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From: "Linda Minor" <[EMAIL PROTECTED]>
To: "conspiracy theory research" <[EMAIL PROTECTED]>
Subject: Blumenthal and Michael Ledeen
Date: Thu, 28 Jan 1999 21:39:58 -0600
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from:
http://www.spectator.org/exclusives/98-08-07-ledeen-m.html

The deposition of Michael Ledeen
Deposition notes
The deposition of Barbara Jeanne Ledeen

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

SIDNEY BLUMENTHAL
and
JACQUELINE JORDAN BLUMENTHAL
Plaintiffs


Civil Action
v.
No. 97-01968 (PLF)
MATT DRUDGE and AMERICA ONLINE, INC.
SERVE: Corporation Services Company
Defendants



Pursuant to Notice, the deposition of MICHAEL LEDEEN was taken on Thursday,
July 30th, 1998, commencing at 10:06 a.m., at the law offices of Williams &
Connolly, 725 12th Street, N.W., Washington, D.C., before Richard D. Baker,
Jr., a Notary Public.

Reported by: Richard D. Baker, Jr.

APPEARANCES:
William Alden McDaniel, Jr., Esquire
Jo Bennett Marsh, Esquire
on behalf of the Plaintiffs


Thomas J. Mikula, Esquire
Michael K. Isenman, Esquire
on behalf of Defendant America Online

Manuel S. Klausner, Esquire
on behalf of Defendant Drudge

WITNESS:
Michael Ledeen

EXAMINATION:
By Mr. McDaniel

EXHIBITS:
1 - Subpoena and Notice
2 - Objections of Michael Ledeen to Plaintiffs' Third-Party Subpoena
3 - (Retained by counsel)
4 - Newspaper article
5 - Document entitled Presswatch
6 - Drudge Report retraction


----------------------------------------------------------------------------
----

MICHAEL LEDEEN, called for examination, having been duly sworn to tell the
truth, the whole truth and nothing but the truth, testified as follows:
(Exhibits 1 through 3 premarked.) EXAMINATION BY MR. McDANIEL:

Q:  State your name, please.

A:  Michael Ledeen.

Q:  How old are you, Mr. Ledeen?

A:  I am 56, almost 57.

Q:  What's your date of birth?

A:  August 1st, 1941.

Q:  And your home address?

A:  deleted.

Q:  And your business address?

A:  deleted.

Q:  What position do you occupy there?

A:  I'm resident scholar.

Q:  Would you summarize your educational attainments for me, sir, after high
school?

A:  I have an undergraduate degree from Pamona College and a master's and
doctorate from the University of Wisconsin.

Q:  In what subjects were your master's and doctorate?

A:  History and philosophy.

Q:  What year did you obtain your doctorate degree?

A:  1969 I think.

Q:  Have you ever testified before in a deposition?

A:  Yes, I have.

Q:  On how many occasions?

A:  I don't recall but I was deposed several times during the Iran-Contra.

Q:  Apart from Iran-Contra have you ever testified at any depositions?

A:  No.

Q:  Have you ever testified in a court of law?

A:  I don't believe so.

Q:  You're represented by counsel here today; is that correct?

A:  Yes.

Q:  Mr. Mikula?

A:  Yes.

Q:  And are you paying Mr. Mikula's fees personally?

A:  Yes.

Q:  How much is he charging you an hour?

A:  We haven't, we haven't discussed that in detail.

Q:  Have you discussed whether you would pay him at all?

A:  I have not discussed it with him. I've discussed it with Mr. Woolsey.

Q:  What have you discussed about fees with Mr. Woolsey?

A:  That he will charge me a fee and I will pay it.

Q:  But you haven't discussed what that fee is?

A:  Correct.

Q:  Mr. Ledeen, since you have been deposed before, you understand how these
matters work I take it. I'll ask you a series of questions. If you need to
have them clarified, please let me know and I'll try to do that for you. If
you wish to take a break at any time, let me know that and we'll be glad to
accommodate you.

A:  Thank you.

Q:  How many times were you deposed in matters relating to the Iran-Contra
affair?

A:  I don't recall the exact number. Several times.

Q:  More than ten?

A:  Could be.

Q:  Did you testify in front of a grand jury in connection with the
Iran-Contra matter?

A:  Yes.

Q:  Did you at any time in connection with the Iran-Contra matter assert
your constitutional right not to testify?

A:  No.

Q:  Were you -- did you ever enter into any type of immunity relating to
your testimony in the Iran-Contra matter?

A:  No.

Q:  How many times did you testify before the grand jury?

A:  Just once I believe.

Q:  And you also gave deposition testimony. Was it the deposition testimony
in civil cases?

A:  I'm not sure how to answer that, Mr. McDaniel. I gave several
depositions to the independent counsel and I gave several depositions to
congressional committees.

Q:  Did you give any depositions in cases that were pending in federal or
state court?

A:  No.

Q:  So your testimony in connection with Iran-Contra was, as I understand
it, either before the grand jury or in deposition before the OIC or in a
congressional inquiry?

A:  Yes, to the best of any memory, that's right.

Q:  Have you ever been arrested in your life?

A:  No.

Q:  I take it you've never also been convicted, correct?

A:  Correct.

Q:  Have you ever been the subject of any disciplinary proceedings by any
professional bodies?

A:  No.

Q:  Have you ever been a defendant in a lawsuit?

A:  No.

Q:  Have you ever been a plaintiff in a lawsuit?

A:  Yes.

Q:  When was that?

A:  That was in Italy in the mid-1980s.

Q:  And do you recall what the allegation was that you made in that lawsuit?

A:  I brought criminal libel charges against an Italian magazine.

Q:  Did that case go to trial in Italy?

A:  Yes.

Q:  What was the result?

A:  It was settled.

Q:  Was it settled after the trial was over?

A:  It was settled before the decision was given by the court.

Q:  There had been the taking of testimony but no decision?

A:  Correct.

Q:  Were you the only plaintiff in that case?

A:  Yes.

Q:  Do you recall the name of the case?

A:  No. I'm not sure I ever knew the name of the case.

Q:  What was the name of the magazine against whom you brought these
charges?

A:  L'Espresso.

Q:  And what was the allegation about which you complained or the
publication about which you complained?

A:  L'Espresso had published several articles with false allegations about
me.

Q:  What were those false allegations?

A:  Well, they included the organization of terrorist training camps in
Tuscany.

Q:  Anything else?

A:  I don't remember all the details. It's quite sometime ago.

Q:  Have you ever been barred from entering Italy?

A:  No.

Q:  Have you ever had any restrictions on your travel in Italy placed upon
you at all?

A:  No.

Q:  What did you settle that case for?

A:  L'Espresso paid a sum of money to me, published something which I had
written, paid all court costs and my legal fees and for expenses of my
staying in Rome at the time the settlement was agreed.

Q:  Do you recall what the sum of money was in total that they paid you?

A:  I don't.

Q:  Can you give me a range?

A:  It was, I don't know, it was more than $15,000, less than 50.

Q:  What year was that that the case settled, Mr. Ledeen?

A:  I don't recall. It would have been sometime between '87 and '89.

Q:  Do you remember when the publication was made concerning you?

A:  In the early to mid-'80s.

Q:  After you received your Ph.D., what job did you hold?

A:  I was instructor at Washington University in St. Louis, Missouri.

Q:  What years were you there, roughly?

A:  I was there off and on from 1987 -- no, sorry. 1967 to 1973.

Q:  And when you left Washington, where did you go?

A:  I went to Rome.

Q:  Your purpose in going to Rome?

A:  I had been offered a visiting professorship at the University of Rome.

Q:  Were you on a tenure track position at Washington?

A:  Yes.

Q:  Did you attain tenure?

A:  No.

Q:  Why not, do you know?

A:  The department voted not to give me tenure.

Q:  Do you know why?

A:  They did not provide an explanation.

Q:  Did you ever, were you ever accused of plagiarism while you were at
Washington University?

A:  No.

Q:  Have you ever heard any statements to the effect that you were accused
of plagiarism while you were there?

A:  Yes.

Q:  Where have you heard those?

A:  One was in an article by Mr. Blumenthal.

Q:  Was that statement false?

A:  I believe it to have been false.

Q:  Did you tell Mr. Blumenthal it was false?

A:  I don't recall his asking me about it but I wrote a letter to The
Washington Post in which I asserted it was false.

Q:  Let me try my question again, Mr. Ledeen, I'd like you to listen to it
and try to answer it. Did you tell Mr. Blumenthal that the story was false?

A:  I don't recall that he asked me if it was false, Mr. McDaniel.

Q:  I didn't ask you whether he asked you, Mr. Ledeen. If I want that
information I'm capable of asking for it. My question is did you tell Mr.
Blumenthal the story was false, yes or no?

A:  What would you include in tell?

Q:  How do you understand the word tell, Mr. Ledeen?

A:  I wrote a letter to The Washington Post --

Q:  Answer my question, how do you understand the word tell?

A:  Communicating.

Q:  Okay. Did you communicate to Sidney Blumenthal that the story about your
plagiarism was false?

