Attorney's Office 555 Fourth Street, N.W. 12th Floor Washington, D.C. 20001 ELISE PACKARD, 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: TY COBB, ESQ. JOHN C. KEENEY, JR., ESQ. Hogan & Hartson, LLP 555 13th Street, N.W. Washington, D.C. 20004 Also present: Thomas Fitton, President, Judicial Watch Jason Aldrich, Esq., Judicial Watch 3 C O N T E N T S EXAMINATION BY: PAGE Counsel for Plaintiff 6 HUANG DEPOSITION EXHIBITS: No. 40 Memorandum to Ann Hughes, et al., from Charles Meissner, Subject: Principal Deputy Assistant Secretary John Huang's Arrival 18 No. 41 Memorandum of January 31, 1994 to H. James Reese, Personnel Officer, Office of Human Resources, from Paul A. Buskirk, Chief, Personnel Security Operations Division, Office of Security, Subject: Waiver Request for John (NMN) Huang 24 No. 42 Executive Branch Personnel Public Financial Disclosure Report 26 No. 43 John Huang, resume of background and qualifications 26 No. 44 Letter dated February 17, 1993 to John Emerson from David Roberti and Maely Tom 35 No. 45 Handwritten note to Jerry Stern from John Huang re: Charles DeQueujoe 38 No. 46 Memorandum for Bruce R. Lindsey from Gary Christopherson, Associate Director, Presidential Personnel, dated October 18, 1993, re: John Huang, Deputy Assistant Secretary for East Asia and the Pacific, International Trade Administration, U.S. Department of Commerce, SES Position 40 No. 47 Memorandum for Bruce Lindsey from Gary Christopherson, Associate Director, Presidential Personnel, Eileen Parisi, White House Liaison, Department of Commerce, dated December 6, 1993 48 4 HUANG DEPOSITION EXHIBITS: No. 48 Memorandum to William H. Kennedy, III, Associate Counsel, from Peg Clark, re: SES Appointment at Department of Commerce, December 30, 1993, and essential information, position and agency personal, data and contact information 49 No. 49 Presidential Transition Resume Routing Form, James Riady, January 11, 1993 53 No. 50 Letter dated January 7, 1992 to Mochtar Riady from Ron Brown 54 No. 51 Letter dated January 7, 1993 to Ron Brown from John Huang 61 No. 52 Letter dated September 10, 1993 to Ron Brown from John Huang 63 No. 53 Scheduling recommendation 64 No. 54 Letter of October 20, 1993 to James Riady from C.J. Giroir, Jr. 70 No. 55 Letter dated October 7, 1993 to Jack Quinn from John Huang 76 No. 56 Letter dated August 30, 1994 to Giroir from Terry Ogletree 85 No. 57 Letter dated November 25, 1997 to Larry Klayman from Brian DiGiacomo, with attachments 89 No. 58 Article dated July 25, 1997 by Pete Yost, "White House Had Controversial Guest" 95 No. 59 Washington Post article dated November 14, 1997 by Bob Woodward, "FBI Had Overlooked Key Files in Probe of Chinese Influence" 131 No. 60 Facsimile sent to John Huang by Melinda Yee 183 5 HUANG DEPOSITION EXHIBITS: No. 61 Memorandum dated September 21, 1994 to John Huang from Joe Hanna, re: Arkansas Delegation List 183 No. 62 Memorandum to Mack McLarty and John Podesta from Bruce Lindsey, re: Arkansas Delegation to APEC 184 No. 63 Memorandum dated September 29, 1994 to Jeffrey Garten from Charles Meissner re: Our missed breakfast and dinner and memorandum for Chuck Meissner from Jeffrey Garten of October 4, 1994 195 No. 64 Washington Times article dated April 9, 1999 by Jerry Seper, "Chinese Money was routed through Lippo Link to the Clinton Campaign" 213 No. 65 Washington Times article dated July 1, 1997 by Jerry Seper, "Did Huang's briefings put lives at risk? Solomon wants White House to talk," 227 No. 66 Wall Street Journal article November 13, 1996, "Huang Talked to Fundraisers While Working at Commerce" 238 No. 67 Memorandum dated April 9, 1996 to John Huang from Maely Tom 272 No. 68 Memorandum dated February 10, 1995 to Mary Ann McFate from John Huang re: Freedom of Information requests 275 No. 69 Document inventory for Ira Sockowitz 283 No. 70 Floor plan of Stephens Inc. 289 No. 71 John Huang's offices at Commerce and Stephens Inc. 290 No. 72 Photocopies of three photographs 312 6 1 P R O C E E D I N G S 2 THE VIDEOGRAPHER: Good morning. This is the 3 continuing deposition of John Huang taken by the counsel for 4 the Plaintiff in the matter of Judicial Watch, Inc. v. U.S. 5 Department of Commerce, Case No. 95-0133 on this date, May 3, 6 1999, and at the time indicated on the video screen, which is 7 10:03 a.m. 8 MR. KLAYMAN: Larry Klayman, General Counsel and 9 Chairman for Judicial Watch. 10 MR. FITTON: Tom Fitton, President, Judicial Watch. 11 MR. COBB: Ty Cobb and Jack Keeney on behalf of the 12 deponent, John Huang. 13 MS. BRASWELL: Marina Braswell from the U.S. 14 Attorney's office on behalf of the Department of Commerce. 15 MS. PACKARD: Elise Packard, Office of the General 16 Counsel, Department of Commerce. 17 Whereupon, 18 JOHN HUANG 19 was recalled as a witness and, after having been previously 20 duly sworn, was examined and testified further as follows: 21 EXAMINATION BY COUNSEL FOR PLAINTIFF (RESUMED) 22 BY MR. KLAYMAN: 23 Q Mr. Huang, you are aware that you are still under 24 oath? 25 A Yes, sir. 7 1 Q I want to refer back to a deposition exhibit, 2 Huang Exhibit 17, which we showed to you during the last 3 deposition, the third part of your continuing deposition. 4 I'm showing you Exhibit 17, which consists of 5 Bates number 755, 756, 757 and 758, four pages. The Bates 6 number, that's the number at the bottom of the right-hand 7 column, 757 -- 8 Excuse me, Your Honor. 9 (Pause.) 10 I'm showing you that exhibit and the Bates number 11 757, do you see where it says "Draft" at the top and there is 12 an "Okay" underneath it? 13 A Mm-hmm. 14 Q Do you see that? 15 A Yes. 16 Q Okay. And then there is an arrow pointing to the 17 okay. 18 A Mm-hmm. 19 Q Did you make that marking on that document? 20 MR. COBB: Respectfully invoke, Your Honor, 21 consistent with the phraseology of -- 22 JUDGE FACCIOLA: May I please see the document? 23 The invocation of the privilege is sustained. 24 MR. COBB: Your Honor, just for the record, can it 25 be understood that when we invoke the privilege, we're 8 1 invoking it as he articulated it in response to the initial 2 questioning? 3 JUDGE FACCIOLA: That is expressly understood. 4 MR. COBB: Thank you, Your Honor. 5 MR. KLAYMAN: If I may take one moment. 6 THE VIDEOGRAPHER: We're going off video 7 record at 10:07. 8 (A brief recess was taken.) 9 THE VIDEOGRAPHER: We're back on video record 10 at 10:09. 11 MR. KLAYMAN: Now, I'm going to ask, Mr. Huang, 12 that we lay out in front of you Exhibits 32, 34, 35, 13 36, 37 and 38. We'll see if we can give you enough room 14 there. 15 MR. COBB: And not 33, Larry? 16 MR. KLAYMAN: Not for the moment. 17 MR. COBB: Okay. 32 and 34, 35 -- 36, 37 -- and 18 38? I'm sorry. 19 MR. KLAYMAN: Yes. 20 MR. COBB: Got it. 21 BY MR. KLAYMAN: 22 Q I'll turn your attention first to Exhibit 35. It's 23 a chronology, a Huang chronology. 24 MS. BRASWELL: What deposition number? 25 MR. KLAYMAN: 35. 9 1 BY MR. KLAYMAN: 2 Q The first entry on the second page under 1994, 3 January 31, 1994, wherein it states, "Secretary Brown sends 4 a memo that it's urgent to get clearance for John Huang 5 and that it be granted to him pending that he get a full 6 background in the future. FBI says they never did a 7 background." 8 Mr. Huang, did Ron Brown send a memorandum asking 9 for emergency security clearance for you in January, on or 10 about the 31st, of 1994? 11 MR. COBB: Respectfully invoke, Your Honor. 12 THE WITNESS: I invoke my privilege. 13 JUDGE FACCIOLA: The invocation of the privilege is 14 sustained. 15 BY MR. KLAYMAN: 16 Q Is it correct and do you have any knowledge as to 17 whether or not the FBI ever did a background check about you? 18 A I invoke my privilege. 19 JUDGE FACCIOLA: The invocation of the privilege is 20 sustained. 21 BY MR. KLAYMAN: 22 Q The entry of February 18, 1994, do you know whether 23 or not Melinda Lee called Wright, Lindsey and Jennings on 24 February 18, 1994? 25 A I invoke my privilege. 10 1 JUDGE FACCIOLA: The invocation of the privilege is 2 sustained. 3 BY MR. KLAYMAN: 4 Q The entry of March 28, 1994, "Mark Middleton calls 5 John Huang." And I turn your attention to Exhibit 34. 6 MR. COBB: Is there a page? 7 MR. KLAYMAN: Yes, I guess it doesn't have this 8 one. 9 MR. COBB: That's okay. 10 MR. KLAYMAN: Yes, it does. 11 BY MR. KLAYMAN: 12 Q Let me just ask the question, simply, did Mark 13 Middleton ever call you on or about March 28, 1994? 14 A I invoke my privilege. 15 JUDGE FACCIOLA: The invocation of the privilege is 16 sustained. 17 BY MR. KLAYMAN: 18 Q Who is Mark Middleton, Mr. Huang? 19 A I invoke my privilege. 20 JUDGE FACCIOLA: The invocation of the privilege is 21 sustained. 22 BY MR. KLAYMAN: 23 Q Is Mark Middleton a Democratic Party fundraiser? 24 A I invoke my privilege. 25 JUDGE FACCIOLA: The invocation of the privilege is 11 1 sustained. 2 BY MR. KLAYMAN: 3 Q Mark Middleton participated and/or attended the 4 trade mission to China in 1994, correct? 5 A I invoke my privilege. 6 JUDGE FACCIOLA: The invocation of the privilege is 7 sustained. 8 BY MR. KLAYMAN: 9 Q The entry of May 31, 1994, "Melinda Yee calls 10 Mitchell Selig law firm in Arkansas," which is Jim Guy 11 Tucker's law firm. 12 Are you aware that Melinda Yee called the Mitchell 13 Selig law firm in Arkansas on May 31, 1994? 14 A I invoke my privilege. 15 JUDGE FACCIOLA: The invocation of the privilege is 16 sustained. 17 BY MR. KLAYMAN: 18 Q Do you know whether or not the Mitchell Selig law 19 firm in Arkansas is Jim Guy Tucker's law firm? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: The invocation of the privilege is 22 sustained. 23 BY MR. KLAYMAN: 24 Q You are aware that at the time Melinda Yee was a 25 political appointee at the Department of Commerce, correct? 12 1 A I invoke my privilege. 2 JUDGE FACCIOLA: The invocation of the privilege is 3 sustained. 4 BY MR. KLAYMAN: 5 Q And you are aware that she went on the trade 6 mission to China in 1994? 7 A I invoke my privilege. 8 JUDGE FACCIOLA: The invocation of the privilege is 9 sustained. 10 BY MR. KLAYMAN: 11 Q The next page, entry of June 1994, do you 12 know whether or not in June 1994 a memo was sent from an 13 individual by the name of Chris Brown, Business Manager 14 for Entergy Power Development Group, which discussed a 15 meeting with Commerce officials regarding Entergy's China 16 projects? 17 A I invoke my privilege. 18 JUDGE FACCIOLA: The invocation of the privilege is 19 sustained. 20 BY MR. KLAYMAN: 21 Q Who is Chris Brown? 22 A I invoke my privilege. 23 Q Did he work for Entergy Corporation at the time? 24 A I invoke my privilege. 25 JUDGE FACCIOLA: The invocation of the privilege is 13 1 sustained as to both questions. 2 BY MR. KLAYMAN: 3 Q On or about June 29, 1994, you were called by David 4 Wilhelm, the chairman of the Democratic Party, twice. Is 5 that not correct? 6 A I invoke my privilege. 7 JUDGE FACCIOLA: The invocation of the privilege is 8 sustained. 9 BY MR. KLAYMAN: 10 Q On or about July 15, 1994, Melinda Yee called 11 LippoBank in Jakarta two times, correct? 12 A I invoke my privilege. 13 JUDGE FACCIOLA: The invocation of the privilege is 14 sustained. 15 BY MR. KLAYMAN: 16 Q On or about July 19, 1994, you, John Huang, 17 attended a meeting on Indonesian trade issues. At the time, 18 you worked for the Commerce Department, correct? 19 A I invoke my privilege. 20 JUDGE FACCIOLA: The invocation of the privilege is 21 sustained. 22 MR. COBB: Not withstanding that, can we invoke 23 your procedure briefly for a procedural -- 24 JUDGE FACCIOLA: Yes. The problem we're having 25 this morning is -- 14 1 MR. COBB: We don't have a separate court reporter? 2 JUDGE FACCIOLA: Yes, we do. We just have to give 3 her a call. 4 (Pause.) 5 MR. COBB: Your Honor, I'm content to proceed until 6 she gets here, if that's -- 7 JUDGE FACCIOLA: No, we're going to use this -- 8 MR. COBB: Okay. Fine. Thank you. 9 JUDGE FACCIOLA: She's portable. She can come in. 10 THE VIDEOGRAPHER: We're going off video record 11 at 10:15. 12 (A brief recess was taken.) 13 THE VIDEOGRAPHER: We're back on video record 14 at 10:20. 15 BY MR. KLAYMAN: 16 Q Mr. Huang, I'm going to ask that you turn to page 17 94063 of Exhibit 32, which is your appointment book of 1994. 18 It's the week of July 18th. 19 Before I ask you about July 19th, this calendar 20 book, 94063, that's the page of July 18th, let me ask you 21 about the first column, which is Monday, July 18th. It lists 22 at the top at 7:15 and 7:30, "Huang's first day." 23 Is that the first day that you began work at the 24 Commerce Department? 25 A I invoke my privilege. 15 1 JUDGE FACCIOLA: The invocation of the privilege 2 will be sustained. 3 MR. COBB: Just for clarification, I think -- I 4 could be wrong, but just for clarification, so the record is 5 accurate, at least the document in front of us indicates that 6 was on the 18th. 7 MR. KLAYMAN: That's what I meant, the 18th. 8 MR. COBB: I'm sorry. I thought you said the 19th. 9 MR. KLAYMAN: Yes. I was flipping back to the 10 18th. 11 MR. COBB: Okay. 12 BY MR. KLAYMAN: 13 Q Whose handwriting is that at 7:15 and 7:30, 14 Mr. Huang? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: The invocation of the privilege 17 will be sustained. 18 BY MR. KLAYMAN: 19 Q Is that your handwriting or your secretary's 20 handwriting? 21 A I invoke my privilege. 22 JUDGE FACCIOLA: The invocation of the privilege is 23 sustained. 24 BY MR. KLAYMAN: 25 Q At 9:15 it says "Staff introduction at 9:15." 16 1 Were you introduced to the staff at 9:15? 2 A I invoke my privilege. 3 Q Whose handwriting is that at 9:15? 4 A I invoke my privilege. 5 JUDGE FACCIOLA: The invocation of the privilege is 6 sustained. 7 BY MR. KLAYMAN: 8 Q Can you read the handwriting at 9:30? 9 A I invoke my privilege. 10 JUDGE FACCIOLA: The invocation of the privilege is 11 sustained. 12 BY MR. KLAYMAN: 13 Q At 10:45, it says "Nancy overview." 14 Was that in reference to Nancy Linn Patton? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: The invocation of the privilege is 17 sustained. 18 BY MR. KLAYMAN: 19 Q Did you know Nancy Linn Patton before you began to 20 work at the Commerce Department? 21 A I invoke my privilege. 22 JUDGE FACCIOLA: The invocation of the privilege is 23 sustained. 24 BY MR. KLAYMAN: 25 Q Was she one of the Asian-American appointees that 17 1 you recommended to the Clinton administration for 2 appointment? 3 A I invoke my privilege. 4 JUDGE FACCIOLA: The invocation of the privilege is 5 sustained. 6 BY MR. KLAYMAN: 7 Q Ms. Patton was to work at the Commerce Department 8 concerning Asia, correct? 9 A I invoke my privilege. 10 JUDGE FACCIOLA: The invocation of the privilege is 11 sustained. 12 BY MR. KLAYMAN: 13 Q And you worked closely with her at the Commerce 14 Department, correct? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: The invocation of the privilege is 17 sustained. 18 BY MR. KLAYMAN: 19 Q And Ms. Patton knows many of the things that you 20 did when you were at the Commerce Department, correct? 21 A I invoke my privilege. 22 JUDGE FACCIOLA: The invocation of the privilege is 23 sustained. 24 BY MR. KLAYMAN: 25 Q At 3:15 on July 18th, it says "Security briefings." 18 1 Did you have a security briefing on that day? 2 A I invoke my privilege. 3 JUDGE FACCIOLA: The invocation of the privilege is 4 sustained. 5 BY MR. KLAYMAN: 6 Q And at 6:00 p.m. it says "U/S Staff meeting 7 room 385." 8 Did you participate in a staff meeting on that day? 9 A I invoke my privilege. 10 JUDGE FACCIOLA: Excuse me just a second. 11 (Pause.) 12 JUDGE FACCIOLA: I'm sorry. Please go ahead. 13 MR. KLAYMAN: I'll show you what I'll ask the court 14 reporter to mark as the next exhibit. 15 MS. BRASWELL: I have the last one as Exhibit 39, 16 it's a photograph. 17 MR. KLAYMAN: Then we'll mark it as 40. 18 (Huang Deposition Exhibit No. 40 19 was marked for identification.) 20 BY MR. KLAYMAN: 21 Q I'm showing you Exhibit 40, Mr. Huang. This is a 22 memorandum to Ann Hughes, Lou Murphy, Nancy Linn Patton, Karl 23 Reiner, Marge Searing, Frank Vargo, Eleanor Lewis from 24 Charles Meissner, Subject: Principal Deputy Assistant 25 Secretary John Huang's Arrival. It consists of two pages. 19 1 Copy to Rob Stein, Jeffrey Garten, Timothy Hauser, David 2 Rothkopf, Ray Vickery, Lauri Fitz-Pegado, Sue Esserman. 3 Have you seen this document before? 4 A I invoke my privilege. 5 JUDGE FACCIOLA: The invocation of the privilege is 6 sustained. 7 BY MR. KLAYMAN: 8 Q Are the contents of this document correct? 9 A I invoke my privilege. 10 Q Are there any inaccuracies in this document? 11 A I invoke my privilege. 12 JUDGE FACCIOLA: The invocation of the privilege 13 will be sustained. 14 BY MR. KLAYMAN: 15 Q Mr. Huang, are you aware that during the Senate 16 Government Affairs Committee hearings in the fall of 1997 17 Jeffrey Garten testified and stated that you were not 18 qualified to be at the Commerce Department? 19 A I invoke my privilege. 20 Q Do you agree with Mr. Garten? 21 A I invoke my privilege. 22 JUDGE FACCIOLA: The invocation of the privilege is 23 sustained. 24 BY MR. KLAYMAN: 25 Q In fact, Mr. Huang, you have much more 20 1 international experience than Mr. Garten, correct? 2 A I invoke my privilege. 3 JUDGE FACCIOLA: The invocation of the privilege is 4 sustained. 5 BY MR. KLAYMAN: 6 Q And, in fact, you are an expert in Asian matters 7 and international trade, correct? 8 A I invoke my privilege. 9 JUDGE FACCIOLA: The invocation of the privilege is 10 sustained. 11 BY MR. KLAYMAN: 12 Q And you are an expert in banking? 13 A I invoke my privilege. 14 JUDGE FACCIOLA: The invocation of the privilege is 15 sustained. 16 BY MR. KLAYMAN: 17 Q Do you know why Mr. Garten would tell the Senate 18 committee under oath that you had no expertise to be 19 Principal Deputy Assistant Secretary for International 20 Economic Policy? 21 MR. COBB: In addition to the privilege, I have an 22 objection. 23 JUDGE FACCIOLA: What is it? 24 MR. COBB: That calls for him to inhabit 25 Mr. Garten's mind. 21 1 JUDGE FACCIOLA: I'll invoke the privilege and 2 since I have, we'll hear the rest of the question. 3 THE WITNESS: I invoke my privilege. 4 JUDGE FACCIOLA: Sustained. 5 BY MR. KLAYMAN: 6 Q Did you ever have contact with Jeffrey Garten when 7 you were at the Commerce Department? 8 A I invoke my privilege. 9 JUDGE FACCIOLA: The invocation of the privilege is 10 sustained. 11 BY MR. KLAYMAN: 12 Q During the time that you worked at the Commerce 13 Department or thereafter, did you ever become aware that 14 Mr. Garten and another individual by the name of David 15 Rothkopf had concerns about your being at the Department of 16 Commerce? 17 A I invoke my privilege. 18 JUDGE FACCIOLA: The invocation of the privilege 19 will be sustained. 20 BY MR. KLAYMAN: 21 Q Did Mr. Charles Meissner in any way violate the 22 instructions of Jeffrey Garten or David Rothkopf concerning 23 what subject matter you could work on while you were employed 24 by the Department of Commerce? 25 A I invoke my privilege. 22 1 JUDGE FACCIOLA: The invocation of the privilege is 2 sustained. 3 BY MR. KLAYMAN: 4 Q In fact, neither Mr. Garten nor Mr. Rothkopf ever 5 told Mr. Meissner that you could not work on Asian or China 6 matters. 7 A I invoke my privilege. 8 JUDGE FACCIOLA: The invocation of the privilege 9 will be sustained. 10 BY MR. KLAYMAN: 11 Q In fact, the testimony of Mr. Garten which he 12 provided to Congress that you were not to work on Asian or 13 China matters and Mr. Meissner was so instructed is false, 14 correct? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: The invocation of the privilege is 17 sustained. 18 BY MR. KLAYMAN: 19 Q Are you willing to -- 20 I'm sorry, go ahead. 21 MR. COBB: I'm sorry. I apologize for 22 interrupting, Mr. Klayman. 23 Your Honor, I just want to revisit a procedural 24 issue. It was my recollection, and just clarify this for 25 me if I'm wrong, that because of the record that we're 23 1 attempting to fashion here that in the event that either the 2 Department of Commerce has objections unrelated to the 3 invocation of privilege or that we do, that we can preserve 4 those in the event that Your Honor sustains the invocation of 5 privilege, but would have to articulate them separately in 6 the event that the Court does not? Is that -- 7 JUDGE FACCIOLA: I believe that was the 8 understanding we had. 9 Ms. Braswell, is that your recollection? 10 MS. BRASWELL: That was my understanding, 11 Your Honor, that the Court did not require us to make our 12 objections if the Fifth Amendment was being asserted because 13 the Court stated that if the Fifth Amendment privilege is 14 ever overruled then we will revisit the issue of whether or 15 not there are other objections to be made. 16 JUDGE FACCIOLA: Indeed. Thank you very much, 17 Ms. Braswell. 18 That is the mutual understanding under which we 19 are operating. 20 MS. BRASWELL: Consequently, we will not make 21 objections regarding the scope of discovery at this time. 22 JUDGE FACCIOLA: No question. Thank you, 23 Ms. Braswell. 24 MR. KLAYMAN: I'll show you what I'll ask the court 25 reporter to mark as Exhibit 41. It's a memorandum of January 24 1 31, 1994 to H. James Reese, Personnel Officer, Office of 2 Human Resources, from Paul A. Buskirk, Chief, Personnel 3 Security Operations Division, Office of Security, Subject: 4 Waiver Request for John -- paren, something's in there -- 5 Huang, H-u-a-n-g. 6 (Huang Deposition Exhibit No. 41 7 was marked for identification.) 8 BY MR. KLAYMAN: 9 Q Mr. Huang, I'm showing you Exhibit 41. Have you 10 ever seen this document before? 11 A I invoke my privilege. 12 JUDGE FACCIOLA: The invocation of the privilege is 13 sustained. 14 BY MR. KLAYMAN: 15 Q Did you have to fill out any paperwork to get 16 your request for a waiver of security clearance -- waiver 17 of background investigation. Excuse me. 18 A I invoke my privilege. 19 JUDGE FACCIOLA: The invocation of the privilege is 20 sustained. 21 BY MR. KLAYMAN: 22 Q What date were you born? 23 A I invoke my privilege. 24 JUDGE FACCIOLA: Hold on just a second. 25 Gentlemen, might I suggest, to move this along, 25 1 would you gentlemen be willing to stipulate with Mr. Klayman 2 independently of his testimony the date of your client's 3 birth? 4 MR. KEENEY: Your Honor, could we invoke the 5 procedure? 6 MR. COBB: I think we have to explain that to you. 7 There's a hidden issue here. 8 MR. KEENEY: Typically, yes, but there's a separate 9 issue, Your Honor. 10 MR. COBB: And in order -- on something like this, 11 maybe we should defer it until there's -- 12 JUDGE FACCIOLA: Well, no, I assume it's 13 preliminary to another question. We'll have to deal with 14 it. 15 THE VIDEOGRAPHER: We're going off video record 16 at 10:31. 17 (A brief recess was taken.) 18 THE VIDEOGRAPHER: We're back on video record 19 at 10:35. 20 JUDGE FACCIOLA: For the reasons stated at the 21 in camera conference, the invocation of the privilege will be 22 sustained. 23 MR. KLAYMAN: Mr. Huang, I'm going to show you what 24 I'll ask the court reporter to mark as Exhibit 42 and another 25 document which I'll ask be marked Exhibit 43. 26 1 (Huang Deposition Exhibit No. 42 2 and No. 43 were marked for 3 identification.) 4 BY MR. KLAYMAN: 5 Q Mr. Huang, when you applied for your position at 6 the Commerce Department, what date did you list as your birth 7 date? 8 A I invoke my privilege. 9 JUDGE FACCIOLA: The invocation of the privilege is 10 sustained. 11 BY MR. KLAYMAN: 12 Q Is it correct that you listed, as set forth in 13 Exhibit 43, a date of April 14, 1945? 14 A I invoke my privilege. 15 JUDGE FACCIOLA: The invocation of the privilege is 16 sustained. 17 BY MR. KLAYMAN: 18 Q Is Exhibit 43 a resume of your background and 19 qualifications consisting of pages Bates numbered 1710 to 20 1713? 21 A I invoke my privilege. 22 JUDGE FACCIOLA: The invocation of the privilege is 23 sustained. 24 BY MR. KLAYMAN: 25 Q On Exhibit 43, it lists your permanent address 27 1 as 10101 Leder Road, Silver Spring, Maryland 20902 U.S.A. 2 Is that your permanent address in the District of Columbia 3 area? 4 A I invoke my privilege. 5 Q You previously told this Court that you had no 6 permanent address in the D.C. area, correct? 7 A I invoke my privilege. 8 JUDGE FACCIOLA: The invocation of the privilege is 9 sustained. 10 BY MR. KLAYMAN: 11 Q Who lives at that address, at 10101 Leder Road? 12 A I invoke my privilege. 13 JUDGE FACCIOLA: The invocation of the privilege is 14 sustained. 15 BY MR. KLAYMAN: 16 Q Who lived at that address at the time this resume 17 was prepared, Exhibit 43? 18 A I invoke my privilege. 19 Q Who lives there now? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: The invocation of the privilege is 22 sustained as to both instances. 23 BY MR. KLAYMAN: 24 Q Is the information provided on Exhibit 43, was it 25 provided by you? 28 1 A I invoke my privilege. 2 Q Is it accurate? 3 A Again, I invoke my privilege. 4 JUDGE FACCIOLA: The invocation of the privilege is 5 sustained as to both questions. 6 BY MR. KLAYMAN: 7 Q Does it omit any material aspects of your prior 8 background and qualifications? 9 A I invoke my privilege. 10 JUDGE FACCIOLA: The invocation of the privilege is 11 sustained. 12 BY MR. KLAYMAN: 13 Q Is Exhibit 43 complete with regard to your prior 14 employment? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: The invocation of the privilege is 17 sustained. 18 BY MR. KLAYMAN: 19 Q The last page of the resume, Exhibit 43, says 20 fluent in both English and Chinese. Is that correct? 21 A I invoke my privilege. 22 Q Are you fluent in five dialects of Chinese? 23 A I invoke my privilege. 24 Q Do you speak Cantonese as well as Mandarin? 25 A I invoke my privilege. 29 1 JUDGE FACCIOLA: The invocation of the privilege is 2 sustained. 3 BY MR. KLAYMAN: 4 Q Do you speak Japanese? 5 A I invoke my privilege. 6 JUDGE FACCIOLA: The invocation of the privilege is 7 sustained. 8 MR. COBB: Just so the record is clear, Your Honor, 9 there were a series of questions. I take it the record 10 should reflect that the Your Honor has sustained the 11 invocation as to each of those? 12 JUDGE FACCIOLA: I certainly did. Yes. 13 MR. COBB: Thank you, Your Honor. 14 BY MR. KLAYMAN: 15 Q Returning to Exhibit 41, the second paragraph, 16 "Huang is granted this waiver due to the critical need for 17 his expertise in the new administration for Secretary Brown." 18 Is that a correct statement? 19 A I invoke my privilege. 20 JUDGE FACCIOLA: The invocation of the privilege is 21 sustained. 22 BY MR. KLAYMAN: 23 Q What knowledge do you have, if any, of the critical 24 need for your expertise in the new administration for 25 Secretary Brown? 30 1 A I invoke my privilege. 2 JUDGE FACCIOLA: The invocation of the privilege is 3 sustained. 4 BY MR. KLAYMAN: 5 Q The third paragraph says "Appropriate paperwork has 6 been processed to initiate a background investigation." 7 What paperwork is being referred to? 8 A I invoke my privilege. 9 Q Then it says, "The Office of Security completed 10 favorable pre-appointment checks on Huang." 11 Who do you know of, if anyone, that participated 12 from the Office of Security in completing favorable 13 pre-appointment checks on you? 14 A I invoke my privilege. 15 JUDGE FACCIOLA: The invocation of the privilege is 16 sustained. 17 BY MR. KLAYMAN: 18 Q Were you notified by the Office of Security that 19 favorable pre-appointment checks were performed on you? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: The invocation of the privilege is 22 sustained. 23 BY MR. KLAYMAN: 24 Q The last paragraph, "Accordingly, an interim top 25 secret clearance is hereby granted Huang to enable him to 31 1 perform his duties. Final clearance will be held in abeyance 2 pending the results of Huang's background investigation." 3 Is that an accurate statement, those two sentences? 4 A I invoke my privilege. 5 JUDGE FACCIOLA: The invocation of the privilege is 6 sustained. 7 BY MR. KLAYMAN: 8 Q Why was it necessary for you to have an interim top 9 secret clearance to enable you, Mr. Huang, to perform your 10 duties? 11 A I invoke my privilege. 12 JUDGE FACCIOLA: The invocation of the privilege is 13 sustained. 14 BY MR. KLAYMAN: 15 Q Was final clearance ever granted to you in terms of 16 your top secret clearance? 17 A I invoke my privilege. 18 Q Who granted that top secret clearance? 19 A I invoke my privilege. 20 JUDGE FACCIOLA: The invocation of the privilege is 21 sustained. 22 BY MR. KLAYMAN: 23 Q I'm showing you Exhibit 42, which is an Executive 24 Branch Personnel Public Financial Disclosure Report. It 25 lists your name, Huang, and John. Is that your handwriting 32 1 on this document? 2 A I invoke my privilege. 3 JUDGE FACCIOLA: The invocation of the privilege is 4 sustained. 5 BY MR. KLAYMAN: 6 Q Was this document prepared in furtherance of your 7 security clearance? 8 A I invoke my privilege. 9 JUDGE FACCIOLA: The invocation of the privilege is 10 sustained. 11 BY MR. KLAYMAN: 12 Q Does this document accurately list all of your 13 assets and liabilities? 14 A I invoke my privilege. 15 JUDGE FACCIOLA: The invocation of the privilege is 16 sustained. 17 BY MR. KLAYMAN: 18 Q Does it accurately list all your assets? 19 A I invoke my privilege. 20 JUDGE FACCIOLA: The invocation of the privilege is 21 sustained. 22 BY MR. KLAYMAN: 23 Q Have you ever applied for visa applications for 24 China and Korea? 25 A I invoke my privilege. 33 1 JUDGE FACCIOLA: The invocation of the privilege is 2 sustained. 3 BY MR. KLAYMAN: 4 Q Were these visa applications lodged with the United 5 States Government? 6 A I invoke my privilege. 7 JUDGE FACCIOLA: The invocation of the privilege is 8 sustained. 9 BY MR. KLAYMAN: 10 Q And is it not true that you stated, John Huang, on 11 these visa applications for China and Korea that you were 12 born in 1941? 13 A I invoke my privilege. 14 JUDGE FACCIOLA: The invocation of the privilege is 15 sustained. 16 BY MR. KLAYMAN: 17 Q Why did you write on these visa applications to 18 China and Korea that you were born in 1941? 19 A I invoke my privilege. 20 JUDGE FACCIOLA: The invocation of the privilege is 21 sustained. 22 BY MR. KLAYMAN: 23 Q Have you ever stated on any documents filed with 24 the United States Government that you were born in the 25 Chinese province of Zhe Jiang, Z-h-e J-i-a-n-g? 34 1 A I invoke my privilege. 2 JUDGE FACCIOLA: The invocation of the privilege is 3 sustained. 4 BY MR. KLAYMAN: 5 Q Have you ever stated on other documents lodged with 6 the United States Government that you were born in the 7 coastal province of Fujian, F-u-j-i-a-n? 8 A I invoke my privilege. 9 JUDGE FACCIOLA: The invocation of the privilege is 10 sustained. 11 BY MR. KLAYMAN: 12 Q Fujian is the province of the Riady family, is it 13 not? Where they were born? 14 A I invoke my privilege. 15 JUDGE FACCIOLA: The invocation of the privilege is 16 sustained. 17 MR. KLAYMAN: I'll show you what I'll ask the court 18 reporter to mark as Exhibit 44. 19 Exhibit 44 is a letter of February 17, 1993 to 20 Mr. John Emerson, Deputy Assistant to the President and 21 Deputy Director of Presidential Personnel at the White House. 22 It's on the letterhead of the State of California from David 23 Roberti, President Pro Tem, and Maeley Tom, M-a-e-l-e-y Tom, 24 Administrative Director. It consists of Bates numbers 52763 25 through and including 52769. 35 1 (Huang Deposition Exhibit No. 44 2 was marked for identification.) 3 BY MR. KLAYMAN: 4 Q Have you ever seen this document before, Mr. Huang? 5 A I invoke my privilege, Mr. Klayman. 6 JUDGE FACCIOLA: The invocation of the privilege is 7 sustained. 8 BY MR. KLAYMAN: 9 Q Do you know Elaine Chao, C-h-a-o? 10 A I invoke my privilege. 11 JUDGE FACCIOLA: The invocation of the privilege is 12 sustained. 13 BY MR. KLAYMAN: 14 Q As stated on page 052765, with regard to Melinda 15 Yee, is it your opinion that she's a savvy political insider 16 due to her experience as the chief lobbyist for the National 17 Organization of Chinese Americans in the District of 18 Columbia, as well as her experience as Director of 19 Constituencies for the Democratic National Committee? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: The invocation of the privilege is 22 sustained. 23 BY MR. KLAYMAN: 24 Q Turning to Bates numbers 52768, wherein it talks 25 about John Huang, this is an area of the document dealing 36 1 with political recommendations, "John Huang," it states, 2 "Executive Vice President of LippoBank, is the political 3 power that advises the Riady family on issues and where to 4 make contributions." 5 That's a correct statement, is it not? 6 A I invoke my privilege. 7 JUDGE FACCIOLA: The invocation of the privilege is 8 sustained. 9 BY MR. KLAYMAN: 10 Q It then states, "They invested heavily in the 11 Clinton campaign." 12 That is correct, is it not? 13 A I invoke my privilege. 14 Q It then states, "John is the Riady family's 15 top priority for placement because he is like one of their 16 own." 17 That is correct, is it not? 18 A I invoke my privilege. 19 JUDGE FACCIOLA: The invocation of the privilege is 20 sustained. 21 BY MR. KLAYMAN: 22 Q It then states down in the paragraph, "A good 23 friend of Ron Brown, John's appointment would be highly 24 endorsed by the Chinese business community, which has made 25 heavy contributions to the campaign, as well as the 37 1 grassroots political activists who appreciate John's efforts 2 to bring the two factions together." 3 That is correct, is it not? 4 A I invoke my privilege. 5 Q It then states, "John is a new breed of Asian 6 Democrat who will help the Asian-Pacific community become as 7 effective as the Jewish constituents within the political 8 arena." 9 That is a correct statement, is it not? 10 A I invoke my privilege. 11 Q In fact, your mission in assisting the Democratic 12 Party with fundraising concerning Asian-Pacific Americans was 13 to do for that group what Jewish-Americans had done for 14 themselves in terms of asserting political influence, 15 correct? 16 A I invoke my privilege. 17 JUDGE FACCIOLA: The invocation of the privilege is 18 sustained. 19 BY MR. KLAYMAN: 20 Q Do you know a Maeley Tom? 21 A I invoke my privilege. 22 JUDGE FACCIOLA: The invocation of the privilege is 23 sustained. 24 MR. KLAYMAN: I'll show you what I'll ask the 25 court reporter to mark as Exhibit 45. 38 1 (Huang Deposition Exhibit No. 45 2 was marked for identification.) 3 BY MR. KLAYMAN: 4 Q Exhibit 45 is a handwritten note which you 5 prepared yourself in your handwriting, Mr. Huang, is it 6 not? 7 A I invoke my privilege. 8 JUDGE FACCIOLA: The invocation of the privilege is 9 sustained. 10 BY MR. KLAYMAN: 11 Q And it was prepared in furtherance of your getting 12 the position with the Clinton Administration after the 13 election in 1992, correct? 14 A I invoke my privilege. 15 Q It is written from you to Mr. Jerry Stern, correct? 16 A I invoke my privilege. 17 JUDGE FACCIOLA: The invocation of the privilege is 18 sustained. 19 BY MR. KLAYMAN: 20 Q Is Mr. Jerry Stern a friend? 21 A I invoke my privilege. 22 Q Where did he work? 23 A Again, I invoke my privilege. 24 JUDGE FACCIOLA: The invocation of the privilege is 25 sustained in both instances. 39 1 BY MR. KLAYMAN: 2 Q Who is Charles DeQueujoe? 3 A I invoke my privilege. 4 JUDGE FACCIOLA: The invocation of the privilege is 5 sustained. 6 BY MR. KLAYMAN: 7 Q It says at the bottom, "Charles would be interested 8 in the following areas: (1) NSC or (2) Department of State, 9 (Southeast Asia affairs in particular) and, (3) Department of 10 Commerce, also wish to have inputs on PTO." 11 Do you know who PTO was or what that means? What 12 does PTO mean? 13 A I invoke my privilege. 14 JUDGE FACCIOLA: The invocation of the privilege is 15 sustained. 16 BY MR. KLAYMAN: 17 Q Were you and Mr. DeQueujoe interested in getting 18 jobs where you would have access to national security 19 information? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: The invocation of the privilege is 22 sustained. 23 BY MR. KLAYMAN: 24 Q Why did you want access to national security 25 information? 40 1 A I invoke my privilege. 2 MR. KLAYMAN: I'll show you what I'll ask the court 3 reporter to mark as Exhibit 46. 4 This is a memorandum, Exhibit 46, for Bruce R. 5 Lindsey from Gary Christopherson, Associate Director, 6 Presidential Personnel, dated October 18, 1993, re: John 7 Huang, Deputy Assistant Secretary for East Asia and the 8 Pacific, International Trade Administration, U.S. Department 9 of Commerce, SES position. It consists of two pages, Bates 10 numbers 9340 and 9341. 11 (Huang Deposition Exhibit No. 46 12 was marked for identification.) 13 BY MR. KLAYMAN: 14 Q Have you seen this document before, Mr. Huang? 15 A Mr. Klayman, I invoke my privilege. 16 JUDGE FACCIOLA: The invocation of the privilege is 17 sustained. 18 BY MR. KLAYMAN: 19 Q Is this document accurate? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: The invocation of the privilege is 22 sustained. 23 BY MR. KLAYMAN: 24 Q Wherein it states background under I. Does that 25 accurately describe the job that you ultimately took at the 41 1 Commerce Department in terms of its duties and 2 responsibilities? 3 A I invoke my privilege. 4 JUDGE FACCIOLA: The invocation of the privilege is 5 sustained. 6 BY MR. KLAYMAN: 7 Q Is it correct that this an SES position reporting 8 to Assistant Secretary for International Economic Policy, 9 Chuck Meissner, if confirmed? 