-Caveat Lector-

Brock?

A:  No, I don't think I have.

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

A:  No.

MR. KLAUSNER: I can't hear you, you're facing the other way. Could you have
the reporter read that back, please? (The reporter read the record as
requested.)

MR. McDANIEL: Did you get that, Mr. Klausner? Can we go on now?

MR. KLAUSNER: I think it's an impertinent comment. The answer is I obviously
got it.

MR. McDANIEL: I don't care whether you think it's impertinent or not. I'm
asking whether we can go on now.

MR. KLAUSNER: You may gone on.

MR. McDANIEL: Thank you. I don't know why you get all worked up. I just
asked you if we can continue.

MR. KLAUSNER: That's fine. I'm not worked up. That's fine, thanks.

Q:  Did you ever discuss the allegation about Mr. Blumenthal with Laura
Ingraham?

A:  No.

Q:  How about this lawsuit, did you ever discuss that with Ms. Ingraham?

A:  Yes, I may have mentioned the fact of our being subpoenaed to Laura
Ingraham.

Q:  Do you recall when you did that?

A:  I don't.

Q:  Other than the fact of being subpoenaed, did you have any further
discussions with her on the topic of the lawsuit or the allegations?

A:  No, I don't think so.

Q:  How about with a person named Ann Coulter, do you know Ann Coulter?

A:  I know Ann Coulter but I've had no discussions with her about this.

Q:  Or about the lawsuit?

A:  Or about the lawsuit.

Q:  Have you ever been at any kind of meeting or gathering of people
associated with The American Spectator where the allegations about Mr.
Blumenthal have been discussed?

A:  No.

Q:  Had you ever been at any such meeting like I just defined where this
lawsuit was discussed other than the dinner party you just described for us?

A:  No.

Q:  Have you ever discussed the allegations about Mr. Blumenthal with Tucker
Carlson?

A:  No.

Q:  Have you ever discussed this lawsuit with Tucker Carlson?

A:  No.

Q:  Have you ever discussed the allegations regarding Sidney Blumenthal with
Richard Carlson?

A:  No.

Q:  Have you ever discussed this lawsuit with Richard Carlson?

A:  No.

Q:  Have you ever discussed the allegation involving Mr. Blumenthal with
Grover Norquist?

A:  No.

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

A:  No.

Q:  Have you ever discussed the allegations involving Mr. Blumenthal with
Andrew Ferguson?

A:  No.

Q:  Have you ever discussed the lawsuit with Mr. Ferguson?

A:  No.

Q:  Have you ever discussed the allegations regarding Sidney Blumenthal with
Fred Barnes?

A:  No.

Q:  Have you ever discussed the lawsuit with Mr. Barnes?

A:  No.

Q:  Did you discuss your subpoena with Mr. Barnes?

A:  No.

Q:  Have you ever discussed the wife beating allegations about Sidney
Blumenthal with a man named Plszenski?

A:  No.

Q:  Have you ever discussed this lawsuit with that person?

A:  I don't remember. I may have, I may have mentioned it to him. I may have
mentioned the fact of the subpoena to him.

Q:  Would you spell his last name so the reporter has it?

A:  You can look it up, Mr. McDaniel.

Q:  That was a trick question, Mr. Ledeen.

A:  Yes, I know.

Q:  Have you ever had any discussions about the wife beating allegations
involving Sidney Blumenthal with David Henderson?

A:  Who is David Henderson?

Q:  If you don't know who it is, then you probably don't believe you had any
such discussions, right?

A:  I don't believe I have.

Q:  Okay.

MR. McDANIEL: Let's take a break for a minute and I'll check my notes and
see if there's anything further I want to ask. (Recess from 12:04 to 12:10
p.m.)

MR. McDANIEL: Back on the record.

MR. MIKULA: Before we get started I'd like to state for the record that
under Federal Rules of Civil Procedure Mr. Ledeen wants the right to review
his testimony and preserves that right.

Q:  Mr. Ledeen, have you ever spoken to Mr. Klausner here before?

A:  Yes.

Q:  When was that?

A:  I think I've spoken to Mr. Klausner twice as I can recall.

Q:  When was the first time?

A:  The first time was a couple of months ago.

Q:  Did he call you?

A:  He did.

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

A:  I think so.

Q:  What did Mr. Klausner tell you and what did you tell him?

A:  I don't remember much of it, Mr. McDaniel. It was basically about Mr.
Klausner was telling me that he represented Mr. Drudge and that he was
involved in this case and that he might want to talk to me at some point.

Q:  Did he tell you why he thought he would want to talk to you?

A:  No.

Q:  Did you tell Mr. Klausner I don't have any knowledge about this case?

A:  I did.

Q:  Did you tell him there's no reason to talk to me?

A:  I said that we didn't know anything about the story.

Q:  What did Mr. Klausner say?

A:  He said that was fine.