A:  Yes.

Q:  How did you do that?

A:  I wrote a letter to The Washington Post.

Q:  Do you have a copy of that letter?

A:  Yes, I do.

Q:  You brought it with you?

A:  Yes, I did.

Q:  Can I see it, please?

A:  Mr. Mikula has it. (Document tendered.) (Exhibit 4 marked.)

Q:  I'm looking at what's been marked as Exhibit 4 for your deposition, Mr.
Ledeen, which is a photocopy handed me by your counsel which bears a Bates
stamp number M00000015.

MR. McDANIEL: If I might inquire of you, Mr. Mikula, did you apply that
number?

MR. MIKULA: Someone in my office did.

MR. McDANIEL: But it was put on there by attorneys?

MR. MIKULA: That's correct.

MR. McDANIEL: Okay, thank you.

Q:  Do you know the date that this letter appeared, Mr. Ledeen? I don't see
it on the exhibit is why I asked. M-A-R 6, does that mean something?

A:  No. I may have a different copy with a date.

Q:  Okay. (Pause in the proceedings.)

A:  Was this the letter that begins some readers may wonder?

Q:  Yes, sir.

A:  The date I have is March 6th, 1987.

Q:  Thank you. I'll come back to that in a few minutes, Mr. Ledeen. You may
have a chance to read it before I ask you about it if you wish. When you
went to Rome for the visiting professorship, how long were you there?

A:  Until early 1977.

Q:  And what did you do after you left that visiting professorship?

A:  I went to work at the Center for Strategic and International Studies.

Q:  In Washington?

A:  Yes.

Q:  What was your position there?

A:  I was the editor of the Washington Quarterly and I was senior staff
member.

Q:  Did you say senior staff member?

A:  Yes.

Q:  Was there any type of tenure track associated with a visiting
professorship in Rome?

A:  No.

Q:  How long did you work in your position at the Center for Strategic and
International Studies? I think you said you went there in 1977.

A:  Until the spring of 1981.

Q:  What did you do then?

A:  I went to work at the Department of State.

Q:  What was your position at the Department of State?

A:  I was senior advisor to the Secretary of State. Perhaps special advisor.
Special advisor.

Q:  Special advisor. And did you have any substantive area that you were
responsible for in that position?

A:  No. There was no -- it wasn't restricted.

Q:  Was there, as a matter of fact, an area that you concentrated on in that
position?

A:  No, I don't think there was one particular area where I focused my
attention.

Q:  Were there a few areas where you focused your attention?

A:  Yes.

Q:  What were they?

A:  Soviet Union, Central America, terrorism. I would say those are the
three principal areas.

Q:  How long did you remain in that position, special advisor to the
Secretary of State?

A:  I was there until the summer of 1982.

Q:  What did you do then?

A:  I returned to the Center for Strategic and International Studies.

Q:  In what position?

A:  Senior staff.

Q:  How long did you remain at the Center on this second tour?

A:  Until either the winter of 1987 or early 1988.

Q:  What job did you take then?

A:  I then devoted my activities to freelance writing and consulting.

Q:  Did you form a company under which to conduct those activities?

A:  I had formed years before a company.

Q:  What was the name of that company?

A:  ISI Enterprises.

Q:  Is that a corporation?

A:  Yes.

Q:  And do you know where -- is it still in existence?

A:  Yes.

Q:  Where is it incorporated?

A:  It's in Maryland.

Q:  Who are the officers of that company?

A:  Myself and my wife are the two principal officers.

Q:  Are there any other officers?

A:  Yes.

Q:  Who are they?

A:  Stephen Bryen, B-R-Y-E-N.

Q:  What position does he hold in the company?

A:  He's the secretary-treasurer I believe.

Q:  Are there any shareholders in the company other than yourself?

A:  My wife.

Q:  That's it, just the two of you?

A:  Yes.

Q:  Does the company have any employees?

A:  Yes; it has me.

Q:  Anybody else?

A:  No.

Q:  What does Mr. Bryen do, do you know?

A:  Mr. Bryen works with The Jefferson Group in Washington.

Q:  What does he do for The Jefferson Group?

A:  I don't know.

Q:  Has ISI Enterprises ever accepted funds from any outside organizations?

A:  Sure.

Q:  Okay. And can you list them for me?

A:  It's quite a long list.

Q:  Well, over the years what organizations has contributed the most to ISI?

A:  If you permit me, it's not contributions, it's fees for work performed.

Q:  Okay. Well, I don't want to ask that. I want to ask you about
contributions, so your answer would be no then to contributions?

A:  That's correct.

Q:  So you've had clients over the years who have paid you for work you've
done?

A:  Yes.

Q:  And has there been any one client that's predominated, say in the last
five years?

A:  Yes.

Q:  Who is that?

A:  The telecommunications group Stet, S-T-E-T.

Q:  What type of work, I don't want any details, Mr. Ledeen, but what type
of work generally do you do through ISI?

A:  I advise corporations on international business activities.

Q:  Do you do any lobbying?

A:  No. Not presently. I once registered as a lobbyist.

Q:  For what nation?

A:  For the Congo.

Q:  Has ISI had employees in the past other than yourself?

A:  No.

Q:  From your testimony I understand, I think, that beginning in late '87 or
early '88 you devoted your working day to your consulting and writing
activities through ISI; is that correct?

A:  Yes.

Q:  That continued for how long as your primary occupation?

A:  A year or two.

Q:  Then what did you do?

A:  I was invited to become a resident scholar at the American Enterprise
Institute.

Q:  How long have you remained in that position?

A:  I'm still there.

Q:  So you've occupied that position continuously since 1988?

A:  Yes.

Q:  And you have also --

A:  Could be '89. I don't remember exactly.

Q:  But at some point you took on that position, you stayed in it?

A:  Yes, sir.

Q:  You've also continued your work through ISI; is that correct?

A:  That's correct.

Q:  Are you employed full time by the American Enterprise Institute?

A:  Yes.

Q:  So the ISI activities are on the side in addition to that, correct?

A:  Right.

Q:  Do you have any other source of income?

A:  No.

Q:  Do you sit on any boards of directors of any organizations?

A:  Yes.

Q:  What are they please?

A:  I'm a director of Advanced Materials Group.

Q:  Is that a corporation?

A:  That's a corporation in southern California.

Q:  What does it make?

A:  It makes industrial foams.

Q:  Foams or phones?

A:  Foams, F-O-A-M-S.

Q:  All right. Any others?

A:  I'm a director of a public relations firm in South

A: Africa by the name of Baird's, B-A-I-R-D apostrophe S.

Q:  Okay.

A:  And I believe that's it.

Q:  Do you sit on -- are you a remember of any editorial boards of any
publications?

A:  I'm the foreign editor of The American Spectator.

Q:  How long have you been in that position?

A:  I think about three or four years.

Q:  Are you on the editorial boards of any other publication?

A:  No.

Q:  I want to show you, Mr. Ledeen, what's been marked as Exhibit Number 1
to your deposition, a copy of which has been previously given to counsel.
This is a copy of a subpoena, notice of deposition and a schedule to the
notice of deposition that was served upon you in this case; is that correct,
sir?

A:  Yes.

Q:  In response to the subpoena that is Exhibit 1, did you make a search for
certain documents responsive to that subpoena?

A:  Yes, sir.

Q:  And you brought those documents today?

A:  Yes.

Q:  Can I see them, please? (Documents tendered.)

MR. McDANIEL: Why don't we mark that as a collective group if you don't
mind?

MR. MIKULA: Sure. That includes obviously the one we talked about
previously.

MR. McDANIEL: So we're clear, the group -- I have been handed a package of
documents by counsel which contains by my count, appears to contain eleven
documents, counsel. This appears to be -- should this be stapled together?

MR. MIKULA: It should be.

MR. McDANIEL: So it appears to contain 11 documents. We add to that what was
previously marked as Exhibit 4. You produced 12 different documents; is that
correct?

MR. MIKULA: Let me just double check that. (Pause in the proceedings.)

MR. MIKULA: That's right. Just for the record, based upon my conversation
with you, we did not produce certain articles that were written by Mr.
Blumenthal. In addition, based on my conversation with you, I did not ask
Mr. Ledeen and as far as I know Mr. Ledeen did not go through every single
one of his books and magazines to see whether or not there was a mention of
Mr. Blumenthal in any of those things. In addition, there were certain
documents that are maintained by my partner, John Rich, which we're
asserting are privileged by the attorney/client privilege and also protected
by the attorney work product doctrine. Mr. Rich is on vacation at this time
and I'll consult with him upon his return about those conclusions I've
drawn, but we're taking the position they are privileged under
attorney/client and work product documents at this time.

MR. McDANIEL: Any other category of privileged documents?

MR. MIKULA: So far as I know, that's it right now.

MR. McDANIEL: What I ask, counsel, is if you would consult with Mr. Rich and
let me know the type of information specified in Rule 26, which will enable
me to draw a conclusion as to whether we wish to challenge your assertion of
the privilege in that regard.

MR. MIKULA: We will. (Exhibit 5 marked.)

