meet - israel lobby · uh-hum. q. now in connection with the south african situation --strike thac....
TRANSCRIPT
((~~ I~-:--'\ \ r---.,",,)\~ul7
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(
:OCR7 OF THE STATE OF CA~:~CR~:A
~~=~£y ?hRKS SHAE3AS, VICTOR AJLOUNY, ~=3~~ A~ENS, ~MA~ BARKOUKI-WINTER, ~~??~~y 3~ANK?~R~, MANUEL DUDUM, COLIN E=WhR~S, CARO~ E~-SHAIEB, GEORGE GREEN, ~~~~A KOTAKIS, STEPHEN MASHNEY, HELEN ~=C~~~ McC~OSKEY, MARGARET ANN McCORMACK,
-. II
I
:=NA~~ ~~3AFF:N, ANNE POIRIER, AGHA SAEED, ~=:K ~h?~, MAR:ANNE TORRES and STEVE ZE~~ZER,
Plaintiffs,
'[ s . ~8. 95:CJ:'
~X~:-~E?AMATION LEA~~E OF E'NAr B'RITH, ~==~A2~ ~=RSCHHA~7, ROY BULLOCK, THOMAS ~E2A2~, and DOES ON~ t~rough TWO HUNDRED,
Defendants. /
D2POS=~=CN OF ~OY BULLOCK Volume II
1 .:
Decemt;e.r 21, 1994
Wecl:1es6ay
11:10 a.~.
l.? T"""". .... ~ r-""'-' --- .-... ... "'-"
"-....... Ee2.2.~:-, C:h.rma.n, Whice & Mc.Q:..:l:'::2~
333 Bush S:reet, 31st Floor San ?:-an~isco, California
!'-J 0 t :.. .:: ~
C S R :\I ~. S 0 '7 9
--------------------~~~~~B~~~~I~~~-------------------
C??=C!~~ 2~PORTSRS and NOTAR=~S
275 SaYa~~;~ Avenue, Suite l~~
Sa~:3 __ a~3, California 9SC~=
) ~ -'~, 262.-9795
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APPEARANCES:
Fo~ the Plaintiffs:
For the Defendant Anti-Defamat~on League of B'Nai B'rith:
and
For the Defendant Thomas Gerard:
For the Defendant Richard Hirschhaut:
LAW OFFICES OF PA0~ N. McC~OSKEY, JR. BY: PAUL N. McCLOSK2Y, ~~.
ATTORNEY AT L?.. W 2925 Woodside Road Woodside, c.n... 94062 (4:"5) 851-9700
HELLER, EHRMAN, WHITE & ,Mc)~UL I FFE BY: DAVID M. GOLDSTEIN, ~;'T~:c'ORNEY .~T LAW 525 University Avenue Pa:.. o .~lto, CA 94301 (415) 324-7000
ANTI-DEFAMATION LEAGUE BY: JILL KAHN MELTZER, AI.TT'ORNEY AT LAW 823 United Nations Plaza New York, NY 10017 (212) 885-7734
ROPERS, MAJESKI, KAEN, BENTLEY, WAGNER & KANE (NO'T PRESENT) 670 Howard S~reet
San Francisco, CA 94105 (41::;) 543-4800
HOWARD, RICE, NEMEROVSKI, CANADY, ROBERTSON & FALK BY: MARLA J. MILLER, A1'TC'RNEY AT LAW Ttree Embarcadero Center Seventh Floor San Francisco, C'.~ 94:=-=(42.5) 434-1600
()
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=·~~~~2-=t\.. :
AMOUR, GOODIN, SC~LOT3 & MacBRIDE BY: ROBERT AL~AN GOO==~ PATRICK HYDER PAT~ER32~,
,AT"rORNEYS AT LAW 505 Sansome Stree~
:NiJ:1th Floor SaI1 Francisco, CA 9412..1. (415) 392-7900
Jeffrey Blankfort
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INDEX OF EX~MINA~!ONS
BY MR. McCLOSKEY (resumed)
INDEX OF EXHIBI~S
Plaint:'ff's
~o. 13 Document with Subject: American Friends Service Committee dated November 1990
No. 14 Document with Subject: SCOUT report dated 5-27-92
No. 15 Document with Subject: Coke Boycott Campaign dated 10-10-90
No. 16 Document with Subject: Survey of Anti-Apartheid Groups In Portland, Oregon dated November 1989
No. 1 7 Document with Subject: African National Congress dated 6-3-C37
No. 18 Rosenthal memorandum dated 8-25-89
No. 19 Hirschhaut lec:er dated 1-21-87
No. 20 Hirschhaut memo~andum dated 12-2-86
Pace
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Pace
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---000-
RO:{ BULLOCK,
3 havina been previously sworn, by
Ce~~i~ied Shorthand Reporcer
:02:: ~he :':-l::,~, ~1·1e whole tru:h, and
~ct~~~g bu~ the truth, testified
as follc)ws:
EXAM:NATION BY MR. McCLOSKEY (resumed)
9 x::.. All right, Mr. Bullock, good morning.