10 A I invoke my privilege. 11 JUDGE FACCIOLA: Just a moment, please. 12 (Pause.) 13 JUDGE FACCIOLA: The invocation of the privilege is 14 sustained. 15 BY MR. KLAYMAN: 16 Q Do you see the handwriting on the top portion of 17 the document, top right-hand portion? Do you see that? 18 A Yes. 19 Q Do you know whose handwriting that is? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: The invocation of the privilege is 22 sustained. 23 BY MR. KLAYMAN: 24 Q Is that Bruce Lindsey's handwriting? 25 A I invoke my privilege. 42 1 JUDGE FACCIOLA: The invocation of the privilege is 2 sustained in both instances. 3 BY MR. KLAYMAN: 4 Q Is that Gary Christopherson's handwriting? 5 A I invoke my privilege. 6 JUDGE FACCIOLA: The invocation of the privilege is 7 sustained. 8 BY MR. KLAYMAN: 9 Q Is that somebody else's handwriting? 10 A I invoke my privilege. 11 JUDGE FACCIOLA: The invocation of the privilege is 12 sustained. 13 BY MR. KLAYMAN: 14 Q Turn to the second page. It says that you 15 are a member, on the second page, of the Asian-Pacific 16 American Advisory Council on the Democratic National 17 Committee. 18 Was that correct on October 18, 1993, that you 19 were a member of those two organizations? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: The invocation of the privilege is 22 sustained. 23 BY MR. KLAYMAN: 24 Q It then states, "Huang is recommended by Senator 25 Paul Simon." 43 1 Did he recommend you for your post at the Commerce 2 Department? 3 A I invoke my privilege. 4 JUDGE FACCIOLA: The invocation of the privilege is 5 sustained. 6 BY MR. KLAYMAN: 7 Q Why did Senator Paul Simon recommend you? 8 A I invoke my privilege. 9 JUDGE FACCIOLA: The invocation of the privilege is 10 sustained. 11 BY MR. KLAYMAN: 12 Q In the course of your activities politically, did 13 you ever generate campaign contributions, directly or 14 indirectly, for Senator Paul Simon? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: The invocation of the privilege is 17 sustained. 18 BY MR. KLAYMAN: 19 Q Did you ever make campaign contributions to Senator 20 Paul Simon? 21 A I invoke my privilege. 22 JUDGE FACCIOLA: The invocation of the privilege is 23 sustained. 24 BY MR. KLAYMAN: 25 Q What relationship, if any, does Senator Paul Simon 44 1 have with James and Mochtar Riady? 2 A I invoke my privilege. 3 JUDGE FACCIOLA: The invocation of the privilege is 4 sustained. 5 BY MR. KLAYMAN: 6 Q It also says that you were recommended by Kent 7 Conrad, Democrat from North Dakota. 8 Were you recommended by Kent Conrad for your 9 position at the Commerce Department? 10 A I invoke my privilege. 11 JUDGE FACCIOLA: The invocation of the privilege is 12 sustained. 13 BY MR. KLAYMAN: 14 Q Did you have anything to do with campaign 15 contributions from either yourself, the Lippo Group or the 16 Riady family to Kent Conrad? 17 A I invoke my privilege. 18 Q Were there any such political contributions? 19 A I invoke my privilege. 20 JUDGE FACCIOLA: The invocation of the privilege is 21 sustained. 22 BY MR. KLAYMAN: 23 Q It also said that you were recommended by Maria 24 Haley, H-a-l-e-y. 25 Do you know Maria Haley? 45 1 A I invoke my privilege. 2 JUDGE FACCIOLA: The invocation of the privilege is 3 sustained. 4 BY MR. KLAYMAN: 5 Q What was Ms. Maria Haley's professional job on 6 October 18, 1993? 7 A I invoke my privilege. 8 Q Did she later become the head of the Export-Import 9 Bank? 10 A I invoke my privilege. 11 JUDGE FACCIOLA: The invocation of the privilege is 12 sustained. 13 BY MR. KLAYMAN: 14 Q Did you or others have contact with Ms. Haley to 15 have export financing provided to American companies who made 16 campaign contributions to the Democratic Party or the 17 Clinton-Gore campaigns? 18 A I invoke my privilege. 19 Q Maria Haley and the Export-Import Bank provided 20 export financing to companies that went on subject Commerce 21 Department trade missions, correct? 22 A I invoke my privilege. 23 Q With regard to the trade mission to China in 1994 24 by the Commerce Department, Maria Haley and the Export-Import 25 Bank provided financing to companies which went on that trade 46 1 mission, correct? 2 A I invoke my privilege. 3 JUDGE FACCIOLA: The invocation of the privilege is 4 sustained. 5 BY MR. KLAYMAN: 6 Q One or more of the companies that went on the trade 7 mission to China received export financing for projects which 8 were negotiated in whole or in part as a result of that trade 9 mission to China in exchange for campaign contributions which 10 these companies made to the Democratic Party or the 11 Clinton-Gore campaign. 12 A I invoke my privilege. 13 JUDGE FACCIOLA: The invocation of the privilege is 14 sustained. 15 BY MR. KLAYMAN: 16 Q Do you know a Philip Yun, Y-u-n? 17 A I invoke my privilege. 18 JUDGE FACCIOLA: The invocation of the privilege is 19 sustained. 20 BY MR. KLAYMAN: 21 Q Do you know a Shan Thever, T-h-e-v-e-r, S-h-a-n? 22 A I invoke my privilege. 23 JUDGE FACCIOLA: The invocation of the privilege is 24 sustained. 25 47 1 BY MR. KLAYMAN: 2 Q Did Mr. Philip Yun or Shan Thever ever receive 3 appointments in the Clinton administration? 4 A I invoke my privilege. 5 JUDGE FACCIOLA: The invocation of the privilege is 6 sustained. 7 BY MR. KLAYMAN: 8 Q Mr. Huang, was your appointment as Deputy Assistant 9 Secretary for East Asia and the Pacific, International Trade 10 Administration, U.S. Department of Commerce, or any other 11 appointment to the Department of Commerce delayed to allow 12 certain fundraising events to occur before you were formally 13 appointed? 14 A I invoke my privilege. 15 JUDGE FACCIOLA: The invocation of the privilege is 16 sustained. 17 BY MR. KLAYMAN: 18 Q Is that what's being referred to in the handwriting 19 on the right-hand side at the top of this document? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: The invocation of the privilege is 22 sustained. 23 BY MR. KLAYMAN: 24 Q Do you know what is meant with the words "check 25 proximity of this job decision with fundraiser"? 48 1 A I invoke my privilege. 2 JUDGE FACCIOLA: The invocation of the privilege is 3 sustained. 4 MR. KLAYMAN: I'll show you what I'll ask the court 5 reporter to mark as the next exhibit. 6 THE COURT REPORTER: 47. 7 MR. KLAYMAN: Exhibit 47 is a memorandum for Bruce 8 Lindsey. It's dated December 6, 1993. Exhibit 46 was dated 9 October 18, 1993. 10 (Huang Deposition Exhibit No. 47 11 was marked for identification.) 12 BY MR. KLAYMAN: 13 Q Have you ever seen Exhibit 47 before? 14 A I invoke my privilege. 15 JUDGE FACCIOLA: The invocation of the privilege is 16 sustained. 17 BY MR. KLAYMAN: 18 Q The fact that this document, Exhibit 47, is dated 19 December 6, 1993 shows that your appointment for a political 20 position at the Commerce Department was delayed until after a 21 fundraiser, correct? 22 A I invoke my privilege. 23 JUDGE FACCIOLA: The invocation of the privilege is 24 sustained. 25 49 1 BY MR. KLAYMAN: 2 Q Who is Jan Piercy, P-i-e-r-c-y? 3 A I invoke my privilege. 4 BY MR. KLAYMAN: 5 Q Do you know Jan Piercy? 6 A I invoke my privilege. 7 Q Who is John Emerson? 8 A I invoke my privilege. 9 Q Do you know John Emerson? 10 A I invoke my privilege. 11 JUDGE FACCIOLA: The invocation of the privilege is 12 sustained as to all of those questions. 13 MR. KLAYMAN: I'll show you what I'll ask the court 14 reporter to mark as Exhibit 48. 15 Exhibit 48 consists of two pages; one is a 16 memorandum to William H. Kennedy, III, Associate Counsel, 17 from Peg Clark, re: SES Appointment at Department of 18 Commerce, December 30, 1993, that's Bates numbers 2123; and 19 the second page is a Bates number 2132 listing essential 20 information, position and agency personal data and contact 21 information. 22 (Huang Deposition Exhibit No. 48 23 was marked for identification.) 24 BY MR. KLAYMAN: 25 Q Have you ever seen either of these two pages of 50 1 documents before? 2 A I invoke my privilege. 3 Q Do you know William Kennedy, III? 4 A I invoke my privilege. 5 Q Have you ever met William Kennedy, III? 6 A I invoke my privilege. 7 JUDGE FACCIOLA: The invocation of the privilege is 8 sustained. 9 BY MR. KLAYMAN: 10 Q Are you aware that Mr. William H. Kennedy, III 11 worked at the Rose Law Firm with Hillary Clinton? 12 A I invoke my privilege. 13 JUDGE FACCIOLA: The invocation of the privilege is 14 sustained. 15 BY MR. KLAYMAN: 16 Q Do you know whether or not William H. Kennedy is a 17 friend of Hillary Clinton? 18 A I invoke my privilege. 19 JUDGE FACCIOLA: The invocation of the privilege is 20 sustained. 21 BY MR. KLAYMAN: 22 Q Do you know who Peg Clark is? 23 A I invoke my privilege. 24 Q Have you ever met Peg Clark? 25 A Again, I invoke my privilege. 51 1 Q Do you know why her name is listed on this 2 document? 3 A I invoke my privilege. 4 JUDGE FACCIOLA: The invocation of the privilege is 5 sustained in each instance. 6 BY MR. KLAYMAN: 7 Q It states below that "President Clinton has 8 approved the following candidate, John Huang, Deputy 9 Assistant Secretary, International Economic Policy, 10 Department of Commerce." 11 President Clinton personally approved your 12 appointment to the Commerce Department, correct? 13 A I invoke my privilege. 14 JUDGE FACCIOLA: The invocation of the privilege is 15 sustained. 16 BY MR. KLAYMAN: 17 Q President Clinton personally recommended your 18 appointment to a position at the Commerce Department, 19 correct? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: The invocation of the privilege is 22 sustained. 23 BY MR. KLAYMAN: 24 Q Do you know an Alice Smith? 25 A I invoke my privilege. 52 1 JUDGE FACCIOLA: The invocation of the privilege is 2 sustained. 3 BY MR. KLAYMAN: 4 Q Where did Alice Smith work on or about December 30, 5 1993? 6 A I invoke my privilege. 7 JUDGE FACCIOLA: The invocation of the privilege is 8 sustained. 9 BY MR. KLAYMAN: 10 Q The bottom of the second page, 2132, it says Steven 11 Ottenstein, I believe it is. Can you recognize what name 12 that is that's written there? 13 A I invoke my privilege. 14 JUDGE FACCIOLA: The invocation of the privilege is 15 sustained. 16 BY MR. KLAYMAN: 17 Q Is that Steven Ottenstein? 18 A I invoke my privilege. 19 JUDGE FACCIOLA: The invocation of the privilege is 20 sustained. 21 BY MR. KLAYMAN: 22 Q Where did Mr. Steven Ottenstein work on or about 23 the date this document was prepared? 24 A I invoke my privilege. 25 JUDGE FACCIOLA: The invocation of the privilege is 53 1 sustained. 2 BY MR. KLAYMAN: 3 Q Where did he work on or about December 30, 1993? 4 A I invoke my privilege. 5 JUDGE FACCIOLA: The invocation of the privilege is 6 sustained. 7 MR. KLAYMAN: I'll show you what I'll ask the court 8 reporter to mark as Exhibit 49. 9 (Huang Deposition Exhibit No. 49 10 was marked for identification.) 11 BY MR. KLAYMAN: 12 Q Referring to page 2, Exhibit 48, where it says 13 personal data, it says "Political party affiliation: 14 Democrat, campaign experience, fundraising. Domicile 15 California." 16 Is that correct information? 17 A I invoke my privilege. 18 JUDGE FACCIOLA: The invocation of the privilege is 19 sustained. 20 BY MR. KLAYMAN: 21 Q I'm showing you Exhibit 49, this is a Presidential 22 Transition Resume Routing Form from finance, name of 23 applicant, James Riady, January 11, 1993. It consists of two 24 pages, Bates numbers 3540680 and 3540681, the second page 25 being a little summary of the background and qualifications 54 1 of James T. Riady. 2 Have you ever seen Exhibit 49 before, consisting of 3 two pages? 4 MS. BRASWELL: Objection. Your Honor, if I might, 5 I understand that the Court has said that if the Fifth 6 Amendment is pled that other objections are not necessary. 7 On the other hand, there are entire lines of 8 questioning that are clearly outside the scope of discovery 9 and therefore it seems to me that certainly at certain times 10 an objection based on scope of discovery is appropriate for 11 the Court to consider, notwithstanding the invocation of the 12 Fifth Amendment. 13 JUDGE FACCIOLA: Thank you, Ms. Braswell. 14 MS. BRASWELL: And such an objection would be 15 appropriate here. 16 JUDGE FACCIOLA: Why is this relevant Mr. Klayman? 17 MR. KLAYMAN: Let me mark the next exhibit, Exhibit 18 50. 19 (Huang Deposition Exhibit No. 50 20 was marked for identification.) 21 JUDGE FACCIOLA: In the interim, if the witness -- 22 I didn't remember, did the witness -- 23 THE WITNESS: I invoke my privilege. 24 JUDGE FACCIOLA: It clearly will be sustained. 25 MR. KLAYMAN: I'll show you this document, 55 1 Your Honor, but the reason it's relevant is that Mr. Huang 2 was put at the Commerce Department, we believe, to do the 3 work of the Lippo Group, of the Riadys. 4 MS. BRASWELL: Again, Your Honor, how this relates 5 to documents at the Department of Commerce that are at issue 6 here has still not been made clear. 7 JUDGE FACCIOLA: Let me see the document. 8 MR. KLAYMAN: It's evidence of that, Your Honor. 9 JUDGE FACCIOLA: All right. Ms. Braswell's 10 objection is overruled. 11 MS. BRASWELL: Your Honor, could I see the document 12 before the Court rules on it? 13 MR. KLAYMAN: Yes, we're going to give you a copy. 14 JUDGE FACCIOLA: I thought you had. 15 MS. BRASWELL: No. 16 JUDGE FACCIOLA: I'm sorry. 17 MR. KLAYMAN: That's the only copy, so I'll just 18 mark that one, if that's all right, Your Honor. 19 JUDGE FACCIOLA: We can make copies here. 20 MR. KLAYMAN: Okay. 21 MS. BRASWELL: Again, Your Honor, this speaks to 22 nothing. This is a document created two years prior to the 23 trade missions at issue. It speaks to nothing regarding 24 documents that are pertinent to this case. 25 JUDGE FACCIOLA: The objection is overruled. 56 1 MR. KLAYMAN: Should we make a copy now, 2 Your Honor? 3 JUDGE FACCIOLA: Yes. Yes. 4 THE VIDEOGRAPHER: We're going off video record 5 at 11:06 6 (A brief recess was taken.) 7 THE VIDEOGRAPHER: We're back on video record 8 at 11:06. 9 BY MR. KLAYMAN: 10 Q Mr. Huang, referring you to Exhibit 49, 11 have you ever seen this document before? I identified 12 two pages. 13 A You're talking about 49, sir? 14 Q Yes. Bates numbers 3540680 and 35480681. 15 A I invoke my privilege. 16 JUDGE FACCIOLA: The invocation of the privilege is 17 sustained. 18 BY MR. KLAYMAN: 19 Q Did you recommend James Riady for a position in the 20 Commerce Department? 21 A I invoke my privilege. 22 Q Do you know of anyone who did? 23 A I invoke my privilege. 24 JUDGE FACCIOLA: The invocation of the privilege is 25 sustained in both instances. 57 1 BY MR. KLAYMAN: 2 Q Was Mr. Riady recommended for a position at the 3 Commerce Department? 4 A I invoke my privilege. 5 JUDGE FACCIOLA: The invocation of the privilege is 6 sustained. 7 BY MR. KLAYMAN: 8 Q I'm showing you Exhibit 50, which is a letter from 9 Ron Brown to Mochtar Riady, January 7, 1992, Mochtar Riady, 10 Chairman, Lippo Group. 11 Ron Brown knew Mochtar Riady, correct? 12 A I invoke my privilege. 13 JUDGE FACCIOLA: The invocation of the privilege is 14 sustained. 15 BY MR. KLAYMAN: 16 Q It states in the first paragraph, "I want to thank 17 you and the Lippo Group for hosting us throughout our stay in 18 Hong Kong." 19 The Riady group hosted Ron Brown in his stay in 20 Hong Kong in and around this period of time, correct? Listed 21 on the letter. 22 A I invoke my privilege. 23 JUDGE FACCIOLA: The invocation of the privilege is 24 sustained. 25 58 1 BY MR. KLAYMAN: 2 Q The second paragraph, "I especially wanted to 3 recognize my friendship with John Huang and the tremendous 4 asset that he is to the Lippo Group. He has worked 5 tirelessly as chairman of the National Association of Chinese 6 American Bankers and has been a strong advocate to Congress 7 on banking issues that affect Asian-owned banks in the United 8 States." 9 Is that a correct statement? 10 A I invoke my privilege. 11 JUDGE FACCIOLA: The invocation of the privilege is 12 sustained. 13 BY MR. KLAYMAN: 14 Q Did you consider Ron Brown to be your friend in and 15 around this time period? 16 A I invoke my privilege. 17 JUDGE FACCIOLA: The invocation of the privilege is 18 sustained. 19 BY MR. KLAYMAN: 20 Q Did he ever tell you that he considered you to be 21 his friend? 22 A I invoke my privilege. 23 JUDGE FACCIOLA: The invocation of the privilege is 24 sustained. 25 59 1 BY MR. KLAYMAN: 2 Q Did you work on the matters set forth in the 3 paragraph that I just read to you? 4 A I invoke my privilege. 5 JUDGE FACCIOLA: The invocation of the privilege is 6 sustained. 7 BY MR. KLAYMAN: 8 Q The reason that you took a job at the Commerce 9 Department was to be able to further the interests of the 10 Riadys and the Lippo Group, correct? 11 A I invoke my privilege. 12 JUDGE FACCIOLA: The invocation of the privilege is 13 sustained. 14 BY MR. KLAYMAN: 15 Q The reason that you took a job at the Commerce 16 Department was to be able to obtain information, classified 17 and otherwise, to provide to the Riadys of the Lippo Group, 18 correct? 19 A I invoke my privilege. 20 JUDGE FACCIOLA: The invocation of the privilege is 21 sustained. 22 BY MR. KLAYMAN: 23 Q The reason that you took a job at the Commerce 24 Department was to be able to arrange for trade missions to 25 China and elsewhere where the interests of the Lippo Group 60 1 and the Riadys would be furthered. 2 A I invoke my privilege. 3 JUDGE FACCIOLA: The invocation of the privilege is 4 sustained. 5 BY MR. KLAYMAN: 6 Q And, in fact, the interests of the Riadys and Lippo 7 Group were furthered on trade missions to China. 8 A I invoke my privilege. 9 JUDGE FACCIOLA: The invocation of the privilege is 10 sustained. 11 BY MR. KLAYMAN: 12 Q And the interests of the Riadys and the Lippo Group 13 were furthered on trade missions to Indonesia. 14 A I invoke my privilege. 15 JUDGE FACCIOLA: The invocation of the privilege is 16 sustained. 17 BY MR. KLAYMAN: 18 Q And to India. 19 A Again, I invoke my privilege. 20 JUDGE FACCIOLA: The invocation of the privilege is 21 sustained. 22 BY MR. KLAYMAN: 23 Q And other trade missions. 24 A Again, I invoke my privilege. 25 JUDGE FACCIOLA: The invocation of the privilege is 61 1 sustained. 2 MR. KLAYMAN: I'll show you what I'll ask the court 3 reporter to mark as Exhibit 51. 4 (Huang Deposition Exhibit No. 51 5 was marked for identification.) 6 BY MR. KLAYMAN: 7 Q The interests of the Riadys and the Lippo Group are 8 also the interests of Chinese intelligence, correct? 9 A I invoke my privilege. 10 JUDGE FACCIOLA: The invocation of the privilege is 11 sustained. 12 BY MR. KLAYMAN: 13 Q The Riadys and the Lippo Group work with and/or for 14 Chinese intelligence, correct? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: The invocation of the privilege is 17 sustained. 18 BY MR. KLAYMAN: 19 Q Mochtar and James Riady are members of the 20 Communist Party of China, correct? 21 A I invoke my privilege. 22 JUDGE FACCIOLA: The invocation of the privilege is 23 sustained. 24 BY MR. KLAYMAN: 25 Q James and Mochtar Riady and their Lippo Group own 62 1 holdings which are also in part owned by the government of 2 China. 3 A I invoke my privilege. 4 JUDGE FACCIOLA: The invocation of the privilege is 5 sustained. 6 BY MR. KLAYMAN: 7 Q James and Mochtar Riady and the Lippo Group 8 collaborate closely with intelligence agencies of the 9 government of China. 10 A I invoke my privilege. 11 JUDGE FACCIOLA: The invocation of the privilege is 12 sustained. 13 BY MR. KLAYMAN: 14 Q And they also, James and Mochtar Riady, work 15 closely with intelligence agencies of other countries as 16 well, correct? 17 A I invoke my privilege. 18 JUDGE FACCIOLA: The invocation of the privilege is 19 sustained. 20 BY MR. KLAYMAN: 21 Q Including Indonesia. 22 A I invoke my privilege. 23 Q Including Taiwan. 24 A I invoke my privilege. 25 JUDGE FACCIOLA: The invocation of the privilege is 63 1 sustained. 2 BY MR. KLAYMAN: 3 Q Including the United States. 4 A I invoke my privilege. 5 JUDGE FACCIOLA: The invocation of the privilege is 6 sustained. 7 BY MR. KLAYMAN: 8 Q You work closely with the intelligence agencies of 9 the United States, correct? 10 A I invoke my privilege. 11 Q You have worked closely with the intelligence 12 agencies of the United States, correct? 13 A I invoke my privilege. 14 JUDGE FACCIOLA: The invocation of the privilege is 15 sustained. 16 MR. KLAYMAN: I'll show you what I'll ask the court 17 reporter to mark as the next exhibit. 18 THE COURT REPORTER: 52. 19 (Huang Deposition Exhibit No. 52 20 was marked for identification.) 21 BY MR. KLAYMAN: 22 Q Mr. Huang, since the date of your last deposition, 23 which was October 29, 1996, have you ever had any 24 communications, oral or written with Sandy Berger, now 25 National Security Advisor? 64 1 MS. BRASWELL: Objection. That was not the last 2 date of his last deposition. 3 JUDGE FACCIOLA: April 15, 1999? 4 MR. KLAYMAN: Okay. Let me rephrase that. 5 BY MR. KLAYMAN: 6 Q Since October 29, 1996, have you had any contact, 7 oral or written, with Sandy Berger, who is now National 8 Security Advisor? 9 A I invoke my privilege. 10 JUDGE FACCIOLA: The invocation of the privilege is 11 sustained. 12 BY MR. KLAYMAN: 13 Q Have you had any contact since October 29, 196 with 14 anyone associated with the Executive Office of the President, 15 otherwise known as the White House? 16 A I invoke my privilege. 17 JUDGE FACCIOLA: The invocation of the privilege is 18 sustained. 19 MR. KLAYMAN: I'll show you what I'll ask the court 20 reporter to mark as Exhibit 51. 21 THE COURT REPORTER: 53. 22 MR. KLAYMAN: 53. I'm sorry. 23 (Huang Deposition Exhibit No. 53 24 was marked for identification.) 25 MR. KLAYMAN: Off the record. 65 1 THE VIDEOGRAPHER: We're going off video record 2 at 11:15. 3 (A brief recess was taken.) 4 THE VIDEOGRAPHER: We're back on at 11:15. 5 BY MR. KLAYMAN: 6 Q I'll show you what has been marked as Exhibit 51, 7 which is a letter to Ronald Brown from John Huang. 8 Is this a letter which you prepared to Ron Brown? 9 A I invoke my privilege. 10 Q Why were you writing to Ron Brown on January 7, 11 1993? 12 A I invoke my privilege. 13 JUDGE FACCIOLA: The invocation of the privilege is 14 sustained. 15 BY MR. KLAYMAN: 16 Q In the third paragraph, it states that "What I 17 really want to do is identify a convenient time in the coming 18 week to arrange a meeting between you and Dr. Mochtar Riady, 19 our group chairman. Dr. Riady will be coming to the States." 20 Why did you want to arrange a meeting? 21 A I invoke my privilege. 22 JUDGE FACCIOLA: The invocation of the privilege is 23 sustained. 24 BY MR. KLAYMAN: 25 Q Was the reason for this meeting so that Ron Brown 66 1 could help Dr. Mochtar Riady of the Lippo Group do 2 international business? 3 A I invoke my privilege. 4 JUDGE FACCIOLA: The invocation of the privilege is 5 sustained. 6 BY MR. KLAYMAN: 7 Q Was the reason so the services of the United States 8 Government could be enlisted to help Dr. Mochtar Riady and 9 the LippoBank do business in the United States? 10 A I invoke my privilege. 11 JUDGE FACCIOLA: The invocation of the privilege is 12 sustained. 13 BY MR. KLAYMAN: 14 Q Was the reason to arrange the meeting to get you a 15 job at the Commerce Department? 16 A I invoke my privilege. 17 JUDGE FACCIOLA: The invocation of the privilege is 18 sustained. 19 BY MR. KLAYMAN: 20 Q Is this your signature at the bottom of Exhibit 51? 21 A I invoke my privilege. 22 JUDGE FACCIOLA: The invocation of the privilege is 23 sustained. 24 BY MR. KLAYMAN: 25 Q Turning to Exhibit 52, a letter of September 10, 67 1 1993 to the Honorable Ron Brown from Mr. John Huang. Did you 2 write this letter? 3 A I invoke my privilege. 4 Q Is that your signature at the bottom? 5 A Again, I invoke my privilege. 6 JUDGE FACCIOLA: The invocation of the privilege is 7 sustained in both instances. 8 BY MR. KLAYMAN: 9 Q At the bottom, it says, "P.S. Personal data, Mr. 10 Shen Jueren," J-u-e-r-e-n, "Chairman, Ms. Liang," L-i-a-n-g, 11 "Rul Lian, Assistant GM," did those individuals at the time, 12 did they work for Lippo Group? 13 A I invoke my privilege. 14 JUDGE FACCIOLA: The invocation of the privilege is 15 sustained. 16 BY MR. KLAYMAN: 17 Q Turning to the first paragraph, "Dr. Mochtar 18 Riady, chairman of our Lippo Group, has asked me to arrange 19 a meeting for a very good Chinese businessman, Mr. Shen 20 Jueren," J-u-e-r-e-n, "with you. Mr. Shen is the chairman of 21 the China Resources (Holdings) Company, Ltd., (CRC), the 22 largest Chinese-owned trading group in Hong Kong with total 23 assets of US $5.8 billion and turnover of US $8 billion 24 annually." 25 Is Mr. Shen Jueren a member of Chinese 68 1 intelligence? 2 A I invoke my privilege. 3 JUDGE FACCIOLA: The invocation of the privilege is 4 sustained. 5 BY MR. KLAYMAN: 6 Q Were you trying to get a meeting with Ron Brown to 7 allow Mr. Shen to have contact with him for purposes of 8 espionage? 9 A I invoke my privilege. 10 JUDGE FACCIOLA: The invocation of the privilege is 11 sustained. 12 BY MR. KLAYMAN: 13 Q I'll show you what I'll ask the court reporter to 14 mark as Exhibit 53. This is a scheduling recommendation, 15 Office of the Secretary, Executive Secretariat, Action Agency 16 ITA OBL. Event: REQ meeting between you and Dr. Mochtar 17 Riady dealing with Japan and other Asian matters. Date of 18 event: ASAP. Inviting group: Huang, John LippoBank. 19 Recommendation: Yes. LippoBank is a major banking firm in 20 Asia, over one-half billion in assets, also headquartered in 21 U.S. in New York with office throughout the U.S. John Huang 22 took President Clinton to Hong Kong in 1985 with an Arkansas 23 trade delegation, was very active in '92. 24 Is that a correct statement? 25 A I invoke my privilege. 69 1 JUDGE FACCIOLA: The invocation of the privilege is 2 sustained. 3 BY MR. KLAYMAN: 4 Q Who signed this document? 5 A I invoke my privilege. 6 Q Do you know whose name that is? 7 A I invoke my privilege. 8 Q Do you know whose handwriting that is? 9 A Again, I invoke my privilege. 10 JUDGE FACCIOLA: The invocation of the privilege is 11 sustained. 12 BY MR. KLAYMAN: 13 Q Was this document signed on or about January 29, 14 1991? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: The invocation of the privilege is 17 sustained. 18 BY MR. KLAYMAN: 19 Q Was the document prepared on February 2, 1993? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: The invocation of the privilege is 22 sustained. 23 MR. KLAYMAN: I'll show you what I'll ask the court 24 reporter to mark as Exhibit 54. 25 Exhibit 54 is a letter of October 20, 1993 to 70 1 Mr. James Riady of the LippoBank, Lippo Center, Jakarta, 2 Indonesia. It consists of three pages, Bates numbers 5381 3 through and including 5383. It's signed by C.J. Giroir, Jr. 4 (Huang Deposition Exhibit No. 54 5 was marked for identification.) 6 BY MR. KLAYMAN: 7 Q Do you know a C.J. Giroir, Jr., Mr. Huang? 8 A I invoke my privilege. 9 JUDGE FACCIOLA: The invocation of the privilege is 10 sustained. 11 BY MR. KLAYMAN: 12 Q Mr. Giroir is a lawyer from Arkansas, correct? 13 A I invoke my privilege. 14 Q Mr. Giroir worked at the Rose Law Firm at the time, 15 correct? 16 A I invoke my privilege. 17 JUDGE FACCIOLA: The invocation of the privilege is 18 sustained. 19 BY MR. KLAYMAN: 20 Q Mr. Giroir at one time worked at the Rose Law Firm. 21 A I invoke my privilege. 22 Q Mr. Giroir is a close friend of Mr. and Mrs. 23 Clinton, correct? 24 A I invoke my privilege. 25 Q And you know him to be a close friend of Mark 71 1 Middleton and Mack McLarty, correct? 2 A I invoke my privilege. 3 Q And, in fact, he's a close friend of yours, 4 correct? 5 A I invoke my privilege. 6 JUDGE FACCIOLA: The invocation of the privilege is 7 sustained in each instance. 8 BY MR. KLAYMAN: 9 Q And he's a close friend of Bruce Lindsey, correct? 10 A I invoke my privilege. 11 Q Turn to the second page. I'm going to ask you 12 actually with regard to all three pages, if you'd like an 13 opportunity to review it. Before I showed this document to 14 you today, were you aware of its contents? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: The invocation of the privilege is 17 sustained. 18 BY MR. KLAYMAN: 19 Q Is the information set forth in the three pages of 20 this document accurate or not? 21 A I invoke my privilege. 22 JUDGE FACCIOLA: The invocation of the privilege is 23 sustained. 24 BY MR. KLAYMAN: 25 Q This document evidences an attempt to have the U.S. 72 1 Government at taxpayer expense do business for the Riadys 2 through trade missions of the Commerce Department, correct? 3 A I invoke my privilege. 4 JUDGE FACCIOLA: The invocation of the privilege is 5 sustained. 6 BY MR. KLAYMAN: 7 Q Turn to page 2, second paragraph, "Concerning the 8 China situation, please be advised to as follows: I have 9 talked with the people at J.B. Hunt, who are anxious to make 10 an exploratory trip to China with a view to entering into an 11 80/20 joint venture with AIDC/Lippo, and will pay a $250,000 12 fee to AIDC if the transaction is pursued. I have also 13 spoken with the Tyson people, who have indicated an interest 14 in also making an exploratory trip and entering into an 80/20 15 partnership if transaction is pursued." 16 Were the companies J.B. Hunt and Tyson Foods 17 attempting to go on trade missions to China to have the 18 Commerce Department at U.S. taxpayers' expense do business 19 for them? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: The invocation of the privilege is 22 sustained. 23 BY MR. KLAYMAN: 24 Q And is it not true that the joint ventures being 25 proposed by J.B. Hunt and Tyson would be joint ventures that 73 1 the Lippo Group would also participate in? 2 A I invoke my privilege. 3 JUDGE FACCIOLA: The invocation of the privilege is 4 sustained. 5 BY MR. KLAYMAN: 6 Q Is it not true that J.B. Hunt and/or Tyson went on 7 trade missions at the Commerce Department? 8 A I invoke my privilege. 9 Q Is it not true that J.B. Hunt and Tyson paid money 10 to the Democratic Party and/or Clinton-Gore campaign to go on 11 these trade missions? 12 A I invoke my privilege. 13 JUDGE FACCIOLA: The invocation of the privilege is 14 sustained. 15 BY MR. KLAYMAN: 16 Q Second paragraph, "I have also met with the 17 representatives of Entergy." Last paragraph. "I have also 18 met with the representatives of Entergy, who are also anxious 19 to pursue a joint venture on the Shandong power project on 20 the basis that we would co-investment, although a substantial 21 portion of the Lippo investment would likely be shared in by 22 other investors, with Entergy understanding that Lippo would 23 be a general contractor for the improvements and that there 24 would be a good will factor plugged into the partnership, 25 including a .01 percent cash fee on a targeted investment of 74 1 $50 million for $500,000. Entergy representatives indicate a 2 desire to negotiate for an effective return in excess of 3 $15,000." 4 Next page. "All of the representatives of Hunt, 5 Tyson, Entergy have indicated a desire to make the trip 6 during the last week of November or the first week of 7 December. Mark Middleton advises me that the White House is 8 going to sponsor a trade mission to China in January, which 9 they want to invite us to join. It would be nice if we could 10 sign the definitive agreements on the three Arkansas projects 11 when that trade mission is held with representatives of the 12 Arkansas companies participating in the trade mission. I 13 need your input into this. Please let me hear from you as 14 soon as possible." 15 Mr. Huang, those are accurate statements I just 16 read to you, are they not? 17 A I invoke my privilege. 18 JUDGE FACCIOLA: The invocation of the privilege is 19 sustained. 20 BY MR. KLAYMAN: 21 Q Mr. Huang, is it not true that Entergy has donated 22 to Governor Clinton and also the 1992 and 1996 Clinton-Gore 23 campaigns and the Democratic Party? 24 A I invoke my privilege. 25 JUDGE FACCIOLA: The invocation of the privilege is 75 1 sustained. 2 BY MR. KLAYMAN: 3 Q Is it not true that this document evidences a 4 scheme by friends of the Clintons such as Joseph Giroir and 5 Mochtar and James Riady of the Lippo Group and Entergy 6 Corporation to use U.S. taxpayer financed services of the 7 Commerce Department to do business for all of these 8 individuals and entities? 9 A I invoke my privilege. 10 JUDGE FACCIOLA: The invocation of the privilege is 11 sustained. 12 BY MR. KLAYMAN: 13 Q And is it not true that the incentive for the 14 Clinton Administration to allow the Commerce Department's 15 taxpayer financed services to be used to do business for 16 these individuals and entities was campaign contributions to 17 the Clinton-Gore campaigns and the Democratic Party? 18 A I invoke my privilege. 19 JUDGE FACCIOLA: The invocation of the privilege is 20 sustained. 21 Do you need a break? 22 THE COURT REPORTER: Whenever. 23 JUDGE FACCIOLA: Would you like a break now? 24 Do you need a moment? 25 Let's give the reporter a five-minute break. 76 1 Reconvene at 11:30, please. 2 THE VIDEOGRAPHER: We're going off video record 3 at 11:28. 4 JUDGE FACCIOLA: Make that 11:35. 5 (A brief recess was taken.) 6 THE VIDEOGRAPHER: We're back on video record 7 at 11:38. 8 MR. KLAYMAN: I show you what I'll ask the court 9 reporter to mark as the next exhibit. 10 THE COURT REPORTER: 55. 11 (Huang Deposition Exhibit No. 55 12 was marked for identification.) 13 BY MR. KLAYMAN: 14 Q This is a letter dated October 7, 1993 to 15 Mr. Jack Quinn, Assistant to the President, Chief of Staff 16 and Counsellor to the Vice Presiden, the White House, from 17 John Huang, Director. 18 Is this a letter that you prepared to Mr. Quinn on 19 or about October 7, 1993? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: The invocation of the privilege is 22 sustained. 23 BY MR. KLAYMAN: 24 Q Is that your handwriting below, Mr. Huang? 25 A I invoke my privilege. 77 1 JUDGE FACCIOLA: The invocation of the privilege is 2 sustained. 3 BY MR. KLAYMAN: 4 Q Down below it says, "Jack, let me know if you 5 decide to go to -- " What does it say after that, 6 Mr. Huang? 7 A I invoke my privilege. 8 JUDGE FACCIOLA: The invocation of the privilege is 9 sustained. 10 BY MR. KLAYMAN: 11 Q Are those your initials next to that? 12 A I invoke my privilege. 13 Q And is that your signature? 14 A I invoke my privilege. 15 JUDGE FACCIOLA: The invocation of the privilege is 16 sustained as to both questions. 17 BY MR. KLAYMAN: 18 Q This document shows that you had a meeting between 19 yourself, Chairman Shan Jueren, J-u-e-r-e-n, and his 20 assistant, Ms. Liang, L-i-a-n-g, of China Resources Group, on 21 September 24th at the office of Jack Quinn in the White 22 House, correct? 23 A I invoke my privilege. 24 JUDGE FACCIOLA: The invocation of the privilege is 25 sustained. 78 1 BY MR. KLAYMAN: 2 Q And that in fact you met Mr. Quinn on or about 3 Monday, September 27th, in Los Angeles where Vice President 4 Gore was also present. 5 A I invoke my privilege. 6 JUDGE FACCIOLA: The invocation of the privilege is 7 sustained. 8 BY MR. KLAYMAN: 9 Q In fact, Vice President Gore has known at all times 10 that seats on trade missions were being sold for campaign 11 contributions at the Commerce Department, correct? 12 A I invoke my privilege. 13 JUDGE FACCIOLA: The invocation of the privilege is 14 sustained. 15 BY MR. KLAYMAN: 16 Q And, in fact, Vice President Al Gore in addition to 17 the President and Mrs. Clinton, devised the scheme to sell 18 seats on trade missions for campaign contributions. 19 A I invoke my privilege. 20 JUDGE FACCIOLA: The invocation of the privilege is 21 sustained. 22 BY MR. KLAYMAN: 23 Q You have done fundraising events for Vice President 24 Gore, you, Mr. Huang. 25 A I invoke my privilege. 79 1 Q And, in fact, you did one at the Buddhist temple 2 close to Hacienda Heights in California, correct? 3 A I invoke my privilege. 4 JUDGE FACCIOLA: The invocation of the privilege is 5 sustained. 6 BY MR. KLAYMAN: 7 Q Vice President Gore also wanted you at the Commerce 8 Department to further the business interests of the Riadys 9 and the Lippo Group, correct? 10 A I invoke my privilege. 11 JUDGE FACCIOLA: The invocation of the privilege is 12 sustained. 13 BY MR. KLAYMAN: 14 Q And Vice President Gore was fully aware that 15 the quid pro quo for your being placed at the Commerce 16 Department was the money that was donated by the Riadys 17 and the Lippo Group to the Clinton-Gore campaign and 18 the Democratic Party in the various elections of 1992 and 19 1996. 20 A I invoke my privilege. 21 JUDGE FACCIOLA: The invocation of the privilege is 22 sustained. 23 BY MR. KLAYMAN: 24 Q Mr. Huang, we've gone about an hour and a half of 25 this deposition today and we've gone over a number of issues 80 1 and you have documents in your possession, custody or control 2 which refer, relate in any way to the matters that we've 3 talked about this morning, correct? 4 A I invoke my privilege. 5 JUDGE FACCIOLA: The invocation of the privilege is 6 sustained. 7 BY MR. KLAYMAN: 8 Q You know of others in addition to yourself who have 9 such documents, correct? 10 A I invoke my privilege. 11 JUDGE FACCIOLA: The invocation of the privilege is 12 sustained. 13 BY MR. KLAYMAN: 14 Q And, in fact, one of the people that you know has 15 documents dealing with the matters that we've discussed this 16 morning is your wife, Jane Huang. 17 A I invoke my privilege. 