Q:  Let me show you also, Mr. Ledeen, what's been marked as Exhibit 2 to
your deposition, copies of which have previously been given to counsel. This
is a document headed Objections of Michael Ledeen to Plaintiff's Third-Party
Subpoena; is that correct?

A:  Yes.

Q:  This is a document filed on behalf of you by your counsel; is that
correct?

A:  Yes.

Q:  And I'm perfectly happy to have your counsel respond to my inquiries on
this or Mr. Ledeen. However you'd like to do it.

MR. MIKULA: I'm happy to discuss them.

MR. McDANIEL: With regard to paragraph number 1, our agreement is as you
stated it, counsel.

MR. ISENMAN: Could we go off the record one second?

MR. McDANIEL: Sure. (Discussion held off the record.)

MR. McDANIEL: Back on the record. Mr. Mikula, your description with
regard -- of our discussion with regard to paragraph 1 is correct. With
regard to paragraph 2, have any documents been withheld under any of the
other privileges you've mentioned here, journalist shield laws, first
amendment, marital communications or other privileges?

MR. MIKULA: So far as I know, we are not withholding any documents at this
time under those privileges.

MR. McDANIEL: Okay. Have any documents been withheld under paragraph 3 of
the objections?

MR. MIKULA: Well, except insofar as our discussions related to you did not
want copies of Mr. Blumenthal's articles themselves. Beyond that, I do not
know of any other documents that are being withheld at this time.

MR. McDANIEL: All right. How about paragraphs 4 or 5, have any documents
been withheld for any reasons beyond those you've articulated so far?

MR. MIKULA: Again, I'm not aware of any documents that are being withheld
other than those that I mentioned that are in Mr. Rich's files and the
matters we discussed earlier with respect to articles generally written by
Mr. Blumenthal or that might appear in some articles or books in Mr.
Ledeen's possession.

Q:  Mr. Ledeen, are you aware of any documents that you're withholding other
than those in the categories described by your counsel?

A:  No.

Q:  When you received Exhibit 1, which is the subpoena, you reviewed the
categories of documents that are listed there, correct?

A:  Correct.

Q:  So when you, I just want to make sure when you gave that previous answer
it was with the knowledge of the categories of documents that were called
for.

A:  Mr. McDaniel, I think I've provided you with everything that we have.

Q:  Okay.

A:  I mean I've tried to be responsive to the subpoena.

Q:  Thank you. Have you reviewed any documents, Mr. Ledeen, in preparation
for your testimony today?

A:  No, I wouldn't say review. I looked at a lot of documents trying to
respond to the subpoena, looking to see if there was anything in there that
had to do with the various subjects listed on the subpoena, but I haven't
reviewed them, no.

Q:  All right. After you received the subpoena that is Exhibit 1, did you
speak to anybody about it?

A:  Yes.

Q:  To whom?

A:  I spoke to counsel.

Q:  Your current counsel?

A:  Current counsel. I spoke to Bob Bennett. Over time -- do you want to
cover the whole period from the time I received the subpoena until now?

Q:  Yes.

A:  Discussed it with various journalists.

Q:  Who are they?

A:  I spoke to a journalist at Newsweek.

Q:  Who was that?

A:  Mark Hosenbahl, I think it's H-O-S-E-N-B-A-H-L. To The Wall Street
Journal.

Q:  Who did you speak to there?

A:  To Jerry Seib, S-E-I-B, and to David Cloud. I spoke to Rich Lowry,
L-O-W-R-Y, and Kate O'Beirne, O apostrophe B-E-I-R-N-E, at National Review.
I spoke to Bob Tyrell, T-Y-R-E-L-L, at The American Spectator. I will say
that I'm sure that as I go through this list there will be people that I'll
forget since I discussed it with many people. I was called by a journalist
from The New York Observer whose name I don't remember. I discussed it with
Britt Hume, H-U-M-E, at Fox News. With Dan Troy, T-R-O-Y, who is a colleague
at the American Enterprise Institute. With my boss there, Chris DeMuth. I
think those are the basic ones.

Q:  When you met with Mr. Bennett, was that for the purpose of securing
legal advice?

A:  Yes, I asked him to represent me in this matter.

Q:  Okay. What was your purpose in speaking with Mr. Hosenbahl?

A:  To tell him what was going on.

Q:  Why did you want to tell him what was going on?

A:  Because I thought that this was a matter of some public interest.

Q:  What did you tell Mr. Hosenbahl?

A:  I told them that my wife and I had been subpoenaed in this matter.

Q:  Anything else?

A:  I don't remember, Mr. McDaniel.

Q:  Did you express anger that you had been subpoenaed?

A:  I don't recall.

Q:  Did you express concern that this was trampling upon your first
amendment rights?

A:  I don't remember, but I doubt it.

Q:  Did you express concern that Mr. Blumenthal was out of control?

A:  I don't recall.

Q:  Did you express concern that the White House was somehow behind this
subpoena?

A:  I don't think so, no.

Q:  Was it just you and Mr. Hosenbahl in that call?

A:  Yes, I think so.

Q:  What did Mr. Hosenbahl say to you?

A:  He asked me to keep him informed if anything further happened.

Q:  Did you send him a copy of the subpoena?

A:  I may have.

Q:  What was your purpose in speaking to Mr. Seib and Mr. Cloud at the
Journal?

A:  The same.

Q:  Did you speak to them together, that is was it one conversation with the
two of them?

A:  No. Serially.

Q:  What did you tell Mr. Seib in addition or different than what you told
Mr. Hosenbahl?

A:  Well, I may have had, in fact I surely had some conversations after I
spoke to Mr. Bennett, and in the ones I had after I spoke to Mr. Bennett I
would have included Mr. Bennett's informing me that you had said to him that
I would be put on hold and you would just go after the wife.

Q:  Okay. And did you tell the reporters from The Wall Street Journal that
this proved that this was just a baseless fishing expedition, the fact you'd
been put on hold?

A:  Combined with the earlier statement from Mr. Bennett that you said you
had evidence that I was the source, I suggested.

Q:  You suggested what?

A:  I suggested that it was incoherent to say at one moment that I was the
source and then, when I denied it, say subsequently well, we'll put him on
hold and just go after the wife.

Q:  Well, you didn't deny just that you were the source, Mr. Ledeen, you
denied you had any relevant knowledge about this matter, didn't you?

A:  I denied that I had any involvement in this matter.

Q:  Try to answer my question as I put it to you, sir.

MR. MIKULA: Excuse me, counsel. Are you asking about communications between
him and Mr. Bennett or between him and one of the reporters?

MR. McDANIEL: I'm asking about right now whether he has ever denied to
anybody after receiving this subpoena that he had any relevant knowledge
about this case.

MR. MIKULA: To the extent that you're asking about counsel, communications
with counsel, we would contend they are privileged unless the privilege was
waived.

MR. McDANIEL: I think it was waived when he authorized Mr. Bennett to
communicate that to me. I don't think the privilege covers communications to
a lawyer made for the purposes of passing those communications on to a third
party.

MR. MIKULA: Are you representing to me that Mr. Bennett communicated to you
that there were communications between him and Mr. Bennett, between Mr.
Ledeen and Mr. Bennett?

MR. McDANIEL: Let me see if I can ask the question.

MR. MIKULA: Okay.

Q:  Did you convey to Mr. Bennett information that you wanted him to convey
to me?

A:  No.

Q:  Did you tell Mr. Bennett anything that you understood he was going to
convey to me? You should be careful to answer yes or no here because there
are privilege concerns, and these questions call for yes or no answers. Did
you give information to Mr. Bennett that you understood he would give to me?

A:  No.

Q:  Did you understand Mr. Bennett was going to call me?

A:  Yes.

Q:  Did you understand that Mr. Bennett was going to tell me that you had no
relevant knowledge about this case?

A:  No.

Q:  Did you understand that Mr. Bennett was going to tell me anything when
he called me?

A:  Yes.

Q:  What did you understand Mr. Bennett was going to tell me when he called
me on your behalf?

MR. McDANIEL: Wait a minute. Your counsel shows signs of thinking about
this.

MR. MIKULA: Yeah. Okay, fine, ask him the question.

Q:  Go ahead.

A:  Could you ask it again?

MR. McDANIEL: Read it back, please. (The reporter read the record as
requested.)

A:  That I had no involvements in this case.

Q:  Anything else?

A:  That I knew nothing about the origin of the story in this case.

Q:  Anything else?

A:  No, sir, I don't think so.

Q:  Okay. And do you believe Mr. Bennett called me and told me that?

A:  Yes.

Q:  And did Mr. Bennett report back on what I said to you?

A:  Yes.

Q:  And what he reported back on what I said to you was what you described a
few minutes ago about putting you on hold and so forth, correct?

A:  Yes, putting me on hold and just going after the wife.

Q:  Then you had a talk after that with Mr. Seib?

A:  Yes.

Q:  And in which you described to Mr. Seib, I think as you put it, how this
was an incoherent stance taken by me, correct?

A:  Yes.

Q:  And then you proceeded to tell Mr. Seib how you had a conversation with
Mr. Drudge immediately after the story had appeared, correct?