2
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Q. You have p~eviously been sworn and this is a
c2~~~~~ation of your deposition of an earlier date.
MR. GOLDSTEIN: Pete, let me just say that r
rv::--. Blankfort is i:1 the deposition room todaY'L_as lS
I -- Ms. Melczer,: and all the parties will be subject to
:~e Dr~tective order as in the first day o~ the
d~DOsi:.:.c)n and. as we agr~ee(j \vith Mr. Bulloc~:, \..;e ::a""'I~
ag~eed w~tn Mr. Gerard, and we have agreed ~~ d~scuss
margin any difficulties anybody has ~with the
~v p:-otec~ive order at the end of the depositio~ today.
M P... M c C ~ 0 S K :::"! : 1~11 right. An C1 it:' s ~ j'"
u~de~s~anding t~at tje p:-evious deposition wti~~
~3~e ~~ ~ro~t of me a~~ nave shown to Mr.
~~a= vo~ have no: yet Jo~e over it to ae~e~x~~e
. ~ " ,2.:-l. C;'.lS eXu,lDlt.
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designate either "Confidential" or- "For Attor~e)Ts'
Eyes Only" as yet.
MR. GOODIN:
And Pete, I think our understand~ng ~s we
will do that at the completion of ~he deposic~cn
which I assume is at the end of today's session and
reporting of it.
MR. McCLOSKEY: That's fine.
Q. (By Mr. McCloskey) Mr .. Bullock, a+:. the
conclusion of the last deposition, I had asked you
during the a previous period, let's say ten years,
how much of your work had been done with respec= to
groups that were opposed to che policies of Israel,
a~d I believe you said about n~ne Dercen= was the
best estimate you could give.
A. (Witness nods head up and down.
Q. Would that be fair?
A. It seems to be.
Q. What about South Africa groups thac were opposed
to apartheid in South Africa?
MR. GOODIN: Over the las: ten y~ars?
MR. rvlcCLOSKEY': Ov~r c~e last ten ye3~S.
THE WITNESS: ?robably even les3.
Maybe four percen:.
"'I -1 1MR. McCLOSKSY: ..-'1. ........ ri-gh:.
Q . . Sy Mr. McCloskey)
~e~~esen~ only two c~asses of people, people t~a: aye
2=~~sej cr have ~~dicated opposition to policies c~
=S~3e: or De~~~2 t~a: aye opposed to apar:held l~
:;h - hl:tTl.
'~ . .~nd .,- am C8~rect, somewhere aro~nd 13 pe~cen~
wc~:d be yo~r bes: estimate of the work you have do~e
:t.ose two areas?
MR. GOC:)IN: That is assuming no ove=:ap
~e:ween the cwo ca:egories.
(Mr. Blank=or~ left the deposition room.)
M?. GOGJ::N: i:s that correct?
MR. McC~OSKEY: All right.
(3y Mr. McC:oskey) With counsel's correc:~~~,
_~ old you find overlap In those categories,
f\1~. 3ullock?
.~. Ch, yes.
What peycen=age o~ overiap would you say?
That ~s impossib~e co extrapolate at this point,
but t~e~e were ov~r~aps.
3~t we can use 13 percen: as
=~=31de r~g~=e :~~ :~e time that you spent In :~ese
~~~~ness ~~G3 head up and down.)