18 JUDGE FACCIOLA: The invocation of the privilege is 19 sustained. 20 BY MR. KLAYMAN: 21 Q And, in fact, these documents are located in your 22 various residences or commercial properties. 23 A I invoke my privilege. 24 JUDGE FACCIOLA: The invocation of the privilege is 25 sustained. 81 1 BY MR. KLAYMAN: 2 Q Mr. Huang, do you have a laptop computer? 3 A I invoke my privilege. 4 JUDGE FACCIOLA: The invocation of the privilege is 5 sustained. 6 BY MR. KLAYMAN: 7 Q When did you first buy a laptop computer? 8 A I invoke my privilege. 9 JUDGE FACCIOLA: The invocation of the privilege is 10 sustained. 11 BY MR. KLAYMAN: 12 Q Did you use a laptop computer at the Commerce 13 Department? 14 A I invoke my privilege. 15 JUDGE FACCIOLA: The invocation of the privilege is 16 sustained. 17 BY MR. KLAYMAN: 18 Q Did you use a dictaphone at the Commerce 19 Department? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: The invocation of the privilege is 22 sustained. 23 BY MR. KLAYMAN: 24 Q Did you use a small hand-held tape recorder at the 25 Commerce Department? 82 1 A I invoke my privilege. 2 JUDGE FACCIOLA: The invocation of the privilege is 3 sustained. 4 BY MR. KLAYMAN: 5 Q Did you use voice mail at the Commerce Department? 6 A I invoke my privilege. 7 JUDGE FACCIOLA: The invocation of the privilege is 8 sustained. 9 BY MR. KLAYMAN: 10 Q Have you ever visited an office or residence of 11 Charlie Trie at the Watergate in Washington, D.C.? 12 A I invoke my privilege. 13 JUDGE FACCIOLA: The invocation of the privilege is 14 sustained. 15 BY MR. KLAYMAN: 16 Q Do you know whether or not Mr. Trie has certain 17 documents which you generated at the Commerce Department in 18 his custody, possession and control? 19 A I invoke my privilege. 20 JUDGE FACCIOLA: The invocation of the privilege is 21 sustained. 22 BY MR. KLAYMAN: 23 Q Do you know whether Mr. Trie has document which 24 refer or relate in any way to the Commerce Department and its 25 trade missions? 83 1 A I invoke my privilege. 2 Q Do you know whether Mr. Trie's apartment has been 3 raided by the Federal Bureau of Investigation? 4 A I invoke my privilege. 5 JUDGE FACCIOLA: The invocation of the privilege is 6 sustained. 7 BY MR. KLAYMAN: 8 Q Have any of your residences or commercial 9 properties ever been entered by the Federal Bureau of 10 Investigation? 11 A I invoke my privilege. 12 JUDGE FACCIOLA: The invocation of the privilege is 13 sustained. 14 BY MR. KLAYMAN: 15 Q Has anyone ever presented you with a warrant issued 16 by a court of the United States or a state which allowed them 17 access to certain documents dealing with the Commerce 18 Department and its trade missions and what went on during 19 those trade missions? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: The invocation of the privilege is 22 sustained. 23 BY MR. KLAYMAN: 24 Q Do you know an individual by the name of Pauline 25 Kanchanalak? 84 1 A I invoke my privilege. 2 JUDGE FACCIOLA: The invocation of the privilege is 3 sustained. 4 BY MR. KLAYMAN: 5 Q Do you know an individual by the name of Johnny 6 Chung? 7 A I invoke my privilege. 8 Q Maria Hsia? 9 A Again, I invoke my privilege. 10 Q Do you know whether or not these individuals have 11 documents in their custody, possession and control which 12 refer or relate in any way to your activities at the Commerce 13 Department and what went on on the subject trade missions? 14 A I invoke my privilege. 15 JUDGE FACCIOLA: The invocation of the privilege is 16 sustained. 17 BY MR. KLAYMAN: 18 Q And in matters leading up to the planning and 19 implementation of those trade missions? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: The invocation of the privilege is 22 sustained. 23 BY MR. KLAYMAN: 24 Q Same question with regard to anybody on the face of 25 the earth. Do you know of anyone who may have documents? 85 1 A I invoke my privilege. 2 Q Do you know of anyone who may have such documents 3 as I've just described? 4 A I invoke my privilege. 5 JUDGE FACCIOLA: The invocation of the privilege is 6 sustained. 7 MR. KLAYMAN: I'll show you what I'll ask the court 8 reporter to mark as the next exhibit. 9 THE COURT REPORTER: 56. 10 (Huang Deposition Exhibit No. 56 11 was marked for identification.) 12 BY MR. KLAYMAN: 13 Q Exhibit 56 is a document that consists of three 14 pages, 3888 through and including 3890. It's to Joe Giroir, 15 G-i-r-o-i-r, from Terry Ogletree. It's a facsimile from 16 Entergy Power Group. 17 Have you ever seen this document which consists of 18 three pages before? 19 A I invoke my privilege. 20 Q Who is Terry Ogletree? Did he work for Entergy 21 Corporation? 22 A I invoke my privilege. 23 Q At the time that this document was apparently 24 written on August 30, 1994? 25 A I invoke my privilege. 86 1 JUDGE FACCIOLA: The invocation of the privilege is 2 sustained in all instances. 3 BY MR. KLAYMAN: 4 Q Do you know someone by the name of Jude Kearney, 5 K-e-a-r-n-e-y? 6 A I invoke my privilege. 7 Q Did Mr. Kearney tell anyone at Entergy something to 8 the effect that I'm a political appointee and I choose those 9 persons on trade missions who are politically connected? 10 Anything to that effect? 11 A I invoke my privilege. 12 JUDGE FACCIOLA: The invocation of the privilege is 13 sustained. 14 BY MR. KLAYMAN: 15 Q This document evidences -- look at the third 16 page -- that Secretary Brown was present at the signing of 17 the North China Power Group -- with the North China Power 18 Group President Jiao Yan, J-i-a-o, Yan, Y-a-n, and Chinese 19 Minister of Energy Shi Dahzhen, S-h-i, last word 20 D-a-h-z-h-e-n and that the U.S. Department of Commerce used 21 its taxpayer-financed resources to help negotiate a power 22 project on behalf of China, on behalf of the Lippo Group and 23 on behalf of Entergy during a trade mission to China in 24 August and September of 1994. 25 A I invoke my privilege. 87 1 JUDGE FACCIOLA: The invocation of the privilege is 2 sustained. 3 BY MR. KLAYMAN: 4 Q Did you participate in any way in arranging for 5 this trade mission that led to the negotiated joint venture 6 between China, Entergy and Lippo Group? 7 A I invoke my privilege. 8 JUDGE FACCIOLA: The invocation of the privilege is 9 sustained. 10 BY MR. KLAYMAN: 11 Q Do you know of anyone who did? 12 A I invoke my privilege. 13 JUDGE FACCIOLA: The invocation of the privilege is 14 sustained. 15 BY MR. KLAYMAN: 16 Q Do you know whether this Chinese Minister of 17 Energy, Shi Dahzhen -- 18 A I invoke my privilege. 19 Q I'm not finished yet. 20 A Oh, I'm sorry. 21 Q Was at that time with Chinese intelligence? 22 A I invoke my privilege. 23 JUDGE FACCIOLA: The invocation of the privilege is 24 sustained. 25 88 1 BY MR. KLAYMAN: 2 Q Did you ever ask to be briefed on energy projects 3 related to this joint venture at the Commerce Department? 4 A I invoke my privilege. 5 Q Did you ever ask to be briefed with classified 6 materials at the Commerce Department concerning this joint 7 venture to which I have just referred? 8 A I invoke my privilege. 9 Q Did you ever ask to be briefed with regard to the 10 energy industry in China in general? 11 A I invoke my privilege. 12 Q Did you ever see classified information about the 13 energy sector in China? 14 A I invoke my privilege. 15 Q Or anywhere in Asia? 16 A I invoke my privilege. 17 Q Lippo Group 18 A I invoke my privilege. 19 JUDGE FACCIOLA: The invocation of the privilege is 20 sustained in all instances. 21 BY MR. KLAYMAN: 22 Q Do you know whether you were briefed with regard to 23 the energy industry in China? 24 A I invoke my privilege. 25 Q At the Commerce Department? 89 1 A I invoke my privilege. 2 Q Or anywhere else in Asia? 3 A I invoke my privilege. 4 JUDGE FACCIOLA: The invocation of the privilege is 5 sustained in each instance. 6 MR. KLAYMAN: I'll show you what I'll ask the court 7 reporter to mark as the next exhibit. 8 THE COURT REPORTER: 57. 9 (Huang Deposition Exhibit No. 57 10 was marked for identification.) 11 BY MR. KLAYMAN: 12 Q This is a document produced by the Department of 13 Commerce on November 25, 1997, Mr. Huang. It has a cover 14 letter to Mr. Klayman, Larry Klayman, who is yours truly, 15 of Judicial Watch from Brian DiGiacomo, D-i-G-i-a-c-o-m-o, 16 Chief, General Law Division. And I'm going to ask you some 17 questions about this document. We'll identify them one by 18 one. It's a composite exhibit. 19 Turn past the first letter to the second page, from 20 a Roza Pace, R-o-z-a P-a-c-e, to Charles Martin, date 21 6/19/95, 6:42 p.m., subject: Mission Energy, Meizhou Wan 22 Power Project, M-e-i-z-h-o-u, Wan, W-a-n, Power Project. "We 23 met today with Mission Energy reps. They mentioned one 24 project which may be of interest to you, the Meizhou Wan coal 25 fired power plant in Fujian Provence." 90 1 That's the province where the Riadys were born, 2 correct? 3 MS. BRASWELL: Objection. Your Honor, I have an 4 objection to any questioning regarding these documents which 5 were produced to Judicial Watch in a separate FOIA case, it's 6 number 96-2747. 7 The document that was just read from was created in 8 June 1995 and does not relate to the trade missions at issue 9 in this case. 10 JUDGE FACCIOLA: Overruled. 11 MR. KLAYMAN: They do, Your Honor. 12 JUDGE FACCIOLA: I know, Mr. Klayman. I just 13 overruled the objection. 14 MR. KLAYMAN: Okay. Thank you. 15 JUDGE FACCIOLA: Please go forward. 16 MR. KLAYMAN: Okay. Thank you. 17 BY MR. KLAYMAN: 18 Q "The project involves a 700 megawatt power plant 19 which will use pulverized coal technology. Total value of 20 the project is $800 million, with $500 million of U.S. 21 content. The ownership includes Lippo Group 55 percent, 22 Mission Energy 20 percent, Bechtel 15 percent and Sembawang," 23 S-e-m-b-a-w-a-n-g, "Singapore. I understand that Secretary 24 Brown advocated on the project's behalf during his 1994 trip 25 to China. The project apparently went through the initial 91 1 approval process. Several broad issues, however, still need 2 to be resolved. These issues, however, are of relevance to 3 all power projects such as sovereign guarantees, foreign 4 exchange availability, et cetera. It has a high chance for 5 deliverable potential. What do you know about it? FYI 6 Mission will try to contact you via their rep in the Asean," 7 A-s-e-a-n, "region. cc Susan Hamrock," H-a-m-r-o-c-k, "TD-BI 8 Catherine Vial," V-i-a-l. 9 Have you ever seen this document before, Mr. Huang? 10 A I invoke my privilege. 11 JUDGE FACCIOLA: The invocation of the privilege is 12 sustained. 13 BY MR. KLAYMAN: 14 Q Who is Roza Pace? 15 A I invoke my privilege. 16 Q Who is Charles Martin? 17 A I invoke my privilege. 18 Q When I say who, where did they work at the time? 19 A I invoke my privilege. 20 JUDGE FACCIOLA: The invocation of the privilege is 21 sustained. 22 BY MR. KLAYMAN: 23 Q This document evidences yet another use of taxpayer 24 services of the Commerce Department to do business for Lippo 25 Group, your former employer, correct? 92 1 A I invoke my privilege. 2 JUDGE FACCIOLA: The invocation of the privilege is 3 sustained. 4 BY MR. KLAYMAN: 5 Q In fact, the Lippo Group was to own 55 percent of 6 this energy project, as referenced in this document, correct? 7 A I invoke my privilege. 8 Q Do you know a company called Mission Energy? 9 A I invoke my privilege. 10 Q That company has its headquarters in Irvine, 11 California, correct? 12 A I invoke my privilege. 13 JUDGE FACCIOLA: The invocation of the privilege is 14 sustained in both instances. 15 BY MR. KLAYMAN: 16 Q And that company has made contributions to the 17 Democratic Party and/or Clinton-Gore campaign, correct? 18 A I invoke my privilege. 19 JUDGE FACCIOLA: The invocation of the privilege is 20 sustained. 21 BY MR. KLAYMAN: 22 Q And Bechtel Corporation, you know of that company, 23 do you not? 24 A I invoke my privilege. 25 Q And that company was to have a 15 percent 93 1 participation in this joint venture, correct? 2 A I invoke my privilege. 3 JUDGE FACCIOLA: The invocation of the privilege is 4 sustained. 5 BY MR. KLAYMAN: 6 Q And you played a role in planning the trade trip 7 to China in 1994 to be able to assist Secretary Brown in 8 advocating on behalf of this joint venture between Lippo, 9 Mission Energy and Bechtel, correct? 10 A I invoke my privilege. 11 JUDGE FACCIOLA: The invocation of the privilege is 12 sustained. 13 BY MR. KLAYMAN: 14 Q This project went through the initial approval 15 process, did it not? 16 A I invoke my privilege. 17 Q It was because of projects such as this that you 18 asked to be briefed by individuals at the Commerce Department 19 with classified information on the energy sector in China, 20 correct? 21 A I invoke my privilege. 22 JUDGE FACCIOLA: The invocation of the privilege is 23 sustained. 24 BY MR. KLAYMAN: 25 Q And that you asked to be briefed with regard to the 94 1 energy sector in Asia generally, correct? 2 A I invoke my privilege. 3 Q Who is Susan Hamrock? 4 A I invoke my privilege. 5 Q And who is Catherine Vial? 6 A I invoke my privilege. 7 Q When I say who they are, I mean where did they work 8 at the time? 9 A Again, I invoke my privilege. 10 JUDGE FACCIOLA: The invocation of the privilege is 11 sustained in both instances. 12 BY MR. KLAYMAN: 13 Q Did you or anyone else that you know of arrange 14 for the participation of Mission Energy and Bechtel with 15 Lippo Group in this Meizhou Wan power project? 16 A I invoke my privilege. 17 JUDGE FACCIOLA: The invocation of the privilege is 18 sustained. 19 BY MR. KLAYMAN: 20 Q Do you know whether or not the reason that this 21 project has never been investigated is because Bechtel 22 Corporation contributes primarily to the Republican Party? 23 A I invoke my privilege. 24 MR. KLAYMAN: I'll show you what I'll ask the court 25 reporter to mark as the next exhibit. 95 1 THE COURT REPORTER: 58. 2 (Huang Deposition Exhibit No. 58 3 was marked for identification.) 4 BY MR. KLAYMAN: 5 Q Have you ever seen this document before? This is 6 an Associated Press story by Pete Yost of July 25, 1997 7 entitled "White House Had Controversial Guest." 8 A I invoke my privilege. 9 Q The first paragraph says, "Then presidential chief 10 of staff Mac McLarty approved a 1994 meeting that brought 11 several Chinese businessmen working on a project with the 12 controversial Lippo Group inside the White House." 13 Is that accurate? 14 A I invoke my privilege. 15 Q Who were those individuals that were invited inside 16 the White House? 17 A I invoke my privilege. 18 JUDGE FACCIOLA: The invocation of the privilege is 19 sustained in both instances. 20 BY MR. KLAYMAN: 21 Q The third paragraph says, "The meeting was sought 22 by Arkansan C. Joseph Giroir, a former law partner of Hillary 23 Rodham Clinton, and was also supposed to involve fundraiser 24 John Huang, according to White House documents obtained by 25 the Associated Press." 96 1 Is that an accurate statement? 2 A I invoke my privilege. 3 JUDGE FACCIOLA: The invocation of the privilege is 4 sustained. 5 BY MR. KLAYMAN: 6 Q Third paragraph. "Then White House aide Mark 7 Middleton hosted the Chinese businessmen and a Lippo Group 8 executive on the afternoon of April 22, 1994. Huang, a Lippo 9 employee, and his wife met with Middleton earlier in the day 10 at the White House, according to Middleton's calendars." 11 Is that a correct statement? 12 A I invoke my privilege. 13 JUDGE FACCIOLA: The invocation of the privilege is 14 sustained. 15 BY MR. KLAYMAN: 16 Q It then states, "The Huangs made $20,000 in 17 donations to the Democratic Party the month before the 18 meeting and another $500 contribution a week after it, 19 federal election records show." 20 Is that correct? 21 A I invoke my privilege. 22 Q The last paragraph, "The disclosure marks the first 23 time a meeting is known to have been held inside the White 24 House related to a proposed $1 billion China power plant 25 project, now dormant, spearheaded by the Indonesian-based 97 1 Lippo Group and Giroir." 2 Is that an accurate statement? 3 A I invoke my privilege. 4 JUDGE FACCIOLA: The invocation of the privilege is 5 sustained. 6 BY MR. KLAYMAN: 7 Q During this meeting, the individuals listed in this 8 article, Mr. Giroir, Mr. McLarty, Mr. Middleton and yourself, 9 in addition to the President and Hillary Rodham Clinton and 10 others, discussed using taxpayer-financed resources of the 11 Commerce Department to further the interests of the Riadys 12 and the Lippo Group with regard to this joint venture in 13 China, correct? 14 A I invoke my privilege. 15 JUDGE FACCIOLA: The invocation of the privilege is 16 sustained. 17 BY MR. KLAYMAN: 18 Q And the quid pro quo for undertaking an advocacy 19 of this joint venture by the U.S. Government for campaign 20 contributions which you, the Riady's and Lippo Group made 21 to the Clinton-Gore campaigns and the Democratic Party, 22 correct? 23 A I invoke my privilege. 24 JUDGE FACCIOLA: The invocation of the privilege is 25 sustained. 98 1 BY MR. KLAYMAN: 2 Q This joint venture which is referred to on page 1 3 as the joint venture which was negotiated during the trade 4 mission to China in August and September of 1994, correct? 5 A I invoke my privilege. 6 JUDGE FACCIOLA: The invocation of the privilege is 7 sustained. 8 BY MR. KLAYMAN: 9 Q Have you ever met Bob Luskin, L-u-s-k-i-n, a lawyer 10 for Mark Middleton? 11 A I invoke my privilege. 12 JUDGE FACCIOLA: The invocation of the privilege is 13 sustained. 14 BY MR. KLAYMAN: 15 Q Do you know an Antonio Pan of the Lippo Group? 16 A I invoke my privilege. 17 Q What does he do professionally? 18 A I invoke my privilege. 19 Q Where is he today? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: The invocation of the privilege is 22 sustained as to all three questions. 23 BY MR. KLAYMAN: 24 Q Did Mr. Pan participate in this joint venture to 25 China as referenced in Exhibit 58? 99 1 A I invoke my privilege. 2 Q I'll then turn back to Exhibit 57. The document at 3 the top says Mission Energy Company, 18101 Von Carmen Avenue, 4 Suite 1700, Irvine, California 92715. 5 Is that the address of Mission Energy Corporation 6 in Irvine? 7 A I invoke my privilege. 8 Q You have visited the Mission Energy company, have 9 you not? 10 A I invoke my privilege. 11 Q James S. Thompson, Vice President and General 12 Manager, Mission Energy Asia-Pacific. You know Mr. Thompson, 13 do you not? 14 A I invoke my privilege. 15 JUDGE FACCIOLA: The invocation of the privilege is 16 sustained as to all these questions. 17 BY MR. KLAYMAN: 18 Q And you worked with Mr. Thompson in furthering this 19 joint venture project as referenced in Exhibit 57, correct? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: The invocation of the privilege is 22 sustained. 23 BY MR. KLAYMAN: 24 Q That joint venture project is Meizhou Wan power 25 project. 100 1 A I invoke my privilege. 2 Q For that power project, U.S. lenders and the U.S. 3 Ex-Im Bank provided political risk coverage, correct? 4 A I invoke my privilege. 5 Q And they did so in exchange for campaign 6 contributions to the Clinton-Gore campaigns and the 7 Democratic Party. 8 A I invoke my privilege. 9 JUDGE FACCIOLA: The invocation of the privilege is 10 sustained. 11 BY MR. KLAYMAN: 12 Q Turn to the handwritten document two pages 13 forward where it says at the top meeting with Mission, 14 Meizhou Wan 900 million. It refers to Bechtel, it refers 15 to Lippo Group. 16 This is your handwriting, is it not, Mr. Huang? 17 A I invoke my privilege. 18 JUDGE FACCIOLA: The invocation of the privilege is 19 sustained. 20 BY MR. KLAYMAN: 21 Q If it's not your handwriting, do you know whose it 22 is? 23 A I invoke my privilege. 24 JUDGE FACCIOLA: The invocation of the privilege is 25 sustained. 101 1 BY MR. KLAYMAN: 2 Q Turn to the next page, India trip planning group. 3 that's Bates numbers 3AB0308. Do you see where you are 4 listed as part of that planning group, Mr. Huang? 5 A I invoke my privilege. 6 JUDGE FACCIOLA: The invocation of the privilege is 7 sustained. 8 MR. KLAYMAN: Can he claim the privilege on that, 9 Your Honor? 10 JUDGE FACCIOLA: I believe he can. 11 MR. KLAYMAN: Because my question was whether or 12 not he sees his name there. 13 JUDGE FACCIOLA: You're acknowledging the accuracy 14 of the document. 15 BY MR. KLAYMAN: 16 Q Did you or anyone else that you know of play a role 17 in trying to plan a trade mission to India at the Commerce 18 Department to further the business interests of the Riadys or 19 the Lippo Group? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: The invocation of the privilege is 22 sustained. 23 BY MR. KLAYMAN: 24 Q Was Mission Energy also involved in that joint 25 venture? 102 1 A I invoke my privilege. 2 JUDGE FACCIOLA: The invocation of the privilege is 3 sustained. 4 BY MR. KLAYMAN: 5 Q Is it not true that Mission Energy went on Commerce 6 Department trade missions? 7 A I invoke my privilege. 8 Q Was Enron Corporation involved in that proposed 9 joint venture in India? 10 A I invoke my privilege. 11 Q Is it not true that Enron went on trade missions to 12 China? 13 A I invoke my privilege. 14 JUDGE FACCIOLA: The invocation of the privilege is 15 sustained as to each of those instances. 16 BY MR. KLAYMAN: 17 Q What, if anything, do you know about advocacy by 18 the U.S. Department of Commerce on trade missions to India 19 concerning Motorola and Hughes Corporation? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: The invocation of the privilege is 22 sustained. 23 BY MR. KLAYMAN: 24 Q Did you play a role in planning the trade mission 25 to India and having it implemented to further the interests 103 1 of Hughes Corporation and Motorola? 2 A I invoke my privilege. 3 JUDGE FACCIOLA: The invocation of the privilege is 4 sustained. 5 BY MR. KLAYMAN: 6 Q Both Hughes Corporation and Motorola have donated 7 to the Clinton-Gore campaigns and the Democratic Party. 8 A I invoke my privilege. 9 JUDGE FACCIOLA: The invocation of the privilege is 10 sustained. 11 BY MR. KLAYMAN: 12 Q And they both have gone on Department of Commerce 13 trade missions, correct? 14 A I invoke my privilege. 15 JUDGE FACCIOLA: The invocation of the privilege is 16 sustained. 17 BY MR. KLAYMAN: 18 Q During the Clinton administration, correct? 19 A I invoke my privilege. 20 JUDGE FACCIOLA: The invocation of the privilege is 21 sustained. 22 BY MR. KLAYMAN: 23 Q Turn to the next document. It says "Background 24 data for companies seeking USG advocacy support." And it 25 lists a Robert M. E-d-g-e-d, it looks like, Executive Vice 104 1 President, Mission Energy Company. 2 Do you know such a gentleman? 3 A I invoke my privilege. 4 JUDGE FACCIOLA: The invocation of the privilege is 5 sustained. 6 BY MR. KLAYMAN: 7 Q This is another energy project which U.S. 8 taxpayer-financed resources of the Commerce Department were 9 being employed to try to effect in Indonesia, correct? 10 A I invoke my privilege. 11 JUDGE FACCIOLA: The invocation of the privilege is 12 sustained. 13 BY MR. KLAYMAN: 14 Q Now, this power project was called the Paiton, 15 P-a-i-t-o-n, Private Power Project, and it was located in 16 East Java, Indonesia, correct? 17 A I invoke my privilege. 18 Q And this project involved Mission Energy as well, 19 did it not? 20 A I invoke my privilege. 21 Q Turn to the next page. While this project did not 22 specifically involve direct participation in the plant itself 23 by Lippo Group, is it not true that it was contemplated that 24 coal produced by the Lippo Group in Indonesia would be used 25 to supply this plant? 105 1 A I invoke my privilege. 2 JUDGE FACCIOLA: The invocation of the privilege is 3 sustained. 4 BY MR. KLAYMAN: 5 Q Turn to the second page, Advocacy Project Profile 6 November 9, 1994. Do you see the first page, November 9, 7 1994 Advocacy Project Profile Indonesia? 8 A Yes. 9 Q Have you ever seen that document before? 10 A I invoke my privilege. 11 JUDGE FACCIOLA: The invocation of the privilege is 12 sustained. 13 BY MR. KLAYMAN: 14 Q Is the information contained therein correct? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: The invocation of the privilege is 17 sustained. 18 BY MR. KLAYMAN: 19 Q Did you help get Charlie Trie to participate on the 20 Indonesian trade mission of the Commerce Department? 21 A I invoke my privilege. 22 JUDGE FACCIOLA: The invocation of the privilege is 23 sustained. 24 BY MR. KLAYMAN: 25 Q Do you know what Mr. Trie did concerning that trade 106 1 mission? 2 A I invoke my privilege. 3 JUDGE FACCIOLA: The invocation of the privilege is 4 sustained. 5 BY MR. KLAYMAN: 6 Q Turn to the second page. Talking points, 7 paragraph, 2. "The Department of Commerce strongly supports 8 the Paiton power project. With it's state-of-the-art 9 emissions control technology and by using low sulphur 10 Indonesian coal, the project will be one of the cleanest, 11 most efficient coal fired facilities in the world." 12 The Riady family and the Lippo Group, either one or 13 the other or both, own interests in deposits of low sulfur 14 Indonesia coal correct? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: The invocation of the privilege is 17 sustained. 18 BY MR. KLAYMAN: 19 Q And is it not true that low sulfur coal is quite a 20 rare commodity in the world? 21 A I invoke my privilege. 22 Q And is it not true that the only other large 23 deposit of low sulfur coal is at the Escalante Monument in 24 Utah? 25 A I invoke my privilege. 107 1 JUDGE FACCIOLA: The invocation of the privilege is 2 sustained. 3 BY MR. KLAYMAN: 4 Q And is it not true that the low sulfur coal at the 5 Escalante Monument in Utah was declared a national park by 6 the Clinton Administration? 7 A I invoke my privilege. 8 JUDGE FACCIOLA: The invocation of the privilege is 9 sustained. 10 BY MR. KLAYMAN: 11 Q By executive order? 12 A Again, I invoke my privilege. 13 Q And, in fact, that declaration turning the 14 Escalante National Park, the portion concerning low sulfur 15 coal, into a national park was in exchange for campaign 16 contributions made by the Riadys and the Lippo Group to the 17 Clinton-Gore campaigns and the Democratic Party, correct? 18 A I invoke my privilege. 19 JUDGE FACCIOLA: The invocation of the privilege is 20 sustained. 21 BY MR. KLAYMAN: 22 Q And the reason why it was turned into a national 23 park was to increase the market value of coal owned by the 24 Riadys, correct? 25 A I invoke my privilege. 108 1 JUDGE FACCIOLA: The invocation of the privilege is 2 sustained. 3 BY MR. KLAYMAN: 4 Q And Commerce Department trade missions were being 5 used to further the energy interests of the Riadys and Lippo 6 Group. 7 A I invoke my privilege. 8 JUDGE FACCIOLA: The invocation of the privilege is 9 sustained. 10 BY MR. KLAYMAN: 11 Q Turn a few pages, it's a few pages down, 12 Subcontracts Paiton Power Project, Indonesia. Mission Energy 13 Construction Services, Inc. is the top listing and then it 14 lists a number of other companies. 15 Do you know anyone or have you had any involvement 16 with any people at those companies that are listed? 17 A I invoke my privilege. 18 JUDGE FACCIOLA: The invocation of the privilege is 19 sustained. 20 BY MR. KLAYMAN: 21 Q Do you know whether any of these companies are 22 owned in whole or in part by the Riadys and Lippo Group? 23 A I invoke my privilege. 24 JUDGE FACCIOLA: The invocation of the privilege is 25 sustained. 109 1 BY MR. KLAYMAN: 2 Q Turn to a few pages down wherein it states at the 3 top left-hand corner of the pate Paiton Project U.S. Supplier 4 Mission Energy Company, Purchaser: P.T. Paiton Energy 5 Company. 6 Do you know whether the Riadys and/or Lippo Group 7 own interest in P.T. Paiton Energy Company? 8 A I invoke my privilege. 9 JUDGE FACCIOLA: The invocation of the privilege is 10 sustained. 11 BY MR. KLAYMAN: 12 Q Wherein it stays Guaranteed Lender: Mission Energy 13 G.E., Mitsui Equity, loans from Ex-Im Bank, ADB Commercial 14 Banks. 15 Do you know whether or not G.E. contemplated or did 16 loan money in furtherance of this Paiton power project? 17 A I invoke my privilege. 18 JUDGE FACCIOLA: The invocation of the privilege is 19 sustained. 20 BY MR. KLAYMAN: 21 Q Turn down into this composite exhibit to a 22 facsimile transmission, Ms. Mary Good, Undersecretary of 23 Commerce, from Mark Grobmyer. 24 Do you see that? 25 A Yes, sir. 110 1 Q Dated May 7, 1996. 2 A Mm-hmm. 3 Q "Mark advised me to send you these two memorandums, 4 U.S. Fuel and Security, Trans-Asia Railroad Project. Thank 5 you. Julie -- " it looks like Lansing, L-a-n-s-i-n-g. 6 Do you know a Mark Grobmyer? 7 A I invoke my privilege. 8 JUDGE FACCIOLA: The invocation of the privilege is 9 sustained. 10 BY MR. KLAYMAN: 11 Q Do you know what role Mark Grobmyer had, if any, in 12 Department of Commerce trade missions -- 13 A I invoke my privilege. 14 Q -- that are the subject of this lawsuit? 15 A I invoke my privilege. 16 Q Do you know whether Mark Grobmyer participated on 17 the trade mission to Russia at the Commerce Department? 18 A I invoke my privilege. 19 Q Do you know what he did on the trade mission to 20 Russia? 21 A I invoke my privilege. 22 JUDGE FACCIOLA: The invocation of the privilege is 23 sustained. 24 BY MR. KLAYMAN: 25 Q Mark Grobmyer is a fundraiser, correct? 111 1 A I invoke my privilege. 2 JUDGE FACCIOLA: The invocation of the privilege is 3 sustained. 4 BY MR. KLAYMAN: 5 Q And he's a close friend of the Clintons, correct? 6 A I invoke my privilege. 7 JUDGE FACCIOLA: The invocation of the privilege is 8 sustained. 9 BY MR. KLAYMAN: 10 Q Do you know whether Governor Roy Romer of Colorado 11 had any involvement in Commerce Department trade missions 12 under Ron Brown? 13 A I invoke my privilege. 14 Q I turn your attention to a document from the State 15 of Colorado which you appear to have already found re: Romer 16 conversation with Commerce Secretary Brown, 1/12/95, to a 17 Marsha Hale, Director, White House Intergovernmental Affairs. 18 Do you know Marsha Hale? 19 A I invoke my privilege. 20 JUDGE FACCIOLA: The invocation of the privilege is 21 sustained. 22 BY MR. KLAYMAN: 23 Q Do you know what her duties and responsibilities 24 were at the White House on or about January 12, 1995? 25 A I invoke my privilege. 112 1 Q The document states, "Marsha, in light of the 2 President's upcoming visit to Colorado on Monday, I thought 3 it might be helpful for you to have a heads up on the 4 attached correspondence from Governor Romer to Commerce 5 Secretary Ron Brown and U.S. Trade Representative Kantor. 6 "The governor spoke to Secretary Brown about 7 holding a hemisphere trade and commerce forum in Colorado 8 later this year. My understanding is that the secretary 9 agreed that Colorado would be an ideal location and we are 10 working with Barbara Schmitz of Secretary Brown's office to 11 figure out how and when to make an announcement. 12 "We thought it might be something the President 13 could announce and get credit for during his visit to 14 Colorado and this is my only reason for sending this to your 15 attention." 16 Does that refresh your recollection as to whether 17 or not Governor Roy Romer, now chairman of the Democratic 18 Party, played any role in Commerce Department trade missions 19 during the Clinton administration? 20 A I invoke my privilege. 21 Q Did he play any role with regard to interests that 22 involved in any way the Lippo Group? 23 A I invoke my privilege. 24 Q Or the Riadys? 25 A Again, I invoke my privilege. 113 1 JUDGE FACCIOLA: The invocation of the privilege is 2 sustained in each instance. 3 BY MR. KLAYMAN: 4 Q Do you know whether or not because of his 5 involvement, if any, in Commerce Department trade missions 6 Governor Romer has instructed individuals of the Democratic 7 Party not to produce documents to this Court? 8 A I invoke my privilege. 9 JUDGE FACCIOLA: The invocation of the privilege is 10 sustained. 11 BY MR. KLAYMAN: 12 Q Have you had any contact with Governor Romer any 13 time since October 29, 1996? 14 A I invoke my privilege. 15 JUDGE FACCIOLA: The invocation of the privilege is 16 sustained. 17 BY MR. KLAYMAN: 18 Q Do you know of anyone who has concerning this 19 lawsuit that you're here on today? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: The invocation of the privilege is 22 sustained. 23 BY MR. KLAYMAN: 24 Q Turn down to the page -- seems like you're 25 following me there -- October 24, 1996 memorandum to 114 1 Frank Record, Committee on International Relations, House 2 of Representatives, from Jane Bobbitt, B-o-b-b-i-t-t, 3 Assistant Secretary for Legislative and Intergovernmental 4 Affairs. 5 Who is Jane Bobbitt? 6 A I invoke my privilege. 7 Q Who is Frank Record? 8 A Again, I invoke my privilege. 9 JUDGE FACCIOLA: The invocation of the privilege is 10 sustained. 11 BY MR. KLAYMAN: 12 Q Do you know a Barbara Fredericks? 13 A I invoke my privilege. 14 Q Have you ever discussed with her this lawsuit? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: The invocation of the privilege is 17 sustained. 18 BY MR. KLAYMAN: 19 Q Do you know a Sue Esserman? 20 A Again, I invoke my privilege. 21 Q Have you ever discussed with her this lawsuit? 22 A I invoke my privilege. 23 JUDGE FACCIOLA: The invocation of the privilege is 24 sustained in all instances. 25 115 1 BY MR. KLAYMAN: 2 Q Second page, "Who reported directly to John Huang 3 during his tenure as Principal Deputy Assistant Secretary?" 4 "The following reported directly to John Huang and 5 Assistant Secretary Charles Meissner, receiving policy 6 direction from Mr. Meissner and management guidance from Mr. 7 Huang." 8 It lists five individuals: Janice Stewart, 9 Mr. Huang's secretary; Peter Hale, H-a-l-e, Director, Office 10 of Policy Coordination; Lewis J. Murphy, Director, Office of 11 Multilateral Affairs; James Holbein, H-o-l-b-e-i-n, Director, 12 NAFTA Secretariat; Halina Malinowski, H-a-l-i-n-a, 13 Malinowski, M-a-l-i-n-o-w-s-k-i, Program Analyst. 14 Are those the people that reported directly to you 15 when you were at the Commerce Department, Mr. Huang? 16 A I invoke my privilege. 17 Q Were there more than these five people who reported 18 directly to you? 19 A I invoke my privilege. 20 JUDGE FACCIOLA: The invocation of the privilege is 21 sustained. 22 BY MR. KLAYMAN: 23 Q In addition to Ms. Janice Stewart, Halina 24 Malinowski was your secretary at the Commerce Department, 25 correct? 116 1 A I invoke my privilege. 2 Q And, in fact, she knows much about what you were 3 doing at the Commerce Department. 4 A I invoke my privilege. 5 Q Are aware that Janice Stewart testified that you 6 directed her to provide classified cables, State Department 7 cables, to you? 8 A I invoke my privilege. 9 JUDGE FACCIOLA: The invocation of the privilege is 10 sustained. 11 BY MR. KLAYMAN: 12 Q And that you directed her to shred some of those 13 cables from time to time? 14 A I invoke my privilege. 15 JUDGE FACCIOLA: The invocation of the privilege is 16 sustained. 17 BY MR. KLAYMAN: 18 Q Did you issue the same directives to Halina 19 Malinowski? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: The invocation of the privilege is 22 sustained. 23 BY MR. KLAYMAN: 24 Q Does Ms. Halina Malinowski have information about 25 your receipt of classified information while you were at the 117 1 Commerce Department? 2 A I invoke my privilege. 3 Q Does she have information about your removal of 4 classified information from the Commerce Department? 5 A I invoke my privilege. 6 JUDGE FACCIOLA: The invocation of the privilege is 7 sustained in each instance. 8 BY MR. KLAYMAN: 9 Q Do you know a Sanford Robinson of Robertson 10 Stephens & Company? 11 A Excuse me. I'm lost a little bit. Let me flip the 12 page, please. 13 Q There's no flipping. 14 A Yes. Go ahead. I'm sorry. 15 Q Do you know a Sanford Robinson? 16 A I invoke my privilege. 17 Q Did you participate -- do you know whether or not 18 Melissa Moss destroyed documents evidencing seats being sold 19 on trade missions for campaign contributions? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: The invocation of the privilege is 22 sustained. 23 BY MR. KLAYMAN: 24 Q Did you have any communication with Ms. Melissa 25 Moss about destroying documents concerning Commerce 118 1 Department trade missions? 2 A I invoke my privilege. 3 Q Do you know where Ms. Moss has stored documents 4 concerning Commerce Department trade missions? 5 A I invoke my privilege. 6 JUDGE FACCIOLA: The invocation of the privilege is 7 sustained. 8 BY MR. KLAYMAN: 9 Q Do you know Mr. K.S. Wu of Pacific Century Group? 10 A I invoke my privilege. 11 JUDGE FACCIOLA: The invocation of the privilege is 12 sustained. 13 BY MR. KLAYMAN: 14 Q Do you know a Mr. James Harmon, H-a-r-m-o-n, of 15 Wertheim Schroder & Company? 16 A I invoke my privilege. 17 Q Wertheim Schroder participated on the trade trip to 18 China, correct? 19 A I invoke my privilege. 20 Q In the fall of 1994, correct? 21 A I invoke my privilege. 22 Q And Wertheim Schroder got its seat on the trade 23 missions by virtue of campaign contributions made by James 24 Harmon and/or Wertheim Schroder to the Democratic Party or 25 Clinton-Gore campaigns. 119 1 A I invoke my privilege. 2 JUDGE FACCIOLA: The invocation of the privilege is 3 sustained. 4 BY MR. KLAYMAN: 5 Q Mr. K.S. Wu participated on a trade mission to 6 China, correct? 7 A I invoke my privilege. 8 Q And he got his seat on that trade mission by virtue 9 of campaign contributions to the Democratic Party and/or 10 Clinton-Gore campaigns, correct? 