A:  I think this was with Mr. Cloud.

Q:  You did describe to Mr. Cloud you had a conversation with Mr. Drudge
immediately after the story appeared, correct?

A:  After the story appeared.

Q:  Right. And you described your conversation with Drudge about Mr.
Blumenthal, didn't you?

A:  I did.

Q:  And did that make you think that you did have some knowledge or
involvement in the issues of this case?

A:  No.

Q:  You still don't think you do?

A:  No, I don't.

Q:  You don't see how your conversation with Mr. Drudge about the story and
about Mr. Blumenthal has any relevance to this case?

MR. MIKULA: Objection to the extent you're asking him to give a legal
conclusion.

Q:  You don't see any logical relationship between what Mr. Drudge told you
on the phone and the issues in this case?

A:  That's what I've said.

Q:  Do you think maybe you don't fully appreciate how those facts might
relate to the issues in the case?

A:  It's possible.

Q:  Now, did you call Mr. Hosenbahl or did he call you?

A:  I believe I called him.

Q:  And you called Mr. Seib?

A:  Yes.

Q:  You called Mr. Cloud?

A:  No, Mr. Cloud called me.

Q:  As a result of your call to Seib?

A:  Yes.

Q:  You called Mr. Lowry?

A:  No, Mr. Lowry recalled me.

Q:  Did you call Ms. O'Beirne?

A:  I don't recall.

Q:  Did you call Mr. Tyrell?

A:  Yes.

Q:  Did you call Mr. Hume?

A:  Yes.

Q:  Did you call or initiate the communication with Mr. Troy?

A:  I don't recall.

Q:  Did you call or initiate the communication with Mr. DeMuth?

A:  Yes.

Q:  You were served a subpoena on the 21st of July; is that correct?

A:  What day of the week is that? (Pause in the proceedings.) MR. ISENMAN:
It's a Tuesday.

A:  Yes. Yes, in the evening.

Q:  When did you start making these calls, the next day?

A:  Yes.

MR. MIKULA: Which calls are you speaking about?

MR. McDANIEL: All of the calls I have listed.

Q:  When did you initiate the first call, the next day?

A:  No, the first call was right then and there.

Q:  That evening?

A:  Yes.

Q:  Who did you call?

A:  Mr. Woolsey.

Q:  One of your attorneys?

A:  Yes.

Q:  Other than him, who did you call that first evening?

A:  I don't think we called anyone.

Q:  The next day, though, you made some calls?

A:  Yes.

Q:  Did your wife also make calls?

MR. MIKULA: Objection, to the extent that it would require Mr. Ledeen to
reveal privileged communications.

MR. McDANIEL: I would take this position, that the fact of making a phone
call to a third party is not a confidential communication within the
marriage, within the sanctity of the marital privilege. I don't want to know
what she said to him, I haven't asked that. My question is whether his wife
made calls to third parties that he's aware of.

MR. MIKULA: How is he aware of it?

MR. McDANIEL: I don't know.

MR. MIKULA: Mr. Ledeen -- let me speak with him.

MR. McDANIEL: Off the record. (Discussion held off the record.)

MR. McDANIEL: Back on the record.

MR. MIKULA: Do you remember the question?

THE WITNESS: Yes.

Q:  Did your wife make calls?

A:  Yes.

Q:  And how many did she make?

A:  I don't know.

Q:  She made them over the next several days?

A:  Yes.

Q:  And do you know with whom she spoke?

A:  No.

Q:  In the packet of documents you've given me which have been marked as
Exhibit 5 there's an article which appears at the page which has been Bates
stamped by your counsel as M, I'm not going to give all of the zeros, I'll
just give the digits, 5.

MR. MIKULA: M5?

MR. KLAUSNER: May I ask, I haven't had a chance to see a copy of any of
these exhibits and I would like to have a copy.

MR. MIKULA: I'd like to keep them here so Mr. Ledeen can take a look at
them.

MR. McDANIEL: I'll give him the exhibit because I have a copy of this
article. Mr. Klausner's point is that there's documents being testified
about that he hadn't seen. I think it's a fair point. Perhaps we can take a
break and just have this exhibit copied.

MR. MIKULA: That's fine with me.

THE WITNESS: I'm sure I have it.

MR. McDANIEL: I think Mr. Klausner is entitled to the whole exhibit. MR.
ISENMAN: Why don't we just give him a set?

MR. McDANIEL: We'll go off the record when it's appropriate, counsel. It's
also appropriate that one lawyer speaks for one side and not two or three.

MR. MIKULA: We understand.

MR. McDANIEL: Why don't we take a break and have a copy made? (Recess from
10:55 a.m. to 11:04 a.m.)

MR. McDANIEL: All right, let's go back on the record.

Q:  Mr. Ledeen, while we were off the record we had copies made of what was
Exhibit 5 and I'll hand that copy back to you. On the page which I indicated
earlier, which was Bates number M and several zeros 5, appears a document
with a heading at the top Exclusive - Sid Blumenthal Lashes Out. Do you see
that?

A:  Yes.

Q:  How did this come to be in your files?

A:  It was on a Web page that I look at.

Q:  What Web page is that?

A:  It's called Free Republic dot com.

Q:  Do you know who sponsors or who controls the Free Republic dot com Web
page?

A:  It's a person named Jim Robinson.

Q:  Who is Jim Robinson?

A:  I don't know.

Q:  This article that appears on pages 5 and 6 of Exhibit 5 that you say was
on that Web page, does it come from something called The National Review?

A:  It says so.

Q:  Is it your belief that's where it comes from?

A:  Yes.

Q:  Do you know who wrote this article?

A:  No, I don't.

Q:  Do you know whether it was Mr. Lowry or Ms. O'Beirne of the National
Review with whom you spoke?

A:  I don't know.

Q:  Do you know whether it was either O'Beirne or Lowry, one or the other?

A:  I don't know who wrote it.

Q:  My question is whether you know if it was one of those two people
without knowing which one it was?

A:  I don't know who wrote it. I don't know whether it was one of those two
people or anybody else.

Q:  You see the bottom of the page 5, the bold Lee-Peat type?

A:  Yes.

Q:  You see right above that the last sentence of the article, the section
above reads the Ledeens must now decide whether to cooperate with this,
quote, out of control, close quote, partisan bent on trampling the first
amendment. Did I read that correctly?

A:  You did.

Q:  Is that something you discussed with Mr. Lowry and Ms. O'Beirne, whether
you should cooperate with an out of control partisan?

A:  I don't believe so.

Q:  Do you believe your wife discussed that with them?

MR. MIKULA: Objection.

A:  I don't know.

Q:  But you didn't use that phrase which is in quotes, out of control,
right?

A:  That's correct. I have not used that phrase, and if you will permit the
gratuitous observation, I'm cooperating and I cooperated from the beginning.

Q:  So you don't know what the basis is for the statement that you had to
decide whether to cooperate?

A:  I don't know why whoever wrote this wrote what they wrote.

Q:  Do you know what the basis is for the statement that the Ledeens must
now decide whether to cooperate?

A:  No.

Q:  Now, do you understand the meaning of the word consigliare in Italian?

A:  Yes.

Q:  Do you speak Italian?

A:  Yes.

Q:  Does that word mean a person who is an advisor to an illegal crime
family?

A:  No.

Q:  Does it mean a person who is an advisor to a crime family?

A:  It just means someone who is an advisor.

Q:  That's not the way you used it in your article, though, about the Mafia
and the Clinton White House, is it, Mr. Ledeen?

A:  That's exactly the way I used it.

Q:  You referred to Jewish consigliare that mob members had in the past,
didn't you?

A:  I did.

Q:  And what you meant by Jewish consigliare that advised mobsters was
people that advised Mafia members on how to commit robbery, extortion,
murder and so forth, right? Yes or no, Mr. Ledeen; isn't that what you
meant?

A:  It certainly -- can I give more than a yes or no?

Q:  After you give yes or no you can explain if you wish, but I'd like a yes
or no answer, or you can tell me you can't answer yes or no.

A:  Would you repeat the question?

Q:  Yeah. You wrote an article in which you referred to Jewish consigliare
for Italian mobsters, didn't you?

A:  Well, I don't think that's exactly correct but I wrote about Jewish
consigliare for Mafia dons.

Q:  And what you meant by that were Jewish people who advised Mafia dons on
how to commit crimes, right?

A:  No.

Q:  Isn't that what the Jewish consigliare for Mafia dons were?

A:  No.

Q:  They weren't?

A:  No.

Q:  What did they advise the Mafia dons on then, Mr. Ledeen?

A:  All kinds of things.

Q:  Including how to get away with criminal activity?

A:  Not necessarily.

Q:  But that's included, isn't it, Mr. Ledeen?

A:  I'm not sure. In any event --

Q:  Wait a minute. I don't need filibusters, I just need an answer to my
question.

MR. MIKULA: Mr. McDaniel, he's answering your question.

MR. McDANIEL: Well, I heard him say I'm not sure; that's an answer. Then I
heard in any event, which I didn't ask for.

