1 UNITED STATES DISTRICT COURT FOR THE

EASTERN DISTRICT OF VIRGINIA

3 NOTRA TRULOCK, III, )

)

4 Plaintiff, )

)

5 v. ) Case No. 00-1527-A

)

6 WEN HO LEE, )

)

7 Defendant. )

______________________________)

8 )

NOTRA TRULOCK, III, )

9 )

Plaintiff, )

10 )

)

11 v. ) Case No. 00-1627-A

)

12 CHARLES E. WASHINGTON, et al.,)

)

13 Defendants. )

14 VOLUME II

VIDEOTAPED DEPOSITION OF SYLVIA LEE

15 Suite 1500E

300 Central, Southwest

16 Albuquerque, New Mexico

October 12, 2001

17 1:47 p.m.

18 PURSUANT TO THE FEDERAL RULES OF CIVIL

PROCEDURE, this deposition was:

TAKEN BY: LARRY KLAYMAN

20 ATTORNEY FOR PLAINTIFF

REPORTED BY: Kendra D. Tellez, NM CCR #205

22 P D & O Reporting, Inc.

Suite 1500E

23 300 Central, Southwest

Albuquerque, New Mexico 87102

1 A P P E A R A N C E S

2 For the Plaintiff:

3 JUDICIAL WATCH, INC.

Attorneys at Law

4 Suite 725

501 School Street, Southwest

5 Washington, D.C. 20024

By: Larry Klayman

6 Thomas J. Fitton

John L. Martin

8 For the Defendant Lee:

9 O'NEILL, LYSAGHT & SUN, LLP

Attorneys at Law

10 Suite 700

100 Wilshire Boulevard

11 Santa Monica, California 90401

By: Mr. Brian A. Sun

For the Defendant Vrooman:

LAW OFFICE OF GARY HOWARD SIMPSON

14 Attorneys at law

9505 Kingsley Avenue,

15 Bethesda, Maryland 20814

By: Ms. Alane Tempchine

Also Present: Will Moir (Videographer)

Mr. Anthony J. Coppolino

18 (United States Attorney)

19 Robert S. Sinton

Ms. Natalia Leons

20 Mike Lowe

(Federal Bureau of Investigation)

James E. Green

22 (DOE officer)

1 INDEX

2 SYLVIA LEE

Cont'd by Mr. Klayman 95

SIGNATURE/CORRECTION PAGE 230

CERTIFICATE PAGE 231

EXHIBITS

6 2. December 13, 1989 Memorandum from Vrooman to

Distribution 102

3. August 13, 2001, cover letter with Chapters 6

8 and 7 of Review Team 130

9 4. January 4, 2000, cover letter with unclassified

version of March 7, 1999, interview 152

5. Subpoena 175

6. July 28, 2000, letter to Chang from Holscher 202

7. March 21, 2000, letter to Chang from Sun 211

8. December 10, 1999, Press Release 214

9. Los Alamos Monitor Vrooman article 219

10. September 19, 1999, "For Immediate Release" 220

11. Declaration of Robert Vrooman 221

12. "Wen Ho Lee Information Packet" 226

13. "Memorandum in support of Motion for Discovery

19 of Materials related to Selective Prosecution

20 CERTIFIED QUESTIONS

21 Certified Question 116 17

Certified Question 120 11

22 Certified Question 152 21

Certified Question 177 2

23 Certified area 177 19

Certified Question 183 22

1 MR. VIDEOGRAPHER: Thank you. We're back on

2 the record, beginning with videotape 2. The time is

3 1:47.

4 MR. KLAYMAN: Okay. There's some things that

5 Mr. Sun said that would help clarify things that we

6 could put on the record.

7 MR. SUN: Well, I don't know about what we'll

8 put on the record, but if you were going to -- I think

9 wherever you left off, you were somewhere among

10 questioning about contacts with Mr. Vrooman, and as you

11 pursue that, I think you can clarify things if you

12 choose to pursue that further.