11 A I invoke my privilege. 12 JUDGE FACCIOLA: The invocation of the privilege is 13 sustained. 14 BY MR. KLAYMAN: 15 Q You know an Edwin Lupberger of Entergy Corporation, 16 correct? 17 A I invoke my privilege. 18 Q He's the chairman and chief executive officer, 19 correct? 20 A I invoke my privilege. 21 Q And he got his seat on the trade mission to China 22 in the fall of '94 by virtue of campaign contributions which 23 either he or Entergy Corporation made to the Clinton-Gore 24 campaigns and/or the Democratic Party, correct? 25 A I invoke my privilege. 120 1 MR. KLAYMAN: We're out of tape, Your Honor. 2 JUDGE FACCIOLA: All right. Let's break for lunch. 3 How much more do you have, Mr. Klayman? 4 MR. KLAYMAN: We're -- a bit. 5 JUDGE FACCIOLA: How much is a bit? Two hours? 6 MR. KLAYMAN: Three, four, somewhere in that range. 7 JUDGE FACCIOLA: All right. We'll reassemble 8 at 1:30. 9 MR. KLAYMAN: We're making good progress. 10 JUDGE FACCIOLA: Okay. Reassemble at 1:30. 11 THE VIDEOGRAPHER: We're going off video record 12 at 12:22. 13 (Whereupon, at 12:22 p.m., a luncheon recess 14 was taken.) 15 * * * * * 121 1 A F T E R N O O N S E S S I O N 2 (1:34 p.m.) 3 THE VIDEOGRAPHER: We're back on video record 4 at 1:34. 5 Whereupon, 6 JOHN HUANG 7 was recalled as a witness and, after having been previously 8 duly sworn, was examined and testified further as follows: 9 EXAMINATION BY COUNSEL FOR PLAINTIFF (RESUMED) 10 BY MR. KLAYMAN: 11 Q Mr. Huang, I want to turn your attention back to 12 Exhibit 32 and the entries of July 18th and July 19th. 13 That's on page 94063. 14 With regard to that Indonesian trade meeting listed 15 at 2:00 p.m., it says room 3407, APEC Intercommunity, is that 16 your handwriting there? 17 A I invoke my privilege. 18 JUDGE FACCIOLA: The invocation of the privilege is 19 sustained. 20 BY MR. KLAYMAN: 21 Q What was discussed at that Indonesian meeting? 22 A I invoke my privilege. 23 JUDGE FACCIOLA: The invocation of the privilege is 24 sustained. 25 122 1 BY MR. KLAYMAN: 2 Q Were there discussions of putting together joint 3 ventures that would benefit Lippo Group? 4 A I invoke my privilege. 5 JUDGE FACCIOLA: The invocation of the privilege is 6 sustained. 7 BY MR. KLAYMAN: 8 Q At 4:15 is listed an Asia-Pacific meeting in 9 room 5430. 10 What was that meeting? Did that meeting take 11 place? 12 A I invoke my privilege. 13 Q Did you attend the meeting? 14 A I invoke my privilege. 15 JUDGE FACCIOLA: The invocation of the privilege is 16 sustained. 17 BY MR. KLAYMAN: 18 Q And what was discussed there? 19 A I invoke my privilege. 20 JUDGE FACCIOLA: The invocation of the privilege is 21 sustained. 22 BY MR. KLAYMAN: 23 Q Let's turn to the next column. 11 a.m., this is 24 July 20th, meeting with Karl Reiner. 25 Is that your handwriting? 123 1 A I invoke my privilege. 2 Q Is that the handwriting of one of your secretaries? 3 A I invoke my privilege. 4 Q Who is Karl Reiner? 5 A I invoke my privilege. 6 JUDGE FACCIOLA: The invocation of the privilege is 7 sustained. 8 BY MR. KLAYMAN: 9 Q At 2:00 p.m., it lists China trip meeting, 10 checklist, Nancy. 11 Was there a China trip meeting at 2:00 p.m.? 12 A I invoke my privilege. 13 JUDGE FACCIOLA: The invocation of the privilege is 14 sustained. 15 BY MR. KLAYMAN: 16 Q You participated in that meeting, did you not? 17 A I invoke my privilege. 18 Q And that was a planning meeting for the trade trip 19 to China in August and September of 1994. 20 A I invoke my privilege. 21 Q The reference to Nancy is Nancy Linn Patton, 22 correct? 23 A I invoke my privilege. 24 JUDGE FACCIOLA: The invocation of the privilege is 25 sustained in each of those instances. 124 1 BY MR. KLAYMAN: 2 Q Marge Searing, did Marge Searing work with you at 3 the Commerce Department? 4 A I invoke my privilege. 5 Q Where did she work? 6 A I invoke my privilege. 7 Q The reference at 5:00 p.m. to LaRussa, 3802, is 8 Mr. LaRussa an employee of Commerce Department? 9 A I invoke my privilege. 10 Q The reference to Ginger Lew at 7:30 p.m., dinner -- 11 A I invoke my privilege. 12 Q Room 772, you know Ginger Lew, correct? 13 A I invoke my privilege. 14 Q In fact, she is a friend of yours, correct? 15 A I invoke my privilege. 16 Q Why were you scheduled to have dinner with her that 17 night? 18 A I invoke my privilege. 19 Q You are aware that Ginger Lew was General Counsel 20 of the Commerce Department, correct? 21 A I invoke my privilege. 22 Q And Ginger Lew put a great emphasis on lowering the 23 barriers to export licenses, correct? 24 A I invoke my privilege. 25 Q And you encouraged others at the Commerce 125 1 Department to lower the barriers to export high technology to 2 China, correct? 3 A I invoke my privilege. 4 JUDGE FACCIOLA: The invocation of the privilege is 5 sustained in each of the instances. 6 BY MR. KLAYMAN: 7 Q On July 20, 1994, you were also called by Mark 8 Middleton, correct? 9 A I invoke my privilege. 10 Q I turn your attention to Exhibit 34 which we 11 previously marked which is John Huang DSC Telephone Data, 12 Domestic Long Distance, Domestic Calling Card, Employment 13 Period Search July 18, 1994 to January 17, 1996. And turn 14 to page 37. 15 Let me ask you whether the telephone number of Mark 16 Middleton appears on this page. 17 A I invoke my privilege. 18 Q On July 28th, you were also called by Joseph Giroir 19 two times, correct? 20 A I invoke my privilege. 21 Q Does the telephone number of Mr. Giroir appear on 22 this page, number 37, of Exhibit 34? 23 A I invoke my privilege. 24 JUDGE FACCIOLA: The invocation of the privilege is 25 sustained in each instance. 126 1 BY MR. KLAYMAN: 2 Q Now, on July 19th, going back one day, you were 3 also called by Mark Grobmyer, correct? 4 A I invoke my privilege. 5 Q Does his telephone number appear on page 37 of 6 Exhibit 34? 7 A I invoke my privilege. 8 Q And, on July 19th, you were called on more than one 9 occasion by Ginger Lew, correct? 10 A I invoke my privilege. 11 Q Does her phone number appear on page 37 of Exhibit 12 34? 13 A I invoke my privilege. 14 JUDGE FACCIOLA: The invocation of the privilege is 15 sustained in each instance. 16 BY MR. KLAYMAN: 17 Q Ginger Lew, General Counsel of the Commerce 18 Department, knew of your efforts to compromise U.S. national 19 security, correct? 20 A I invoke my privilege. 21 Q Ginger Lew knew that you had access to classified 22 information at the Commerce Department, correct? 23 A I invoke my privilege. 24 Q And she knew that you passed that classified 25 information to Chinese authorities, correct? 127 1 A I invoke my privilege. 2 Q And she knew that you passed that classified 3 information to the Lippo Group and the Riadys. 4 A I invoke my privilege. 5 JUDGE FACCIOLA: The invocation of the privilege is 6 sustained in each instance. 7 BY MR. KLAYMAN: 8 Q And she knew you passed that information to others 9 as well, correct? 10 A I invoke my privilege. 11 Q Ms. Lew knew that the Commerce Department was being 12 used on the trade trip to China, Indonesia and India to do 13 business at U.S. taxpayer expense for the Lippo Group, 14 correct? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: The invocation of the privilege is 17 sustained. 18 BY MR. KLAYMAN: 19 Q And Ms. Lew knew that seats on trade missions of 20 the Commerce Department were being sold for campaign 21 contributions to the Clinton-Gore campaigns and the 22 Democratic Party. 23 A I invoke my privilege. 24 JUDGE FACCIOLA: The invocation of the privilege is 25 sustained. 128 1 BY MR. KLAYMAN: 2 Q Ms. Lew participated in allowing satellite 3 encryptions to leave the Commerce Department through Ira 4 Sockowitz, correct? 5 A I invoke my privilege. 6 JUDGE FACCIOLA: The invocation of the privilege is 7 sustained. 8 BY MR. KLAYMAN: 9 Q You are aware that -- you do know an Ira Sockowitz, 10 do you not? 11 A I invoke my privilege. 12 Q Are you aware that Mr. Sockowitz left the Commerce 13 Department with satellite encryptions? 14 A I invoke my privilege. 15 Q Are you aware that they were classified? 16 A I invoke my privilege. 17 Q Are you aware that he took three CIA reports on 18 Russia, India and China? 19 A I invoke my privilege. 20 JUDGE FACCIOLA: The invocation of the privilege is 21 sustained in each instance. 22 BY MR. KLAYMAN: 23 Q Who else was Mr. Sockowitz working with, if anyone, 24 in removing the classified satellite encryptions and the 25 three CIA reports? 129 1 A I invoke my privilege. 2 Q He was working with you, wasn't he, Mr. Huang? 3 A I invoke my privilege. 4 JUDGE FACCIOLA: The invocation of the privilege is 5 sustained. 6 BY MR. KLAYMAN: 7 Q That classified information was removed to provide 8 to Communist Chinese authorities, was it not? 9 A I invoke my privilege. 10 JUDGE FACCIOLA: The invocation of the privilege is 11 sustained. 12 BY MR. KLAYMAN: 13 Q Or it was removed to provide to private companies 14 in the satellite, missile and telecommunications area, 15 correct? 16 A I invoke my privilege. 17 JUDGE FACCIOLA: The invocation of the privilege is 18 sustained. 19 BY MR. KLAYMAN: 20 Q The purpose of removing that information was to 21 sell it to the highest bidder, correct? 22 A I invoke my privilege. 23 JUDGE FACCIOLA: The invocation of the privilege is 24 sustained. 25 130 1 BY MR. KLAYMAN: 2 Q Do you know why it is that no one has ever 3 investigated the removal of encryptions and CIA reports by 4 Ira Sockowitz? 5 A I invoke my privilege. 6 JUDGE FACCIOLA: The invocation of the privilege is 7 sustained. 8 BY MR. KLAYMAN: 9 Q Do you know whether anyone has investigated it? 10 A I invoke my privilege. 11 JUDGE FACCIOLA: Sustained. 12 BY MR. KLAYMAN: 13 Q Did you work with Ginger Lew on Democratic 14 fundraising matters? 15 A I invoke my privilege. 16 Q Do you know whether Ms. Lew did get involved in 17 Democrat or Clinton-Gore fundraising matters? 18 A I invoke my privilege. 19 JUDGE FACCIOLA: The invocation of the privilege is 20 sustained in each instance. 21 BY MR. KLAYMAN: 22 Q Do you know where Ms. Lew works today? 23 A I invoke my privilege. 24 Q Are you aware that she works for a 25 telecommunications company? 131 1 A I invoke my privilege. 2 JUDGE FACCIOLA: The invocation of the privilege is 3 sustained. 4 MR. KLAYMAN: I'll show you what I'll ask the court 5 reporter to mark as the next exhibit. 6 THE COURT REPORTER: 59. 7 (Huang Deposition Exhibit No. 59 8 was marked for identification.) 9 BY MR. KLAYMAN: 10 Q This is an article entitled "FBI Had Overlooked Key 11 Files in Probe of Chinese Influence" by Bob Woodward of 12 November 14, 1997. It consists of five pages. 13 Have you ever seen this article before? 14 A Can I take a glance look at it? 15 Q Sure. 16 (Pause.) 17 A I don't believe so, Mr. Klayman. 18 Q Do you know who Bob Woodward is? 19 A Yes, I do. 20 Q Okay. Do you know that he's the -- 21 A I know of this person. 22 Q He's the famous reporter of the Washington Post 23 that uncovered Watergate. You know that? 24 A Yes. 25 Q Are you aware of his reputation in the journalistic 132 1 community? 2 A I invoke my privilege. 3 JUDGE FACCIOLA: The invocation of the privilege is 4 sustained. 5 BY MR. KLAYMAN: 6 Q The first paragraph, "The FBI has acknowledged 7 overlooking key intelligence information gathered as far 8 back as 1991 that investigators believe shows further 9 Chinese government efforts to buy political influence in 10 the United States, senior U.S. Government sources said 11 yesterday." 12 I turn your attention to the second page, wherein 13 it says in the second paragraph from the bottom, "Hsia worked 14 closely with Huang and was co-chair with him of an April 1996 15 luncheon attended by Vice President Gore at the Hsi Lai 16 Buddhist temple," H-s-i Lai, L-a-i, "in California." 17 Is that a true statement? 18 A I invoke my privilege. 19 JUDGE FACCIOLA: The invocation of the privilege is 20 sustained. 21 BY MR. KLAYMAN: 22 Q Turn to the next page. Have you ever discussed 23 anything related to this whole campaign finance controversy 24 with Chinese president Jiang Zemin? 25 A I invoke my privilege. 133 1 JUDGE FACCIOLA: The invocation of the privilege is 2 sustained. 3 BY MR. KLAYMAN: 4 Q Do you know whether or not Maria Hsia is an agent 5 of the government of China? 6 A I invoke my privilege. 7 Q Do you know whether she's passed classified 8 information to the Chinese? 9 A I invoke my privilege. 10 JUDGE FACCIOLA: The invocation of the privilege is 11 sustained. 12 BY MR. KLAYMAN: 13 Q Look at the fourth paragraph. "Freeh's order 14 turned up other previously undisclosed leads from FBI files, 15 including reports considered reliable but unconfirmed that 16 Huang, while serving as a senior Commerce Department in the 17 Clinton administration, passed a classified document to the 18 Chinese government." 19 Is that a true statement? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: The invocation of the privilege is 22 sustained. 23 BY MR. KLAYMAN: 24 Q Mr. Huang, did you pass a classified document to 25 the Chinese government? 134 1 A I invoke my privilege. 2 Q Did you keep a classified document in the safe of 3 the office that you occupied at the Commerce Department and 4 did you pass that to the Chinese? 5 A I invoke my privilege. 6 JUDGE FACCIOLA: The invocation of the privilege is 7 sustained. 8 BY MR. KLAYMAN: 9 Q What general subject matter did that document 10 involve? 11 A I invoke my privilege. 12 JUDGE FACCIOLA: The invocation of the privilege is 13 sustained. 14 BY MR. KLAYMAN: 15 Q Did you have a safe in your office at the Commerce 16 Department? 17 A I invoke my privilege. 18 Q Was that safe transferred to the White House at any 19 time either that you worked in the Commerce Department or 20 thereafter? 21 A I invoke my privilege. 22 JUDGE FACCIOLA: The invocation of the privilege is 23 sustained. 24 BY MR. KLAYMAN: 25 Q Do you have any knowledge as to whether or not any 135 1 of your telephone calls to anyone were intercepted by the 2 Federal Bureau of Investigation? 3 A I invoke my privilege. 4 JUDGE FACCIOLA: The invocation of the privilege is 5 sustained. 6 BY MR. KLAYMAN: 7 Q On July 21, 1994, were you called by Maria Haley of 8 the Ex-Im Bank? 9 A I invoke my privilege. 10 JUDGE FACCIOLA: The invocation of the privilege is 11 sustained. 12 BY MR. KLAYMAN: 13 Q Turn to page 64 of Exhibit 34. Is Ms. Maria 14 Haley's telephone number listed on that telephone log? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: The invocation of the privilege is 17 sustained. 18 BY MR. KLAYMAN: 19 Q Is Exhibit 34 a listing of your phone calls, long 20 distance, at the Commerce Department? 21 A I invoke my privilege. 22 JUDGE FACCIOLA: Sustained. 23 BY MR. KLAYMAN: 24 Q On or about July 21st, were you called by Colonel 25 John Luke, L-u-k-e, concerning the China trip of the Commerce 136 1 Department? 2 A I invoke my privilege. 3 JUDGE FACCIOLA: Sustained. 4 BY MR. KLAYMAN: 5 Q Did you ever receive a letter of recommendation for 6 appointment to the Commerce Department by Tom Daschle, 7 D-a-s-c-h-l-e, of South Dakota, a senator? 8 A I invoke my privilege. 9 Q Do you know Mr. Daschle? 10 A I invoke my privilege. 11 JUDGE FACCIOLA: The invocation of the privilege is 12 sustained. 13 BY MR. KLAYMAN: 14 Q Did you, the Riadys, or the Lippo Group ever donate 15 monies to Mr. Daschle's political campaigns? 16 A I invoke my privilege. 17 A I invoke my privilege. 18 JUDGE FACCIOLA: The invocation of the privilege is 19 sustained in each instance. 20 BY MR. KLAYMAN: 21 Q Did you, the Riadys or the Lippo Group ever donate 22 monies to the political campaign of Don Nickles, a senator 23 from Oklahoma? 24 A I invoke my privilege. 25 JUDGE FACCIOLA: The invocation of the privilege is 137 1 sustained. 2 BY MR. KLAYMAN: 3 Q Did you, the Riadys or the Lippo Group ever donate 4 monies to any Republican senators? 5 A I invoke my privilege. 6 JUDGE FACCIOLA: The invocation of the privilege is 7 sustained. 8 BY MR. KLAYMAN: 9 Q Same question with regard to Mitch McConnell. 10 A I invoke my privilege. 11 JUDGE FACCIOLA: The invocation of the privilege is 12 sustained. 13 BY MR. KLAYMAN: 14 Q In fact, you, the Riadys and the Lippo Group 15 donated monies not only to Democrat candidates, but also 16 Republican ones, didn't you? 17 A I invoke my privilege. 18 JUDGE FACCIOLA: The invocation of the privilege is 19 sustained. 20 BY MR. KLAYMAN: 21 Q Did you, John Huang, ever give a contribution to 22 Governor Evan Bayh, Democrat, of Indiana? 23 A I invoke my privilege. 24 Q On the declaration form used to list that 25 contribution, did you ever state that it was going on behalf 138 1 of Lippo Group, that contribution? 2 MS. BRASWELL: Your Honor, I'm going to object to 3 this continued line of questioning. It's clearly outside the 4 scope of discovery. 5 JUDGE FACCIOLA: I'm going to sustain the 6 privilege. 7 BY MR. KLAYMAN: 8 Q On July 22, 1994, were you called at the Commerce 9 Department by Webster Hubbell? 10 A I invoke my privilege. 11 Q Can you look at page 37 of Exhibit 34? Is 12 Mr. Hubbell's phone number contained on that listing? 13 A I invoke my privilege. 14 JUDGE FACCIOLA: The invocation of the privilege is 15 sustained. 16 BY MR. KLAYMAN: 17 Q On the calendar for July 22nd, this is Exhibit 32, 18 11:15, it lists ITI diversity meetings, room 3406. 19 What were diversity meetings about? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: The invocation of the privilege is 22 sustained. 23 BY MR. KLAYMAN: 24 Q On July 25, 1994, were you called by Mark Middleton 25 at the Commerce Department? 139 1 A I invoke my privilege. 2 Q What did you discuss with Mr. Middleton? 3 A Again, I invoke my privilege. 4 Q The same question with regard to Maria Haley on 5 July 21, 1994. What did you discuss? 6 A I invoke my privilege. 7 JUDGE FACCIOLA: The invocation of the privilege is 8 sustained. 9 BY MR. KLAYMAN: 10 Q Same question with regard to the telephone 11 conversations with Mark Middleton and Joseph Giroir on 12 July 20, 1994. What was discussed? 13 A I invoke my privilege. 14 Q And same question with regard to the phone 15 conversations you had with Mark Grobmyer and Ginger Lew in 16 July 1994. What was discussed? 17 A I invoke my privilege. 18 JUDGE FACCIOLA: Sustained in each instance. 19 BY MR. KLAYMAN: 20 Q Were you called by Joseph Giroir twice on July 26, 21 1994? 22 A I invoke my privilege. 23 JUDGE FACCIOLA: The invocation of the privilege is 24 sustained. 25 140 1 BY MR. KLAYMAN: 2 Q What was discussed with Mr. Giroir? 3 A I invoke my privilege. 4 JUDGE FACCIOLA: The invocation of the privilege is 5 sustained. 6 BY MR. KLAYMAN: 7 Q Do the listings of telephone calls from 8 Mr. Middleton on July 25th and Joseph Giroir on July 26th 9 appear on page 37 of Exhibit 34? 10 A I invoke my privilege. 11 JUDGE FACCIOLA: Sustained. 12 BY MR. KLAYMAN: 13 Q On July 26, 1994, it lists that you had a meeting 14 with Chuck Meissner at 1:30 p.m. 15 Did you have a meeting at that time? 16 A I invoke my privilege. 17 Q What was discussed? 18 A I invoke my privilege. 19 JUDGE FACCIOLA: Sustained. 20 BY MR. KLAYMAN: 21 Q On July 27, 1994, in your calendar, which is 22 Exhibit 32, it lists a pre-brief with Nancy and Rothkopf. 23 Is that Nancy Linn Patton that's being referred to? 24 A I invoke my privilege. 25 Q Is that David Rothkopf? 141 1 A I invoke my privilege. 2 Q What was discussed? 3 A I invoke my privilege. 4 JUDGE FACCIOLA: The invocation of the privilege is 5 sustained in each instance. 6 BY MR. KLAYMAN: 7 Q Turning to page 94066 of your calendar, 10:00 a.m., 8 it says "Asia-Pacific task force with Rothkopf." 9 What is the Asia-Pacific task force? 10 A I invoke my privilege. 11 JUDGE FACCIOLA: Sustained. 12 BY MR. KLAYMAN: 13 Q Was there a meeting that took place at that time? 14 A I invoke my privilege. 15 Q It shows that you had a meeting at 11:30 a.m. with 16 Cortland Cox, room 6010. Do you know Cortland Cox? 17 A I invoke my privilege. 18 Q Did you have a meeting with him? 19 A I invoke my privilege. 20 Q What was discussed? 21 A I invoke my privilege. 22 Q Do you have any information as to whether or not 23 Cortland Cox has removed documents from the Department of 24 Commerce and deposited them in Howard University, documents 25 which should have been produced in this lawsuit? 142 1 A I invoke my privilege. 2 JUDGE FACCIOLA: Sustained as to each question 3 asked. 4 BY MR. KLAYMAN: 5 Q On Monday, June 20, 1994, did you meet with Webster 6 Hubbell and Mrs. Clinton? 7 A I invoke my privilege. 8 JUDGE FACCIOLA: Sustained. 9 BY MR. KLAYMAN: 10 Q And did you both attend a business leaders 11 reception with President Clinton on the south lawn of the 12 White House? 13 A I invoke my privilege. 14 JUDGE FACCIOLA: Sustained. 15 BY MR. KLAYMAN: 16 Q On Wednesday, June 22, 1994, did Ng Lap Seng, 17 Charlie Trie and Mark Middleton have lunch at the White 18 House? 19 A I invoke my privilege. 20 JUDGE FACCIOLA: Sustained. 21 BY MR. KLAYMAN: 22 Q And did you and James Riady make another visit with 23 Mr. Middleton to the White House on that day? 24 A I invoke my privilege. 25 JUDGE FACCIOLA: Sustained. 143 1 BY MR. KLAYMAN: 2 Q On Thursday, June 23, 1994, did Mr. Riady meet with 3 Webster Hubbell twice for breakfast and lunch? 4 A I invoke my privilege. 5 Q Did Mr. Riady return to the White House for a third 6 time that day and you and he, did you make two visits to the 7 White House on that day? 8 A I invoke my privilege. 9 JUDGE FACCIOLA: Sustained. 10 BY MR. KLAYMAN: 11 Q What was discussed during these various meetings 12 that I've just asked about? 13 A I invoke my privilege. 14 JUDGE FACCIOLA: Sustained. 15 BY MR. KLAYMAN: 16 Q In the afternoon of Thursday, June 23rd, did you 17 and James Riady visit the Ex-Im Bank commissioner Maria 18 Haley? 19 A I invoke my privilege. 20 Q She's an old friend from Arkansas, correct? 21 A I invoke my privilege. 22 Q At the time of that meeting, the Ex-Im Bank was 23 considering supporting a Lippo joint venture energy project 24 in China with Entergy Corporation, correct? 25 A I invoke my privilege. 144 1 JUDGE FACCIOLA: Sustained in each instance. 2 BY MR. KLAYMAN: 3 Q What was discussed with Maria Haley on that day? 4 A I invoke my privilege. 5 Q On Friday, June 24th, James Riady and you visited 6 the White house twice, once to meet with Middleton and once 7 to meet with then Assistant to the President for Economic 8 Policy, Treasury Secretary Robert Rubin. 9 A I invoke my privilege. 10 Q What was discussed? 11 A I invoke my privilege. 12 Q On Saturday, June 25, 1994, you and James Riady 13 attended the President's weekly radio address in the Oval 14 Office, correct? 15 A I invoke my privilege. 16 Q On Monday, June 27, 1994, the first business day 17 after the radio address, the Lippo-controlled Hong Kong 18 Chinese Bank paid Webster Hubbell $100,000 from a Riady 19 company account, correct? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: Sustained. 22 BY MR. KLAYMAN: 23 Q In exchange for that $100,000 payment made to 24 Webster Hubbell, you received a security clearance, correct, 25 Mr. Huang? 145 1 A I invoke my privilege. 2 JUDGE FACCIOLA: Sustained. 3 BY MR. KLAYMAN: 4 Q The money that was paid to Webster Hubbell by this 5 Riady company account was Hong Kong China, Ltd., correct? 6 A I invoke my privilege. 7 JUDGE FACCIOLA: The invocation of the privilege is 8 sustained. 9 BY MR. KLAYMAN: 10 Q The reason for that payment was a bribe to keep 11 Webster Hubbell quiet, correct? 12 A I invoke my privilege. 13 JUDGE FACCIOLA: Sustained. 14 BY MR. KLAYMAN: 15 Q On Monday, June 27, 1994, you received a memorandum 16 from the Lippo Group in Jakarta congratulating you on your 17 new position at the Commerce Department, correct? 18 A I invoke my privilege. 19 Q And that memorandum promised you a severance 20 package that would be at least $468,125, correct? 21 A I invoke my privilege. 22 Q In fact, that money was paid to you because you 23 were taking a substantial cut in salary in going to work for 24 the Commerce Department, correct? 25 A I invoke my privilege. 146 1 JUDGE FACCIOLA: Sustained as to each question. 2 BY MR. KLAYMAN: 3 Q That money was an advance payment by the Lippo 4 Group for services that you would later render at the 5 Commerce Department, correct? 6 A I invoke my privilege. 7 JUDGE FACCIOLA: Sustained. 8 MR. KLAYMAN: Your Honor, in this area, and you may 9 know the answer, but I believe you did review an immunity 10 agreement which deals with whether or not he has immunity 11 with regard to this Hubbell matter and, if he does have 12 immunity, he may be able to testify to this. 13 JUDGE FACCIOLA: I will have to review again the 14 documents. Give me a moment. 15 MR. KLAYMAN: Sure. 16 THE VIDEOGRAPHER: We're going off video record 17 at 2:03. 18 (A brief recess was taken.) 19 THE VIDEOGRAPHER: We're back on video record 20 at 2:10. 21 JUDGE FACCIOLA: I have again reviewed certain 22 documents made available to me by Mr. Huang's counsel. 23 On the basis of my review of them, I am convinced 24 again, refreshed my recollection, I should say, as to the 25 situation here. 147 1 On the basis of those documents, it is clear to me 2 that this witness has never received transactional immunity 3 from any law enforcement agency in general and specifically 4 with reference to the topic of whether or not there were 5 payments made by the Riady family or the Lippo Group to 6 Webster Hubbell. Therefore, in my view, his Fifth Amendment 7 persists and I will sustain the application of the privilege. 8 MR. KLAYMAN: Your Honor, may I just ask that if 9 you haven't already done so, you may have, that we put on the 10 record, on your confidential sealed version, what that 11 immunity agreement is? I believe you have a copy of it or at 12 least you asked for a copy of it. 13 JUDGE FACCIOLA: I have, yes. And what do you want 14 me to do with it? 15 MR. KLAYMAN: If you will make that an exhibit to 16 your sealed transcript, the immunity agreement. 17 JUDGE FACCIOLA: I'll take that under advisement. 18 I don't know. I'll see. I want to talk to the chief judge 19 about that. 20 MR. KLAYMAN: Is there any aspect of this line of 21 testimony that Mr. Huang could testify to? 22 JUDGE FACCIOLA: Unquestionably not. 23 MR. KLAYMAN: May I ask one other question? 24 Does he have some other kind of immunity, generically 25 speaking? 148 1 JUDGE FACCIOLA: The law recognizes two kinds 2 of immunity: one is transactional; the other, use immunity. 3 Transactional immunity is an immunity granted by a 4 prosecution for any discussions whatsoever with reference to 5 an entire transaction. That is, if the witness were to be 6 asked any question whatsoever about a transaction, he would 7 have immunity for any criminal activity supposedly coming out 8 of that transaction. It is the broadest grant of immunity. 9 It was replaced by the use immunity permitted by the statute. 10 The latter immunity only prohibits the prosecution's use of 11 the testimony the witness gives. 12 All right? Those are the only two forms of 13 immunity granted. On the basis of my review of the 14 documents, I am convinced Mr. Huang has never been given 15 transactional immunity. It would therefore follow that 16 discussions about this particular topic are matters on which 17 he is still vulnerable to prosecution. 18 I therefore find that his invocation of privilege 19 is valid. 20 MR. KLAYMAN: I'm going to ask a few questions, 21 Your Honor, just to see if I can make this a little bit more 22 precise without getting into the substance. 23 BY MR. KLAYMAN: 24 Q Mr. Huang, did you provide testimony about Webster 25 Hubbell to Independent Counsel Kenneth Starr? 149 1 A I invoke my privilege. 2 JUDGE FACCIOLA: Sustained. 3 MR. KLAYMAN: I don't think that would incriminate 4 him, Your Honor. I'm not asking what it was. 5 JUDGE FACCIOLA: It certainly would. 6 BY MR. KLAYMAN: 7 Q Well, let's take Webster Hubbell out of it. Have 8 you provided any information on any subject to Independent 9 Counsel Kenneth Star? 10 A Again, on advice of counsel, I invoke my privilege. 11 JUDGE FACCIOLA: The invocation of the privilege is 12 sustained. 13 BY MR. KLAYMAN: 14 Q Were you given your job at the Commerce Department 15 by the Clinton administration in exchange for the $100,000 16 payment by the Riady company called Hong Kong China, Ltd.? 17 A I invoke my privilege. 18 JUDGE FACCIOLA: Sustained. 19 BY MR. KLAYMAN: 20 Q You and Mr. James Riady, the President of the 21 United States, and Mrs. Clinton all knew that that $100,000 22 payment to Webster Hubbell was meant as an inducement that he 23 should not testify in the independent counsel proceeding of 24 Kenneth Starr. 25 A I invoke my privilege. 150 1 JUDGE FACCIOLA: Sustained. 2 BY MR. KLAYMAN: 3 Q Mr. Mark Middleton was the individual who arranged 4 for this $100,000 payment to be made to Webster Hubbell 5 by this Riady company, Hong Kong China, Ltd. in exchange for 6 Mr. Hubbell's silence in the Independent Counsel's 7 investigation. 8 A I invoke my privilege. 9 JUDGE FACCIOLA: The invocation of the privilege is 10 sustained. 11 BY MR. KLAYMAN: 12 Q Why were you being called by Webster Hubbell at the 13 Commerce Department? 14 A I invoke my privilege. 15 JUDGE FACCIOLA: The invocation of the privilege is 16 sustained. 17 BY MR. KLAYMAN: 18 Q On Tuesday, August 2nd, as reflected on Exhibit 32, 19 at 12:15 in the afternoon, you met with Webster Hubbell at 20 Sam & Harry's Restaurant at 19th and M. 21 A I invoke my privilege. 22 JUDGE FACCIOLA: Sustained. 23 BY MR. KLAYMAN: 24 Q And at 2:00 p.m., you had a meeting as reflected on 25 Exhibit 32, concerning the trip to China later that month. 151 1 A I invoke my privilege. 2 Q At 3:30 p.m., on August 2nd, there's an entry in 3 your calendar, Exhibit 32, Asian-American -- looks like it's 4 execution -- or executive seminar meeting with Melinda Yee 5 and Nancy. 6 What does that mean? 7 A I invoke my privilege. 8 Q Did you meet with Melinda Yee and Nancy Linn Patton 9 on that day? 10 A I invoke my privilege. 11 Q You have a close relationship with Melinda Yee, do 12 you not? 13 A I invoke my privilege. 14 Q Melinda Yee participated with you in removing 15 classified documents and information from the Commerce 16 Department, correct? 17 A I invoke my privilege. 18 Q Is Melinda Yee an agent of the government of China? 19 A I invoke my privilege. 20 JUDGE FACCIOLA: Sustained in each instance. 21 BY MR. KLAYMAN: 22 Q What information do you have, if any, about the 23 destruction of notes that Melinda Yee took on the China trade 24 mission? 25 A I invoke my privilege. 152 1 JUDGE FACCIOLA: The invocation of the privilege is 2 sustained. 3 BY MR. KLAYMAN: 4 Q What information do you have about the destruction 5 of notes that Melinda Yee took on the trade missions to India 6 by the Commerce Department? 7 A I invoke my privilege. 8 JUDGE FACCIOLA: The invocation of the privilege is 9 sustained. 10 BY MR. KLAYMAN: 11 Q At 5:30 p.m. on August 2nd, it says -- there's an 12 entry, "Reception White House, DNC meeting." 13 Did you attend a reception at the White House on 14 August 2nd? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: The invocation of the privilege is 17 sustained. 18 BY MR. KLAYMAN: 19 Q Did you attend a meeting about the DNC at the White 20 House on that day? 21 A I invoke my privilege. 22 JUDGE FACCIOLA: The invocation of the privilege is 23 sustained. 24 BY MR. KLAYMAN: 25 Q Mr. Huang, Exhibit 32, which is your desk diary of 153 1 1994, shows certain erasures. Did you erase certain entries 2 from that desk diary? 3 A I invoke my privilege. 4 JUDGE FACCIOLA: The invocation of the privilege is 5 sustained. 6 BY MR. KLAYMAN: 7 Q Do you know who, if anyone, did erase certain 8 entries from that desk diary? 9 A I invoke my privilege. 10 JUDGE FACCIOLA: Sustained. 11 BY MR. KLAYMAN: 12 Q On August 3rd at 11:30, and you can turn to that 13 page, what does that say? 14 A I invoke my privilege. 15 Q Does it say there -- was that entry erased? 16 A I invoke my privilege. 17 JUDGE FACCIOLA: Sustained. 18 BY MR. KLAYMAN: 19 Q Does that entry say "ERS Asia strategy with Chuck 20 and Nancy"? 21 A I invoke my privilege. 22 Q Strike that. Does that say there "Strategy with 23 Chuck and Nancy"? 24 A I invoke my privilege. 25 JUDGE FACCIOLA: Sustained. 154 1 BY MR. KLAYMAN: 2 Q Who had access to your desk diaries in addition to 3 yourself? 4 A I invoke my privilege. 5 JUDGE FACCIOLA: Sustained. 6 Q On August 5, 1994, were you called by Joseph Giroir 7 at the Commerce Department? 8 A I invoke my privilege. 9 Q On that same day, were you called by the ambassador 10 of Prague, Czechoslovakia? 11 A I invoke my privilege. 12 Q Do the telephone numbers of Joseph Giroir and 13 the ambassador of Czechoslovakia appear on page 38 of Exhibit 14 34? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: Sustained. 17 BY MR. KLAYMAN: 18 Q On August 9th, were you called by Joseph Giroir? 19 A I invoke my privilege. 20 JUDGE FACCIOLA: Sustained. 21 BY MR. KLAYMAN: 22 Q On August 9th, were you called by Ambassador 23 Sinegar of Indonesia, S-i-n-e-g-a-r, at the Commerce 24 Department? 25 A I invoke my privilege. 155 1 Q Does page 38 of Exhibit 34 reflect the phone calls 2 from Mr. Giroir and Ambassador Sinegar of Indonesia? 3 A I invoke my privilege. 4 Q Can you turn to Exhibit 32, the entries for August 5 9th? 6 A Mm-hmm. 7 Q It shows a meeting with Jim Hackney at 2:00 p.m., 8 "Courtesy call," correct? 9 A I invoke my privilege. 10 Q Do you know who James Hackney is? 11 A I invoke my privilege. 12 Q Do you know that he's a very close aide or was a 13 close aide to Ron Brown? 14 A I invoke my privilege. 15 Q There's a meeting here of E. Lewis. Do you know 16 who E. Lewis is? 17 A I invoke my privilege. 18 Q What did you discuss on that day with Mr. Hackney 19 and Ms. E. Lewis? 20 A I invoke my privilege. 21 Q And it shows a reception at 6:00 p.m. Did you go 22 to a reception at 6:00 p.m.? 23 A I invoke my privilege. 24 Q Who held that privilege? 25 A Again, I invoke my privilege. 156 1 Q Where did it take place? 2 A Again, I invoke my privilege. 3 JUDGE FACCIOLA: The invocation of the privilege is 4 sustained in each instance. 5 BY MR. KLAYMAN: 6 Q On August 10th, looking at Exhibit 32, it shows a 7 meeting with Jeff Garten at 6:00 p.m., correct? 8 A I invoke my privilege. 9 JUDGE FACCIOLA: Sustained. 10 BY MR. KLAYMAN: 11 Q What did you discuss with Mr. Garten at that time? 12 A I invoke my privilege. 13 Q Exhibit 32, entry at 4:30, it shows a meeting with 14 Clyde Robinson, Advocacy Center. 15 Who is Clyde Robinson? 16 A I invoke my privilege. 17 Q What did he do? 18 A Again, I invoke my privilege. 19 Q What did you discuss during that meeting? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: Sustained in each instance. 22 BY MR. KLAYMAN: 23 Q Meetings on August 16th, Exhibit 32, did you have a 24 meeting at 3:30? 25 A I invoke my privilege. 157 1 Q Who was that meeting with? 2 A I invoke my privilege. 3 Q At 4:30, it lists John Walker. What was his 4 position at the time? 5 A I invoke my privilege. 6 Q Did you have a meeting with him? 7 A I invoke my privilege. 8 Q What was it about? 9 A I invoke my privilege. 10 Q On August 17th at 11:00 a.m., it says "TPC 11 Indonesia Advocacy." Is that correct? 12 A I invoke my privilege. 13 Q What does it say under that at 11:15? 14 A I invoke my privilege. 15 Q Was there a meeting at the Commerce Department on 16 Indonesian trade issues on that day? 17 A I invoke my privilege. 18 Q At 3:30, we see an entry for Jude Kearney, 19 "DAS INF/TD." 20 Did you have a meeting with Jude Kearney on 21 that day? 22 A I invoke my privilege. 23 Q What was discussed? 24 A Again, I invoke my privilege. 25 Q Did you discuss selling seats on trade missions in 158 1 exchange for campaign contributions? 2 A I invoke my privilege. 3 Q Did you discuss removal of classified information 4 from the Commerce Department? 5 A I invoke my privilege. 6 Q Did you discuss Johnny Chung or Charlie Trie and 7 their involvement in Commerce Department trade missions? 8 A I invoke my privilege. 9 Q And at 5:00, there's an entry for Chuck and Nancy. 10 Does that refer to Chuck Meissner and Nancy Linn 11 Patton? 12 A I invoke my privilege. 13 Q Did you have a meeting at that time? 14 A I invoke my privilege. 15 Q What was discussed? 16 A Again, I invoke my privilege. 17 JUDGE FACCIOLA: The invocation of the privilege is 18 sustained in each instance. 19 BY MR. KLAYMAN: 20 Q On Friday, August 19th at 10:00, it lists Mark 21 Grobmyer with a phone number listed at the entry at 10:30 22 501-370-9700. 23 Is that an Arkansas exchange? 24 A I invoke my privilege. 25 JUDGE FACCIOLA: Sustained. 159 1 BY MR. KLAYMAN: 2 Q Is that Mr. Grobmyer's phone number? 3 A I invoke my privilege. 4 Q Down at 7:00 p.m., we see "The Seven Seas, Natalie 5 H. Pelocci," or something to that effect. 6 Can you read what's written between 7:00 p.m. 7 and 7:45? 8 A I invoke my privilege. 9 Q Did you meet with these people at that time? 10 A I invoke my privilege. 11 Q What was discussed? 12 A I invoke my privilege. 13 JUDGE FACCIOLA: Sustained in each instance. 14 BY MR. KLAYMAN: 15 Q The entries on August 18th, can you tell me whether 16 they're accurate? 17 A I invoke my privilege. 18 Q What, if anything, happened on August 18th with 19 regard to the Holiday Inn? 20 A I invoke my privilege. 