Q:  You write in this article about the Godfather moving to --

A:  Can I have time out for a second?

THE WITNESS: Could you read me back my answer to his last question?

Q:  Mr. Ledeen, we're going to conduct this deposition the way it's
conducted everywhere else. I'm going to ask you questions. If you want to
consult with your lawyer about that answer and have him ask you some
questions later, you'll have a chance. Right now we're going to proceed just
like we always do.

MR. MIKULA: Mr. McDaniel, he made a request to the court reporter to have
his answer read back so he could understand what answer he gave.

MR. McDANIEL: And if you want to clear that up --

MR. MIKULA: I wish you would accommodate that request.

MR. McDANIEL: If you want to clear that up on cross-examination, Mr. Mikula,
you can do so.

MR. MIKULA: I know I can. He made a request to the court reporter.

MR. McDANIEL: He may have, but the appropriate time to do that is when you
examine him.

Q:  Now, do you understand that the Jewish consigliare that you're referring
to advised, among other things, on how to commit crimes?

A:  No.

Q:  You don't think that was any part of their advice?

MR. KLAUSNER: Asked and answered.

A:  No.

Q:  Okay. Now, in this article you talked about the Mafia movie The
Godfather, correct?

A:  Yes.

Q:  You talked about the books The Godfather, correct?

A:  I don't recall.

Q:  You referred to Mario Puzo in your article, don't you?

A:  I may have, I don't remember.

Q:  And he wrote The Godfather books, correct?

A:  Correct.

Q:  And the consigliare in The Godfather books advised the Mafia dons on how
to commit crimes, don't they, sir?

A:  I don't think so. In any case, that is not the way I used the word.

Q:  You used -- let's look at the article. I think it's contained in the
exhibit in front of you, isn't it, Mr. Ledeen? Do you have that in front of
you as part of Exhibit 5?

A:  I do.

Q:  What page does that appear on on Exhibit 5?

A:  3.

Q:  And the title of this article is Clinton The Chin, correct?

A:  Correct.

Q:  That's a reference to Vincent Giganti (phonetic), who's known as The
Chin, isn't it?

A:  No.

Q:  You know who Vincent Giganti is, don't you, Mr. Ledeen?

A:  I do not.

Q:  Why is this article entitled Clinton The Chin?

A:  I don't know.

Q:  You don't know that there's a notorious mobster in New York that goes by
the nickname The Chin?

A:  I don't.

Q:  You've never heard that before?

A:  I have not.

Q:  You have no understanding of why your article would be called Clinton
The Chin; is that your testimony?

A:  That's correct.

Q:  Now, in this article in paragraph two you refer to the tandem of Francis
Ford Coppola and Mario Puzo. Do you see that?

A:  Yes.

Q:  Francis Ford Coppola, he's the man that directed The Godfather movies,
right?

A:  That's right.

Q:  And Mario Puzo is the man that wrote The Godfather books, correct?

A:  Correct.

Q:  And you compare the Clinton White House to the Corleone family, don't
you?

MR. MIKULA: Mr. McDaniel, would you mind telling me where you're going with
this?

MR. McDANIEL: Ask the witness to leave the room and I'll do so.

MR. MIKULA: Mr. Ledeen, if you would leave the room briefly. (The witness
left the room.)

MR. McDANIEL: Have you read this article?

MR. MIKULA: I've skimmed it.

MR. McDANIEL: Have you read the reference to my client, Mr. Blumenthal?

A: Apparently you don't recall it. Well, there is a reference in there to
him and I would like to use it to establish this witness' bias. I think I'm
entitled to do that.

MR. MIKULA: For what purpose?

MR. McDANIEL: The purpose of impeaching his testimony at the appropriate
time or for other purposes related to his testimony. I'm entitled to
establish his malice and bias.

MR. MIKULA: His knowledge about the subject matter of this lawsuit is quite
limited. We have been here for longer than an hour and we haven't gotten to
that except briefly.

MR. McDANIEL: You may think we haven't but I think we have.

MR. MIKULA: I said except briefly.

MR. McDANIEL: I don't mean except briefly. I think we have gotten to it.

MR. MIKULA: Okay, fair enough.

MR. McDANIEL: I'm entitled to test who he is, find out what his background
is and I'm certainly entitled to inquire as to his attitude in April of this
year about this man who is a plaintiff in this case.

MR. MIKULA: I can understand that, except for the fact that we haven't
gotten to the substantive information except only barely.

MR. McDANIEL: I have given you my proffer. You can instruct him not to
answer, you can walk out, you can do whatever you want to do, but I'd like
to continue the questioning. (The witness returns to the room.)

MR. McDANIEL: Please don't discuss with the witness anything that's been
discussed in here.

MR. KLAUSNER: I wasn't going to.

MR. MIKULA: Excuse me for just one second before we start. (Pause in the
proceedings.)

MR. McDANIEL: What are we doing?

MR. MIKULA: Excuse me, I wanted to consult with counsel for a second.

MR. McDANIEL: You've been out of the room for several minutes. What are we
doing right now?

MR. MIKULA: We're about to reconvene a deposition as soon as I'm finished
consulting with my co-counsel.

MR. McDANIEL: Go ahead and do it.

MR. MIKULA: Okay, thank you. (Pause in the proceedings.)

MR. MIKULA: Okay. Back on the record.

Q:  Mr. Ledeen, when you were out of the room did you consult with anybody
about your testimony?

A:  No.

Q:  Did you discuss your testimony with anybody?

A:  Yes.

Q:  With whom?

A:  With counsel.

Q:  What did you tell him?

MR. MIKULA: Objection. Attorney/client privilege.

MR. McDANIEL: I don't believe it's proper, counsel, for you during the
middle of a deposition while a question is pending to leave the room and
consult with a witness about his testimony.

MR. MIKULA: I did not consult with the witness about any answer to any
question that was pending.

MR. McDANIEL: He just said he discussed his testimony with you. I think
that's highly improper in a deposition for counsel to go out of the room and
discuss testimony with a witness. I can't believe you've done it. Wait a
minute, Mr. Ledeen, don't say anything. I can't believe you've done it, Mr.
Mikula, it's highly improper.

MR. MIKULA: We did not discuss his testimony.

MR. McDANIEL: Well, he just testified under oath that you did.

MR. MIKULA: We did not discuss the substance of any testimony. BY MR.
McDANIEL:

Q:  Mr. Ledeen, did you discuss the substance of your testimony with your
counsel?

A:  I will be happy to tell you what I said to him, Mr. McDaniel. I think it
will probably relieve whatever concerns you have.

Q:  Why don't you answer my question first? Did you discuss the substance of
your testimony with your counsel?

A:  I don't think it lends itself to a yes or no answer since I'm not sure
what discussed means. I will be glad to tell you what it was.

Q:  What was it?

A:  I just said to him by the way, this is not my title and I don't know
what chin refers to.

Q:  Did you discuss anything else?

A:  No, sir.

Q:  Did he tell you anything about your testimony?

A:  No.

Q:  Now, do you bear ill will towards Sidney Blumenthal?

A:  Yes.

Q:  You hate him, don't you?

A:  No, I don't hate him.

Q:  Well, you dislike him intensely; would that be more accurate?

A:  I certainly dislike him.

Q:  You think he's evil, don't you?

A:  I certainly dislike him.

Q:  You think he's evil, don't you, Mr. Ledeen?

A:  I think he has done evil things to me, Mr. McDaniel.

Q:  You think he in general does evil things to many people, don't you?

A:  I don't have a general opinion about what he does to many people.

Q:  You know he's done evil things to people other than you, don't you?

A:  The basis for my feeling about Mr. Blumenthal has to do with what he's
done to me.

MR. McDANIEL: Read my question back, please. (The reporter read the record
as requested.)

Q:  Can you answer that, please?

A:  I have not followed his activities closely enough to be able to answer
that, Mr. McDaniel.

Q:  You have no view one way or the other?

A:  I don't have information on which to make that decision.

Q:  Do you have a view?

A:  I don't have a view since I don't have information.

Q:  All right. But you know he has committed evil acts directed toward you?

A:  Yes.

Q:  And you believe he was inspired by malice and hatred of you when he did
that, don't you?

A:  I'm allergic to ascribing motives to people. I simply know what he did.

Q:  You don't know what his motive was?

A:  No.

Q:  You don't have any opinion about what it was?

A:  That's correct.

Q:  But you know that it was evil, the act was evil, correct?

MR. MIKULA: Objection, asked and answered.

Q:  Go ahead and answer.

MR. MIKULA: Go ahead.

A:  Could you ask that again?

Q:  You know what he did was evil, you just don't know what the motive was,
correct?

A:  Correct.

Q:  And he falsely accused you of plagiarism; is that correct?

A:  He falsely reported that I had been terminated at Washington University
because of accusations of plagiarism.

Q:  What else has he done to harm you?

A:  He made falls statements concerning an article I had written for
Partisan Review. He gave a lopsided and incomplete account of a lawsuit I
was involved in in Italy. He reported uncritically and without checking a
series of accusations that had been made about me in other media. He
co-authored an article in The Washington Post which included accusations
without reporting facts that showed that at least some of the accusations
were false.