Q:  Did he leave you with the impression that he was going to come and talk
to you anyway?

A:  I didn't have an impression one way or the other.

Q:  Did you make notes of this conversation?

A:  No.

Q:  How long did it last?

A:  A few minutes.

Q:  Did he also speak to your wife, do you know?

A:  Do you mean separately? I don't know if he and my wife have spoken.

Q:  Your wife wasn't on this phone call I take it?

A:  No.

Q:  You don't know whether he spoke to her otherwise?

A:  I don't.

Q:  When did the second phone call occur?

A:  That was a few days ago, subsequent to my receiving the subpoena.

Q:  Did he call you?

A:  I called him.

Q:  Why did you call him?

A:  I just wanted to tell him that I had received the subpoena.

Q:  What did you and he discuss in that phone call?

A:  Just the fact of having received the subpoena and he said he would be
undoubtedly coming to Washington for the deposition.

Q:  Did you discuss anything else?

A:  No.

Q:  Have you and Mr. Klausner ever exchanged any other information of any
type, e-mails, letters, documents, anything at all?

A:  No.

Q:  Have you ever had any other communications other than these two
telephone calls with any lawyer that you believed was representing Drudge?

A:  No.

Q:  Any type of communication, I'm including electronic, mail, oral,
anything at all.

A:  I understand.

Q:  Have you distributed any money to Drudge's defense fund?

A:  No.

Q:  Are you aware of any of the sources of money that's been contributed to
Drudge?

A:  No.

Q:  Are you aware of any persons that have served as sources for any Drudge
stories?

A:  No.

Q:  Did Mr. Drudge reveal to you any information about any persons in the
White House that commented to him about the Blumenthal story?

A:  No.

Q:  Have you heard any information from any source about the identity of
people referred to in Drudge's story as a White House source?

A:  No.

Q:  Have you ever heard any information from any source about the identity
of the influential Republicans whom Drudge quotes in his story?

A:  No.

Q:  There have been published reports quoting Drudge as saying his story was
based upon two sources. Do you have any information as to who those two
sources were?

A:  No.

Q:  When you spoke to Mr. Drudge on the telephone and you said you described
for him ways he could check police records and so forth, did Mr. Drudge in
that phone call describe to you the sources upon -- did he delineate for you
the sources as to which he was inquiring?

A:  No.

Q:  I may not have phrased that very well.

A:  I understand your question. I have no clue as to who the sources may be.

Q:  Did he, when he asked you how do you go about checking certain
information, did he delineate for you what that information was?

A:  Wife beating allegations.

Q:  Okay. Did he refer at all to FBI files?

A:  No.

Q:  Did you ever discuss FBI files with Mr. Drudge?

A:  No. I have not, I have not discussed the subject with Mr. Drudge except
insofar as I have described it to you, Mr. McDaniel.

Q:  Are you aware of Mr. Drudge's attitude towards President Clinton?

A:  I don't think I ever discussed President Clinton with Drudge.

Q:  Do you have any understanding what Drudge's political bias is, if any?

A:  I think I have seen Drudge described in print as a conservative.

Q:  Do you have any understanding beyond that?

A:  No.

Q:  Does that accord with your understanding?

A:  I don't have any additional information.

Q:  Have all of the stories you've discussed with Mr. Drudge where you've
tried to verify the truth of the stories been critical of the
administration?

A:  I don't think they were stories that were either favorable or critical
to the administration, some of them were just factual.

MR. McDANIEL: Mark that, would you, please? (Exhibit 6 marked.)

Q:  I want to show you what's been marked as Exhibit 6 for your deposition.
I don't have copies but I'll show counsel. If you can pass it down to the
counsel at the end of table, that would be appreciated. Have you had a
chance to review Exhibit 6?

A:  Yes.

Q:  Do you recall seeing Exhibit 6 before, Mr. Ledeen?

A:  No.

Q:  Mr. Ledeen, has anyone ever in any way led you to believe that that
person had heard rumors about Sidney Blumenthal committing abuse against
Jackie Blumenthal prior to the appearance of this story?

A:  No.

Q:  Now, I want to be clear on my question because what I'm asking is even
since the story appeared, has anyone said anything or done anything to lead
you to believe that that person had heard such rumors before the story
appeared?

A:  No.

Q:  Okay, thank you.

A:  Wait, no. There was somebody. The journalist who called me from The New
York Observer asked me why are you -- what do you have to do with this
story, and I said I was hoping you could tell me. And he said well, there
was a story, there's a claim that there was a cocktail party in New York
where some of these people named in the subpoena were present and that this
matter came up and that one of them claimed to have evidenced something,
rumors about this story. And I said oh, well, that's at least something
because I have been baffled, what do I have to do with these people and what
are all these people doing here, and this at least put some of them at a
cocktail party where the matter was supposedly discussed. That's a story
that I was told after having received the subpoena that deals with the
question you're asking.

Q:  Okay. Anything else come to mind?