21 Q Did you meet with a Winston Lord at 10:00 a.m. of 22 the State Department? 23 A I invoke my privilege. 24 Q Winston Lord was the ambassador of China, correct? 25 A I invoke my privilege. 160 1 Q What was discussed with Mr. Lord? 2 A I invoke my privilege. 3 JUDGE FACCIOLA: The privilege is sustained in each 4 instance. 5 BY MR. KLAYMAN: 6 Q On August 22nd, entries at 8:30 p.m., "Ambassador 7 and Mrs. Sinegar, Indonesian Embassy, Chancellery, 2020 8 Massachusetts Avenue." 9 Did you go there on that date? 10 A I invoke my privilege. 11 Q Did you meet with the ambassador and the first lady 12 ambassador to Indonesia? 13 A I invoke my privilege. 14 Q What was discussed? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: The privilege is sustained in each 17 instance. 18 BY MR. KLAYMAN: 19 Q Did that relate to Commerce Department trade 20 missions? 21 A I invoke my privilege. 22 Q And doing business on behalf of the Lippo Group at 23 U.S. taxpayer expense? 24 A I invoke my privilege. 25 Q Did that meeting concern passing classified 161 1 information to the Indonesian government? 2 A I invoke my privilege. 3 Q The next day, on August 23rd, at 6:00 p.m., 4 "Dinner with Chuck." 5 Does that refer to Chuck Meissner? 6 A I invoke my privilege. 7 Q Did you have dinner with Chuck Meissner on that 8 day? 9 A I invoke my privilege. 10 Q On August 23, 1994, you were called by Webster 11 Hubbell on more than one occasion, correct? 12 A I invoke my privilege. 13 Q And his phone number appears at page 39 of Exhibit 14 34, correct? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: The privilege is sustained in each 17 instance. 18 BY MR. KLAYMAN: 19 Q On August 24th, as reflected in Exhibit 32, you had 20 lunch with Vernon Weaver at 12:00 p.m., correct? 21 A I invoke my privilege. 22 Q Vernon Weaver was the individual who was running 23 Stephens Inc. at the Willard Hotel at the time, correct? 24 A I invoke my privilege. 25 Q Vernon Weaver assisted you in using facilities of 162 1 Stephens Inc. across the street from the Commerce Department 2 so you could fax documents and make phone calls to 3 individuals other than the Commerce Department, correct? 4 A I invoke my privilege. 5 Q And Mr. Weaver knew that in fact you were 6 communicating with foreign governments and releasing U.S. 7 national security information on his premises, correct? 8 A I invoke my privilege. 9 JUDGE FACCIOLA: The invocation of the privilege is 10 sustained. 11 BY MR. KLAYMAN: 12 Q Vernon Weaver later became the ambassador to the 13 European Union, correct? 14 A I invoke my privilege. 15 Q And, in fact, Mr. Vernon Weaver was fired from that 16 post, correct? 17 A I invoke my privilege. 18 Q There was an entry at 2:00 p.m. which is an 19 erasure, Mr. Huang. Do you know who erased it, that entry? 20 A I invoke my privilege. 21 Q Does that refer to a meeting with a Vickey, 22 V-i-c-k-e-y, in room 3832? 23 A I invoke my privilege. 24 Q Who is Vickey, V-i-c-k-e-y? 25 A Again, I invoke my privilege. 163 1 JUDGE FACCIOLA: The invocation of the privilege is 2 sustained in each instance. 3 BY MR. KLAYMAN: 4 Q What was discussed with a Mr. or Ms. Vickey? 5 A I invoke my privilege. 6 Q Is it a Vickery? 7 A I invoke my privilege. 8 Q There's an entry at 2:00 p.m. on August 25th, 9 "Meeting with Vickery," room 3832 or 3837. Is that the same 10 thing as Vickey, Vickery? 11 A I invoke my privilege. 12 Q And then it says at 2:30, "Global trade meeting." 13 Did you attend such a meeting? 14 A I invoke my privilege. 15 Q What was discussed at 2:00 p.m. with a Mr. or 16 Ms. Vickery and at the global trade meeting? 17 A I invoke my privilege. 18 Q On the next day, August 26th -- excuse me. There 19 appear to be erasures at 7:30 a.m. and 10:00 p.m. on August 20 25th. This is Exhibit 32, your calendar. 21 Do you know who made those erasures? 22 A I invoke my privilege. 23 Q Do you know what was erased? 24 A I invoke my privilege. 25 Q Did it deal with AS-PDA, meeting room 3850? 164 1 A I invoke my privilege. 2 Q Did another erasure deal with a Ms. Mary Inousen, 3 I-n-o-u-s-e-n? 4 A I invoke my privilege. 5 Q What was Ms. Inousen's position at the time? 6 A I invoke my privilege. 7 Q What did you discuss with regard to this AS-PDA 8 meeting and with Ms. Inousen? 9 A I invoke my privilege. 10 JUDGE FACCIOLA: The invocation of the privilege is 11 sustained in each instance. 12 BY MR. KLAYMAN: 13 Q On August 26th, it lists another entry for Mary 14 Inousen. Did you meet with her at that time? 15 A I invoke my privilege. 16 Q What was discussed? 17 A I invoke my privilege. 18 Q At 10:00 a.m., it says "SES recertification, 19 training room 4830." 20 What is that about? 21 A I invoke my privilege. 22 Q August 29th, referring to Exhibit 32, entry at 23 9:30 a.m., "IEPDAS meeting, diversity, J. Bruce." 24 Did such a meeting occur? 25 A I invoke my privilege. 165 1 Q What was discussed? 2 A I invoke my privilege. 3 Q There's an entry on August 30th, 11:30 a.m., "Peter 4 Hall." 5 What was his position at the time? 6 A I invoke my privilege. 7 Q Did you have a meeting with him? 8 A I invoke my privilege. 9 Q What was discussed? 10 A I invoke my privilege. 11 Q Entry at 3:00 p.m., "S. Miller, room 2037." 12 Did you have a meeting with him? 13 A I invoke my privilege. 14 Q What was discussed? 15 A Again, I invoke my privilege. 16 Q What was Mr. Miller's position at the time? 17 A I invoke my privilege. 18 Q On August 30, 1994, Entergy Corporation and Lippo, 19 as I showed you previously, announced a billion dollar energy 20 deal during the trade mission to China. Were you advised of 21 that announcement on August 30, 1994? 22 A I invoke my privilege. 23 JUDGE FACCIOLA: The invocation of the privilege is 24 sustained in each instance. 25 166 1 BY MR. KLAYMAN: 2 Q On August 30th, Vernon Weaver called you at the 3 Commerce Department. Is that correct? 4 A I invoke my privilege. 5 Q His phone number appears at page 39 of Exhibit 34, 6 correct? 7 A I invoke my privilege. 8 Q And on August 30th, you wrote a memorandum to the 9 ethics committee of the Senate asking for a clearance in 10 order that you could speak to the Senate committee hearing 11 focusing on U.S.-China trade, correct? 12 A I invoke my privilege. 13 JUDGE FACCIOLA: Sustained. 14 BY MR. KLAYMAN: 15 Q Throughout September of 1994, you attended various 16 meetings with James and/or Mochtar Riady with President 17 Clinton, correct? 18 A I invoke my privilege. 19 JUDGE FACCIOLA: Sustained. 20 BY MR. KLAYMAN: 21 Q On August 31st, it shows an entry at 3:00 p.m., a 22 Jack Alston. Is that a correct pronunciation of what's 23 written there? 24 A I invoke my privilege. 25 Q What was discussed with this individual? 167 1 A I invoke my privilege. 2 Q At 10:00 a.m., there's an entry for Dick Harding. 3 What was Mr. Harding's profession at the time? 4 A I invoke my privilege. 5 Q What, if anything was discussed with him? 6 A I invoke my privilege. 7 JUDGE FACCIOLA: Sustained in each instance. 8 BY MR. KLAYMAN: 9 Q A 12:00 p.m. lunch with C.S. -- it looks like Pan. 10 CCNAA. What does CCNAA stand for? 11 A I invoke my privilege. 12 Q Who is C.S. Pan? 13 A I invoke my privilege. 14 Q What was his position at the time? 15 A I invoke my privilege. 16 Q What was discussed with him? 17 A Again, I invoke my privilege. 18 Q With regard to the entries of September 1st, 19 September 2nd and September 3rd, what can you tell me, if 20 anything, about what occurred on those days as reflected on 21 your calendar? 22 A I invoke my privilege. 23 JUDGE FACCIOLA: The invocation of the privilege is 24 sustained. 25 168 1 BY MR. KLAYMAN: 2 Q Were Department of Commerce trade missions 3 discussed with regard to the meetings or other appointments 4 listed on the calendars for September 1st, 2nd and 3rd, 1994? 5 A I invoke my privilege. 6 JUDGE FACCIOLA: Sustained. 7 BY MR. KLAYMAN: 8 Q On September 6th, this is page 94077, we list at 9 3:00 p.m. "UNTAD with Meissner." 10 What is UNTAD? 11 A I invoke my privilege. 12 JUDGE FACCIOLA: Sustained. 13 BY MR. KLAYMAN: 14 Q Did you have a meeting with Chuck Meissner on that 15 day? 16 A I invoke my privilege. 17 Q And at 4:00 p.m., it lists Donald Forest, Room 18 2317. 19 Did you have a meeting with him on that day? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: Sustained. 22 BY MR. KLAYMAN: 23 Q Did that meeting concern the trade mission to 24 China? 25 A I invoke my privilege. 169 1 Q On September 7th at 10:00 a.m., Lou Murphy, what 2 position did he occupy at the time? 3 A I invoke my privilege. 4 JUDGE FACCIOLA: Sustained. 5 BY MR. KLAYMAN: 6 Q What was discussed, if anything? 7 A I invoke my privilege. 8 Q At 3:00 p.m., Phil -- and I can't read that. Can 9 you read that name? 10 A I invoke my privilege. 11 Q That was in room 2320, correct? 12 A I invoke my privilege. 13 Q And what was discussed with that gentleman? 14 A I invoke my privilege. 15 JUDGE FACCIOLA: Sustained in each instance. 16 BY MR. KLAYMAN: 17 Q The next page, September 11th -- entries for 18 Thursday, September 8th; Friday, September 9th; Saturday, 19 September 10th. 20 What can you tell me about the entries that appear 21 on those three days? 22 What transpired with regard to each entry? 23 A I invoke my privilege. 24 JUDGE FACCIOLA: Sustained. 25 170 1 BY MR. KLAYMAN: 2 Q On September 9th at 9:00 a.m., you had a meeting 3 concerning the India trip with David Rothkopf. Is that 4 correct? 5 A I invoke my privilege. 6 Q And what was discussed at that meeting? 7 A I invoke my privilege. 8 Q And you also had a meeting with Nancy Linn Patton 9 at 11:00 a.m., correct? Concerning India? 10 A I invoke my privilege. 11 Q What was discussed? 12 A I invoke my privilege. 13 JUDGE FACCIOLA: Sustained in each instance. 14 BY MR. KLAYMAN: 15 Q At 5:15, it lists Jim Yang, Y-a-n-g. Is that 16 correct? 17 A I invoke my privilege. 18 Q Where did Mr. Jim Yang work at the time? 19 A I invoke my privilege. 20 Q What, if anything, was discussed with him? 21 A I invoke my privilege. 22 MR. COBB: Your Honor, if I might, and I don't 23 want to intrude on Mr. Klayman's time unnecessarily, but I 24 think we've spent enough time with these diaries now. I 25 think it's also clear under the law that he can't acknowledge 171 1 even the interpretation of anything in his own handwriting 2 without -- 3 JUDGE FACCIOLA: Admitting the authenticity of the 4 document. 5 MR. COBB: Right. 6 JUDGE FACCIOLA: That's the problem. 7 MR. COBB: And so I see no point in further 8 questions with regard to the diary. 9 JUDGE FACCIOLA: Mr. Klayman, is your record fully 10 protected if I were to rule, as has been implicit in all of 11 my decisions, that inquiry of this witness as to (a) the 12 accuracy of entries in the diary, (b) whether there are 13 erasures in the diaries, and (c) whether he wrote in the 14 diaries are all questions which fall within the Fifth 15 Amendment privilege because any acknowledgment by the witness 16 of the authenticity of the document would tend to incriminate 17 him because the document obviously contains information which 18 could provide a link in a chain for prosecution of him for 19 various criminal offenses? 20 MR. KLAYMAN: Well, Your Honor, I appreciate that 21 general instruction. That does help in terms of preserving 22 my right to challenge the privilege and the sustaining of 23 that privilege, but I've been asking questions not so much 24 based on what's written in the diaries as to what happened on 25 those days, so I'm using that as a benchmark and, you know, 172 1 given Your Honor's general instruction, if you will 2 instruct -- or put on the record, rather, that anything with 3 regard to what's written in the diaries or what's reflected 4 in the diaries in terms of his own entries is subject to 5 Fifth Amendment privilege, that may speed things along and 6 then I'll just ask specific questions about certain events. 7 JUDGE FACCIOLA: But the point I'm trying to make 8 is that it's really two-headed. You're asking him is this 9 entry on such and such a date accurate, did you erase it, 10 that's one question. 11 If you then ask him thanks -- because you were 12 looking at the document, on September 10th did you meet at 13 2:00 with so and so, implicit and perhaps explicit in that 14 question is that an acknowledgment of the accuracy of the 15 entry. So you're back where you started from, whether you 16 ask your question directly or indirectly. 17 MR. KLAYMAN: I understand -- 18 JUDGE FACCIOLA: So that's the way I would rule. 19 MR. KLAYMAN: My problem is that I have to ask 20 about particular meetings or particular persons to preserve 21 my right to get the testimony. 22 JUDGE FACCIOLA: Okay. Well, let's proceed as best 23 we can. 24 MR. KLAYMAN: I'm trying -- you can see I tried to 25 group a few questions together so we could move quicker. 173 1 JUDGE FACCIOLA: I appreciate that. Let's see if 2 we can move along. 3 MR. KLAYMAN: Thank you. 4 BY MR. KLAYMAN: 5 Q On September 12th at 4:30, it lists an APEC meeting 6 with Rothkopf, 3862. 7 Was there such an APEC meeting on that day? 8 A I invoke my privilege. 9 JUDGE FACCIOLA: Sustained. 10 BY MR. KLAYMAN: 11 Q And what was discussed? 12 A Again, I invoke my privilege. 13 Q On September 13th, entry at 2:00 p.m., a 14 Ying Price. 15 Have you ever heard of Ying Price? 16 A I invoke my privilege. 17 JUDGE FACCIOLA: Sustained. 18 BY MR. KLAYMAN: 19 Q The entry at 4:00 p.m., was there an erasure there, 20 Mr. Huang? 21 A I invoke my privilege, Mr. Klayman. 22 JUDGE FACCIOLA: Sustained. 23 BY MR. KLAYMAN: 24 Q Did that relate to Ying Price of Taipei? 25 A I invoke my privilege. 174 1 Q September 14th, 2:00 p.m., "Meeting with Winston 2 Lord/Meissner, 6205." 3 Did you have a meeting with Winston Lord and 4 Charles Meissner that you were present at at the State 5 Department on that day? 6 A I invoke my privilege. 7 Q What was discussed? 8 A I invoke my privilege. 9 Q Did it concern assisting the Lippo Group at U.S. 10 taxpayers' expense do business on Commerce Department trade 11 missions? 12 A I invoke my privilege. 13 Q Did it involve business of the Lippo Group in 14 China? 15 A I invoke my privilege. 16 Q Meeting at 5:00, Dick Roebik, what was his position 17 at the time? 18 A I invoke my privilege. 19 Q Did you have a meeting with him? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: Sustained. 22 BY MR. KLAYMAN: 23 Q What was discussed? 24 A I invoke my privilege. 25 Q Next page, 94080. Bob Conan, C-o-n-a-n, at 11:00. 175 1 What was his position at the time? 2 A I invoke my privilege. 3 Q Did you have a meeting with him? 4 A I invoke my privilege. 5 Q What was discussed? 6 A I invoke my privilege. 7 Q At 2:00 p.m., there appears to be some erasures. 8 A I invoke my privilege. 9 Q Did that concern a DBAS meeting control workshop in 10 room 111? 11 A I invoke my privilege. 12 Q What was that workshop all about? 13 A I invoke my privilege. 14 JUDGE FACCIOLA: The invocation of the privilege is 15 sustained in all instances. 16 BY MR. KLAYMAN: 17 Q During the time that you worked at the Commerce 18 Department, did you ever have contact by telephone, in 19 person or any other means with the Chinese consulate in 20 Los Angeles? 21 A I invoke my privilege. 22 JUDGE FACCIOLA: Sustained. 23 BY MR. KLAYMAN: 24 Q The Chinese consulate in Los Angeles is used an 25 intelligence basing ground for the Chinese government, is it 176 1 not? 2 A I invoke my privilege. 3 JUDGE FACCIOLA: Sustained. 4 BY MR. KLAYMAN: 5 Q The entries of September 19, 20, and 21 in 6 your calendar, can you tell me whether the entries are 7 accurate? 8 A I invoke my privilege. 9 Q And what took place with regard to these entries in 10 terms of actual meetings or encounters with the people listed 11 in your diary? People and entities? 12 A I invoke my privilege. 13 Q Do you know an Annette Lu, L-u? 14 A I invoke my privilege. 15 Q At 6:00 p.m. on September 21, Asia Society 16 reception, Ritz Carlton, 2100 Massachusetts Avenue. Did 17 Ms. Ginger Lew attend that reception? 18 A I invoke my privilege. 19 Q Did individuals of the Asian-Pacific-American 20 community which you recommended for appointment by the 21 Clinton administration attend that reception? 22 A I invoke my privilege. 23 Q Look at the entry for September 22nd at 1:30 p.m., 24 another erasure. Did you erase that entry? 25 A I invoke my privilege. 177 1 Q What you erased was the acronym DNC, correct, 2 Mr. Huang? 3 A I invoke my privilege. 4 Q That stands for Democratic National Committee? 5 A Again, I invoke my privilege. 6 Q What, if anything, happened with regard to the 7 Democratic National Committee on that day, September 22, 8 1994? 9 A I invoke my privilege. 10 Q With regard to the other entries on page 94082, 11 what can you tell us, if anything, about what occurred on 12 those days as reflected in your diary? 13 A I invoke my privilege. 14 Q At 3:00 p.m. on September 23, 1994, did you attend 15 a meeting concerning the Department of Commerce trip to 16 India? 17 A I invoke my privilege. 18 Q What was discussed at that meeting? 19 A I invoke my privilege. 20 Q On September 27, 1994, did you attend an arrival 21 ceremony for President Yeltsin at the State Department? 22 A I invoke my privilege. 23 Q On September 28, 1994, as reflected in your diary 24 at page 94083, did you attend at 11:00 a.m. a DOC task force 25 meeting in room 3868A? 178 1 A I invoke my privilege. 2 Q What occurred at that meeting? 3 A I invoke my privilege. 4 Q Was there a discussion of trade missions which are 5 the subject of this case? 6 A I invoke my privilege. 7 Q At 3:00 p.m., it shows "APEC with Rothkopf, 3862." 8 The acronym APEC stands for Asian-Pacific Economic Council? 9 A I invoke my privilege. 10 Q And you played a role in planning that meeting, did 11 you not? 12 A I invoke my privilege. 13 Q And at that meeting, President Clinton had direct 14 contact with the Riadys of the Lippo Group, correct? 15 A I invoke my privilege. 16 Q On September 28th, Karsumi Tawasaki, Executive Vice 17 President of TEPCO, T-E-P-C-O, wrote to you about 18 strengthening cooperation between Japan and the U.S. electric 19 power industries. Is that correct? 20 A I invoke my privilege. 21 Q In fact, that was another reason why you asked for 22 access to classified information in the energy sector, was to 23 assist TEPCO, correct? 24 A I invoke my privilege. 25 Q Do the Riadys or Lippo Group own any interest in 179 1 TEPCO? 2 A I invoke my privilege. 3 JUDGE FACCIOLA: Sustained in each instance. 4 BY MR. KLAYMAN: 5 Q In October of 1994, former Associate Attorney 6 General Webster Hubbell traveled to Indonesia for the Riadys 7 of the Lippo Group, correct? 8 A I invoke my privilege. 9 Q After Mr. Hubbell left the employment of the 10 Justice Department, he received $250,000 from the Lippo 11 Group, correct? 12 A I invoke my privilege. 13 Q And he received that money before he pled guilty to 14 two felony counts in December of 1994. 15 A I invoke my privilege. 16 Q In October of 1994, the Riadys hosted a private 17 lunch arranged by Melinda Yee with Indonesian businessmen for 18 two Commerce Department officials, Jeffrey Garten and David 19 Rothkopf, correct? 20 A I invoke my privilege. 21 Q And that lunch was held in Indonesia, correct? 22 A I invoke my privilege. 23 Q And that was held during the APEC summit. 24 A I invoke my privilege. 25 JUDGE FACCIOLA: The invocation privilege is 180 1 sustained. 2 BY MR. KLAYMAN: 3 Q Was there any clearance for Melinda Yee, Jeffrey 4 Garten and David Rothkopf given by the Commerce Department 5 that you know of to attend that private lunch given by the 6 Riadys in Indonesia? 7 A I invoke my privilege. 8 Q Did they accept any gratuities, anything that they 9 got without having to pay for it, at that private lunch? 10 A I invoke my privilege. 11 JUDGE FACCIOLA: Sustained in each instance. 12 BY MR. KLAYMAN: 13 Q During that APEC summit in October of 1994, 14 President Suharto of Indonesia allowed for a private meeting 15 with President Clinton, Vice President Gore, Secretary of 16 State Warren Christopher, Commerce Secretary Ron Brown, U.S. 17 Trade Representative Mickey Kantor, and the chairman of the 18 Joint Chiefs of Staff, John Shalikashvili, at the White 19 House. Is that not true? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: Sustained. 22 BY MR. KLAYMAN: 23 Q And during that meeting, the provision of services 24 paid for by U.S. taxpayers to the benefit of the Lippo Group 25 were discussed, correct? 181 1 A I invoke my privilege. 2 Q And the use of the Commerce Department to provide 3 those services was also discussed. 4 A I invoke my privilege. 5 JUDGE FACCIOLA: Sustained in each instance. 6 BY MR. KLAYMAN: 7 Q Looking back at Exhibit 32 at 10:00 a.m., Abe 8 Lowenthal, Pacific something. Do you know an Abe Lowenthal? 9 A I invoke my privilege. 10 Q What was his position at the time? 11 A I invoke my privilege. 12 Q What was discussed with Mr. Lowenthal on that date? 13 A I invoke my privilege. 14 Q A meeting at 4:00 p.m. with T.S. Chun, C-h-u-n. 15 Did you meet with Mr. Chun on that date? 16 A I invoke my privilege. 17 Q What was discussed? 18 A I invoke my privilege. 19 Q Ms. Melinda Yee has told you that she has destroyed 20 documents that were to be produced in this lawsuit, correct? 21 A I invoke my privilege. 22 Q What involvement, if any, do you have in a legal 23 defense fund that was set up on behalf of Melinda Yee? 24 A I invoke my privilege. 25 Q Are you aware of such a legal defense fund? 182 1 A I invoke my privilege. 2 Q October 3rd, entry at 2:00 p.m., Melinda, that 3 refers to Melinda Yee, correct? 4 A I invoke my privilege. 5 Q At 6:00 p.m. that day, "Ambassador, Republic of 6 Korea, reception," you attended a reception that day at the 7 Korean embassy, did you not? 8 A I invoke my privilege. 9 Q And during that reception, you discussed Commerce 10 Department trade missions to Korea, correct? 11 A I invoke my privilege. 12 Q And you discussed matters involving Lippo Group 13 holdings in Korea, correct? 14 A I invoke my privilege. 15 Q On October 5th -- 16 I'll show you what I'll ask the court reporter to 17 mark as the next exhibit. 18 THE COURT REPORTER: 60. 19 MR. COBB: Does that mean we have to come back on 20 October 5th for that? 21 MR. KLAYMAN: Hmm? 22 MR. COBB: That's a joke. 23 MR. KLAYMAN: For what? 24 MR. COBB: You were in the middle of your sentence. 25 You said "On October 5th, I'll show you this." 183 1 MR. KLAYMAN: Right. Good point. 2 THE COURT REPORTER: No. 60. 3 (Huang Deposition Exhibit No. 60 4 was marked for identification.) 5 BY MR. KLAYMAN: 6 Q I'll show you Exhibit 60, Mr. Huang. This is a 7 facsimile which was sent by Melinda Yee to you, correct? 8 A I invoke my privilege. 9 JUDGE FACCIOLA: Sustained. 10 BY MR. KLAYMAN: 11 Q And the second page, Bates number 1165, says "I'll 12 miss you all, please call, write, visit. Melinda Yee." 13 A I invoke my privilege. 14 Q You were very close and are very close with Melinda 15 Yee, correct? 16 A I invoke my privilege. 17 Q You consider her to be your good friend. 18 A I invoke my privilege. 19 Q You collaborated closely with her at the Commerce 20 Department, correct? 21 A I invoke my privilege. 22 MR. KLAYMAN: I'll show you what I'll ask the court 23 reporter to mark as Exhibit 61. 24 (Huang Deposition Exhibit No. 61 25 was marked for identification.) 184 1 BY MR. KLAYMAN: 2 Q I'm showing you Exhibit 61. Have you seen this 3 document before? It's a September 21, 1994 memorandum to you 4 from Joe Hanna, Arkansas Delegation List. 5 A I invoke my privilege. 6 Q Who is Joe Hanna? 7 A I invoke my privilege. 8 Q What was his job at the time? 9 A I invoke my privilege. 10 Q These are names of people who you arranged to have 11 see the Riadys during the APEC summit in Indonesia, correct? 12 A I invoke my privilege. 13 Q These people represented the Arkansas delegation? 14 A I invoke my privilege. 15 Q Number 15, Webster Hubbell, Webster Hubbell was 16 included on this trip, was he not? 17 A I invoke my privilege. 18 JUDGE FACCIOLA: I'll show you what I'll ask the 19 court reporter to mark as the next exhibit. 20 THE COURT REPORTER: 62. 21 (Huang Deposition Exhibit No. 62 22 was marked for identification.) 23 MR. COBB: Your Honor, that exhibit, I would 24 respectfully ask the Court to indicate its ruling with regard 25 to invocation. 185 1 JUDGE FACCIOLA: Oh, I'm sorry. Sustained. 2 MR. COBB: Thank you. 3 MR. KLAYMAN: Exhibit 62 is a memorandum to Mack 4 McLarty and John Podesta from Bruce Lindsey, Arkansas 5 Delegation to APEC. 6 "I spoke with John Tisdale and Doug Bouford 7 yesterday about the Arkansas delegation to the APEC 8 conference in Indonesia and the list has been whittled down 9 to the following." 10 And listed in there is Mark Grobmyer, the 11 representative of Entergy. 12 BY MR. KLAYMAN: 13 Q Who is Alan and Jean Sugg, S-u-g-g? 14 A I invoke my privilege. 15 Q Wayne and Francis Cranford? 16 A I invoke my privilege. 17 Q Alice Walton? 18 A I invoke my privilege. 19 Q A representative of Systematics? 20 A I invoke my privilege. 21 Q Paul Berry? 22 A I invoke my privilege. 23 Q It then states "All except Berry," Paul Berry, 24 "appear to have some legitimate reason for being there." 25 Why didn't Berry have a legitimate reason for being 186 1 there? 2 A I invoke my privilege. 3 JUDGE FACCIOLA: Sustained. 4 BY MR. KLAYMAN: 5 Q It says below, "James Riady and his father would 6 like to have the opportunity to visit briefly with President 7 Clinton in the hotel during the visit." 8 Did you arrange for such a visit, Mr. Huang? 9 A I invoke my privilege. 10 JUDGE FACCIOLA: Sustained. 11 BY MR. KLAYMAN: 12 Q Did such a visit take place? 13 A I invoke my privilege. 14 Q And what was discussed? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: Sustained in each instance. 17 BY MR. KLAYMAN: 18 Q Whose handwriting appears below on this document? 19 A I invoke my privilege. 20 Q What does it say? 21 A I invoke my privilege. 22 Q Does number one say "Lew"? Does that mean Ginger 23 Lew? 24 A I invoke my privilege. 25 JUDGE FACCIOLA: The invocation of the privilege is 187 1 sustained in each instance. 2 BY MR. KLAYMAN: 3 Q You've had a lot of contact over the years with 4 Ginger Lew, haven't you? 5 A I invoke my privilege. 6 JUDGE FACCIOLA: Sustained. 7 BY MR. KLAYMAN: 8 Q Are you aware that Ms. Lew claims that she's had 9 little contact with you? 10 A I invoke my privilege. 11 Q Does that surprise you? 12 A I invoke my privilege. 13 JUDGE FACCIOLA: Sustained in each instance. 14 BY MR. KLAYMAN: 15 Q October 4th, 3:30, Exhibit 32, "Taiwan meeting with 16 Rothkopf." 17 Did you have a meeting on that date about Taiwan? 18 A I invoke my privilege. 19 Q What was discussed? 20 A I invoke my privilege. 21 Q Did you participate in putting together an energy 22 project in Taiwan called Dragon Gate? 23 A I invoke my privilege. 24 Q Did you use Commerce Department resources to help 25 put that project together? 188 1 A I invoke my privilege. 2 Q Did you travel to Taiwan for that purpose? 3 A I invoke my privilege. 4 Q And do the Riadys and.or the Lippo Group have an 5 interest, financial or otherwise, in that Dragon Gate 6 project? 7 A I invoke my privilege. 8 JUDGE FACCIOLA: The invocation of privilege is 9 sustained in each instance. 10 BY MR. KLAYMAN: 11 Q October 5th, 6:30, "India minister, reception." 12 Did you attend a reception at the embassy of India 13 that day? 14 A I invoke my privilege. 15 Q Or anything with regard to India? 16 A I invoke my privilege. 17 Q Going back to October 5th, at 9:00 a.m., it's 18 listed John Dickerson, correct? 19 A I invoke my privilege. 20 Q John Dickerson is the CIA agent that briefed you 21 at the Commerce Department with classified materials, 22 correct? 23 A I invoke my privilege. 24 Q Were you provided classified materials on that day? 25 A I invoke my privilege. 189 1 JUDGE FACCIOLA: The invocation of privilege is 2 sustained in each instance. 3 BY MR. KLAYMAN: 4 Q After you met with Mr. Dickerson, did you have 5 meetings later that day with a Judy Barnett at 12:00 p.m.? 6 A I invoke my privilege. 7 Q Did you have meetings at 4:15 p.m. with a Joji, 8 J-o-j-i, Konoshima, K-o-n-o-s-h-i-m-a? 9 A I invoke my privilege. 10 JUDGE FACCIOLA: The invocation of the privilege is 11 sustained. 12 BY MR. KLAYMAN: 13 Q Excuse me. That's Judy. Who is Judy Konoshima? 14 A I invoke my privilege. 15 Q Did you have a meeting with Judy Barnett at 16 12:00 p.m.? 17 A I invoke my privilege. 18 Q Who is she? 19 A I invoke my privilege. 20 Q Who did she work with at the time? 21 A I invoke my privilege. 22 Q And you did have a meeting at the Indian embassy at 23 6:30 that day. 24 A I invoke my privilege. 25 Q Do you know a Shirley Young? 190 1 A I invoke my privilege. 2 Q What position did she occupy professionally on or 3 about October 6, 1994? 4 A I invoke my privilege. 5 Q Do you know a Barry Desher? I'm referring to 6 October 12th, an entry at 2:30. 7 A I invoke my privilege. 8 Q Did you meet with him at that time? 9 A I invoke my privilege. 10 Q Was Nancy Linn Patton also there? 11 A I invoke my privilege. 12 Q What was discussed? 13 A I invoke my privilege. 14 Q At 6:30, did you attend a reception at the Four 15 Seasons Hotel for the Taiwanese? 16 A I invoke my privilege. 17 JUDGE FACCIOLA: The invocation of the privilege is 18 sustained in all respects. 19 BY MR. KLAYMAN: 20 Q October 13th, you had a meeting with Mr. Russi at 21 1:00 p.m., it appears. 22 Did you have a meeting at that time? 23 A I invoke my privilege. 24 Q What was Mr. Russi's title at the time? 25 A I invoke my privilege. 191 1 Q 3:00 p.m., India trip meeting, did you attend a 2 meeting concerning the India trip? 3 A I invoke my privilege. 4 Q Who attended? 5 A I invoke my privilege. 6 Q What was discussed? 7 A I invoke my privilege. 8 JUDGE FACCIOLA: The invocation of the privilege is 9 sustained. 10 BY MR. KLAYMAN: 11 Q 5:15 p.m., "L.A. meeting with Rothkopf." What does 12 L.A. meeting mean? 13 A I invoke my privilege. 14 Q Did you attend such a meeting? 15 A I invoke my privilege. 16 Q What went on? 17 A I invoke my privilege. 18 Q At 6:30, "Mayflower Hotel, State Room, Indonesia 19 Society." Was that a reception? 20 A I invoke my privilege. 21 Q Did you go? 22 A I invoke my privilege. 23 Q Was that with regard to the trade trip to 24 Indonesia? 25 A I invoke my privilege. 192 1 Q Was Lippo business discussed in conjunction with 2 Department of Commerce services? 3 A I invoke my privilege. 4 Q October 14th, 5:30 p.m., were you briefed by John 5 Dickerson or anyone else with classified information on 6 October 14, 1994? 7 A I invoke my privilege. 8 Q Did you have a meeting half an hour thereafter with 9 Pauline Kanchanalak? 10 A I invoke my privilege. 11 Q Do you attend a reception, a Thai reception? 12 A I invoke my privilege. 13 Q Did you have a meeting with Pauline Kanchanalak on 14 October 18, 1994? 15 A I invoke my privilege. 16 Q October 18th, 12:00 p.m., it says "Old Ebbitt." 17 Did you meet someone at the Old Ebbitt on that day? 18 A I invoke my privilege. 19 Q Who did you meet? 20 A I invoke my privilege. 21 Q What was discussed? 22 A Again, I invoke my privilege. 23 Q Did it relate to Commerce Department trade 24 missions? 25 A I invoke my privilege. 193 1 Q You had a 2:00 p.m., "Indian interest meeting, 2 Garten." 3 Did you meet with Jeffrey Garten at that time? 4 A I invoke my privilege. 5 Q What, if anything, was discussed? 6 A I invoke my privilege. 7 Q Did you meet with Pauline Kanchanalak, U.S.-Thai 8 Business Council, at 3:30 on October 18th? 9 A I invoke my privilege. 10 Q What was discussed? 11 A I invoke my privilege. 12 Q Was the release of classified information from the 13 Commerce Department discussed? 14 A I invoke my privilege. 15 Q October 19th, 12:30, "Hay Adams Hotel, Grobmyer." 16 Did you meet with Mark Grobmyer at that time on 17 that date? 18 A I invoke my privilege. 19 Q And what was discussed with Mr. Grobmyer? 20 A I invoke my privilege. 21 Q Was the use of Commerce Department services in 22 exchange for campaign contributions discussed? 23 A I invoke my privilege. 24 Q At 3:30, you had a briefing with John Dickerson of 25 the CIA, correct? 194 1 A I invoke my privilege. 2 Q And you received classified information at that 3 time, correct? 4 A I invoke my privilege. 5 JUDGE FACCIOLA: The invocation of the privilege is 6 sustained. 7 BY MR. KLAYMAN: 8 Q Did you review information concerning the energy 9 sector at that time? 10 A I invoke my privilege. 11 Q The next day, October 20th, 4:00 p.m., Larry 12 Middleton. 13 Is he related to Mark Middleton? 14 A I invoke my privilege. 15 Q Is Larry Middleton a friend of the Riadys? 16 A I invoke my privilege. 17 Q Did you disclose to Mr. Middleton classified 18 information you had received the day earlier from 19 Mr. Dickerson? 20 A I invoke my privilege. 21 Q Did you make copies of any classified information 22 from the Commerce Department and give them to Mr. Middleton 23 at that time? 24 A I invoke my privilege. 25 Q At 3:00 p.m., you discussed the India trip. 195 1 Is that correct? 2 A I invoke my privilege. 3 Q And at 11:00 a.m., you discussed the APEC summit. 4 A I invoke my privilege. 5 MR. KLAYMAN: I'll show you what I'll ask the court 6 reporter to mark as the next exhibit. 7 THE COURT REPORTER: 63. 8 (Huang Deposition Exhibit No. 63 9 was marked for identification.) 10 MR. KLAYMAN: This is a document dated September 11 29, 1994 for Jeffrey Garten from Charles Meissner, "Our 12 missed breakfast and dinner." It consists of six pages. 13 Mr. Huang, take an opportunity to look at that 14 document and tell me if you've ever seen it before. 15 Actually, the document consists of two memos, the 16 top three pages are September 29, 1994 to Jeffrey Garten from 17 Charles Meissner, "Our missed breakfast and dinner;" and the 18 second one, a memorandum for Chuck Meissner from Jeffrey 19 Garten of October 4, 1994, also three pages. 20 BY MR. KLAYMAN: 21 Q Have you seen the first document, the September 29, 22 1994 document, before? 23 A I invoke my privilege. 24 Q Is this document accurate? 25 A I invoke my privilege. 196 1 Q Do you know whether Mr. Meissner wrote it? 2 A I invoke my privilege. 3 Q Do you know whether Mr. Garten received it? 4 A I invoke my privilege. 5 Q Same questions with regard to the October 4, 1994 6 memorandum from Garten to Meissner. 7 A I invoke my privilege. 8 Q Do you know what information has been removed from 9 the two documents that I've just identified for you? 10 A I invoke my privilege. 11 Q Is the second memorandum accurate? 12 A I invoke my privilege. 13 Q The October 4, 1994 one? 14 A I invoke my privilege. 15 MR. KLAYMAN: Your Honor, could we take a 16 five-minute break? 17 JUDGE FACCIOLA: Sure. Yes. 18 THE VIDEOGRAPHER: We're going off video record 19 at 3:08. 20 JUDGE FACCIOLA: Let's try at 3:15. 21 (A brief recess was taken.) 22 THE VIDEOGRAPHER: We're back on video record 23 at 3:15. 24 BY MR. KLAYMAN: 25 Q October 25th, 4:00 p.m., Exhibit 32, there's a 197 1 listing, "Garten, Vietnam meeting." 2 Was there a meeting concerning Vietnam on that day? 3 A I invoke my privilege. 4 JUDGE FACCIOLA: Sustained. 5 BY MR. KLAYMAN: 6 Q Did you play a role in that? 7 A I invoke my privilege. 8 Q Do you have any information as to whether or not 9 Brown or persons on behalf of Ron Brown received money from 10 the government of Vietnam in exchange for opening up trade 11 relations? 12 A I invoke my privilege. 13 JUDGE FACCIOLA: Sustained. 14 BY MR. KLAYMAN: 15 Q On October 25th at 2:15, there is what appears to 16 be an erasure. Did you erase the word "car"? 17 A I invoke my privilege. 18 JUDGE FACCIOLA: Sustained. 19 BY MR. KLAYMAN: 20 Q October 25th, 5:30, does that say "Taipei EC, Lu 21 and Hsia"? 22 A I invoke my privilege. 23 Q Did you have a meeting with Mr. Lu on that day? 24 A I invoke my privilege. 25 Q Do you know a Benjamin Lu who used to be ambassador 198 1 of Taiwan? 2 A I invoke my privilege. 3 Q Is Mr. Lu involved in any way with -- was he 4 involved in any way with what you were doing at the Commerce 5 Department? 6 A I invoke my privilege. 7 JUDGE FACCIOLA: Sustained. 8 BY MR. KLAYMAN: 9 Q Does the Hsia there refer to Maria Hsia? 10 A I invoke my privilege. 11 JUDGE FACCIOLA: Sustained. 12 BY MR. KLAYMAN: 13 Q October 26th, it says, "Travel to California." 14 Did you travel to California on October 26th 15 and 27th? 16 A I invoke my privilege. 17 JUDGE FACCIOLA: Sustained. 18 BY MR. KLAYMAN: 19 Q The reference to Lu, does that refer to a Colonel 20 Lu? 21 A I invoke my privilege. 22 JUDGE FACCIOLA: Sustained. 23 BY MR. KLAYMAN: 24 Q Who is connected to Chinese intelligence? 25 A I invoke my privilege. 199 1 Q October 28, 1994, Exhibit 32, shows that you 2 had a briefing with John Dickerson at 2:00 p.m. Is that 3 correct? 4 A I invoke my privilege. 5 Q And at that briefing, classified information was 6 provided to you, correct? 7 A I invoke my privilege. 8 JUDGE FACCIOLA: Sustained. 9 BY MR. KLAYMAN: 10 Q And after you had that briefing with John Dickerson 11 at 2:00 p.m., you later had a meeting, did you not, with 12 Benjamin Lu on October 31, 1994. 13 A I invoke my privilege. 14 JUDGE FACCIOLA: Sustained. 15 BY MR. KLAYMAN: 16 Q However, before you had the meeting with 17 John Dickerson, you also had a meeting with Benjamin Lu 18 on that day, October 28, 1994, as reflected in your diary, 19 correct? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: Sustained. 22 BY MR. KLAYMAN: 23 Q On October 27th at 3:00 p.m., you erased something 24 there, didn't you? 25 A I invoke my privilege. 200 1 Q And you erased "India trip meeting, room 37 -- " 2 we can't read the last two digits. Is that correct? 3 A I invoke my privilege. 4 Q What was discussed at that meeting? 5 A I invoke my privilege. 6 JUDGE FACCIOLA: Sustained. 7 BY MR. KLAYMAN: 8 Q October 31st, 5:00 p.m., Scott -- it looks Goddin, 9 G-o-d-d-i-n. 10 Do you know a Mr. Goddin? 11 A I invoke my privilege. 12 Q Who is Scott Goddin? 13 A I invoke my privilege. 14 Q And then at 7:00 p.m., we see another meeting with 15 Mr. Benjamin Lu, correct? 16 A I invoke my privilege. 17 Q What was discussed there? 18 A I invoke my privilege. 19 JUDGE FACCIOLA: Sustained in each instance. 20 BY MR. KLAYMAN: 21 Q Mr. Lu, did you erase things from your diary to 22 avoid incriminating yourself? 23 A I invoke my privilege. 24 JUDGE FACCIOLA: Sustained. 25 201 1 BY MR. KLAYMAN: 2 Q Why did you erase entries in your diary? 3 A I invoke my privilege. 4 JUDGE FACCIOLA: Sustained. 5 BY MR. KLAYMAN: 6 Q Did you erase entries in your diary to keep that 7 information from the Court in this lawsuit? 8 A I invoke my privilege. 9 JUDGE FACCIOLA: Sustained. 10 BY MR. KLAYMAN: 11 Q On November 4th, this is page 94094, your diary of 12 1994, it shows that you received a briefing at 2:15 in the 13 afternoon, correct? 14 A I invoke my privilege. 15 JUDGE FACCIOLA: Sustained. 16 BY MR. KLAYMAN: 17 Q Who is S.Y. Lee? 18 A I invoke my privilege. 19 Q What information was provided to you at that 20 briefing session? 21 A I invoke my privilege. 22 Q Was it classified? 23 A I invoke my privilege. 24 JUDGE FACCIOLA: Sustained in each instance. 25 202 1 BY MR. KLAYMAN: 2 Q On November 4, 1994, did you have a meeting at the 3 Army Navy Club involving Asian, A-s-i-a-n? 4 A I invoke my privilege. 5 Q What was discussed? 6 A I invoke my privilege. 7 JUDGE FACCIOLA: Sustained in each instance. 8 BY MR. KLAYMAN: 9 Q November 4th at 11:00 a.m., it says something 10 there, Pres. W-a-r-n-e k-e-i? Who is that in reference to? 11 A I invoke my privilege. 12 Q Who is that in reference to? 13 A I invoke my privilege. 14 Q What is k-e-i? 15 JUDGE FACCIOLA: Sustained in each instance. 16 BY MR. KLAYMAN: 17 Q You had a meeting at 10:00 a.m. with John Lynch. 18 What was his position at the time? 19 A I invoke my privilege. 20 Q What was discussed? 21 A I invoke my privilege. 22 JUDGE FACCIOLA: Sustained in each instance. 23 BY MR. KLAYMAN: 24 Q Turning to November 9th, page number 94095, at 25 4:00 p.m., did you have a briefing session with John 203 1 Dickerson, CIA agent, at that time? 2 A I invoke my privilege. 3 JUDGE FACCIOLA: Sustained. 4 BY MR. KLAYMAN: 5 Q Did you obtain information at that meeting which 6 you later passed to the Communist Chinese? 7 A I invoke my privilege. 8 JUDGE FACCIOLA: Sustained. 9 BY MR. KLAYMAN: 10 Q Did you obtain information which you later passed 11 to the Riadys and/or Lippo Group? 12 A I invoke my privilege. 13 Q Did you obtain information which you later passed 14 to others? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: The invocation of the privilege is 17 sustained. 18 BY MR. KLAYMAN: 19 Q Turn to the entry of November 15, 1994, 10:30 a.m., 20 Mr. Campos. 21 Who is Mr. Campos? 22 A I invoke my privilege. 23 Q Did you have a meeting with Mr. Campos? 24 A I invoke my privilege. 25 Q What was discussed? 204 1 A I invoke my privilege. 2 Q At 6:00 p.m. on November 14th, it looks like 3 certain things were erased. Did you erase something at 4 6:00 p.m.? 5 A I invoke my privilege. 6 Q Did it deal with senior staff, room 3850? 7 A I invoke my privilege. 8 JUDGE FACCIOLA: The invocation of the privilege is 9 sustained in each instance. 10 BY MR. KLAYMAN: 11 Q Was there a meeting with senior staff on that day? 12 A I invoke my privilege. 13 Q What was discussed? 14 A I invoke my privilege. 15 Q On November 18, 1994, page 94098, Exhibit 32, 1:30 16 in the afternoon, was there something erased there? 17 A I invoke my privilege. 18 JUDGE FACCIOLA: Sustained. 19 BY MR. KLAYMAN: 20 Q Did you erase "Car to Treasury"? 21 A I invoke my privilege. 22 Q November 21st, entry at 3:00 p.m. It says 23 "Beckmeyer," B-e-c-k-m-e-y-e-r. What was Mr. Beckmeyer's 24 position at the time? 25 A I invoke my privilege. 205 1 Q Did you have a meeting with him? 2 A I invoke my privilege. 3 Q What was discussed? 4 A I invoke my privilege. 5 JUDGE FACCIOLA: The invocation of the privilege is 6 sustained in each instance. 7 BY MR. KLAYMAN: 8 Q Throughout this diary I've seen several entries 9 concerning a Mr. Hauser, Tim Hauser. What was his position 10 at the time? 11 A I invoke my privilege. 12 JUDGE FACCIOLA: Sustained. 13 BY MR. KLAYMAN: 14 Q Tell me anything you can remember about your 15 discussions with Mr. Hauser. 16 A I invoke my privilege. 17 Q November 30th, 9:00 a.m., a meeting with Ray 18 Vickery concerning Dragon Gate, room 3832. 19 Did you have a meeting with Mr. Vickery at that 20 time? 21 A I invoke my privilege. 22 Q What was discussed? 23 A I invoke my privilege. 24 Q 2:30 p.m., "Meeting with Betty Lin, reporter." 25 Do you remember that meeting? 206 1 A I invoke my privilege. 2 Q What publication does Ms. Lynn report for? 3 A I invoke my privilege. 4 Q What did Ms. Lynn ask you at the time? 5 A I invoke my privilege. 6 Q Is Ms. Lynn the person who revealed your identity, 7 causing the scandal that we now find ourselves enmeshed in? 8 A I invoke my privilege. 9 JUDGE FACCIOLA: Sustained. 10 BY MR. KLAYMAN: 11 Q 3:30, John Dickerson, did you have a briefing 12 session with John Dickerson at that time? 13 A I invoke my privilege. 14 Q What information, if any, did you receive at that 15 meeting? 16 A I invoke my privilege. 17 Q Did you pass that information to persons outside of 18 the Commerce Department? 19 A I invoke my privilege. 20 Q Did you ask for information about the energy sector 21 at that meeting? 22 A I invoke my privilege. 23 Q Nuclear energy sector? 24 A I invoke my privilege. 25 JUDGE FACCIOLA: The invocation of the privilege is 207 1 sustained in each instance. 2 BY MR. KLAYMAN: 3 Q At 6:00 p.m., we see an entry, "Asian-Pacific- 4 American Bar Association, APABA, Ed Fund." 5 Do you know an Ed Fund? 6 A I invoke my privilege. 7 Q What was his position at the time? 8 A I invoke my privilege. 9 JUDGE FACCIOLA: That assumes he's a human being. 10 Wouldn't that be educational fund? 11 MR. KLAYMAN: You're right. Good point. 12 JUDGE FACCIOLA: No, I've met some people at the 13 Asian-Pacific Bar Association and I think they have an 14 educational fund. 15 THE WITNESS: I invoke my privilege. 16 MR. KLAYMAN: I didn't think it was John Fund. 17 BY MR. KLAYMAN: 18 Q Who attended that meeting? 19 A I invoke my privilege. 20 Q Did you meet people at that meeting? 21 A I invoke my privilege. 22 Q Do you know Mr. James Wood? 23 A I invoke my privilege. 24 Q Was Mr. James Wood ambassador to Taiwan? 25 A I invoke my privilege. 208 1 Q Do you know whether or not Mr. Wood participated in 2 meetings with Mark Middleton in Taiwan where monies were 3 offered by the government of Taiwan in exchange for favors by 4 the Clinton administration? 5 A I invoke my privilege. 6 Q Next page, December 1, 1994, Exhibit 32, "Special 7 staff meeting with Garten." 8 Did you attend such a meeting? 9 A I invoke my privilege. 10 JUDGE FACCIOLA: Sustained. 11 BY MR. KLAYMAN: 12 Q What occurred at this meeting? 13 A I invoke my privilege. 14 Q 3:00 p.m., "India trip meeting." 15 Did such a meeting occur at that time? 16 A I invoke my privilege. 17 Q What was discussed? 18 A Invocation. 19 Q Did you depart for Los Angeles on December 2nd? 20 A I invoke my privilege. 21 Q And did you then go to Taiwan on December 3rd? 22 A I invoke my privilege. 23 Q What was the reason for you going to Taiwan? 24 A I invoke my privilege. 25 JUDGE FACCIOLA: The invocation of the privilege is 209 1 sustained in each instance. 2 BY MR. KLAYMAN: 3 Q Did you go to use Department of Commerce services 4 paid for by U.S. taxpayers to further the interests of the 5 Riadys or the Lippo Group? 6 A I invoke my privilege. 7 Q December 12th, 10:30, page 94105, "Meeting with 8 Rothkopf, White House." 9 Did you attend a meeting with David Rothkopf at the 10 White House on that day? 11 A I invoke my privilege. 12 Q Who was present at any such meeting? 13 A I invoke my privilege. 14 Q What was discussed? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: The invocation of the privilege is 17 sustained. 18 BY MR. KLAYMAN: 19 Q December 13th, 2:00 p.m. entry, "John Dickerson." 20 Were you briefed by John Dickerson on that day? 21 A I invoke my privilege. 22 Q What information were you provided? 23 A I invoke my privilege. 24 Q Did you provide that information to anyone outside 25 of the Commerce Department? 210 1 A I invoke my privilege. 2 Q Did that information refer or relate in any way to 3 Commerce Department trade missions? 4 A I invoke my privilege. 5 Q Or what went on during the trade missions? 6 A I invoke my privilege. 7 Q Did you have a meeting with BOFT, Board of Foreign 8 Trade, of the Taiwanese government at 4:00 p.m. on December 9 14, 1994? 10 A I invoke my privilege. 11 Q Did that meeting take place in Washington? 12 A I invoke my privilege. 13 Q On December 14, 1994 at 2:00 p.m., did you discuss 14 the India trip at the Commerce Department? 15 A I invoke my privilege. 16 Q What was discussed? 17 A I invoke my privilege. 18 Q On December 15th, did you have a meeting as 19 reflected on your diaries at 7:00 a.m. with a Mr. Chang, 20 C-h-a-n-g, for breakfast at the Capitol Hilton? 21 A I invoke my privilege. 22 Q What was Mr. Chang's position at the time? 23 A I invoke my privilege. 24 Q What was discussed? 25 A I invoke my privilege. 211 1 Q Did you have lunch with Don Forest on that day? 2 A I invoke my privilege. 3 Q What was discussed? 4 A I invoke my privilege. 5 Q On December 16th, did you go to the Korean embassy 6 at 6:30 p.m.? 7 A I invoke my privilege. 8 Q Did you take with you classified information which 9 you had received by virtue of your briefings from John 10 Dickerson 11 A I invoke my privilege. 12 Q Did you share that classified information with 13 individuals at the Korean embassy? 14 A I invoke my privilege. 15 Q WCommerce Departmentere you going to the 16 Korean embassy to further the business interests of the Lippo 17 Group or the Riadys or both? 18 A I invoke my privilege. 19 Q On December 19, 1994, you met with Johnny Chung at 20 2:30. 21 A I invoke my privilege. 22 Q Where did you meet with Johnny Chung at 2:30? 23 A I invoke my privilege. 24 Q What was discussed? 25 A I invoke my privilege. 212 1 Q Who was present? 2 A I invoke my privilege. 3 Q Why did you meet with Johnny Chung? 4 A I invoke my privilege. 5 Q During that meeting, did you discuss passing 6 classified information to the government of China, classified 7 information of the Commerce Department to the government of 8 China? 9 A I invoke my privilege. 10 Q Did you discuss Johnny Chung's participation on 11 Commerce Department trade missions? 12 A I invoke my privilege. 13 Q Did you discuss laundering money from Communist 14 China into the Clintons' legal defense fund? 15 A I invoke my privilege. 16 Q Did you discuss laundering money from Communist 17 China into the Democratic Party and/or Clinton-Gore 18 campaigns? 19 A I invoke my privilege. 20 Q Did you discuss lowering the barriers to export 21 licensing from the United States to China? 22 A I invoke my privilege. 23 Q Did you discuss Johnny Chung's contacts with 24 Chinese intelligence? 25 A I invoke my privilege. 213 1 Q Did you discuss your own contacts with Chinese 2 intelligence? 3 A I invoke my privilege. 4 Q Did you discuss compromising the national security 5 interests of the United States? 6 A I invoke my privilege. 7 Q Have you discussed with Johnny Chung joint ventures 8 in China between American companies and Chinese companies? 9 A I invoke my privilege. 10 MR. KLAYMAN: I show you what I'll ask the court 11 reporter to mark as the next exhibit or what was marked -- 12 what will be marked as the next exhibit. 13 THE COURT REPORTER: 64. 14 (Huang Deposition Exhibit No. 64 15 was marked for identification.) 16 BY MR. KLAYMAN: 17 Q This is an article in The Washington Times of April 18 9, 1999 written by Jerry Seper, "Chinese Money was routed 19 through Lippo links to the Clinton campaign." It consists of 20 two pages. 21 Have you ever seen this document before? 22 A I invoke my privilege. 23 JUDGE FACCIOLA: I think you can tell us if you've 24 seen it, just simply if you've seen it. 25 MR. COBB: May I confer? 214 1 JUDGE FACCIOLA: Sure. 2 (The witness conferred with counsel.) 3 JUDGE FACCIOLA: The question was have you ever 4 seen it. 5 MR. COBB: And we have told the client he can 6 answer it yes or no. 7 JUDGE FACCIOLA: Fine. Thank you. 8 THE WITNESS: I don't believe so. No. 9 MR. COBB: Yes or no or I don't believe so. 10 BY MR. KLAYMAN: 11 Q Turn to the second page, the first paragraph, 12 "Johnny Chung, a California businessman who gave more than 13 $350,000 to the Democratic Party, has linked Democratic 14 fundraiser John Huang with Charles Yah Lin Trie to the PLA 15 fundraising scheme in grand jury testimony and sworn 16 statements as part of the plea agreement in a Justice 17 Department probe." 18 Do you have information as to whether or not Johnny 19 Chung has linked you and Charlie Trie to a PLA, People's 20 Liberation Army, fundraising scheme? 21 A I invoke my privilege. 22 JUDGE FACCIOLA: Sustained. 23 BY MR. KLAYMAN: 24 Q Have you talked to Mr. Johnny Chung in the last 25 three years? 215 1 A Again, I invoke my privilege. 2 JUDGE FACCIOLA: Sustained. 3 BY MR. KLAYMAN: 4 Q Have you talked to persons who themselves have 5 talked to Johnny Chung? 6 A I invoke my privilege. 7 JUDGE FACCIOLA: Sustained. 8 BY MR. KLAYMAN: 9 Q Do you have any information as to whether Johnny 10 Chung has been subjected to retaliation by the government of 11 China? 12 A I invoke my privilege. 13 Q Do you know whether or not agents of the government 14 of China have tried to kill Mr. Chung? 15 A I invoke my privilege. 16 Q Have you participated in any efforts to harm 17 Mr. Chung? 18 A I invoke my privilege. 19 JUDGE FACCIOLA: Sustained. 20 BY MR. KLAYMAN: 21 Q Do you have any information as to whether or 22 not Johnny Chung recorded conversations between you and 23 himself? 24 A I invoke my privilege. 25 JUDGE FACCIOLA: Sustained. 216 1 BY MR. KLAYMAN: 2 Q Do you have any information as to whether or not 3 Johnny Chung recorded conversations between himself and 4 individuals of Chinese intelligence? 5 A I invoke my privilege. 6 JUDGE FACCIOLA: Sustained. 7 BY MR. KLAYMAN: 8 Q Do you have any information as to whether or not 9 anyone ever suggested to Mr. Chung that he would be pardoned 10 by President Bill Clinton? 11 A I invoke my privilege. 12 JUDGE FACCIOLA: Sustained. 13 BY MR. KLAYMAN: 14 Q Do you have any information as to whether or not 15 U.S. counter-intelligence agents received information that 16 Chung and his family, including his two children of preschool 17 age, would be harmed by agents of the government of China? 18 A I invoke my privilege. 19 JUDGE FACCIOLA: Sustained. 20 BY MR. KLAYMAN: 21 Q Do you have any information as to whether he was 22 then escorted by heavily armed FBI agents to the Embassy 23 Suites Hotel on Imperial Highway in El Segundo, California? 24 A I invoke my privilege. 25 JUDGE FACCIOLA: Sustained. 217 1 BY MR. KLAYMAN: 2 Q Do you know of any material witnesses in the 3 campaign finance controversy who have been killed by agents 4 of China? 5 A I invoke my privilege. 6 JUDGE FACCIOLA: Sustained. 7 BY MR. KLAYMAN: 8 Q On the trade mission to China in 1994, in the fall, 9 August to September, do you know the substance of any 10 conversations between Jude Kearney and Johnny Chung? 11 A I invoke my privilege. 12 Q With regard to the same trade mission, do you know 13 the substance of any conversations between Johnny Chung and 14 Melinda Yee? 15 A I invoke my privilege. 16 Q The same question with regard to the substance of 17 any conversations between Johnny Chung and Ron Brown. 18 A I invoke my privilege. 19 JUDGE FACCIOLA: Sustained in each instance. 20 BY MR. KLAYMAN: 21 Q The same question with regard to the substance 22 of any conversation between Johnny Chung and Ng Lap 23 Seng. 24 A I invoke my privilege. 25 JUDGE FACCIOLA: Sustained. 218 1 BY MR. KLAYMAN: 2 Q Same question with regard to any conversations by 3 and between all of the individuals I just mentioned. 4 A I invoke my privilege. 5 JUDGE FACCIOLA: Sustained. 6 BY MR. KLAYMAN: 7 Q Do you know what any of these individuals were 8 doing in China in the fall of 1994? 9 A I invoke my privilege. 10 JUDGE FACCIOLA: Sustained. 11 BY MR. KLAYMAN: 12 Q Have you met with Johnny Chung on more than one 13 occasion? 14 A I invoke my privilege. 15 JUDGE FACCIOLA: Sustained. 16 BY MR. KLAYMAN: 17 Q Did you pass classified information to Johnny Chung 18 from the Commerce Department? 19 A I invoke my privilege. 20 JUDGE FACCIOLA: Sustained. 21 BY MR. KLAYMAN: 22 Q Did you ever hear of anything called the Trie 23 Group, T-r-i-e, Trie Group? 24 A I invoke my privilege. 25 Q Are you aware that Ron Brown at a White House 219 1 coffee referred to the Trie Group in a conversation with 2 President Clinton. 3 A I invoke my privilege. 4 Q You are part of the Trie Group, aren't you? 5 A I invoke my privilege. 6 Q Did you ever hear of an organization called Triad? 7 A I invoke my privilege. 8 Q Are you a member of Triad? 9 A I invoke my privilege. 10 Q Triad is part of what is commonly referred to as 11 the Chinese Mafia, correct? 12 A I invoke my privilege. 13 Q And it has links to Chinese intelligence, correct? 14 A I invoke my privilege. 15 Q Are you aware of any connections between Kearney 16 and Johnny Chung and Kearney and Charlie Trie? 17 A I invoke my privilege. 18 JUDGE FACCIOLA: Sustained. 19 BY MR. KLAYMAN: 20 Q Do you know whether or not Jude Kearney passed 21 classified information to Charlie Trie? 22 A I invoke my privilege. 23 JUDGE FACCIOLA: Sustained. 24 BY MR. KLAYMAN: 25 Q Classified information which he obtained at the 220 1 Commerce Department? 2 A I invoke my privilege. 3 Q Has Mr. Trie ever told you that Kearney gave him 4 access to classified information from the Commerce 5 Department? 6 A I invoke my privilege. 7 Q Entry of December -- let's go back to December 8 21st, Exhibit 32, your calendars. On December 21st, you had 9 lunch at the White House at 12:00 p.m., correct? 10 A I invoke my privilege. 11 JUDGE FACCIOLA: Sustained. 12 BY MR. KLAYMAN: 13 Q Who did you have lunch with? 14 A I invoke my privilege. 15 Q What was discussed? 16 A I invoke my privilege. 17 JUDGE FACCIOLA: Sustained. 18 BY MR. KLAYMAN: 19 Q You had lunch with President Bill Clinton, correct? 20 A I invoke my privilege. 21 Q At 4:00 p.m., "Robert Tanner and Scott." 22 What were their positions at the time? 23 A I invoke my privilege. 24 Q Did you meet with them on that day? 25 A I invoke my privilege. 221 1 Q What was discussed? 2 A I invoke my privilege. 3 JUDGE FACCIOLA: Sustained. 4 BY MR. KLAYMAN: 5 Q December 22nd, "Lunch with Walker," 12:00 p.m. 6 What was Mr. Walker's first name? 7 A I invoke my privilege. 8 Q Did you have lunch with him? 9 A I invoke my privilege. 10 Q What was discussed? 11 A I invoke my privilege. 12 JUDGE FACCIOLA: Sustained in each respect. 13 BY MR. KLAYMAN: 14 Q Next day, 9:00 a.m. What is the entry there at 15 9:00 a.m.? 16 A I invoke my privilege. 17 Q Is this a Bernard McMahn, M-c-M-a-h-n? 18 A I invoke my privilege. 19 Q Who is that person? 20 A I invoke my privilege. 21 Q What was his position at the time? 22 A I invoke my privilege. 23 Q What was discussed with him? 24 A I invoke my privilege. 25 Q 12:00 p.m., James T. T-s-a-o, what was his position 222 1 at the time, Mr. Tsao? 2 A I invoke my privilege. 3 Q Did you meet with him? 4 A I invoke my privilege. 5 Q What was discussed? 6 A I invoke my privilege. 7 Q Did it concern Commerce Department trade missions? 8 A I invoke my privilege. 9 Q A breach of U.S. national security? 10 A I invoke my privilege. 11 Q Passing classified information to the Chinese? 12 A I invoke my privilege. 13 Q Is Mr. Tsao an agent of the Chinese government? 14 A I invoke my privilege. 15 Q Does he have ties with Chinese intelligence? 16 A I invoke my privilege. 17 JUDGE FACCIOLA: The invocation of the privilege is 18 sustained in each instance. 19 BY MR. KLAYMAN: 20 Q Turning to the back of Exhibit 32, "Phone numbers 21 frequently used," it lists two entries. 22 Is that your handwriting? 23 A I invoke my privilege. 24 JUDGE FACCIOLA: Sustained. 25 223 1 BY MR. KLAYMAN: 2 Q The first says "NEC meeting, Marilyn, OEOB." 3 Is that Old Executive Office Building? 4 A I invoke my privilege. 5 JUDGE FACCIOLA: Sustained. 6 BY MR. KLAYMAN: 7 Q Who is Marilyn? 8 A I invoke my privilege. 9 Q What was her position at the time? 10 A I invoke my privilege. 11 Q Then it says "State staff meeting, room 6705." 12 A I invoke my privilege. 13 Q Do you know what that entry is all about? 14 A I invoke my privilege. 15 Q And on the next page, it says "Boyd," B-o-y-d, " 16 7/13/57." 17 Who is Boyd? 18 A I invoke my privilege. 19 Q Is that somebody's birth date? 20 A I invoke my privilege. 21 Q Do you know what that is? 22 A I invoke my privilege. 23 Q Let's turn to Exhibit 33. Entry of December 29th. 24 MR. COBB: I'm sorry -- 25 THE WITNESS: December 29th. 224 1 MR. KLAYMAN: That's 95007. 2 BY MR. KLAYMAN: 3 Q 2:30, "Brainstorming." Do you know what it says 4 after that? Follow-up? Is that it? 5 A I invoke my privilege. 6 Q What does "Brainstorming" mean? 7 A I invoke my privilege. 8 Q Turning over to 95008, 7:00 p.m., "Taiwan 9 Benevolent Association." 10 Is that what that says? Dinner? 11 A I invoke my privilege. 12 Q What is the Taiwan Benevolent Association? 13 A I invoke my privilege. 14 Q 9:00 a.m. that day, January 4th, "Senate Russell 15 Office Building." 16 Did you have a meeting up there at that time? 17 A I invoke my privilege. 18 Q Who did you meet with? 19 A I invoke my privilege. 20 Q What was discussed? 21 A I invoke my privilege. 22 Q Were you doing business for the Riadys or the Lippo 23 Group at that time? 24 A I invoke my privilege. 25 Q Next day, January 5th, "Lunch Old Ebbitt." 225 1 Did you have lunch at Old Ebbitt? 2 A I invoke my privilege. 3 Q Who did you have lunch with? 4 A I invoke my privilege. 5 Q What was discussed? 6 A I invoke my privilege. 7 Q 2:30 -- 8 JUDGE FACCIOLA: The invocation of the privilege is 9 sustained. 10 BY MR. KLAYMAN: 11 Q It shows an entry of John Dickerson. Were you 12 briefed by John Dickerson, CIA agent, at that time? 13 A I invoke my privilege. 14 Q Did he provide classified information to you? 15 A I invoke my privilege. 16 Q Did you then release that classified information to 17 agents of the government of China? 18 A I invoke my privilege. 19 Q Or others? 20 A Again, I invoke my privilege. 21 Q Including the Riadys and/or Lippo Group? 22 A I invoke my privilege. 23 Q January 11th -- January 6th. Let's go back to 24 that. Did you have lunch with a Mr. -- it begins with 25 S-c-h-e-n-e-y-e-r of the Ex-Im Bank, with Chuck and somebody 226 1 else on that date? 2 A I invoke my privilege. 3 JUDGE FACCIOLA: Sustained. 4 BY MR. KLAYMAN: 5 Q Was that Maeley Tom or Maria Haley? 6 A I invoke my privilege. 7 Q Mr. Huang, are you aware of any sources being 8 killed as a result of classified information being passed 9 from the Commerce Department to foreign agents? 10 A Mr. Klayman, I invoke my privilege. 11 JUDGE FACCIOLA: Sustained. 12 BY MR. KLAYMAN: 13 Q Same question with regard to foreign agents of the 14 government of China. 15 A I invoke my privilege. 16 MR. COBB: Can I request a good faith basis for 17 either of those questions? Which I do think is required when 18 you ask a question like that. 19 MR. KLAYMAN: Well, it deals with the whole area 20 that we've been asking about. 21 MR. COBB: I think that book has something about it 22 in its contents. 23 MR. KLAYMAN: I'll show you what -- I'll give you a 24 copy. I'll show you what I'll ask -- 25 Do you want to change? 227 1 MR. COBB: Yes, he needs to change the video tape. 2 MR. KLAYMAN: Okay. 3 THE VIDEOGRAPHER: We're going off video record 4 at 3:47. 5 (A brief recess was taken.) 6 THE VIDEOGRAPHER: We're back on video record 7 at 3:49. 8 MR. KLAYMAN: I'll show you what I'll ask the court 9 reporter to mark as the next exhibit. 10 THE COURT REPORTER: 65. 11 (Huang Deposition Exhibit No. 65 12 was marked for identification.) 13 BY MR. KLAYMAN: 14 Q "Did Huang's briefings put lives at risk? 15 Solomon wants White House to talk," by Jerry Seper, article 16 of July 1, 1997. 17 Have you ever seen this article before, Mr. Huang? 18 MR. KEENEY: The witness may answer that yes or no. 19 THE WITNESS: I don't believe so. 20 BY MR. KLAYMAN: 21 Q Are you aware that according to this article that 22 Mr. John Dickerson testified to the House of Representatives 23 that if the security briefings that you received by him were 24 released it could result in the death of a source? 25 A I invoke my privilege. 228 1 JUDGE FACCIOLA: Sustained. 2 MR. KLAYMAN: Your Honor, I think I asked the 3 question but since I'm a little bit hazy as to whether I did 4 or not -- 5 BY MR. KLAYMAN: 6 Q Do you know whether any sources were killed? 7 A I invoked my privilege. I think you did. 8 JUDGE FACCIOLA: Sustained. 9 BY MR. KLAYMAN: 10 Q Is Charles DeQueujoe, whom I referenced earlier, 11 Q-u-e-j-o-e, was he Lippo Securities' president in December 12 of '94? 13 A I invoke my privilege. 14 Q In December of 1994, Mr. DeQueujoe was appointed by 15 U.S. Trade Representative to sit on a special panel, the 16 Investment and Services Policy Advisory Committee, that 17 advises the U.S. Trade Representative, Charlene Barshefsky. 18 Is that not correct? 19 A I invoke my privilege. 20 JUDGE FACCIOLA: Sustained. 21 BY MR. KLAYMAN: 22 Q In fact, Mr. DeQueujoe and his wife had given more 23 than $25,000 to the Democratic Party in 1993 and 1994. 24 You're aware of that correct? 25 A I invoke my privilege. 229 1 Q And you had contact with Mr. DeQueujoe with regard 2 to your activities at the Commerce Department, correct? 3 A I invoke my privilege. 4 Q And, in fact, you passed classified information to 5 him, did you not? 6 A I invoke my privilege. 7 JUDGE FACCIOLA: Sustained. 8 BY MR. KLAYMAN: 9 Q In November of 1994, you are aware that Secretary 10 Ron Brown attended a trade mission in Indonesia with 11 President Clinton, correct? 12 A I invoke my privilege. 13 JUDGE FACCIOLA: Sustained. 14 BY MR. KLAYMAN: 15 Q And in that month you were formally advised by the 16 U.S. Government to recuse yourself from any Indonesia issues, 17 correct? 18 A I invoke my privilege. 19 JUDGE FACCIOLA: Sustained. 20 BY MR. KLAYMAN: 21 Q And despite being asked to do so, you did 22 not recuse yourself from issues involving Indonesia, 23 correct? 24 A I invoke my privilege. 25 JUDGE FACCIOLA: Sustained. 230 1 BY MR. KLAYMAN: 2 Q And, in fact, when I asked you this question 3 earlier during your first deposition in 1996, you denied 4 having any involvement in Indonesia, correct? 5 A I invoke my privilege. 6 JUDGE FACCIOLA: Sustained. 7 BY MR. KLAYMAN: 8 Q Then-Secretary Pena of the Transportation 9 Department traveled to Taiwan on December 14, 1994, correct? 10 A I invoke my privilege. 11 JUDGE FACCIOLA: Sustained. 12 BY MR. KLAYMAN: 13 Q And he participated along with you in the United 14 States getting the Dragon Gate contracts, correct? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: Sustained. 17 Q And Lippo and Riady participated in Dragon Gate, 18 correct? 19 A I invoke my privilege. 20 JUDGE FACCIOLA: Sustained. 21 BY MR. KLAYMAN: 22 Q And the Commerce Department played a role in 23 putting that together, correct? 24 A I invoke my privilege. 25 JUDGE FACCIOLA: Sustained. 231 1 BY MR. KLAYMAN: 2 Q And the reason the Commerce Department played a 3 role in putting that together was because of the campaign 4 contributions and other monies that had been provided by the 5 Riadys and Lippo Group to either the Clinton-Gore campaign, 6 the Democratic Party and/or Webster Hubbell, correct? 7 A I invoke my privilege. 8 JUDGE FACCIOLA: Sustained. 9 BY MR. KLAYMAN: 10 Q On December 15, 1994, you were called by Melinda 11 Yee at the Commerce Department, correct? 12 A I invoke my privilege. 13 Q And that call is reflected on page 44 of Exhibit 14 34, correct? 15 MR. COBB: This was asked, answered, invoked and 16 sustained. 17 MR. KLAYMAN: I don't think so. 18 JUDGE FACCIOLA: All right. Please. I don't 19 specifically recall. 20 MR. KLAYMAN: Well, there are many other calls. 21 JUDGE FACCIOLA: Okay. 22 Mr. Huang, do you claim the privilege? 23 THE WITNESS: Yes, I do. 24 JUDGE FACCIOLA: Sustained. 25 232 1 BY MR. KLAYMAN: 2 Q And on December 20, 1994, Mark Middleton called 3 you concerning a lunch at the White House with a message 4 "Need your family DOB." 5 That's correct, is it not? 6 A I invoke my privilege. 7 Q And that call from Middleton is reflected at page 8 58 of Exhibit 34. 9 MR. COBB: Also asked, answered, invoked and 10 sustained. 11 MR. KLAYMAN: It wasn't. It sounds like it, but it 12 wasn't. 13 JUDGE FACCIOLA: The privilege is sustained in any 14 event. 15 BY MR. KLAYMAN: 16 Q What does DOB mean? 17 A I invoke my privilege. 18 JUDGE FACCIOLA: Sustained. 19 BY MR. KLAYMAN: 20 Q Is DOB date of birth? 21 A I invoke my privilege. 22 JUDGE FACCIOLA: Sustained. 23 BY MR. KLAYMAN: 24 Q Turn to the entry on January 12th. January 12th, 25 this is Exhibit 33, at 10:30, you were briefed by John 233 1 Dickerson with classified materials, correct? 2 A I invoke my privilege. 3 JUDGE FACCIOLA: Sustained. 4 BY MR. KLAYMAN: 5 Q On January 19, 1995 at 7:00 p.m., you attended an 6 ambassador's dinner at the Chinese embassy or residence, 7 correct? 8 A I invoke my privilege. 9 JUDGE FACCIOLA: Sustained. 10 BY MR. KLAYMAN: 11 Q Did you pass the classified information you 12 obtained from John Dickerson to the Chinese at that dinner? 13 A I invoke my privilege. 14 Q What information did you pass to them? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: Sustained. 17 BY MR. KLAYMAN: 18 Q The entry with regard to the ambassadorial dinner 19 at the People's Republic of China residence or embassy 20 appears on your calendar, Exhibit 33, at 7:00 p.m., correct? 21 A I invoke my privilege. 22 Q And at 7:15 p.m., you have a telephone number 23 there. 24 What telephone number is that? 25 A I invoke my privilege. 234 1 Q Is that the telephone number of the ambassador of 2 China? 3 A I invoke my privilege. 4 Q Can you read the number? 5 A I invoke my privilege. 6 Q Turning to the entry for January 25, 1995, 7 11:00 a.m., it shows a briefing with John Dickerson, correct? 8 A I invoke my privilege. 9 Q And he provided to you classified information at 10 that time, correct? 11 A I invoke my privilege. 12 Q And on the prior day, the 24th of January at 13 4:00 p.m., you erased what was there, correct? 14 A I invoke my privilege. 15 Q And is that name Marge, M-a-r-g-e, S-e-a-r-e? 16 Who is S-e-a-r-e? 17 A I invoke my privilege. 18 Q Do you know what was erased? 19 A I invoke my privilege. 20 Q Now, after you received that briefing by John 21 Dickerson on the 25th of January 1995, you met with Bill Chao 22 at 12:00 p.m. on January 26, 1995, correct? 23 A I invoke my privilege. 24 Q Who is Bill Chao? What was his position at the 25 time? 235 1 A I invoke my privilege. 2 Q Did you pass classified information to Bill Chao at 3 that meeting? 4 A I invoke my privilege. 5 Q Was that information you obtained from John 6 Dickerson? 7 A I invoke my privilege. 8 Q You met with Johnny Chung on January 30th, correct? 9 At 11:30 a.m.? 10 A I invoke my privilege. 11 Q What was discussed with Mr. Chung at that time? 12 A I invoke my privilege. 13 Q Did you pass classified information which you had 14 obtained from John Dickerson to Johnny Chung at that meeting? 15 A I invoke my privilege. 16 Q What was that information about? 17 A I invoke my privilege. 18 MR. COBB: Wait. I'm sorry. That's an inquiry 19 into what classified information he had? I don't think 20 you're authorized to ask that. 21 MR. KLAYMAN: Just generically. 22 JUDGE FACCIOLA: The invocation of privilege is 23 sustained. It's sustained. 24 BY MR. KLAYMAN: 25 Q You had a meeting on January 31, 1995 at 1:00 p.m. 236 1 with the Taiwan Office in Roslyn, Virginia, correct? 2 A I invoke my privilege. 3 JUDGE FACCIOLA: Sustained. 4 BY MR. KLAYMAN: 5 Q What was discussed at that meeting? 6 A I invoke my privilege. 7 JUDGE FACCIOLA: Sustained. 8 BY MR. KLAYMAN: 9 Q Before that, you had a meeting with Mark Grobmyer, 10 did you not, at 12:00 p.m.? 11 A I invoke my privilege. 12 Q What was discussed at that meeting? 13 A I invoke my privilege. 14 JUDGE FACCIOLA: Sustained. 15 BY MR. KLAYMAN: 16 Q Did that concern Commerce Department trade 17 missions? 18 A I invoke my privilege. 19 Q With regard to all of the meetings that we have 20 talked about in Exhibit 32 and 33, your desk calendars of 21 1994 and 1995, did you keep notes of what went on at these 22 meetings? 23 A I invoke my privilege. 24 Q Did you keep recorded, tape recorded, records of 25 these meetings? 237 1 A I invoke my privilege. 2 Q Was anyone present at these meetings, other than 3 you, that kept notes? 4 A I invoke my privilege. 5 Q On February 1st at 11:45 a.m., you had a meeting 6 with the Democratic National Committee, correct? 7 A I invoke my privilege. 8 Q Was that meeting with or at the Democratic National 9 Committee or both? 10 A I invoke my privilege. 11 Q What was discussed? 12 A I invoke my privilege. 13 Q You discussed fundraising at the Democratic 14 National Committee, correct? 15 A I invoke my privilege. 16 Q And, in fact, you engaged in fundraising while you 17 worked at the Commerce Department. 18 A I invoke my privilege. 19 Q And you engaged in fundraising on behalf of the 20 Democratic National Committee and Clinton-Gore campaigns, 21 correct? 22 A I invoke my privilege. 23 Q In fact, this meeting with the Democratic National 24 Committee at 11:45 on February 1st was on government time, 25 was it not? 238 1 A I invoke my privilege. 2 JUDGE FACCIOLA: Sustained in each instance. 3 BY MR. KLAYMAN: 4 Q And, in fact, you knew that was illegal at the 5 time. 6 A I invoke my privilege. 7 Q You had a meeting at 3:00 p.m. with Amy Chung. 8 Is Amy Chung related to Johnny Chung? 9 A I invoke my privilege. 10 Q Where did that meeting take place? 11 A I invoke my privilege. 12 JUDGE FACCIOLA: Sustained. 13 BY MR. KLAYMAN: 14 Q What was discussed? 15 A I invoke my privilege. 16 Q What was the meeting about? 17 A I invoke my privilege. 18 JUDGE FACCIOLA: Sustained. 19 JUDGE FACCIOLA: I'll show you what I'll ask the 20 court reporter to mark as the next exhibit. 21 THE COURT REPORTER: 66. 22 (Huang Deposition Exhibit No. 66 23 was marked for identification.) 24 BY MR. KLAYMAN: 25 Q Have you ever seen Exhibit 66 before? 239 1 JUDGE FACCIOLA: Yes or no. 2 THE WITNESS: I don't believe so. 3 MR. KLAYMAN: Take an opportunity and review 4 Exhibit 66, Mr. Chung. This is a -- 5 THE WITNESS: Mr. Huang. 6 MR. COBB: Mr. Huang. 7 MR. KLAYMAN: Mr. Huang. Excuse me. 8 THE WITNESS: That's all right. 9 BY MR. KLAYMAN: 10 Q This is a Wall Street Journal article of Wednesday, 11 November 13, 1996, "Huang talked to Fundraisers While Working 12 at Commerce." 13 Is the information contained in Exhibit 66 14 accurate? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: Sustained. 17 BY MR. KLAYMAN: 18 Q Do you know an Ari Swiller? 19 A I invoke my privilege. 20 Q Mr. Swiller worked at the Democratic National 21 Committee when you did, correct? 22 A I invoke my privilege. 23 JUDGE FACCIOLA: Sustained. 24 BY MR. KLAYMAN: 25 Q And, in fact, he worked there even before you went 240 1 to the DNC from the Commerce Department, correct? 2 A I invoke my privilege. 3 Q And Mr. Swiller was in charge of the DNC managing 4 trustee program, correct? 5 A I invoke my privilege. 6 Q And Mr. Swiller participated in providing names of 7 DNC managing trustees to the Commerce Department so these 8 donors could be taken on trade missions, correct? 9 A I invoke my privilege. 10 Q And Mr. Swiller participated in selling seats on 11 Commerce Department trade missions to DNC managing trustees, 12 correct? 13 A I invoke my privilege. 14 Q You had contact with Mr. Swiller, did you not? 15 A I invoke my privilege. 16 Q Do you know where Mr. Swiller is today? 17 A I invoke my privilege. 18 JUDGE FACCIOLA: The invocation of the privilege is 19 sustained as to all these questions. 20 BY MR. KLAYMAN: 21 Q Did you receive calls from Mark Middleton on 22 January 3, 1995 at the Commerce Department? 23 A I invoke my privilege. 24 Q Are those calls reflected at page 58 of Exhibit 34? 25 A I invoke my privilege. 241 1 Q Did you receive calls from Joe Giroir at the 2 Commerce Department on January 4, 1995? 3 A I invoke my privilege. 4 Q Are those calls reflected in Exhibit 34, page 66? 5 A I invoke my privilege. 