Q:  Anything else?

A:  There may be other things.

Q:  And he did all of these things prior to August 1 of 1987, didn't he, Mr.
Ledeen?

A:  I don't know.

Q:  Do you know of any -- isn't it true that each of these things you told
me about were done prior to August of '87?

A:  It could be.

Q:  Could you tell me any that occurred after August '87? I'm sorry, 1997,
they were all before August of '97, correct?

A:  August of '97, yes, yes.

Q:  And as a result of these acts you bear ill will towards Mr. Blumenthal?

A:  Yes.

Q:  And you view Mr. Blumenthal as part of a corrupt White House?

A:  Yes.

Q:  And you view Mr. Blumenthal as part of a group in the White House that
have committed crimes?

A:  Yes.

Q:  And what crimes is it Mr. Blumenthal has committed in the White House in
your view?

A:  The crimes referred to a White House that has committed crimes.

Q:  You wrote in the article about something called the code of silence
among Mafia members; do you recall that?

A:  Yes.

Q:  Omerta, is that how you pronounce it?

A:  Yes.

Q:  You say the omerta depended upon -- let me read what you wrote. For the
code to work effectively, all members must be guilty of serious crimes. Do
you recall writing that?

A:  Yes.

Q:  And you view Mr. Blumenthal as part of the group in the White House
covered by the code of silence, don't you, Mr. Ledeen?

A:  I described him as a consigliare.

Q:  Do you view Mr. Blumenthal as part of the group in the White House who
is covered by omerta or the code of silence?

A:  Yes.

Q:  And so you therefore believe he's guilty of serious crimes; isn't that
right?

A:  Yes.

Q:  And what serious crimes is it Mr. Blumenthal is guilty of in your
judgment?

A:  I believe he's a member of an administration that has committed serious
crimes and he has participated in them.

Q:  What are they?

A:  First and foremost the arming of China.

Q:  What else?

A:  Well, various other activities. That's the greatest, as I have
repeatedly written.

Q:  What are the others?

A:  The failure to advance American national security.

Q:  What else?

A:  I think that's sufficient for the time being.

Q:  Now, are any of those points mentioned in your article, arming of China,
failure to advance American security?

A:  No.

Q:  You do mention the intimidation of witnesses, though, don't you?

A:  I don't know. Where is that?

Q:  Third paragraph, you refer to the spectacular purge of all U.S.
Attorneys culminating with the intimidation of potentially damaging
witnesses, probing journalists and independent counsel Kenneth Starr. Do you
see that? Right before you mention Mr. Blumenthal's name.

A:  Yes.

Q:  And in that same paragraph you also refer to blackmail, extortion, don't
you?

MR. KLAUSNER: Counsel, I have been silent but I would like to object on the
grounds of relevance and inquire if you have a proffer as to how you believe
this relates to the issues in this case.

MR. McDANIEL: I have given the proffer I intend to give. I believe you were
here for it.

MR. KLAUSNER: I heard what you said before. I think that these questions are
abusive and frustration of the proper and legitimate purposes of discovery
and I think they're impinging on the first amendment rights of the witness
and I would like the record to so note.

Q:  You do mention extortion in that paragraph, don't you?

A:  With regard to Don Corleone and his sons.

Q:  But not with regard to Mr. Blumenthal?

A:  I'm just going to let what I wrote speak for itself, Mr. McDaniel.

Q:  Tell me this, Mr. Ledeen: Do you think Mr. Blumenthal, when he assumed
his position at the White House, was unfit for that position? Did you
believe that?

A:  No.

Q:  You thought he was fit for it?

A:  Yes.

Q:  That's because it's a nest of criminals there, correct?

A:  No.

Q:  Why did you think he was fit for it?

A:  I think he's qualified for the job he's doing.

MR. KLAUSNER: Counsel, I'd like to say at this point, since Judge Freeman
has indicated he would be receptive to telephone calls, I think this is
abusive, frankly, and I would like to suggest we try to get Judge Freeman on
the line.

MR. McDANIEL: Go ahead, Mr. Klausner, I'm going to continue with my
questioning. You want to get him on the line, go right ahead.

MR. KLAUSNER: If you don't want to take a break --

MR. McDANIEL: I don't want to take a break.

MR. KLAUSNER: Apparently you don't want to do it. I don't want to miss
his --

MR. MIKULA: Mr. McDaniel, Mr. Klausner represents a party in this lawsuit
and is entitled in my view to suspend the deposition to get Judge Freeman on
the line if he so chooses.

MR. McDANIEL: I don't think he's entitled to suspend it just sort of
willy-nilly when there's no question pending.

MR. KLAUSNER: You have a line of questions, counsel, that you've
indicated --

MR. McDANIEL: I'm ready to move on, Mr. Klausner.

MR. KLAUSNER: You're going to a different subject?

MR. McDANIEL: Yeah. If you'd just sit there and keep your pants on you would
have learned that.

MR. KLAUSNER: I appreciate your being very sensitive to these issues here.

MR. McDANIEL: I don't know what you're talking about, Mr. Klausner.

MR. KLAUSNER: That's fine.

MR. McDANIEL: I don't know what you mean you appreciate me being sensitive
to these issues.

MR. KLAUSNER: You want to move on, that's fine.

MR. McDANIEL: I think I'm entitled to inquire into this witness' writing of
this article for these purposes and I think it's perfectly proper and
perfect impeachment in a court of law. So you can leave or stay as you
choose, Mr. Klausner, but I'm going to continue.

MR. KLAUSNER: You are continuing on this line or a different line?

MR. McDANIEL: Mr. Klausner, I'm going to continue and I'm not going to
answer any more of your questions. You can stay or go.

Q:  Now, Mr. Ledeen, when did you first meet this Matt Drudge?

A:  I never met him.

Q:  When did you first speak to him?

A:  I believe I first spoke to him a day or two after the article about Mr.
Blumenthal appeared.

Q:  Did he call you?

A:  Yes.

Q:  Do you know how he got your phone number?

A:  No.

Q:  You had never in your life spoke to him prior to that day?

A:  I believe that's true.

Q:  Had he spoken to your wife?

A:  No, I don't think he had.

Q:  Did he call to directly talk to you, ask for you when he called?

A:  I think on the occasion that I spoke to him he called to speak to me.

Q:  Did he explain to you why it was he was calling you?

A:  Yes.

Q:  What did he tell you?

A:  He asked me whether I knew anything about the story he'd written about
Mr. Blumenthal and whether I could help him, whether I knew of anybody who
knew anything about it or how he could confirm it or check it.

Q:  Did he explain why he picked you of all the people to call in the United
States to ask that question of?

A:  No.

Q:  Do you have any understanding of why he did pick you of all the people
to call to ask that question?

A:  No.

Q:  Have you ever discussed that with anybody?

A:  No.

Q:  Did you say to Mr. Drudge why are you calling me?

A:  No, I didn't.

Q:  You've never asked that question of anybody, why did Drudge call me that
day?

A:  Well, he had spoken with my wife.

Q:  When?

A:  Either that day or the day before.

Q:  Was that the first time she had ever spoken to him?

A:  Yes.

Q:  Have you ever been the source for any stories that Mr. Drudge has
published?

A:  I don't know, Mr. McDaniel.

Q:  Do you believe that you have been?

A:  No.

Q:  Do you know why Mr. Drudge was calling people in Washington to check out
your veracity as a source?

A:  No.

Q:  Do you know whether he did that?

A:  No.

Q:  Has anyone ever reported to you that Mr. Drudge made phone calls to
check out your veracity as a source?

A:  No.

Q:  Do you know whether your wife has ever been a source for any stories by
Mr. Drudge?

A:  No.

Q:  Do you know why Mr. Drudge made phone calls to check out whether your
wife was reliable as a source?

A:  No.

Q:  Have you ever heard anyone say that Mr. Drudge was checking out your
wife's reliability as a source?

A:  No.

Q:  Have you ever communicated prior to this day, which I believe we'll
agree was in August of last year when Mr. Drudge called you, had you ever
communicated with him before that date by any means other than a voice
conversation?

A:  Yes.

Q:  How?

A:  I sent him an e-mail.

Q:  When did you do that?

A:  I don't recall. Probably some months before.

Q:  What was the contents of the e-mail?

A:  I said that I loved his page and that if he ever came to Washington he
should come have lunch.

Q:  Have you preserved that e-mail?

A:  No.

Q:  Did he reply?

A:  No.

Q:  What else did the e-mail say?

A:  That's it.

Q:  And you just sent that one e-mail on one occasion?

A:  Yes.

Q:  Did you ever communicate with Mr. Drudge prior to the phone call you
described to us in any fashion other than through this one e-mail?

A:  No, sir, not to the best of my memory.

Q:  What was it about his page that you loved, as you put it?

A:  It's enormously useful to anybody who follows news.

Q:  What was it about his page that you loved, Mr. Ledeen?

A:  It gave me access to all kinds of information on the Web just by
clicking from one location rather than going through a long list of separate
links.