13 MR. KLAYMAN: Okay. Before we went off the

14 record, we were talking about the potential to take

15 your deposition, the mainstay of your deposition. We

16 may be able to start it for a period before you leave,

17 but I want to finish Ms. Lee first -- Mrs. Lee. And

18 you are under the time constraint that you have to

19 leave by noon tomorrow, and I posed some dates during

20 the first week of December.

21 MR. SUN: November, I think.

22 MR. KLAYMAN: November, excuse me, in Los

23 Angeles. And I just want to get your agreement that we

24 can resume your deposition then or start it then.

25 MR. SUN: Well, I can do this: Right now, it

1 looks like I can do it some time this weekend. I just

2 don't know when. At the present time, that Saturday

3 and Sunday is -- is -- I don't have any previous

4 commitment that I'm aware of. I'm going to -- I didn't

5 get ahold of my secretary unfortunately, but I will try

6 to endeavor to do that before the end of the day.

7 Secondly, again -- and as to which day that

8 weekend, I'll have to determine that after checking

9 with my family.

10 MR. KLAYMAN: Well, you can choose which day.

11 I can be flexible on that.

12 MR. SUN: Okay. Thank you.

13 MR. KLAYMAN: But let me just put the dates

14 on the record.

15 MR. SUN: I think it's the 3rd and 4th,

16 somewhere around then.

17 MR. KLAYMAN: That's correct, December 3rd or

18 4th.

19 MR. SUN: November.

20 MR. KLAYMAN: November, I'm sorry.

21 MR. SUN: Fri- -- Saturday or Sunday.

22 MR. KLAYMAN: Saturday or Sunday. So we'll

23 count on that. Okay.

24 MR. SUN: Yeah, at the present time I know of

25 no conflict. I have to check with my office further,

1 but I will keep you apprised. But, yes, that's a

2 weekend we can focus on.

3 MR. KLAYMAN: And if there is a conflict,

4 you'll make yourself available at a reasonable time and

5 place before the close of discovery?

6 MR. SUN: Yes. I think what I indicated was

7 I'm in trial in Las Vegas. There's a possibility I

8 might even suggest that we do the deposition in Las

9 Vegas if for some reason my trial commitments require

10 me to stay in Las Vegas that weekend, but I will work

11 with you to try to give you an appropriate time frame.

12 Assuming there's some time left on my deposition that

13 you're entitled to, then I'll try to work with you on

14 it.

15 MR. KLAYMAN: All right. Well, there will

16 be, because we need to go through Ms. Lee, and we're

17 making no -- excruciating slow process here.

18 MR. SUN: I agree with that.

19 MR. KLAYMAN: Progress, not process.

20 MR. SUN: Okay. Why don't we proceed.

21 MR. KLAYMAN: We can blame the Government for

22 that one.

23 MR. COPPOLINO: It wouldn't be the first time

24 that you blamed us for something.

25 MR. KLAYMAN: No, we have to just blame you.

1 We're in business to blame you. Just a joke.

2 MR. COPPOLINO: I understand.

3 MR. SUN: There are a few things that Mr.

4 Klayman and I can agree on from time to time. Let's

5 proceed.

6 Q. (By Mr. Klayman) Ms. Lee, we were talking

7 about your contacts with the People's Republic of

8 China, and we were talking about your trip. Was it in

9 1986? Correct?

10 A. Yes.

11 MR. SUN: Is there -- is there --

12 Q. All right. Now, at that point, the

13 Government's representatives wanted to take a break,

14 because they wanted to, I think, consult on some other

15 issues. Were there other issues that you were

16 consulting on?

17 MR. COPPOLINO: I don't -- I don't recall.

18 There was no other issue we consulted on than the issue

19 we've already alerted you to the subject matter --

20 MR. KLAYMAN: Okay.

21 MR. COPPOLINO: -- that we described to you

22 is my recollection.

23 MR. SUN: Right.

24 Q. Okay. We were talking about meetings that

25 you had with Robert Vrooman and Mr. Sullivan. Do you

1 remember that?

2 A. (Witness nods head.)

3 Q. Harold Sullivan?

4 A. Yes.

5 Q. And I asked you to explain to me what went on