6 Q Did you receive more calls from Mark Middleton on 7 January 5, 1995? 8 A I invoke my privilege. 9 Q Are those calls reflected at page 59 of Exhibit 34? 10 A I invoke my privilege. 11 Q On January 5th, did you receive calls from Vernon 12 Weaver of Stephens Inc.? 13 A I invoke my privilege. 14 Q And are those calls reflected at page 59 of Exhibit 15 34? 16 A I invoke my privilege. 17 JUDGE FACCIOLA: The invocation of the privilege is 18 sustained. 19 BY MR. KLAYMAN: 20 Q On January 19th, did you receive calls from Mark 21 Grobmyer at the Commerce Department? 22 A I invoke my privilege. 23 Q And are those calls reflected at page 59 of Exhibit 24 34? 25 A I invoke my privilege. 242 1 Q And did you attend a dinner at the ambassador's 2 residence, the People's Republic of China, with a Mrs. Li Dan 3 Yu, L-i D-a-n Y-u, on January 19th? 4 A I invoke my privilege. 5 Q Have you ever stayed overnight at the embassy or 6 the residence at the People's Republic of China in 7 Washington, D.C.? 8 A I invoke my privilege. 9 Q Have you ever used the telecommunications 10 facilities of the embassy or residence of the People's 11 Republic of China? 12 A I invoke my privilege. 13 Q Have you ever used those telecommunications 14 facilities to transmit classified information to the 15 government of China? 16 A I invoke my privilege. 17 Q Either by yourself or in conjunction with others? 18 A Again, I invoke my privilege. 19 JUDGE FACCIOLA: Sustained in each instance. 20 BY MR. KLAYMAN: 21 Q When this Court was looking for you in October 22 of 1996 to be served with a subpoena, were you during that 23 time period located at the embassy of China or at its 24 residence? 25 A I invoke my privilege. 243 1 JUDGE FACCIOLA: Sustained. 2 BY MR. KLAYMAN: 3 Q Did the government of China help you in trying to 4 avoid the service of process of this Court in October of 5 1996? 6 A I invoke my privilege. 7 JUDGE FACCIOLA: Sustained. 8 BY MR. KLAYMAN: 9 Q On January 25, 1995, you received calls from 10 Senator Barbara Boxer's office, did you not? 11 A I invoke my privilege. 12 JUDGE FACCIOLA: Sustained. 13 BY MR. KLAYMAN: 14 Q What involvement, if any, did Senator Boxer have 15 with your activities at the Commerce Department when you 16 worked there? 17 A I invoke my privilege. 18 JUDGE FACCIOLA: Sustained. 19 BY MR. KLAYMAN: 20 Q Has Senator Boxer received contributions generated 21 by you, the Riadys and/or Lippo Group? 22 A I invoke my privilege. 23 JUDGE FACCIOLA: Sustained. 24 BY MR. KLAYMAN: 25 Q On January 15, 1995, did you have a meeting with 244 1 regard to Vietnam with trade ministry officials of the 2 government of Vietnam? 3 A I invoke my privilege. 4 JUDGE FACCIOLA: Sustained. 5 BY MR. KLAYMAN: 6 Q What was discussed at that meeting? 7 A I invoke my privilege. 8 JUDGE FACCIOLA: Sustained. 9 BY MR. KLAYMAN: 10 Q On February 3rd, did you receive calls from Webster 11 Hubbell at the Commerce Department? 12 A I invoke my privilege. 13 JUDGE FACCIOLA: Sustained. 14 BY MR. KLAYMAN: 15 Q Are those calls reflected at page 48 of Exhibit 34? 16 A I invoke my privilege. 17 JUDGE FACCIOLA: Sustained. 18 BY MR. KLAYMAN: 19 Q On February 14th, did you receive calls from Trisha 20 Lum, daughter of Nora and Gene Lum at the Commerce 21 Department? 22 A I invoke my privilege. 23 JUDGE FACCIOLA: Sustained. 24 BY MR. KLAYMAN: 25 Q Are those calls reflected at page 48 of Exhibit 34? 245 1 A I invoke my privilege. 2 JUDGE FACCIOLA: Sustained. 3 BY MR. KLAYMAN: 4 Q On that same date, did you receive calls from 5 Melinda Yee at the Commerce Department? 6 A I invoke my privilege. 7 Q And are those calls reflected on page 48 of Exhibit 8 34? 9 A I invoke my privilege. 10 JUDGE FACCIOLA: Sustained. 11 BY MR. KLAYMAN: 12 Q What information do you have, if any, that Nora and 13 Gene Lum, through the son of Ron Brown, Michael Brown, 14 laundered money from the Lums into the accounts of Ron Brown? 15 A I invoke my privilege. 16 Q Assuming monies were laundered into the accounts of 17 Ron Brown through the Lums, did that money come from the 18 Lippo Group or the Riadys? 19 A I invoke my privilege. 20 MR. COBB: And I object on the scope. 21 JUDGE FACCIOLA: Sustained. 22 MR. KLAYMAN: It's no different than anything else, 23 Your Honor, if the money is coming from the Riadys. 24 JUDGE FACCIOLA: Please go on. 25 MR. KLAYMAN: Okay. 246 1 BY MR. KLAYMAN: 2 Q February 6, 1995, meeting at the White House, 3 2:00 p.m. 4 Did you have a meeting on that date? 5 A I invoke my privilege. 6 JUDGE FACCIOLA: Sustained. 7 BY MR. KLAYMAN: 8 Q Who did you meet with? 9 A I invoke my privilege. 10 Q Who did you meet with? 11 A I invoke my privilege. 12 Q And what was discussed? 13 A I invoke my privilege. 14 Q At 4:00 p.m., it shows a meeting with John 15 Dickerson. 16 Did you receive national security information at 17 that time? 18 A I invoke my privilege. 19 Q Was that information then removed from the 20 Commerce Department and provided to agents of the government 21 of China? 22 A I invoke my privilege. 23 Q To anyone else? 24 A I invoke my privilege. 25 JUDGE FACCIOLA: Sustained. 247 1 BY MR. KLAYMAN: 2 Q Did any of that information concern the subject 3 trade missions? 4 A I invoke my privilege. 5 JUDGE FACCIOLA: Sustained. 6 BY MR. KLAYMAN: 7 Q On February 3, 1995, you received two additional 8 phone calls from Webster Hubbell, correct? 9 A I invoke my privilege. 10 Q And you received more calls from Vernon Weaver, 11 correct? 12 A I invoke my privilege. 13 Q And all these calls were received at the Commerce 14 Department. 15 A I invoke my privilege. 16 Q And all these calls are reflected at page 60 of 17 Exhibit 34, correct? 18 A I invoke my privilege. 19 JUDGE FACCIOLA: Sustained. 20 BY MR. KLAYMAN: 21 Q On February 10th, you received calls from a C.C. 22 Chang, C-h-a-n-g. 23 A I invoke my privilege. 24 Q And these calls are reflected at page 48 of Exhibit 25 34, correct? 248 1 A I invoke my privilege. 2 Q What were the calls that I've just referenced, 3 the ones to Webster Hubbell, Vernon Weaver and C.C. Chang, 4 about? 5 A I invoke my privilege. 6 Q What were the calls from Senator Barbara Boxer's 7 office about? 8 A I invoke my privilege. 9 JUDGE FACCIOLA: Sustained. 10 BY MR. KLAYMAN: 11 Q On February 8th, you had a dinner at the Willard 12 Hotel, correct? 13 A I invoke my privilege. 14 Q What was the reason for that dinner? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: Sustained. 17 BY MR. KLAYMAN: 18 Q Who was there? 19 A I invoke my privilege. 20 JUDGE FACCIOLA: Sustained. 21 BY MR. KLAYMAN: 22 Q What was discussed? 23 A I invoke my privilege. 24 Q Were Commerce Department trade missions discussed? 25 A I invoke my privilege. 249 1 JUDGE FACCIOLA: Sustained. 2 BY MR. KLAYMAN: 3 Q Are you an agent of the government of Korea? 4 A I invoke my privilege. 5 JUDGE FACCIOLA: Sustained. 6 BY MR. KLAYMAN: 7 Q Why is it that you've had as reflected in your 8 diary so much contact with Korea? 9 MS. BRASWELL: Objection. 10 JUDGE FACCIOLA: Sustained on both grounds, the 11 privilege and the relevance. 12 BY MR. KLAYMAN: 13 Q Is it with regard to trade missions of the Commerce 14 Department to Korea? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: Sustained. 17 BY MR. KLAYMAN: 18 Q Have you ever passed classified information that 19 you received at the Commerce Department to the Korean 20 government? 21 A I invoke my privilege. 22 Q Or anybody in Korea? 23 A I invoke my privilege. 24 Q Did any of this classified information relate or 25 refer in any way to the subject trade missions? 250 1 A I invoke my privilege. 2 Q February 14th -- 3 MR. COBB: Valentine's Day. 4 BY MR. KLAYMAN: 5 Q 4:00 p.m., meeting with John Dickerson. 6 Did you receive classified information on that day? 7 A I invoke my privilege. 8 Q Was that information passed to anyone outside of 9 the Commerce Department? 10 A I invoke my privilege. 11 JUDGE FACCIOLA: Sustained. 12 BY MR. KLAYMAN: 13 Q Did it relate to Commerce Department trade 14 missions? 15 A I invoke my privilege. 16 Q February 16th, page 95021, did you have a meeting 17 at the White House that day? 18 A I invoke my privilege. 19 Q There is an erasure there. Does that say Car? 20 A I invoke my privilege. 21 Q Did you erase that? 22 A I invoke my privilege. 23 JUDGE FACCIOLA: Sustained in each instance. 24 BY MR. KLAYMAN: 25 Q Did the White House send a car for you? 251 1 A I invoke my privilege. 2 Q And it says "White House briefing." Were you 3 briefed at the White House that day? 4 A I invoke my privilege. 5 Q What did you get briefed about? 6 A I invoke my privilege. 7 Q Who was present? 8 A I invoke my privilege. 9 Q Did it relate to the subject trade missions? 10 A I invoke my privilege. 11 Q Did it relate to passing classified information to 12 foreign governments? 13 A I invoke my privilege. 14 Q Did it relate to payments to Webster Hubbell? 15 A I invoke my privilege. 16 Q In exchange for receiving your post at the Commerce 17 Department? 18 A I invoke my privilege. 19 Q Or obtaining a national security clearance? 20 A I invoke my privilege. 21 Q 9:30 that day, meeting with Sue Hamrock, Clyde 22 Robinson. What were their positions at the time? 23 MS. BRASWELL: Your Honor, I object to this 24 continued line of questioning. 25 JUDGE FACCIOLA: Yes, I think this -- 252 1 MS. BRASWELL: Mr. Klayman has more than laid his 2 foundation regarding the claim of the Fifth Amendment 3 privilege. 4 JUDGE FACCIOLA: Let's kind of talk about where we 5 are and where we're going. It's 4:15. 6 MS. BRASWELL: If we're going to go through this 7 entire diary like we've just gone through the last, it is 8 pointless. 9 MR. KLAYMAN: Why is it pointless? 10 JUDGE FACCIOLA: It is now -- just a second, 11 Mr. Klayman. 12 It is now 4:15. The record reflects that the prior 13 deposition of Mr. Huang ended at 4:48, so we have been at it 14 since this morning, since 10:00 when we started promptly. 15 Allowing for the breaks we took and the one-hour lunch 16 recess, a combination of the two depositions are inching 17 towards 16 hours, I think, they're somewhere between 12 and 18 16 hours. 19 It is quite clear that the witness will claim the 20 Fifth Amendment privilege with reference to any diary entry 21 on the grounds that obviously if he admits the accuracy of 22 the information in that diary entry, he's not only admitting 23 the accuracy of that entry, but the other entries. 24 Now, he also is going to claim the Fifth Amendment 25 and will continue to claim it with reference to the telephone 253 1 records for the same reason, that admission of the accuracy 2 of one of those telephone records would be an admission not 3 only that that phone call took place, but all the others have 4 taken place. 5 It is also quite clear that if we were to divide 6 his testimony into broad topics, he would be claiming the 7 Fifth Amendment with reference, for example, to his receipt 8 or raising of fundraising funds for the Democratic National 9 Committee, to his knowledge, participation and personal 10 involvement and the involvement of others in invitations and 11 going on trade missions. 12 And, finally, he would claim the Fifth Amendment 13 with reference to any relationship he had whatsoever with 14 Mr. Trie and Mr. Chung. 15 Given that, those topics have been completely 16 exhausted, that you have my ruling on the scope of the Fifth 17 Amendment, you have my ruling with reference to waiver to it, 18 that he did not, Mr. Klayman, what will we possibly 19 accomplish in the future that we have not already 20 accomplished here today? 21 MR. KLAYMAN: Well, first of all, Your Honor, I 22 understand and you have been very patient, we appreciate 23 that. We even thank counsel for Mr. Huang for being patient. 24 Ms. Braswell, the fact that she's getting tired, I mean, I'm 25 getting tired, too. 254 1 If there's a way to short-circuit it, that's fine, 2 but we've had a procedure in place and I'm just simply trying 3 to comply with the question-by-question procedure. If 4 Your Honor has a better way of doing it, we're open to 5 suggestion. 6 JUDGE FACCIOLA: Well, how about this -- 7 MR. KLAYMAN: And then I'll just ask specific 8 questions -- 9 JUDGE FACCIOLA: Maybe we could agree among counsel 10 and we could proceed with a series of summary questions which 11 would now echo what I have just said. 12 Question number one would be if I were to ask you 13 additional questions about the accuracy of the information 14 contained in your diary, would you claim the Fifth Amendment? 15 MR. COBB: Absolutely. 16 JUDGE FACCIOLA: If I were to continue to ask you 17 questions about the accuracy of the information contained 18 in any of the phone records to which Mr. Klayman has been 19 referring today, would the witness claim the Fifth Amendment? 20 MR. COBB: Absolutely. 21 JUDGE FACCIOLA: If the witness were asked 22 questions about his participation in fundraising for the 23 Democratic National Committee, the Clinton-Gore campaign or 24 any other entity, would he claim the Fifth Amendment? 25 MR. COBB: Absolutely. 255 1 JUDGE FACCIOLA: If the witness were to be asked 2 additional questions with reference to his relationship with 3 gentlemen named Charlie Trie and Johnny Chung, would he claim 4 the Fifth Amendment? 5 MR. COBB: Absolutely. 6 JUDGE FACCIOLA: If the witness were to be asked in 7 general about his relationship with entities, business or 8 governmental entities, that are owned and operated in whole 9 or in part by the Chinese government, would he claim the 10 Fifth Amendment? 11 MR. COBB: Absolutely. 12 JUDGE FACCIOLA: If the witness were to be asked 13 any questions with reference to CIA briefings provided him in 14 this capacity at the Department of Commerce by a man named 15 Dickerson or any other person employed by the CIA or any 16 other agency that has as part of its statutory 17 responsibilities the protection of the national security of 18 the United States, would he claim the Fifth Amendment? 19 MR. COBB: He would, Your Honor. In addition, he 20 would be obligated legally not to answer those questions. 21 JUDGE FACCIOLA: If he were to be asked any 22 questions with reference to his relationships with foreign 23 governments, and more particularly whether or not any 24 information made available to him either officially or 25 unofficially in his capacity at the Department of Commerce, 256 1 either by officials of the United States employed by any 2 agency of the United States, whether he caused that 3 information to be transmitted to representatives of any 4 foreign government, would he claim the Fifth Amendment? 5 MR. COBB: Yes, Your Honor. 6 JUDGE FACCIOLA: Are there any other topics we 7 could possibly inquire about, Mr. Klayman? 8 MR. KLAYMAN: Well, again, Your Honor, you're 9 referring to what generally is in the diary and then you went 10 a little broader. I appreciate that. Let me see, you know, 11 if we can preserve all of our claims that there is no 12 privilege on these topics, that obviously helps reserve with 13 all due deference to the Court our right to request, if 14 necessary, to bring Mr. Huang back in the event that -- 15 JUDGE FACCIOLA: Well, if my Fifth Amendment 16 rulings are overturned, then we go back to square one. 17 There's nothing anybody can do from there. 18 MR. KLAYMAN: Right. But let me just ask some 19 specific questions in areas that you didn't cover and see if 20 we can move this along. I appreciate your trying to preserve 21 the record and protect the rights of all parties. 22 JUDGE FACCIOLA: Let's see if you can help us. 23 BY MR. KLAYMAN: 24 Q Throughout 1995, did you have any telephone 25 conversations with Vanessa Weaver when you were at the 257 1 Commerce Department? 2 A I invoke my privilege. 3 Q And what were those telephone conversations about? 4 A I invoke my privilege. 5 Q Is Vanessa Weaver related to Vernon Weaver? 6 A I invoke my privilege. 7 JUDGE FACCIOLA: The invocation of the privilege in 8 each instance will be sustained. 9 BY MR. KLAYMAN: 10 Q Throughout 1994 and 1995, during the period you 11 were employed by the Commerce Department, did you have any 12 contact, oral or written, with Congressman Matsui's office? 13 A I invoke my privilege. 14 Q Did any of those conversations concern your 15 activities at the Commerce Department? 16 A I invoke my privilege. 17 Q Did any of those communications concern the subject 18 trade missions? 19 A I invoke my privilege. 20 Q Or what was going on on the trade missions? 21 A I invoke my privilege. 22 Q Did Congressman Matsui or anyone in his office ever 23 ask you to recommend to take any Democratic donors on those 24 trade missions? 25 A I invoke my privilege. 258 1 Q Were there campaign contributions that were 2 provided by any donors recommended by Congressman Matsui to 3 go on the trade missions? 4 A I invoke my privilege. 5 Q Did you ever have any contact with Doris Matsui 6 during 1994 or 1995? 7 A I invoke my privilege. 8 Q Did you discuss Commerce Department trade missions 9 with her? 10 A I invoke my privilege. 11 Q Did you discuss taking participants on those trade 12 missions who had made contributions to the Democratic Party 13 or Clinton-Gore campaign with Doris Matsui? 14 A I invoke my privilege. 15 Q Does Doris Matsui, to the best of your knowledge, 16 have any knowledge about your activities at the Commerce 17 Department? 18 A I invoke my privilege. 19 JUDGE FACCIOLA: The invocation of the privilege is 20 sustained in each respect. 21 BY MR. KLAYMAN: 22 Q During 1994 and 1995, you had contact with Harry 23 Thomason, a famous Hollywood producer, did you not? 24 A I invoke my privilege. 25 JUDGE FACCIOLA: Sustained. 259 1 BY MR. KLAYMAN: 2 Q Why did you have contact with Harry Thomason? 3 A I invoke my privilege. 4 Q You had contact with Harry Thomason at the Commerce 5 Department, correct? 6 A I invoke my privilege. 7 Q Was Mr. Thomason asking you to do favors for him at 8 the Commerce Department? 9 JUDGE FACCIOLA: Sustained. 10 BY MR. KLAYMAN: 11 Q You are aware that he is a contributor to the 12 Clinton-Gore campaigns and/or the Democratic Party. 13 A I invoke my privilege. 14 JUDGE FACCIOLA: Sustained. 15 BY MR. KLAYMAN: 16 Q Did Mr. Thomason recommend to you anyone to be 17 included on Commerce Department trade missions? 18 A I invoke my privilege. 19 JUDGE FACCIOLA: Sustained. 20 BY MR. KLAYMAN: 21 Q During 1994 and 1995, you had contact with Harold 22 Ickes, correct? 23 A I invoke my privilege. 24 Q And Harold Ickes was in charge of selling 25 government services in exchange for campaign contributions at 260 1 the White House, correct? 2 A I invoke my privilege. 3 Q Harold Ickes played a role in selling government 4 services in exchange for campaign contributions at the White 5 House, correct? 6 A I invoke my privilege. 7 JUDGE FACCIOLA: Sustained. 8 BY MR. KLAYMAN: 9 Q Do you know whether or not Harold Ickes has 10 organized crime ties? 11 A I invoke my privilege. 12 Q Did you ever hear anyone say that it was Hillary 13 Rodham Clinton who devised the scheme to sell seats on 14 Commerce Department trade missions? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: Sustained. 17 BY MR. KLAYMAN: 18 Q Did you ever discuss selling seats on trade 19 missions with Hillary Rodham Clinton? 20 A I invoke my privilege. 21 Q With the President of the United States? 22 A I invoke my privilege. 23 Q With the Vice President of the United States? 24 A I invoke my privilege. 25 Q With Harold Ickes? 261 1 A I invoke my privilege. 2 JUDGE FACCIOLA: Sustained in each instance. 3 BY MR. KLAYMAN: 4 Q With Alexis Herman? 5 A I invoke my privilege. 6 Q Why did you leave the Commerce Department and go to 7 the Democratic National Committee? 8 A I invoke my privilege. 9 JUDGE FACCIOLA: Sustained. 10 BY MR. KLAYMAN: 11 Q You left the Commerce Department formally on 12 December 3, 1995? 13 A I invoke my privilege. 14 Q And between December 4, 1995 and January 17, 1996, 15 you were on leave without pay, correct? 16 A I invoke my privilege. 17 Q Why were you on leave without pay? 18 A I invoke my privilege. 19 JUDGE FACCIOLA: Sustained in each instance. 20 BY MR. KLAYMAN: 21 Q Either you or persons on your behalf asked that you 22 continue on as a consultant for the Commerce Department while 23 you worked for the Democratic National Committee. 24 A I invoke my privilege. 25 JUDGE FACCIOLA: Sustained. 262 1 BY MR. KLAYMAN: 2 Q The purpose for that was so that you could continue 3 to hold your security clearance, correct? 4 A I invoke my privilege. 5 JUDGE FACCIOLA: Sustained. 6 BY MR. KLAYMAN: 7 Q And the purpose for that was so you could continue 8 to review classified information and pass it on to persons 9 outside of the Commerce Department, correct? 10 A I invoke my privilege. 11 JUDGE FACCIOLA: Sustained. 12 BY MR. KLAYMAN: 13 Q And the persons you intended to pass that 14 information to were agents of the government of China. 15 A I invoke my privilege. 16 Q James and Mochtar Riady. 17 A I invoke my privilege. 18 Q Individuals at the Lippo Group. 19 A I invoke my privilege. 20 JUDGE FACCIOLA: Sustained. 21 BY MR. KLAYMAN: 22 Q Individuals or agents of the embassies of Taiwan 23 and Korea. 24 A I invoke my privilege. 25 Q Indonesia. 263 1 A I invoke my privilege. 2 Q When you left the Commerce Department on or about 3 December 3, 1995, you didn't turn in your keys, did you? 4 A I invoke my privilege. 5 Q And, in fact, even after you went off of leave 6 without pay on January 17, 1996, you never turned in your 7 keys. 8 A I invoke my privilege. 9 JUDGE FACCIOLA: Sustained. 10 BY MR. KLAYMAN: 11 Q In fact, throughout 1996, you continued to visit 12 the Commerce Department, correct? 13 A I invoke my privilege. 14 JUDGE FACCIOLA: Sustained. 15 BY MR. KLAYMAN: 16 Q And you were admitted by virtue of your continuing 17 security clearance, correct? 18 A I invoke my privilege. 19 Q When you worked at the Commerce Department, 20 you were usually the last person out of your office, 21 correct? 22 A I invoke my privilege. 23 JUDGE FACCIOLA: Sustained. 24 BY MR. KLAYMAN: 25 Q And the reason you stayed late was to be able to 264 1 take classified information out of the Commerce Department 2 without detection, correct? 3 A I invoke my privilege. 4 Q Do you have any information about an individual by 5 the name of Barbara Wise? 6 A I invoke my privilege. 7 Q Did she work with you? 8 A I invoke my privilege. 9 Q Are you aware that shortly after Christmas in 1996 10 she was found dead at the Commerce Department? 11 A I invoke my privilege. 12 Q Do you have any information as to the cause of her 13 death? 14 A I invoke my privilege. 15 JUDGE FACCIOLA: Sustained in each instance. 16 BY MR. KLAYMAN: 17 Q Was her death in any way related to your activities 18 at the Commerce Department? 19 A I invoke my privilege. 20 JUDGE FACCIOLA: Sustained. 21 BY MR. KLAYMAN: 22 Q Did you ever attend meetings at the house of Rob 23 Stein? 24 A I invoke my privilege. 25 JUDGE FACCIOLA: Sustained. 265 1 BY MR. KLAYMAN: 2 Q Are you aware that Rob Stein had meetings at his 3 house where he and others discussed obstructing the 4 proceedings in this lawsuit? 5 A I invoke my privilege. 6 JUDGE FACCIOLA: Sustained. 7 BY MR. KLAYMAN: 8 Q Did you know William Ginsberg, the chief of staff 9 after Rob Stein at the Commerce Department? 10 A I invoke my privilege. 11 Q Are you aware that Mr. Ginsberg kept a 12-volume 12 diary of what he had observed at the Commerce Department? 13 A I invoke my privilege. 14 Q Do you know whether or not you're in that diary? 15 A I invoke my privilege. 16 Q Have you ever discussed that diary with him? 17 A I invoke my privilege. 18 Q Are you aware that classified information is 19 contained in that diary? 20 A I invoke my privilege. 21 Q Are you aware that he took that diary out of the 22 Commerce Department without authorization? 23 A I invoke my privilege. 24 Q Did you work with William Ginsberg in compromising 25 U.S. national security? 266 1 A I invoke my privilege. 2 Q Did he participate in any way in the trade missions 3 to China or otherwise? 4 A I invoke my privilege. 5 Q Have you had any conversations with Mr. Ginsberg 6 since October 29, 1996? 7 A I invoke my privilege. 8 JUDGE FACCIOLA: The invocation of the privilege is 9 sustained in each instance. 10 BY MR. KLAYMAN: 11 Q Do you know Marvin Rosen? 12 A I invoke my privilege. 13 JUDGE FACCIOLA: Sustained. 14 BY MR. KLAYMAN: 15 Q Have you had any conversations with Marvin Rosen 16 since October 29, 1996? 17 A I invoke my privilege. 18 Q Do you know whether your lawyers have been in 19 contact with lawyers for Marvin Rosen? 20 A I invoke my privilege. 21 Q Whether they've been in contact with Marvin Rosen? 22 A I invoke my privilege. 23 Q Do you know whether Marvin Rosen has been offered a 24 pardon by the President of the United States if necessary? 25 A I invoke my privilege. 267 1 Q Have you ever been in a meeting with Marina 2 Braswell, other than in this deposition that we've been 3 conducting in the last few weeks? 4 MR. COBB: Can we confer on this? 5 JUDGE FACCIOLA: Certainly. 6 MR. COBB: Thanks. 7 JUDGE FACCIOLA: With me or just with your client? 8 MR. COBB: Just with our client. 9 JUDGE FACCIOLA: Please. 10 THE VIDEOGRAPHER: We're going off video record 11 at 4:31. 12 (A brief recess was taken.) 13 THE VIDEOGRAPHER: We're back on video record 14 at 4:35. 15 MR. COBB: You may answer the question. 16 THE WITNESS: No. 17 BY MR. KLAYMAN: 18 Q No to what? 19 A Your question was -- 20 MR. COBB: Had he ever met with Ms. Braswell. 21 MR. KLAYMAN: Oh, okay. 22 THE WITNESS: Other than this time. 23 BY MR. KLAYMAN: 24 Q Other than here? 25 A Mm-hmm. 268 1 Q Have you met with anyone at the Justice Department 2 about this case? Outside of at this deposition. 3 MR. COBB: Asked, answered, invoked and sustained. 4 JUDGE FACCIOLA: Sustained. 5 THE WITNESS: I invoke my privilege. 6 MR. KLAYMAN: Showing you Exhibit 33, your diary 7 again -- 8 I'm just going ask very limited questions here, 9 Your Honor, in light of your instruction. 10 THE WITNESS: It's 33 or 34? 11 MR. KLAYMAN: 33. 12 THE WITNESS: Okay. 13 BY MR. KLAYMAN: 14 Q At 12:00 p.m. on April 27th, you had a meeting with 15 Hoyt Zia. 16 MS. BRASWELL: Objection, Your Honor. We seem to 17 be right back where we were. 18 JUDGE FACCIOLA: Let's see what he can do. 19 THE WITNESS: It's April 30th. 20 MR. COBB: I'm sorry, what date? April 30th? 21 THE WITNESS: Mm-hmm. 22 MR. KLAYMAN: I'm just using it as a reference 23 point. 24 BY MR. KLAYMAN: 25 Q Did you have meetings with Mr. Zia to discuss 269 1 specific export licenses of high technology to China? 2 A I invoke my privilege. 3 Q And did you make it clear to Mr. Zia that certain 4 export licenses were to be granted because the companies 5 requesting them had made large contributions to the 6 Democratic Party and/or Clinton-Gore campaigns? 7 A I invoke my privilege. 8 Q Was one of those companies Loral Corporation? 9 A I invoke my privilege. 10 JUDGE FACCIOLA: The invocation of the privilege is 11 sustained. 12 BY MR. KLAYMAN: 13 Q Lockheed Martin? 14 A I invoke my privilege. 15 Q Mr. Huang, during the period of 1994 through 1996, 16 you took 61 trips to the White House. Were any of those 17 trips related to your activities at the Commerce Department? 18 A I invoke my privilege. 19 Q And did you discuss anything with regard to 20 Commerce Department trade missions when you were at the White 21 House? 22 A I invoke my privilege. 23 JUDGE FACCIOLA: Sustained. 24 BY MR. KLAYMAN: 25 Q Did any meetings take place where individuals that 270 1 you can remember were present where matters concerning the 2 Commerce Department and trade missions were discussed? 3 A I invoke my privilege. 4 Q During that same period, you took six trips to the 5 People's Republic of China, correct? 6 A I invoke my privilege. 7 Q And when you went to the People's Republic of 8 China, did you carry classified information that you had 9 obtained from the Commerce Department? 10 A I invoke my privilege. 11 Q Did you discuss in China any matters related to 12 your work at the Commerce Department? 13 A I invoke my privilege. 14 JUDGE FACCIOLA: Sustained in each instance. 15 BY MR. KLAYMAN: 16 Q Did you discuss in China any matters related to the 17 trade missions to China? 18 A I invoke my privilege. 19 Q You were provided names by Terry McAuliffe, were 20 you not, of donors to take on Commerce Department trade 21 missions to China and otherwise? 22 A I invoke my privilege. 23 JUDGE FACCIOLA: Sustained. 24 BY MR. KLAYMAN: 25 Q You do know Terry McAuliffe very well, don't you? 271 1 A I invoke my privilege. 2 JUDGE FACCIOLA: Sustained. 3 BY MR. KLAYMAN: 4 Q When you left the Commerce Department, you took 5 documents with you to the Democratic National Committee, 6 correct? 7 A I invoke my privilege. 8 JUDGE FACCIOLA: Sustained. 9 BY MR. KLAYMAN: 10 Q Where did you store those documents at the 11 Democratic National Committee? 12 A I invoke my privilege. 13 JUDGE FACCIOLA: Sustained. 14 BY MR. KLAYMAN: 15 Q Where are those documents today? 16 A I invoke my privilege. 17 JUDGE FACCIOLA: Sustained. 18 BY MR. KLAYMAN: 19 Q You know a Sam Newman of the Democratic National 20 Committee, correct? 21 A I invoke my privilege. 22 Q And he kept notes of his various meetings with you, 23 correct? 24 A I invoke my privilege. 25 Q Where are those notes today? 272 1 A I invoke my privilege. 2 JUDGE FACCIOLA: Sustained. 3 BY MR. KLAYMAN: 4 Q Have you had any contact with any surviving members 5 of the Brown family after the tragic accident that involved 6 Secretary Brown on April 3, 1996? 7 A I invoke my privilege. 8 JUDGE FACCIOLA: Sustained. 9 MR. KLAYMAN: I'll show you what I'll ask the court 10 reporter to mark as the next exhibit. 11 THE COURT REPORTER: 67. 12 (Huang Deposition Exhibit No. 67 13 was marked for identification.) 14 BY MR. KLAYMAN: 15 Q Did you ever have contact, Mr. Huang, with a 16 Cassidy & Associates when you were at the Commerce 17 Department? 18 A Mr. Klayman, I invoke my privilege. 19 Q Did you ever have contact with Cassidy & Associates 20 concerning Ron Brown? 21 A I invoke my privilege. 22 JUDGE FACCIOLA: Sustained. 23 BY MR. KLAYMAN: 24 Q Has the Government Reform Committee subpoenaed your 25 documents? 273 1 A I invoke my privilege. 2 JUDGE FACCIOLA: Sustained. 3 BY MR. KLAYMAN: 4 Q Have you turned over any documents to the 5 Government Reform Committee? 6 A I invoke my privilege. 7 JUDGE FACCIOLA: Sustained. 8 MR. KLAYMAN: Your Honor, one thing we didn't get 9 into the last time is that the Fifth Amendment really doesn't 10 apply to documents. 11 JUDGE FACCIOLA: That would be a great shock to the 12 Court of Appeals in their recent decision in United States v. 13 Hubbell. They went on for 37 pages and talked about it. 14 MR. KLAYMAN: Well, they blew it. 15 JUDGE FACCIOLA: Concededly. Who knows. 16 Actually, the Boyd case, it's very interesting, the 17 Boyd case was decided in 1908 and actually connects the 18 Fourth Amendment to the Fifth Amendment and describes them as 19 coterminous in their application and said that requiring a 20 person to produce his own personal papers was simultaneously 21 a violation of both. 22 That line of authority never gathered historically 23 in terms of the Fourth Amendment, but there was a time in 24 American history when both amendments seemed to protect a 25 person from the very question, "Is this your diary, are these 274 1 your papers?" Interesting. So the Fifth Amendment does 2 apply to documents unquestionably. 3 MR. KLAYMAN: Well, it's an issue that we want to 4 revisit. I just wanted to raise that with you. 5 JUDGE FACCIOLA: Okay. 6 BY MR. KLAYMAN: 7 Q Have you had conversations or have your lawyers had 8 conversations with members of the Government Reform 9 Committee? 10 MR. COBB: And I object on attorney-client 11 privilege as well. 12 JUDGE FACCIOLA: Sustained. 13 BY MR. KLAYMAN: 14 Q I'll just ask if you've ever seen this document 15 before, Exhibit 67. 16 A I invoke my privilege. 17 JUDGE FACCIOLA: Sustained. 18 BY MR. KLAYMAN: 19 Q Mr. Huang, did you ever it said when you were 20 at the Commerce Department that you weren't -- do you 21 have any knowledge as to whether or not Secretary Ron 22 Brown felt comfortable in having you at the Commerce 23 Department? 24 A I invoke my privilege. 25 JUDGE FACCIOLA: Sustained. 275 1 BY MR. KLAYMAN: 2 Q Had you ever heard it said at the Commerce 3 Department that you were a member of the Arkansas crowd? 4 A I invoke my privilege. 5 Q And Secretary Brown was not of the Arkansas crowd? 6 A I invoke my privilege. 7 Q Is it correct that the Arkansas crowd includes the 8 President, the First Lady, Harold Ickes, Bruce Lindsey and 9 Mickey Kantor? 10 MS. BRASWELL: Objection. Scope. 11 JUDGE FACCIOLA: Yes. Sustained. 12 THE WITNESS: I invoke my privilege. 13 JUDGE FACCIOLA: Well, you don't have to. I have 14 sustained it on the grounds of scope. 15 MR. KLAYMAN: I'll show you what I'll ask the court 16 reporter to mark as Exhibit -- 17 THE COURT REPORTER: 68. 18 MR. KLAYMAN: -- 68. 19 (Huang Deposition Exhibit No. 68 20 was marked for identification.) 21 BY MR. KLAYMAN: 22 Q You've seen 68 before, haven't you, Mr. Huang? 23 A February 10, 1995 memorandum? 24 A I invoke my privilege. 25 Q In responding to Judicial Watch's Freedom of 276 1 Information Act requests, did you actually see those 2 Freedom of Information Act requests before you looked for 3 documents? 4 A I invoke my privilege. 5 Q Did you ever look for documents in response to 6 those Freedom of Information Act requests? 7 A I invoke my privilege. 8 Q Do you know of anyone who did? 9 A I invoke my privilege. 10 JUDGE FACCIOLA: The invocation of the privilege is 11 sustained in each instance. 12 BY MR. KLAYMAN: 13 Q Did you withhold documents that should have been 14 produced to Judicial Watch pursuant to its Freedom of 15 Information Act request? 16 A I invoke my privilege. 17 Q Do you know of anyone who did? 18 A I invoke my privilege. 19 JUDGE FACCIOLA: The invocation of the privilege is 20 sustained. 21 BY MR. KLAYMAN: 22 Q Do you know whether at the time of his death 23 Ron Brown had any documents in his office that referred to 24 related in any way to you or your activities at the Commerce 25 Department? 277 1 A I invoke my privilege. 2 JUDGE FACCIOLA: Sustained. 3 BY MR. KLAYMAN: 4 Q Do you know whether or not those documents were 5 destroyed after he died? 6 MR. COBB: Objection. Scope. Documents with 7 regard to Mr. Huang? 8 JUDGE FACCIOLA: Documents in general. 9 THE WITNESS: I invoke my privilege. 10 JUDGE FACCIOLA: Sustained. 11 BY MR. KLAYMAN: 12 Q Prior to your deposition on October 29, 1996, on 13 October 20, 1996, Senator Chris Dodd and chairman of the 14 Democratic Party offered to make you available to the press 15 to answer questions. Later, he reneged. 16 Do you know why he reneged? 17 MS. BRASWELL: Objection. Scope. 18 MR. COBB: Objection. Scope. 19 JUDGE FACCIOLA: Sustained. 20 MR. KLAYMAN: Your Honor, in all due respect, just 21 because we hear theatrics here from Ms. Braswell -- 22 JUDGE FACCIOLA: She just said the word objection. 23 MR. KLAYMAN: No, it's a legitimate question. We 24 were seeking to get his deposition at that time. 25 JUDGE FACCIOLA: Rephrase your question, let me 278 1 hear it again. Let me see if we can work something out here. 2 BY MR. KLAYMAN: 3 Q Was Chairman Chris Dodd's reneging on making you 4 available to the press related to your upcoming deposition to 5 Judicial Watch? It's a little narrower. 6 A I invoke my privilege. 7 BY MR. KLAYMAN: 8 Q Do you know why that was reneged? 9 A I invoke my privilege. 10 JUDGE FACCIOLA: Sustained. 11 BY MR. KLAYMAN: 12 Q During that period, on or about October 24, 1996, 13 this Court asked the General Counsel of the Democratic 14 National Committee, Joseph Sandler, to come to court 15 voluntarily. He did not come voluntarily until the 16 judge ordered the marshals to go get him. 17 Do you know why he did not come voluntarily? 18 A I invoke my privilege. 19 Q Does Mr. Sandler have knowledge about your 20 activities at the Commerce Department relating to trade 21 missions and receipt of classified information and what went 22 on on trade missions? 23 A I invoke my privilege. 24 JUDGE FACCIOLA: Sustained. 25 279 1 BY MR. KLAYMAN: 2 Q Does anyone at the Democratic National Committee 3 have information about this? 4 A I invoke my privilege. 5 JUDGE FACCIOLA: Sustained. 6 BY MR. KLAYMAN: 7 Q Was there a file prepared at the Democratic 8 National Committee about your activities at the Commerce 9 Department when you were there? 10 A I invoke my privilege. 11 JUDGE FACCIOLA: Sustained. 12 BY MR. KLAYMAN: 13 Q Did you solicit funds from a My, M-y, R-h-u Ahn, 14 A-h-n, of Penn Metal while you were at the Commerce 15 Department? 16 A I invoke my privilege. 17 JUDGE FACCIOLA: Sustained. 18 BY MR. KLAYMAN: 19 Q And when I say solicit funds, I mean campaign 20 contributions. 21 A I invoke my privilege. 22 Q Did you solicit campaign contributions from the 23 Kenneth Winn, President of Lippo Land, when you were at the 24 Commerce Department? 25 A I invoke my privilege. 280 1 JUDGE FACCIOLA: Sustained. 2 BY MR. KLAYMAN: 3 Q During the time that you were at the Commerce 4 Department, did you participate in arranging for and 5 implementing a fundraiser which took place on November 2, 6 1995 for the Clinton-Gore campaign or the Democratic Party? 7 A I invoke my privilege. 