Q:  Anything else?

A:  No.

Q:  Now, Mr. Drudge calls you on the phone. Were you at home when he called
you?

A:  Yes.

Q:  Was it in the evening hours?

A:  I think so.

Q:  And it was just the two of you on the phone call as far as you know?

A:  Yes.

Q:  And Mr. Drudge called you and asked you if you had seen his story about
Mr. Blumenthal; is that correct?

A:  Yes.

Q:  Had you seen the story?

A:  Yes.

Q:  And you saw it on Mr. Drudge's Drudge Report Web page?

A:  Yes.

Q:  Had you called that Web page up yourself that contained the story about
Mr. Blumenthal or had it been sent to you by Mr. Drudge?

A:  No, no, I called it up.

Q:  When had you done that?

A:  I don't know. It's my home page.

Q:  Did you read the story that Mr. Drudge put on his Drudge Report about
Mr. Blumenthal?

A:  Yes.

Q:  Did you believe it?

A:  I didn't have an opinion. I'd never heard it before.

Q:  It was the first you'd ever heard of it?

A:  Yes.

Q:  You'd never heard anybody mention a rumor about Mr. Blumenthal beating
his wife, ever?

A:  Never.

Q:  Had you ever heard anything about Mrs. Blumenthal seeking medical or
legal help?

A:  No.

Q:  Had you ever heard anything that clicked in your mind when you saw the
Drudge story that led you to think you had heard something about it in the
past?

A:  No.

Q:  So it was completely out of the blue when you saw it there?

A:  Yes.

Q:  Did you tell that to Mr. Drudge?

A:  He didn't ask that question.

Q:  Did you tell him?

A:  I don't recall. I may have.

Q:  Tell me as best you can recall everything Mr. Drudge said to you in that
conversation and everything you said to him.

A:  He asked me if there were any way to check information of this sort, and
I said that if it were true there should be some record of it someplace,
police complaint, police report, something of that nature. That he could
check wherever it was Mr., wherever the Blumenthals lived, he could talk to
local police and see if there were any record of it. And he said -- he then
asked me what I thought he should do if he concluded, as he was rapidly
concluding, that the story was false, and I said he should retract it and
make a full apology immediately.

Q:  Did he say anything else?

A:  That's my recollection of the conversation, Mr. McDaniel.

Q:  Did Mr. Drudge tell you anything about the sources of his story?

A:  No.

Q:  Did you ask him?

A:  No.

Q:  Did Mr. Drudge tell you that he had not checked any of the information
he had printed about the Blumenthals?

A:  No.

Q:  Did you understand from what he said that he had not checked?

A:  No.

Q:  Did you understand from what he said, is there any way to check
information of this type, did you understand that to mean he hadn't done it
yet?

A:  No.

Q:  You thought maybe he had checked already?

A:  He might have done some checking and was looking for additional ways.

Q:  But he didn't say anything that led you to conclude that one way or
another?

A:  I didn't draw a conclusion from what he said, if that's what you're
asking.

Q:  You didn't conclude one way or the other whether he had previously done
any checking or not?

MR. MIKULA: Objection, asked and answered.

Q:  Right?

A:  Right.

Q:  Now, after you read the Drudge Report about Mr. Blumenthal, did you
discuss it with anybody?

A:  I don't recall but I doubt it, aside from Barbara.

Q:  Your wife?

A:  Yes.

Q:  Did anyone attempt to discuss it with you?

A:  Not that I can remember.

Q:  Did you know when you went to look at the Drudge Report that day that
there was going to be a story about Mr. Blumenthal?

A:  No.

Q:  Did you disseminate the story about Mr. Blumenthal in any way?

A:  No.

Q:  Did you transmit the Drudge Report to anybody else?

A:  No.

Q:  Have you ever, since August of 1997 when you saw the Drudge Report,
repeated that story to anybody?

A:  I don't think so.

Q:  Have you ever transmitted the story in any form to any other person?

A:  I don't think so.

Q:  How long did you and Mr. Drudge speak on this occasion?

A:  A couple of minutes.

Q:  Did Mr. Drudge say anything after you gave him suggestions as to how he
could check some of the information that had been printed in the Drudge
Report?

A:  He may have said something like I think I've been had.

Q:  All right. What was his tone of voice in this telephone conversation,
calm, upset, you couldn't tell one way or another? Could you draw any
conclusions about his tone of voice?

A:  I couldn't. I had no baseline to measure it against. It was my first
conversation.

Q:  Did he say who he thought had him, as he put it?

A:  No.

Q:  Did he say anything further about in what manner he had been had?

A:  No. It was clear enough.

Q:  Clear enough, what do you mean?

A:  That he was -- he had concluded that the story was false.

Q:  And you base that upon what you've related to us so far?

A:  Yes.

Q:  Do you recall anything else that Mr. Drudge told you in this
conversation?

A:  No.

Q:  Did Mr. Drudge speak with your wife at or about the time of his
conversation with you?

A:  I think he spoke to her before he spoke to me.

Q:  Why do you think that?

A:  Because as Barbara and I tried to remember what had happened around the
time of that --

MR. MIKULA: Objection. To the extent that you're being asked to give any
privileged marital communications between the two of you, you're not
required to answer that question.

A:  Right. That's the time sequence that we reconstructed.

Q:  Okay. She didn't speak to him in the same phone call that you spoke to
him?

A:  No, I don't think so.

Q:  Was she present at your end of that phone call?

A:  No.

Q:  Were you present at your wife's end of the phone call when she spoke to
Drudge?

A:  No.

Q:  After this telephone call in August, did you have any further, have you
had since then any further communications with Drudge?

A:  Yes.

Q:  How many?

A:  Perhaps half a dozen.

Q:  And have any of them been in person?

A:  No.

Q:  Have they all been over the telephone?

A:  Yes.

Q:  Have any of them been by e-mail?

A:  Yes.

Q:  So you had e-mail communications with him, you had voice telephone
communications with him?

A:  Yes.

Q:  Any other type of communications?

A:  No.

Q:  Have you preserved any of the e-mails that you either sent or received?

A:  I haven't, although I might be able to, I might be able to find one or
two.

Q:  I think they're called for by the subpoena.

A:  Yes. I have looked and I haven't found any, but I'll continue to look
and if I find any I'll provide them to you.

Q:  Thank you. With regard to the voice communications, you and he spoke on
the telephone I take it?

A:  Yes.

Q:  Was it just the two of you on those calls?

A:  I think so.

Q:  Tell me when the next phone call was after the one you just discussed.

A:  I don't know when it was.

Q:  What can you recall about the next phone call? Well, let me ask you
this, Mr. Ledeen, before you answer. Can you distinguish for me in your
testimony the contents of these other phone calls, we discussed this in this
phone call, discussed that in the next phone call?

A:  Yeah, I could, but what could I say to cover the whole subject is that
we had no subsequent discussions of this matter in phone calls; that
subsequent phone calls dealt with other new stories and he would ask me
whether I thought they were true or false or things of that nature.

Q:  Is that true also of your e-mails, that in none of the e-mails did you
and he communicate about Mr. Blumenthal and the story regarding Blumenthal?

A:  Yes. I don't believe we ever had an e-mail communication on that matter.

Q:  Did you ever have any communication with Mr. Drudge about this lawsuit?

A:  I think we may have had one conversation.

Q:  Tell me about that conversation. What did you say and what did he say?

A:  I don't recall it but I may have said something to him at one point --
and I'm straining here, Mr. McDaniel. I don't have a clear memory of this.

Q:  Fair enough.

A:  But I'm trying to be responsive to your questions. I may have said to
him at one point look, libel suits against public officials are rare --
libel suits by public officials are rare, that indeed when I was a public
official and was inclined to bring libel suits against people, I was
strongly advised not to do it by counsel.

Q:  And what was your point?

A:  My point was that it would be, that it would be tough for a libel suit
to be brought against him, especially since I thought he had behaved well in
apologizing and retracting quickly.

Q:  When did he apologize?

A:  As I recall it, within a couple of days of the story.

Q:  Where did you see the apology?

A:  On the Drudge page.

Q:  Really? You saw on the Drudge page the words I apologize for this?

A:  My recollection is there were words saying I'm sorry, yes.

Q:  You're clear about that? Because I have never seen that page.

A:  Well, I may be wrong, Mr. McDaniel. That's my recollection.

Q:  Did Mr. Drudge ever tell you he had apologized?

A:  No.

Q:  After you made this remark about libel suits being tough, you were
referring to Sidney Blumenthal, weren't you, about public figures?

A:  Yes.

Q:  Were you referring also to Mrs. Blumenthal?

A:  No.

Q:  She's not a public figure in your view, is she?

A:  No.

Q:  She's also a plaintiff, though, isn't she?

MR. KLAUSNER: I object to the question as calling for a legal conclusion.

Q:  She's also a plaintiff in this case; did you understand that?

A:  I was referring to Sidney Blumenthal.

Q:  What did Mr. Drudge say in response to your remarks?

A:  I don't recall.

Q:  Can you recall anything else you and he discussed about the lawsuit?