~.: ~. 3 ~ 3. ~. ~: == :.' ~ :: e r1 t ere d the d e p 0 sit i C) ~
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MR. McCLOSKEY': (::ndica~i!1g. )
THE WITNESS:
MR. McCLOSKEY: Okay.
Q. (By Mr. McCloskey) Remember you have to a~swe~
audibly for the for the ~eco~d.
A. Uh-hum.
Q. Now in connection with the South African
situation -- strike thac.
Let me go back to an orga~ization called the
American Friends Service Committee.
A. Uh-hum.
Q. I have a document here
MR. McCLOSKEY: Whac would be L~e nex~
exhibit in order, Miss Reporter?
MR. GOODIN: It would be around 12.
MR. GOLDSTEIN: 1.3 or 14.
MR. GOODIN: Yeah., maybe.
THE REPORTER: If you have the las= depoe
MR. GOODIN: Yeah, it would be 13.
MR. McCLOSKEY: 13.
MR. GOODIN: U]:1-hU:TI.
MR. McCLOSKE"{ : Let me ask ~he ~epor~~~
yC'-.l 'IJQuld mark thi.s (ind~Lca:'':':1g) 3S 2x~.=-l:i:. 2.-±.
iJ1 R . GOODIN: Nc) I I a.m
T~e next exhibi: will be :3.
MR. McCLOSl<E"{:
~1R. GOOe:N: Yea.h"
2 ~e went t~roug~ 12 last time.
3 So t~is is 13, Pet.e?
!vlR . McCLOSKEY': Yes, this will be 13.
5 \;1 T'";
1 • .K. • 300[;:1'J: .~11 .right.
!viR. GO~DS~E IN: One more copy UD there?
7 f\1R. McC~~SKEY: She has got a mark O~ ~
s \Plai~t~~~'s Exhibit No. 13 was marked f~~
_ 'v
nx . (3y
MR.
Mr.
McCLeSKEY:
McCl~s~ey)
Okay.
Mr. do you have please
~ea~ t:.~at, i: you vY"ot.:ld,. Mr. Bullock.
A. Read what?
':J . T~i.s Exr:ibi~ you have a copy of it in fro:lt.
IS
:7
c=
ae:
y'Qu.
~te
you like,
copy back.
g:_VE~ you the . .orlglna l ... aria
.~ . On, it. cl<:Jesn' m~--.;::::l-Yl.lel ' ..... __ •
1 .~ . All right.
Read the enci~e:y?
;.... . ( ~~; 2- t :1 e sse 0 rn p .... :. ~ s .
::: ':; 'l.1 jon' t n. a v e :- ':: a j ita lou d .
=~s::. \..;ant ~amiliarize you~self ~i~~
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A. I thought you wanted to read it aloud.
Okay, I have already done.
Do you recognize chis ,as a ;ene~ated
you?
A. Yes.
Q. In November of 1990 you were looki~g a~ the
American Friends Service Committee.
Why?
A. It was one of the orga~izations which I believe
engaged in activities in support of the
African National Congress.
Q. Did they also engage in ac~ivities ehat would
conflict from time to time with the policies of
~srael, to your knowled~~e?
, ... wou~a. soA. There is nothing i~ t~is report chat
reflect it.
Q. I understand in the report.
But I ask you the question.
Did they engage in activities deemed inimical to
the interest of Israel, to your judgment?
A. There is nothing in the
American Friends Service Commit~ee In Pcr::and wt~ct
would i~dicate that.
Q. Okay.
A. No~ do I have any k~owledge of ic.
~. .~ll rigtt. So wha: was che pu~pQse
1 ~~ves:iga~i~n in Po~tland of an anti-aparthe~d gro~p?
?urelv a simple one.
3 ~sl~3 nocting but public material, easily
c~~al~able ~o anyone. I made a brief synopsis of t~e
5 cr;a~iza~~on.
6 =id you ask any police officers for in~o~~a:~c~
at2~~ the Ame~ican Fr~ends Service Committee?
.~ . .:;b sol ute 1 y not .
~id you obta~~ any information abou~ them from
ar:v theiY members?
A. Ajsolucely noc.
1 2 n 'x: •
7\ • ., .......... s lee ~Yom this report, on the
( 1 3 ..;:-:1e~:-can SE:rvice F~:_end.s Service Committee, did
1 ,., you make any othe~ repor:s in the course of yo~r
....