8 JUDGE FACCIOLA: Sustained. 9 BY MR. KLAYMAN: 10 Q During the time that you were at the Commerce 11 Department, did you solicit campaign contributions from 12 Pauline Kanchanalak, who was of the U.S. Thai Business 13 Council? 14 A I invoke my privilege. 15 JUDGE FACCIOLA: Sustained. 16 BY MR. KLAYMAN: 17 Q During the time that you were at the Commerce 18 Department, did you tell anyone at the Democratic National 19 Committee to list contributions which you had generated from 20 donors under your wife's name? 21 A I invoke my privilege. 22 JUDGE FACCIOLA: Sustained. 23 BY MR. KLAYMAN: 24 Q During the time that you were at the Commerce 25 Department, did you have any contact with David Mercer of 281 1 the Democratic National Committee? 2 A I invoke my privilege. 3 JUDGE FACCIOLA: Sustained. 4 BY MR. KLAYMAN: 5 Q During the time that were you at the Commerce 6 Department, did you engage in any political fundraising that 7 involved in any way Arief, A-r-i-e-f, and Sonya, S-o-n-y-a, 8 W-i-r-i-a-d-i-n-a-t-a? 9 A I invoke my privilege. 10 JUDGE FACCIOLA: Sustained. 11 BY MR. KLAYMAN: 12 Q Have you ever discussed with Ginger Lew the 13 circumstances behind the removal by Ira Sockowitz of 14 satellite encryptions and CIA reports from the Commerce 15 Department? 16 A I invoke my privilege. 17 Q Have you ever discussed that with anybody? 18 A I invoke my privilege. 19 JUDGE FACCIOLA: The invocation of the privilege is 20 sustained. 21 MR. KLAYMAN: Your Honor, I may have asked this 22 question, but just to be sure because it's important -- 23 BY MR. KLAYMAN: 24 Q Did Ms. Melinda Yee ever tell you she was going to 25 destroy notes that she took on the China trade missions? 282 1 A I invoke my privilege. 2 JUDGE FACCIOLA: Sustained. 3 BY MR. KLAYMAN: 4 Q Since October 29, 1996, have you had contact of any 5 kind with anyone from Iridium Corporation? 6 A I invoke my privilege. 7 Q Globalstar? 8 A I invoke my privilege. 9 Q Microsoft? 10 A I invoke my privilege. 11 JUDGE FACCIOLA: Sustained in each instance. 12 BY MR. KLAYMAN: 13 Q During the time that you were at the Commerce 14 Department, did you ever visit President Clinton in the White 15 House to discuss China or Asia policy and fundraising at the 16 Democratic National Committee? 17 A I invoke my privilege. 18 JUDGE FACCIOLA: Sustained. 19 BY MR. KLAYMAN: 20 Q Or fundraising at the Democratic National 21 Committee? 22 A I invoke my privilege. 23 JUDGE FACCIOLA: Sustained. 24 BY MR. KLAYMAN: 25 Q Did you ever attend a meeting at the White House 283 1 where President Clinton, one or more of the Riadys, Bruce 2 Lindsey and Joseph Giroir were present? 3 A I invoke my privilege. 4 JUDGE FACCIOLA: Sustained. 5 MR. KLAYMAN: For the purposes of speed, 6 Your Honor, I'm just going to mark this as the next exhibit. 7 I think it was previously marked at the first deposition 8 session. 9 THE COURT REPORTER: 69. 10 (Huang Deposition Exhibit No. 69 11 was marked for identification.) 12 BY MR. KLAYMAN: 13 Q This is the document inventory of documents taken 14 by one Ira Sockowitz out of the Commerce Department, 15 classified documents, taken to the Small Business 16 Administration, where at the time Ginger Lew worked. 17 And I'll ask you, Mr. Huang, please review this 18 list of documents and tell me whether you have any 19 information of any kind about any of these documents. 20 A I invoke my privilege. 21 JUDGE FACCIOLA: Sustained. 22 BY MR. KLAYMAN: 23 Q Do you have any of these documents in your 24 possession? 25 A I invoke my privilege. 284 1 JUDGE FACCIOLA: Sustained. 2 BY MR. KLAYMAN: 3 Q Do you know whether anyone other than the Small 4 Business Administration and Judge Lamberth, these documents 5 have been impounded, have possession of copies of the 6 documents? 7 A I invoke my privilege. 8 JUDGE FACCIOLA: Sustained. 9 BY MR. KLAYMAN: 10 Q Did you see the recent reports over the weekend in 11 the New York Times that classified nuclear information in the 12 form of CIA reports was compromised with regard to Russia, 13 India and China? 14 MS. BRASWELL: Objection. Scope. 15 MR. COBB: Scope. 16 MR. KLAYMAN: Just a foundation, Your Honor. 17 JUDGE FACCIOLA: Overruled. 18 Did you read anything in the newspaper this week 19 about this business of the man at Los Alamos giving secrets 20 to the -- 21 THE WITNESS: Your Honor, I believe Mr. Klayman 22 mentioned the New York Times, right? 23 MR. KLAYMAN: Yes. 24 THE WITNESS: I did not. 25 285 1 BY MR. KLAYMAN: 2 Q You didn't read that? 3 A No. 4 Q Is there anything in particular with regard to 5 China, India and Russia, which also forms the countries which 6 Mr. Sockowitz took CIA reports about, that was of particular 7 interest to you, the Riadys or the Lippos? 8 A I invoke my privilege. 9 JUDGE FACCIOLA: Sustained. 10 BY MR. KLAYMAN: 11 Q Were those countries of particular interest to 12 agents of the government of China? 13 A I invoke my privilege. 14 Q Were they of particular interest to companies which 15 went on the trade mission to China in the fall of '94? 16 A I invoke my privilege. 17 JUDGE FACCIOLA: Sustained. 18 BY MR. KLAYMAN: 19 Q Were you arrested by the Immigration and 20 Naturalization Service in 1992? 21 MS. BRASWELL: Objection. 22 THE WITNESS: I invoke my privilege. 23 JUDGE FACCIOLA: Sustained. 24 BY MR. KLAYMAN: 25 Q 1972. I'm sorry. 286 1 A I invoke my privilege. 2 JUDGE FACCIOLA: Sustained. The invocation of the 3 privilege is sustained. 4 BY MR. KLAYMAN: 5 Q Was that related to your providing false 6 information to the INS? 7 A I invoke my privilege. 8 JUDGE FACCIOLA: Sustained. 9 BY MR. KLAYMAN: 10 Q Have you ever been convicted of a crime? 11 A I invoke my privilege. 12 JUDGE FACCIOLA: Sustained. 13 BY MR. KLAYMAN: 14 Q Have you ever been reimbursed for contributions you 15 made to any political party? 16 A I invoke my privilege. 17 JUDGE FACCIOLA: Sustained. 18 BY MR. KLAYMAN: 19 Q Do you have any knowledge as to whether or not 20 there were ever discussions at the Democratic National 21 Committee to claim government services in the form of seats 22 on trade missions as offsets in terms of reporting to the 23 Federal Election Commission? 24 A I invoke my privilege. 25 JUDGE FACCIOLA: Sustained. 287 1 BY MR. KLAYMAN: 2 Q Have you ever been contacted by the Federal 3 Election Commission with regard to the issue of the sale of 4 seats on trade missions? 5 A I invoke my privilege. 6 Q Do you know of anyone who has? 7 A I invoke my privilege. 8 JUDGE FACCIOLA: Sustained in both instances. 9 BY MR. KLAYMAN: 10 Q Have you ever discussed the sale of seats on trade 11 missions at the Commerce Department with Mac McLarty? 12 A I invoke my privilege. 13 Q Have you ever discussed your activities at the 14 Commerce Department with Mac McLarty? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: Sustained. 17 BY MR. KLAYMAN: 18 Q Did you attend the funeral of Ron Brown? 19 MR. KEENEY: You can answer that. 20 THE WITNESS: Yes, I did. 21 BY MR. KLAYMAN: 22 Q Did you discuss -- 23 THE WITNESS: I think we need to clarify. The 24 service for the funeral, in the church, the service, I did. 25 Yes. 288 1 BY MR. KLAYMAN: 2 Q Did you discuss at that time Secretary Brown's 3 activities with regard to foreign trade missions with anyone? 4 A I invoke my privilege. 5 JUDGE FACCIOLA: Sustained. 6 BY MR. KLAYMAN: 7 Q Do you know a Ms. Green that worked at Stephens 8 Inc.? 9 A I invoke my privilege. 10 Q Did she help you send Commerce Department documents 11 by fax machine? 12 A I invoke my privilege. 13 JUDGE FACCIOLA: Sustained. 14 BY MR. KLAYMAN: 15 Q Did you use the fax machine at Stephens Inc. when 16 you worked at the Commerce Department? 17 A I invoke my privilege. 18 Q Was there a fax log that recorded the facsimile 19 transmissions at Stephens? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: Sustained. 22 BY MR. KLAYMAN: 23 Q Do you know whether Stephens Inc. is a publicly 24 traded corporation? 25 MS. BRASWELL: Objection. 289 1 JUDGE FACCIOLA: Overruled. 2 MR. KEENEY: You can answer that. 3 JUDGE FACCIOLA: Do you know? 4 THE WITNESS: Your Honor, I don't believe it's 5 publicly traded. 6 JUDGE FACCIOLA: That's fine. You answered the 7 question. Thank you, Mr. Huang. 8 BY MR. KLAYMAN: 9 Q Do you own any portion of Stephens Inc.? 10 JUDGE FACCIOLA: Consult with your client. 11 MR. KEENEY: You can answer that. 12 THE WITNESS: No, I don't. 13 BY MR. KLAYMAN: 14 Q Do the Riadys? 15 A I don't know. 16 MR. KLAYMAN: I'll show you what I'll ask the court 17 reporter to mark as the next exhibit. 18 THE COURT REPORTER: 70. 19 (Huang Deposition Exhibit No. 70 20 was marked for identification.) 21 BY MR. KLAYMAN: 22 Q Is this Exhibit 70 an accurate or reasonably 23 accurate depiction of the offices that Stephens Inc. across 24 the street from the Commerce Department that you visited when 25 you worked at the Commerce Department? 290 1 MS. BRASWELL: Objection. 2 JUDGE FACCIOLA: Do you invoke the privilege? 3 THE WITNESS: I invoke my privilege. 4 JUDGE FACCIOLA: Sustained. 5 MR. COBB: Your Honor, if I might, in light of the 6 hour, I would respectfully move to terminate the deposition 7 without prejudice. 8 JUDGE FACCIOLA: Well, let's see where we are. 9 How much longer do you think you have? 10 MR. KLAYMAN: I don't have that much more. 11 MR. COBB: Okay. 12 JUDGE FACCIOLA: Okay. Five-thirty, you think? 13 Okay? 14 MR. KLAYMAN: Yes, I think I can do it. 15 JUDGE FACCIOLA: Great. Let's do it. 16 MR. COBB: Thank you, Your Honor. 17 MR. KLAYMAN: I'll show you what I'll ask the court 18 reporter to mark as Exhibit 71. 19 (Huang Deposition Exhibit No. 71 20 was marked for identification.) 21 BY MR. KLAYMAN: 22 Q Mr. Huang, is Exhibit 71, which is John Huang's 23 offices at Commerce and Stephens Inc., a reasonable accurate 24 depiction of the proximity of Stephens Inc.'s offices to the 25 Commerce Department? 291 1 A On advice of counsel, I invoke my privilege. 2 JUDGE FACCIOLA: Sustained. 3 BY MR. KLAYMAN: 4 Q During the time that you were at the Commerce 5 Department, did you receive national security briefings on 6 four generic areas: one CIA briefings? 7 A I invoke my privilege. 8 JUDGE FACCIOLA: Sustained. 9 BY MR. KLAYMAN: 10 Q CIA material shared by others? 11 A I invoke my privilege. 12 JUDGE FACCIOLA: Sustained. 13 BY MR. KLAYMAN: 14 Q Classified State Department cables on foreign 15 economic and political matters? 16 A I invoke my privilege. 17 Q And information that is otherwise confidential? 18 A I invoke my privilege. 19 Q Did you ever see documents provided to you by John 20 Dickerson which had the designation MEM DISSEM? 21 MS. BRASWELL: Objection. 22 MR. COBB: Two objections. 23 JUDGE FACCIOLA: Is the witness going to assert the 24 privilege? 25 MR. COBB: Without invoking the privilege, I think 292 1 it calls for classified information. 2 MS. BRASWELL: Yes. That was the basis of my 3 objection. 4 MR. KLAYMAN: No, that's a designation. 5 JUDGE FACCIOLA: Well, is he going to invoke the 6 privilege? 7 MR. COBB: Yes, he will. 8 THE WITNESS: Yes, sir. I will invoke the 9 privilege. 10 JUDGE FACCIOLA: The invocation of the privilege i 11 sustained. 12 MR. KLAYMAN: That's just the designation, that's 13 not the information. 14 JUDGE FACCIOLA: Sustained. 15 BY MR. KLAYMAN: 16 Q It has been reported that the Thompson Committee 17 provided a list of ten types of major intelligence items 18 which you received, Mr. Huang, at the Commerce Department, 19 every one of which would be of intense interest to Lippo, 20 Stephens Inc. or the Chinese government. 21 Did those ten areas include business opportunities 22 in Vietnam? 23 A I invoke my privilege. 24 JUDGE FACCIOLA: Sustained. 25 293 1 BY MR. KLAYMAN: 2 Q Economic issues confronting Taiwan and China? 3 A I invoke my privilege. 4 JUDGE FACCIOLA: Sustained. 5 BY MR. KLAYMAN: 6 Q Investment opportunities in China? 7 A I invoke my privilege. 8 JUDGE FACCIOLA: Sustained. 9 BY MR. KLAYMAN: 10 Q The North Korean food shortage? 11 A I invoke my privilege. 12 JUDGE FACCIOLA: Sustained. 13 BY MR. KLAYMAN: 14 Q Succession of power in China? 15 A I invoke my privilege. 16 Q China technology transfers? 17 A I invoke my privilege. 18 Q The nuclear power industry in Asia? 19 A I invoke my privilege. 20 Q Investments in the Chinese auto industry? 21 A I invoke my privilege. 22 Q Investment climate in Hong Kong? 23 A I invoke my privilege. 24 Q Chinese government influence on investment in China 25 and Taiwan? 294 1 A I invoke my privilege. 2 JUDGE FACCIOLA: The invocation of the privilege is 3 sustained in each instance. 4 A I invoke my privilege. 5 BY MR. KLAYMAN: 6 Q Did you ever provide any of your own analysis on 7 these issues to John Dickerson or others at the Commerce 8 Department? 9 A I invoke my privilege. 10 JUDGE FACCIOLA: Sustained. 11 BY MR. KLAYMAN: 12 Q You are aware, are you not, that the Chinese 13 military during the period you were at the Commerce 14 Department placed a priority on obtaining American encryption 15 technology? 16 A I invoke my privilege. 17 JUDGE FACCIOLA: Sustained. 18 BY MR. KLAYMAN: 19 Q On the morning of October 4, 1994, you were briefed 20 for the first time by John Dickerson, correct? 21 A I invoke my privilege. 22 JUDGE FACCIOLA: Sustained. 23 BY MR. KLAYMAN: 24 Q And late that afternoon you sent a fax from 25 Stephens Inc. to Lippo Ltd. in Hong Kong, correct? 295 1 A I invoke my privilege. 2 JUDGE FACCIOLA: Sustained. 3 BY MR. KLAYMAN: 4 Q The next afternoon, October 5th, a fax was sent 5 from Stephens to LippoBank in Jakarta, correct? 6 A I invoke my privilege. 7 Q And on at least two other occasions after you 8 received security briefings at the Commerce Department, faxes 9 were sent by you from Stephens Inc. to Lippo entities, 10 correct? 11 A I invoke my privilege. 12 JUDGE FACCIOLA: Sustained. 13 BY MR. KLAYMAN: 14 Q Did you ever submit expense account records showing 15 that you visited the Indonesian embassy on October 11, 1995, 16 claiming a $5.00 reimbursement for taxicab fare? 17 A I invoke my privilege. 18 Q And these same expense records indicate that 19 you did not return to your office at the Commerce 20 Department until the following day when you took another 21 $5.00, not from the Indonesian embassy but, according to 22 your own records, from the residence of the Chinese 23 ambassador? 24 A I invoke my privilege. 25 JUDGE FACCIOLA: Sustained. 296 1 BY MR. KLAYMAN: 2 Q During the period after your deposition on 3 October 29, 1996, did anyone ever contact you on behalf of 4 Vice President Gore and ask you to be quiet? 5 A I invoke my privilege. 6 JUDGE FACCIOLA: Sustained. 7 BY MR. KLAYMAN: 8 Q Has anyone ever told you that if you talked you 9 could jeopardize Mr. Gore's chances for election to the 10 presidency in the year 2000? 11 A I invoke my privilege. 12 JUDGE FACCIOLA: Sustained. 13 BY MR. KLAYMAN: 14 Q Do you know a Ted Sioeng, S-i-o-e-n-g? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: Sustained. 17 BY MR. KLAYMAN: 18 Q Did he have any involvement in your activities at 19 the Commerce Department with regard to trade missions to 20 China or anywhere else? 21 A I invoke my privilege. 22 JUDGE FACCIOLA: Sustained. 23 BY MR. KLAYMAN: 24 Q Do you know a Nina Wang, W-a-n-g? 25 A What's the spelling of the last name? 297 1 Q W-a-n-g, 2 A I invoke my privilege. 3 JUDGE FACCIOLA: Sustained. 4 BY MR. KLAYMAN: 5 Q Did you participate in any way in having Nina Wang 6 donate $50,000 towards refurbishing President Clinton's 7 boyhood home in Hope, Arkansas while you were an official at 8 the Department of Commerce? 9 MS. BRASWELL: Objection. 10 THE WITNESS: I invoke my privilege. 11 JUDGE FACCIOLA: Sustained. 12 BY MR. KLAYMAN: 13 Q Is Ted Sioeng an agent of the government of China? 14 A I invoke my privilege. 15 Q During the time that you were at the Commerce 16 Department and participating in trade missions, are you aware 17 that Ng Lap Seng showed up on a trade mission to China in the 18 fall of 1994? 19 A I invoke my privilege. 20 Q During the time that you were with the Commerce 21 Department, did you assist Mr. Ng Lap Seng and/or Charlie 22 Trie in laundering Communist Chinese money into the United 23 States into the accounts of the Democratic Party and/or the 24 Clinton Gore campaign? 25 A I invoke my privilege. 298 1 JUDGE FACCIOLA: Sustained. 2 BY MR. KLAYMAN: 3 Q Same question with regard to money laundering by Ng 4 Lap Seng and/or Charlie Trie into the Clintons' legal defense 5 fund. 6 A I invoke my privilege. 7 Q Are you aware that China Resources, China Travel 8 Service and China Ocean Shipping Company, otherwise known as 9 COSCO, are all known to be associated with Chinese 10 intelligence operations? 11 A I invoke my privilege. 12 JUDGE FACCIOLA: Sustained. 13 BY MR. KLAYMAN: 14 Q During the time that you were at the Commerce 15 Department, you had contact with one or more of those 16 companies, did you not? 17 A I invoke my privilege. 18 JUDGE FACCIOLA: Sustained. 19 BY MR. KLAYMAN: 20 Q Are you aware that in the 1991 and 1992 election 21 cycle Bernard Schwartz personally donated only $12,500 for 22 the Clinton-Gore campaigns? 23 MS. BRASWELL: Objection. 24 THE WITNESS: I invoke my privilege. 25 JUDGE FACCIOLA: Sustained. 299 1 BY MR. KLAYMAN: 2 Q Are you aware that in the period that followed 3 thereafter from 1992 to 1996 that Mr. Schwartz donated well 4 over a million dollars personally? 5 A I invoke my privilege. 6 JUDGE FACCIOLA: Sustained. 7 BY MR. KLAYMAN: 8 Q Did you ever discuss his personal donations with 9 him to the Democratic Party? 10 A I invoke my privilege. 11 Q Did you ever meet Dick Morris? 12 A I invoke my privilege. 13 Q Did you ever discuss raising money to support Dick 14 Morris' advertising campaign during the 1996 election cycle? 15 MS. BRASWELL: Objection. 16 THE WITNESS: I invoke my privilege. 17 JUDGE FACCIOLA: Sustained. 18 BY MR. KLAYMAN: 19 Q Did you ever discuss with Dick Morris using the 20 sale of seats on Commerce Department trade missions to raise 21 the money for his advertising campaign for the 1996 election 22 cycle. 23 MS. BRASWELL: Objection. 24 THE WITNESS: I invoke my privilege. 25 JUDGE FACCIOLA: Sustained. 300 1 BY MR. KLAYMAN: 2 Q Have you ever worked for the People's Liberation 3 Army? 4 A I invoke my privilege. 5 Q Have you done anything by or on behalf of the 6 People's Liberation Army? 7 MS. BRASWELL: Objection. 8 THE WITNESS: I invoke my privilege. 9 JUDGE FACCIOLA: Sustained. 10 BY MR. KLAYMAN: 11 Q You are aware that Sandy Berger led the charge to 12 repeal export controls on the export of satellites to China? 13 MS. BRASWELL: Objection. 14 THE WITNESS: I invoke my privilege. 15 JUDGE FACCIOLA: Sustained. 16 BY MR. KLAYMAN: 17 Q And you are aware that Sandy Berger was 18 instrumental in having the authority to approve export 19 licenses transferred from the State and Defense Departments 20 to the Commerce Department? 21 MS. BRASWELL: Objection. 22 THE WITNESS: I invoke my privilege. 23 JUDGE FACCIOLA: Sustained. 24 BY MR. KLAYMAN: 25 Q Do you know an Ann Hughes? 301 1 A I invoke my privilege. 2 Q Did you ever have a meeting with Ambassador Lee of 3 China? 4 A I invoke my privilege. 5 JUDGE FACCIOLA: Sustained. 6 BY MR. KLAYMAN: 7 Q What was discussed during your meeting on or about 8 May 10, 1995? 9 A I invoke my privilege. 10 JUDGE FACCIOLA: Sustained. 11 BY MR. KLAYMAN: 12 Q Did you discuss trade missions to China and the 13 transfer of high technology to China? 14 A I invoke my privilege. 15 JUDGE FACCIOLA: Sustained. 16 BY MR. KLAYMAN: 17 Q Did you ever discuss with Chinese authorities 18 laundering large amounts of Chinese cash into Clinton-Gore or 19 Democratic Party to be able to have high technology 20 transferred to China? 21 A I invoke my privilege. 22 JUDGE FACCIOLA: Sustained. 23 BY MR. KLAYMAN: 24 Q Does President Clinton speak Chinese? 25 MS. BRASWELL: Objection. 302 1 JUDGE FACCIOLA: Sustained. 2 THE WITNESS: I invoke my privilege. 3 JUDGE FACCIOLA: Sustained. 4 How do you say y'all in Chinese? 5 MR. COBB: Well, there are more of them -- 6 That's all right. Don't answer that. Don't 7 answer. 8 BY MR. KLAYMAN: 9 Q Do you know what the E. Hill Group is, the E. Hill 10 Group? 11 A I invoke my privilege. 12 Q Did you ever hear of an individual by the name of 13 Min Wang, W-a-n-g? 14 A I invoke my privilege. 15 Q Who was he employed for on or about June 5, 1995? 16 A I invoke my privilege. 17 Q At 5:00 p.m. on June 6, 1995, you had a meeting 18 with Manatt, Phelps & Phillips law firm at 1501 M Street, 19 Suite 700, correct? 20 MS. BRASWELL: Objection. We're back to going 21 through the diaries again. 22 MR. KLAYMAN: I'm just getting specific -- 23 THE WITNESS: I invoke my privilege. 24 JUDGE FACCIOLA: All right. Go ahead. Keep going, 25 Mr. Klayman. He's invoked his privilege. I want to hear a 303 1 few more questions so I can rule. 2 BY MR. KLAYMAN: 3 Q Did you meet with Manatt Phelps with regard to 4 Commerce Department trade missions? 5 A I invoke my privilege. 6 JUDGE FACCIOLA: The invocation of the privilege is 7 sustained as to all those questions. 8 BY MR. KLAYMAN: 9 Q Did Mickey Kantor have any involvement in your 10 meeting with Manatt Phelps? 11 A I invoke my privilege. 12 Q Was he present? 13 A I invoke my privilege. 14 Q And what was discussed? 15 A I invoke my privilege. 16 JUDGE FACCIOLA: The invocation of the privilege is 17 sustained. 18 BY MR. KLAYMAN: 19 Q Did you ever discuss Mickey Kantor with agents of 20 China in the context of trade missions to China? 21 A I invoke my privilege. 22 JUDGE FACCIOLA: Sustained. 23 BY MR. KLAYMAN: 24 Q Have you been offered asylum in China, Mr. Huang? 25 MS. BRASWELL: Objection. 304 1 THE WITNESS: I invoke my privilege. 2 JUDGE FACCIOLA: Sustained. 3 BY MR. KLAYMAN: 4 Q Has anyone from the government of China ever urged 5 you to leave the United States? 6 A I invoke my privilege. 7 JUDGE FACCIOLA: Sustained. 8 BY MR. KLAYMAN: 9 Q Have you been in the witness protection program of 10 the U.S. Department of Justice? 11 MS. BRASWELL: Objection. 12 THE WITNESS: I invoke my privilege. 13 JUDGE FACCIOLA: Sustained. 14 BY MR. KLAYMAN: 15 Q Are you currently in the witness protection program 16 of the U.S. Department of Justice? 17 MR. COBB: Actually, I think the Justice Department 18 may not permit those questions. 19 JUDGE FACCIOLA: Yes. I don't think it does 20 either, but we'll sustain it on the basis on of the 21 invocation of the privilege. 22 BY MR. KLAYMAN: 23 Q On August 9, 1995, you attended a reception of the 24 ambassador of Singapore, correct? 25 A I invoke my privilege. 305 1 JUDGE FACCIOLA: Sustained. 2 BY MR. KLAYMAN: 3 Q Did you take to the embassy of Singapore classified 4 information from the Commerce Department concerning trade 5 missions on that day? 6 A I invoke my privilege. 7 JUDGE FACCIOLA: Sustained. 8 BY MR. KLAYMAN: 9 Q Who is Charlie Wang, W-a-n-g? 10 A I invoke my privilege. 11 Q What was his position on or about August 14, 1995? 12 A I invoke my privilege. 13 JUDGE FACCIOLA: Sustained in both instances. 14 BY MR. KLAYMAN: 15 Q On August 30, 1995, you had breakfast with Jonathan 16 Doh, D-o-h. 17 MS. BRASWELL: Objection. 18 BY MR. KLAYMAN: 19 Q Do you know a Jonathan Doh? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: Sustained. 22 BY MR. KLAYMAN: 23 Q What position did he have in and around that time 24 period? 25 A I invoke my privilege. 306 1 JUDGE FACCIOLA: Sustained. 2 BY MR. KLAYMAN: 3 Q Do you know a Mr. Yang Lee, L-e-e? 4 A I invoke my privilege. 5 Q What professional position did he have on or about 6 September 6, 1995? 7 A I invoke my privilege. 8 JUDGE FACCIOLA: Are we all agreed that the 9 references are now being made to the diary? 10 MR. KLAYMAN: Yes. 11 MR. COBB: Yes. 12 MR. KLAYMAN: Well, no -- 13 JUDGE FACCIOLA: That's why I'm sustaining the 14 privilege because, again, if he admits the truth of knowing 15 these people, he's admitting the truth of the entries in the 16 diary and he can't do that under the Fifth Amendment. 17 MR. KLAYMAN: Actually, I'm not referring to 18 the diary, I'm just using that as a guidepost to get their 19 names. 20 JUDGE FACCIOLA: Okay. But you see how you 21 get back to where you started from, because if he answers 22 the question positively then that is evidence of the 23 truth of the diary. That puts us back where we started 24 from. 25 MS. BRASWELL: I might also note that if he's asked 307 1 a question whether he knows an individual and he pleads the 2 Fifth, it seems pointless to ask follow-up questions about 3 what they talked about or anything else. 4 MR. KLAYMAN: Well, I'm closing fast, Ms. Braswell. 5 JUDGE FACCIOLA: That may have been my fault, 6 Ms. Braswell, because I couldn't see from where I'm sitting 7 whether or not Mr. Klayman was looking at the diary. So if 8 he asked the witness did he know Joe Blow, I thought he was 9 looking at that book. 10 MR. KLAYMAN: Well, I'm just -- 11 JUDGE FACCIOLA: So I had to wait for the next 12 question to see what the connection was between knowing Joe 13 Blow and what Joe Blow did. 14 MR. KLAYMAN: Well, the problem is, Your Honor, is 15 that virtually all the names in the diary are also contained 16 in books written on the subject. These are all very well 17 known names. They're legendary at this point. 18 BY MR. KLAYMAN: 19 Q Did you ever meet with Westinghouse executives? 20 A I invoke my privilege. 21 JUDGE FACCIOLA: Sustained. 22 BY MR. KLAYMAN: 23 Q What was discussed with them? 24 A I invoke my privilege. 25 JUDGE FACCIOLA: Sustained. 308 1 BY MR. KLAYMAN: 2 Q Did you ever meet with the Chinese delegation in 3 September of '95? 4 A I invoke my privilege. 5 Q A Vice Governor Zong Min? 6 A I invoke my privilege. 7 Q What was discussed with him? 8 A I invoke my privilege. 9 Q Did you pass classified information of the Commerce 10 Department to the Chinese delegation at that time? 11 A I invoke my privilege. 12 JUDGE FACCIOLA: Sustained in each instance. 13 BY MR. KLAYMAN: 14 Q On September 27th, if I can be indulged on this 15 one, Your Honor, of 1995, there was a reception of the 16 Asian-Pacific-American appointees. Did you attend that? 17 A I invoke my privilege. 18 JUDGE FACCIOLA: Sustained. 19 BY MR. KLAYMAN: 20 Q During the time that you were at the Commerce 21 Department, did you participate in recommending 22 Asian-Pacific-American appointees to the Clinton 23 Administration? 24 MS. BRASWELL: Objection. 25 THE WITNESS: I invoke my privilege. 309 1 JUDGE FACCIOLA: Sustained. 2 BY MR. KLAYMAN: 3 Q Was a basis to be recommended if you're an 4 Asian-Pacific-American appointee to make campaign 5 contributions to the Democratic Party or Clinton-Gore 6 campaigns? 7 A I invoke my privilege. 8 JUDGE FACCIOLA: Sustained. 9 BY MR. KLAYMAN: 10 Q Did you recommend any Asian-Pacific-American 11 appointees to the Clinton administration while you were at 12 the Department of Commerce? 13 MR. COBB: Asked, answered, invoked and sustained. 14 JUDGE FACCIOLA: The invocation of the privilege is 15 sustained. 16 MR. KLAYMAN: Thank you, Judge. 17 BY MR. KLAYMAN: 18 Q Did you ever recommend appointees to the Clinton 19 administration of the Asian-Pacific-American community while 20 you were at the Democratic National Committee? 21 A I invoke my privilege. 22 JUDGE FACCIOLA: Sustained. 23 BY MR. KLAYMAN: 24 Q Do you know a Min Zhou Wenzang, W-e-n-z-h-a-n-g? 25 MR. COBB: Is this one of the legendary names? 310 1 MR. KLAYMAN: They're all legendary. 2 THE WITNESS: I invoke my privilege. 3 JUDGE FACCIOLA: Okay. Your next question, 4 Mr. Klayman? 5 BY MR. KLAYMAN: 6 Q Did you ever attend a meeting on October 18, 1995 7 of the Asian-Pacific-American Bar Association, a Capitol Hill 8 reception? 9 MS. BRASWELL: Objection. 10 THE WITNESS: I invoke my privilege. 11 JUDGE FACCIOLA: Sustained. 12 BY MR. KLAYMAN: 13 Q On that same date, you had lunch with Congressman 14 Matsui, did you not? 15 A I invoke my privilege. 16 Q And he provided to you names of donors to take on 17 Commerce Department trade missions? 18 A I invoke my privilege. 19 JUDGE FACCIOLA: Sustained. 20 BY MR. KLAYMAN: 21 Q On October 19th, you had a meeting with Hoyt Zia, 22 correct? 23 A I invoke my privilege. 24 Q And later you had a meeting with Boeing 25 Corporation, correct? 311 1 A I invoke my privilege. 2 JUDGE FACCIOLA: Sustained. 3 BY MR. KLAYMAN: 4 Q Was your meeting with Zia with regard to 5 transferring technology of Boeing Corporation to the Chinese? 6 A I invoke my privilege. 7 JUDGE FACCIOLA: Sustained. 8 BY MR. KLAYMAN: 9 Q On October 25, 1995, you attended a dinner at the 10 Chinese embassy, correct? 11 A I invoke my privilege. 12 JUDGE FACCIOLA: Sustained. 13 BY MR. KLAYMAN: 14 Q Did you take classified documents to the Chinese 15 embassy from the Commerce Department that night? 16 A I invoke my privilege. 17 Q Did you provide them to the Chinese? 18 A I invoke my privilege. 19 Q And did you stay overnight at the Chinese embassy 20 that night 21 A I invoke my privilege. 22 JUDGE FACCIOLA: The invocation of the privilege is 23 sustained in each instance. 24 BY MR. KLAYMAN: 25 Q Did Chuck Meissner ever tell you that he feared 312 1 for his own safety? 2 A I invoke my privilege. 3 MR. KEENEY: You can answer that. 4 THE WITNESS: No. No, Mr. Klayman. 5 MR. KLAYMAN: I'll show you what I'll ask the court 6 reporter to mark as the next exhibit. 7 THE COURT REPORTER: 72. 8 (Huang Deposition Exhibit No. 72 9 was marked for identification.) 10 BY MR. KLAYMAN: 11 Q This is a photocopy of a photograph of you and Vice 12 President Gore and the Wiriadinatas, correct? 13 A I invoke my privilege. 14 JUDGE FACCIOLA: Sustained. 15 BY MR. KLAYMAN: 16 Q And this photograph was taken during the time that 17 you worked for the Commerce Department, correct? 18 A I invoke my privilege. 19 Q That's the top page. Look at the second page. Is 20 that a photograph of Chairman Don Fowler of the Democratic 21 Party with the Wiriadinatas and Mr. James Riady? 22 A I invoke my privilege. 23 Q And the last photograph is a picture of you shaking 24 hands with Vice President Gore, correct? 25 A I invoke my privilege. 313 1 Q And all these pictures were taken during the period 2 you worked at the Commerce Department. 3 A I invoke my privilege. 4 Q Mr. Huang, do you know of anybody that would have 5 information concerning the issue of whether or not seats on 6 trade missions at the Commerce Department were offered in 7 exchange for campaign contributions? 8 A I invoke my privilege. 9 JUDGE FACCIOLA: Sustained. 10 BY MR. KLAYMAN: 11 Q Did you send e-mails when you were at the Commerce 12 Department? 13 A I invoke my privilege. 14 JUDGE FACCIOLA: Sustained. 15 BY MR. KLAYMAN: 16 Q Do you know of anyone who did that worked on the 17 trade missions? 18 A I invoke my privilege. 19 JUDGE FACCIOLA: Sustained. 20 MR. KLAYMAN: We're closing, Your Honor. Just a 21 few more questions. 22 (Pause.) 23 BY MR. KLAYMAN: 24 Q Did you ever have any discussions in 1996 up to the 25 present with anyone from the Democratic National Committee 314 1 where they asked you not to reveal that seats on Commerce 2 Department trade missions were being offered for campaign 3 contributions to the Democratic Party? 4 A I invoke my privilege. 5 JUDGE FACCIOLA: The invocation of the privilege is 6 sustained. 7 BY MR. KLAYMAN: 8 Q Were you ever asked by Chairman Fowler or Chairman 9 Dodd any questions about whether or not you had information 10 that seats on Commerce Department trade missions were being 11 offered in exchange for campaign contributions? 12 A I invoke my privilege. 13 JUDGE FACCIOLA: Sustained. 14 BY MR. KLAYMAN: 15 Q Were you ever asked that by anyone at the 16 Democratic National Committee? 17 A I invoke my privilege. 18 JUDGE FACCIOLA: Sustained. 19 BY MR. KLAYMAN: 20 Q Do you know whether the Democratic National 21 Committee destroyed documents which evidence the sale or 22 offering of seats on trade missions for political campaign 23 contributions? 24 A I invoke my privilege. 25 JUDGE FACCIOLA: Sustained. 315 1 MR. KLAYMAN: I have no further questions, 2 Your Honor. 3 JUDGE FACCIOLA: Thank you very much, Mr. Klayman. 4 MR. KLAYMAN: Thank you, Your Honor. 5 JUDGE FACCIOLA: Thank you, everyone. Good night. 6 MR. COBB: Your Honor, could I respectfully request 7 that before we adjourn that we set a briefing schedule in 8 connection with your contemplated show cause order? 9 JUDGE FACCIOLA: Sure. 10 MR. COBB: And could I request further that 11 Your Honor not issue the order until 48 hours after receipt 12 of the transcript? Because I would like to direct 13 Your Honor's attention to portions of the transcript with the 14 hope that Your Honor might reconsider. 15 JUDGE FACCIOLA: Certainly. Thank you. 16 MR. COBB: And to the extent that Your Honor does 17 even after reconsideration elect to issue that, that we have 18 five days to -- 19 JUDGE FACCIOLA: Yes. Well, let's discuss that in 20 terms of kind of where we are. I was thinking about that 21 today. 22 As you know, Mr. Klayman has taken an appeal of my 23 original determination that the privilege was not waived and 24 subsists. 25 MS. BRASWELL: He has? 316 1 MR. KLAYMAN: I haven't filed anything with the 2 Court as of this time. 3 JUDGE FACCIOLA: I'm sorry. I am mistaken. But if 4 he were to take such appeal -- 5 MR. KLAYMAN: But we are diligently -- I'm sorry, 6 Your Honor. 7 JUDGE FACCIOLA: If he were to take such an appeal, 8 it would seem to me I would defer any direction to you to 9 show cause until Judge Lamberth resolved that because then it 10 would seem, if Judge Lamberth said I was in error, then we go 11 back to square one and have to do this all over again, it 12 moots that issue out. Or is that inappropriate? 13 What do you think, Ms. Braswell? 14 MS. BRASWELL: Your Honor, that seems the 15 appropriate way to go. 16 MR. COBB: Yes, I think that makes good sense. So 17 if the appeal would precede the show cause proceeding, that 18 would be fine. 19 MR. KLAYMAN: That sounds fine. 20 JUDGE FACCIOLA: We'll leave an open issue as to 21 whether it is and I'll just have to remember that we'll have 22 to -- 23 MR. KLAYMAN: However, I don't want to get 24 sandbagged with regard to any further claims by Mr. Cobb on 25 behalf of Mr. Huang that a question was posed in a certain 317 1 way that doesn't qualify for your contempt order. 2 JUDGE FACCIOLA: If after 16 hours, Mr. Cobb makes 3 such -- 4 MR. COBB: I also think, Mr. Klayman, if you review 5 the transcript, you will see that I repeatedly and on more 6 than one occasion tried to make it plain that I think you've 7 adequately made a record and that I'm willing to waive all 8 technical objections -- 9 JUDGE FACCIOLA: All right. Well, let's do it that 10 way and then we'll get back to it, all right? If you will 11 promise to remind me when it is all over, you will bring it 12 to my attention. 13 Would you make a proposal for your briefing 14 schedule, subject to whatever Judge Lamberth does? 15 MR. KLAYMAN: My only caveat, Your Honor, is I 16 would like to get this issue up in front of Judge Lamberth as 17 quickly as possible. My understanding is that he will be 18 able to rule on the issue of whether or not Mr. Huang is 19 subject to contempt by virtue of not answering these 20 questions. 21 MR. COBB: Well, that's a different issue than the 22 issue you would be currently in a position to appeal. 23 MR. KLAYMAN: It's my understanding you already 24 make a ruling -- 25 JUDGE FACCIOLA: I've ruled that the witness has a 318 1 Fifth Amendment privilege and it wasn't waived and that we 2 are obliged to go through it, as we did, on a 3 question-by-question basis. 4 MR. COBB: Right. 5 JUDGE FACCIOLA: During the course of the previous 6 deposition, if my memory serves me right, there two instances 7 where I overruled the claim of privilege and the witness 8 persisted in a claim of the privilege. 9 MR. COBB: Only a single instance. 10 JUDGE FACCIOLA: One instance? 11 MS. BRASWELL: I remember only one, Your Honor. 12 JUDGE FACCIOLA: Well, given that it's one 13 instance, maybe it is silly to wait. Should I just simply 14 issue the order to show cause? And you can move to stay it 15 pending Judge Lamberth's decision on the other. Would that 16 make sense? 17 MR. COBB: That would be fine, although, could 18 we -- what I would like is at least five days after receipt 19 of the transcript to brief it. 20 JUDGE FACCIOLA: No question about that. All 21 right. I'll say -- I'll give you an order to show cause why 22 he shouldn't be held in contempt within 10 days of your 23 receipt of the transcript. 24 MR. COBB: Very well. 25 JUDGE FACCIOLA: With the understanding that you 319 1 can of, course move me, or Judge Lamberth or both to postpone 2 that determination pending any appeal. 3 MR. COBB: Very well. 4 JUDGE FACCIOLA: In the meanwhile, Mr. Klayman may 5 take his appeal. 6 MR. COBB: Fine. 7 JUDGE FACCIOLA: All right? 8 MR. COBB: That's fine. 9 JUDGE FACCIOLA: Make sense? 10 MR. KLAYMAN: That's fine, Your Honor. 11 JUDGE FACCIOLA: Good. Well, I want to complement 12 all of you on your professionalism and your civility to each 13 other and your courtesy and your patience. 14 MR. KLAYMAN: Thank you, Your Honor. 15 MR. COBB: Thank you. 16 JUDGE FACCIOLA: You make me proud to be a lawyer. 17 Thank you very much. 18 THE VIDEOGRAPHER: We're going off video record 19 at 5:36 p.m. 20 (Whereupon, at 5:36 p.m., the deposition of 21 JOHN HUANG was adjourned.) 22 * * * * *