A:  No.

Q:  In these other telephone conversations you had with Mr. Drudge did you
serve as a source to verify any of the news stories that he was running by
you?

A:  I would not use the word source the way you've used it, but I gave him
my opinion of stories from time to time.

Q:  Tell me what stories you gave him your opinion about.

A:  These would be stories regarding American technology sales to China and
other foreign policy stories.

Q:  What were the other topics?

A:  I don't remember.

Q:  Did you comment on any stories to Mr. Drudge regarding Mr. Blumenthal?

A:  No.

Q:  Regarding Mrs. Blumenthal?

A:  No.

Q:  Did you ever pass on information to Mr. Drudge that other people had
given you to be passed on to him?

A:  No.

Q:  Did you ever refer persons to Mr. Drudge who had information you thought
Mr. Drudge might be interested in?

A:  Not that I can recall.

Q:  Have you ever discussed this lawsuit with anyone other than your lawyers
and Mr. Drudge and your wife? I know you discussed it with your wife as well
because you alluded to that. Putting them aside.

A:  Aside from the people we've already discussed, the journalists, Mr.
Bennett, et cetera?

Q:  Right.

A:  No.

Q:  Since the story about Mr. Blumenthal appeared in the Drudge Report, the
story that's the subject of this lawsuit --

A:  Just a minute. I'd like to go back to that last question.

Q:  Go ahead.

A:  We have had sort of general remarks about the lawsuit with various
friends since people will call up and say sorry to hear you've been
subpoenaed and so forth and we would respond not to worry, we have no
involvement in this matter.

Q:  Since the story appeared in the Drudge Report about Mr. Blumenthal, the
story you read that was the subject of your phone call, have you --

A:  His phone call.

Q:  Okay. The phone call the two of you had. Have you seen those
allegations, the substance of those allegations about Mr. Blumenthal
repeated anywhere else?

A:  No.

Q:  Have you heard anybody repeat the substance of those allegations?

A:  No, I don't think so.

Q:  Have you heard anyone, overheard anyone or heard anyone discussing these
allegations about Sidney?

A:  No.

Q:  How long have you been working in Washington?

A:  Since 1977.

Q:  And you consider yourself a person who has a wide range of professional
and personal connections in the city of Washington?

A:  Not particularly.

Q:  Does your wife have a wide range of personal and professional
connections in Washington?

A:  I wouldn't speak for her.

Q:  I'd like to go back to this list of media with whom you spoke. You say
you spoke with Mr. Seib and I think you told me that you told him the same
thing you told Hosenbahl plus what you'd learned from Bennett, correct?

A:  The substance of what I had to say to The Wall Street Journal was to
David Cloud and that was the same of what I said to Mr. Hosenbahl, including
the conversations between you and Mr. Bennett as I understood them.

Q:  And you also described your phone call with Mr. Drudge; isn't that
correct?

A:  I may have, yeah.

Q:  How about with Mr. Lowry, what was the substance of your communication
with Mr. Lowry?

A:  I don't recall. Generally these were the same conversation.

Q:  Would this be true of the list of people, O'Beirne, Tyrell, the person
from the Observer whose name you can't recall, Hume, Troy and DeMuth?

A:  DeMuth it was much shorter since he's my boss and I wanted to inform him
I had been subpoenaed.

Q:  Have you ever spoken to -- do you know a person named Ted Olsen?

A:  Yes.

Q:  Have you ever spoken to Mr. Olsen about any matter related to Mr.
Blumenthal and these allegations, the lawsuit, the substance of the
allegations, the Drudge Report, anything at all encompassed by those topics?

A:  Yes.

Q:  When did you talk to Mr. Olsen?

A:  We had dinner at Mr. Olsen's house on Saturday night.

Q:  This past Saturday?

A:  Yes.

Q:  Was that the first time you discussed it with him?

A:  I think so.

Q:  Who was present?

A:  Mr. Tyrell and his wife, Mr. Olsen and his wife, Terry Eastland and his
wife. Ted Boutrous and his wife. I think it's B-O-U-T-R-O-U-S, but it may be
B-U-T-R-O-U-S, I don't know. And Tim O'Brien and his wife.

Q:  Is that it?

A:  I'm going around the room. I think that's it.

Q:  Mr. O'Brien, is this the correspondent for ABC?

A:  Yes, I think he is.

Q:  And Mr. Boutrous is a lawyer?

A:  That's correct.

Q:  And he represents The Wall Street Journal?

A:  I don't know about that.

Q:  Do you know who he represents? Do you know any media that Mr. Boutrous
represents?

A:  I think he represents a large number of media.

Q:  Okay. And Terry Eastland, does he work for The American Spectator?

A:  Yes, he's the publisher.

Q:  And Tyrell, he works for The American Spectator?

A:  Yes, he's the editor.

Q:  And Barbara Olsen works with your wife at The Independent Women's Forum?

A:  Yes.

Q:  And what was discussed at this dinner party about this lawsuit or about
these allegations relating to Mr. Blumenthal?

A:  There was no discussion of the allegations with regard to Mr.
Blumenthal.

Q:  What was discussed then?

A:  The fact that we had been subpoenaed.

Q:  Was anything other than the bare fact of your having been subpoenaed
discussed?

A:  No. We discussed ways we might react to that.

Q:  Who is the we you're referring to?

A:  Barbara and I.

Q:  Referring here to your wife?

A:  Yes.

Q:  In what way did you discuss how you might react to the subpoena?

A:  We discussed generally things, how proper would it be to make public
statements on what sorts of circumstances, would it be a good idea, would it
be reasonable for us to ask that the deposition be open to the press for
example.

Q:  What else did you discuss?

A:  I think that was it, that kind of conversation.

Q:  Did anybody at this dinner party on Saturday say anything about having
heard the allegations about Mr. Blumenthal in the past, the spousal abuse
allegation?

MR. MIKULA: Objection, vague.

Q:  Go ahead and answer.

A:  No.

Q:  Did anyone raise any issues at all?

A:  Mr. McDaniel, could I make some simple statement that might save us some
time?

Q:  Go right ahead.

MR. MIKULA: Mr. Ledeen, your job is to answer questions.

Q:  Is there something you want to tell me? Let me ask you a question. Is
there something you want to tell me?

A:  No, I'll just answer your questions.

Q:  Okay. Did Mr. Olsen say that he had been approached by Mr. Drudge to
represent Mr. Drudge in this lawsuit?

A:  Not that I recall.

Q:  Do you know whether Mr. Olsen was so approached?

A:  I don't.

Q:  Do you -- you never referred Mr. Drudge to Mr. Olsen for Mr. Olsen to be
Drudge's lawyer in this case, did you?

A:  I did not.

Q:  Did your wife?

A:  I don't think so, I don't know.

Q:  Do you know of anybody who ever referred Mr. Drudge to Mr. Olsen?

A:  No, I don't.

Q:  Do you know a man named David Horowitz?

A:  Yes.

Q:  Did you refer Mr. Drudge to Mr. Horowitz in any way?

A:  No.

Q:  Do you know anybody who did?

A:  My wife did.

Q:  Do you know why she did that?

MR. MIKULA: Objection to the extent it would require you to reveal anything
that is a privileged marital communication between you and your wife.

A:  I'll let her answer that.

Q:  Do you know that she did that because she told you?

A:  Yes.

Q:  Have you ever talked to Mr. Horowitz about it?

A:  No.

Q:  Have you ever talked to Mr. Horowitz about the allegations regarding Mr.
Blumenthal?

A:  No.

Q:  Have you ever talked to Mr. Horowitz about this lawsuit?

A:  I'm sure I have.

Q:  What have you and he discussed about this lawsuit?

A:  I don't recall.

Q:  Have you ever discussed the allegations about Mr. Blumenthal with Mrs.
Silberman?

A:  No.

Q:  Have you ever discussed the allegations about Mr. Blumenthal with John
Fund?

A:  No.

Q:  Have you ever discussed this lawsuit with Mr. Fund?

A:  No.

Q:  Do you know Mr. Fund?

A:  I do.

Q:  Have you ever had any discussions about Mr. Blumenthal with Mr. Fund?

A:  I don't think I have.

Q:  Have you ever been present when such discussions occurred when Mr. Fund
was also present?

A:  No.

Q:  Do you know a person named Richard Larry.

A:  Yes.

Q:  Who is Richard Larry?

A:  He's with the Scaife Foundation and Carthage Foundation, works with
Richard Scaife in Pittsburgh.

Q:  Have you ever spoken to Mr. Larry about the allegation regarding Mr.
Blumenthal?

A:  No.

Q:  Have you ever spoke to Mr. Larry about this lawsuit?

A:  No.

Q:  Have you ever spoke to Mr. Larry about funding Mr. Horowitz's
operations?

A:  No.

Q:  Do you know whether the Scaife Foundation has funded Mr. Horowitz's
operations?

A:  I don't know.

Q:  Did you ever refer Mr. Drudge to Mr. Larry for any reason?

A:  No.

Q:  Have you ever discussed the allegation about Mr. Blumenthal with David

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