A:  No, sir. I don't think so. There's something along those lines in The
Wall Street Journal editorial.

Q:  Have you discussed that editorial with anybody?

A:  That's addressed to me?

Q:  Yes.

A:  Yes.

Q:  With whom?

A:  With family and friends.

Q:  Which friends?

A:  We're going to go through a very long list. The discussion was what a
nice editorial.

Q:  Any discussion about the substance of the editorial?

A:  No, sir.

Q:  Do you agree with the editorial?

A:  I'm grateful for the editorial.

Q:  Do you agree with the editorial?

MR. KLAUSNER: I object to the question as being overly broad.

Q:  Do you agree with the editorial?

A:  With everything in the editorial?

Q:  Yes.

A:  Probably not. There's hardly ever everything I agreed with a hundred
percent.

Q:  What are you grateful for about the editorial?

A:  Kind words about us.

Q:  And harsh words about Mr. Blumenthal?

A:  Yes.

Q:  Are you grateful for those?

A:  Yes.

Q:  Because of your ill will towards Mr. Blumenthal, right?

A:  Because I think he deserves it.

Q:  You think he deserves more than that, don't you?

A:  Yeah, I think more criticism would be better.

Q:  Maybe some punishment?

A:  No, I don't think punishment.

Q:  You don't think he should be punished for his crimes?

A:  Punishment is not what I have in mind. Criticism is what I have in mind.

Q:  But no punishment?

A:  Criticism, not punishment.

Q:  Here's Mr. Blumenthal, a person who's done you harm, correct?

A:  Correct.

Q:  Serious harm, correct?

A:  I don't know how serious but he's certainly done me harm.

Q:  Well, you took it seriously?

A:  I think he did too, I think he tried hard to do me harm.

Q:  And you don't like it?

A:  I don't like it.

Q:  And you don't like him, do you?

A:  We have been through this, Mr. McDaniel.

Q:  It's true, isn't it?

MR. MIKULA: Asked and answered.

Q:  Answer it again.

MR. KLAUSNER: I object to the question.

MR. McDANIEL: There's no reason to yell, Mr. Mikula, I'm sitting right
across the table from you.

MR. KLAUSNER: I didn't hear any yelling going on.

MR. McDANIEL: Well, I did, Mr. Klausner, that's just false to even start
that stuff.

MR. KLAUSNER: That's fine. I was going to say if you want to persist --

MR. McDANIEL: I have one or two more questions and I'll be finished. Just
keep your pants on.

A:  What's the question?

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

A:  No, I don't like him.

Q:  And you read this story on the Internet about his beating his wife
attributed to influential Republicans and there are court records and you
didn't discuss that with anybody; is that what you're telling me?

A:  That's what I'm telling you. Could I provide you with one fact --

Q:  Do you want to say something else?

A:  Yes.

Q:  Go ahead.

A:  I'm not a Republican.

Q:  So?

A:  Well, you referred to influential Republicans as if that meant something
to me.

Q:  I was referring -- have you ever served in a Democratic administration?

A:  No.

Q:  Have you served in a Republican administration?

A:  Yes.

Q:  At high levels?

A:  I suppose.

Q:  Were you implicated in the Iran-Contra scandal?

MR. MIKULA: We're getting pretty far afield at this point, Mr. McDaniel.

MR. McDANIEL: The witness opened the gate to the field, Mr. Mikula.

A:  I just said I'm not a Republican.

Q:  Were you implicated in the Iran-Contra scandal?

A:  I was investigated in Iran-Contra.

Q:  That was a Republican administration, wasn't it?

A:  Yep.

MR. McDANIEL: Okay, I don't have any further questions at this time.

MR. KLAUSNER: I don't have any questions at this time.

(Deposition concluded at 12:25 p.m.)

**********

CERTIFICATE OF DEPONENT

I hereby certify that I have read and examined the aforegoing transcript,
and the same is a true and accurate record of the testimony given by me.

Any additions or corrections that I feel are necessary, I will attach on a
separate piece of paper to the original transcript.

Michael Ledeen

STATE OF MARYLAND, COUNTY OF BALTIMORE:

I, Richard D. Baker, Jr., a Notary Public in and for the State of Maryland,
County of Baltimore, do hereby certify the within named MICHAEL LEDEEN
personally appeared before me at the time and place herein set out and,
after having been duly sworn by me according to law, was interrogated by
counsel.

I further certify that the examination was recorded stenographically by me
and then transcribed from my stenographic notes to the within typewritten
matter in a true and accurate manner. I further certify that the
stipulations contained herein were entered into by counsel in my presence. I
further certify that I am not of counsel to any of the parties, nor an
employee of counsel, nor related to any of the parties, nor in any way
interested in the outcome of this action.

AS WITNESS my hand and notarial seal this 5th day of August, 1998, at
Baltimore, Maryland.

Richard D. Baker, Jr., Notary Public


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