..... .':J employment at ADL?
..... ~ v
"1\ r •. On ~Nhat?
-- ~ Q. About the Amerlca~ Friends Service Comm~::ee.
- - mi.ghc
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.... J Sa~ Francisco group co~cerning a public meeting
') ~
\) d~aling with perhaps t~e Middle East.
Th~s an ove~lap
~~ :n you~ =~dgment?
.D.. . ~ ~ a +:. T';'/ () U 1 j b ea... ':J 'OJ ~ ~ 2. 3. E=l a t t hat poi:: ~
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I ca~not tell you if the
i~ an~i-Israeli or whatever Midd~e Easte~~ te~~s.
Q. Okay. When d~d you go t8 Por~land to gather
this information?
A. Obviously-
:MR. GOLDSTEIl'J: I want I wa:1~ to objec:
to that to the extent he needs to reveal meet~~9S oy
dates of meetings with anybody in Portland to th~
extent it would infringe upon attoyney's privi:ege.
~1R. McCLOSKE:{: The objection is noted.
Y·ou may anSWE:r.
T'HE WITNESS: As t~e date i~dicates
(indicating) / November 1990.
Q. (By Mr. McCloskey) Do you remembe~ how long
you were in Portland?
A. Oh/ approximately three or four days.
Q. Did yo~ bill the ADL ~or you~ exoenses l~ t~a~
connection?
A. Yes/ because I went in conjunction with the
covering the Metzge~ trial.
Q. Was that the primary purpose that you we~c to
.~ .
24 would pay me.
Qo you ~nderstand my quescion?
)..':...•."~
.~
Was thac cie p~rpose
A. ~id you u~ders:and my answer?
'ioC,. • t~e pu~pose you went to Portland?
Q. i'\ ~ , .~nQ new 10:1g stay there, S ~ 'Y"? ............
6
I jus~ tali ~lOU.
Three O~ four days.
~uri~g t~a: time did you visit the headq~a~~ers
3 o~ :he Amerlcan Friends Service Committee?
A. 1 visited this add~ress (indicatiYlg), uh-~.. urn.
You dE~scribe t::at "Ttle fyont part of the
headquarteYs cons~scs of a literature room and a
:2 la~ge~ area equipped w~th tables, desks and a bank o~
t~:'ephones.
~ea:-. "
A few c~amped offices are located i~ the
A.
:1x .
Un-hum.
Did you intervie~ anyone in the of~ice?
A. ! interviewed no one in the office.
''1x . Did you identify yourself on your visi~ t~ the
Outside of jus~ wa~ting some literature, no.
~. On you~ visi~ t~ ~~e
~~~er:.can ...... .. t"~l.e:1GS C CI m~. i t. tee , you
33 be:'..:1g
~~ ;J'--':S2..:-'.2SS, alC::!. ~/OUI s:.~?
.j i d :1'~:'
~~ all of your lnvesci9ati~~s
1;.'.:~;."".(
"
lover this past ten years, that you concea~ed the ~ac~
2 t~at you were working for ALL at ~he t~me?
3 MR. GOODIN: I object to the use 0: the
4 word" conceal. "
5 Yo~ mean did he not reveal that he was a
6 member of the ADL?
7 ~1R. McCLOSKEY': All right:.
8 Q. (By Mr. McCloskey) Did you ever reveal to any
9 place or pe~son that you were ascertaining facts
10 about during the past ten years that you were working
11 for the ADL at the time?
12 A. No.
Q. Was that your decision or was that made by13
14 someone in ADL above you?
15 A. That was my decision.
16 Q. Did you ever discuss that fact with
17 Mr. Hirschhaut?
l8 A. I did not.
19 Q. Did you ever discuss that fact with M~. S~a:l?
20 A. I did not.
..... ' .. ~
Q. Did you understand :: rom ~r. Hl2:'.sC::['.a~:
22 Mr. Suall or any other offic~al 3: A~L that you we~e
23 no~ to disclose your associ3~~O~ with AD~?
~.. L have no such recogni:ion of that.24
n.2 5 "-:i.. When you first star~ed gecc~ng paid by
) M~. ;{ochma:1, \vas :'t :-lot Y'ou~~ '~.nd~~.sta.nd:':1cj :.h3: :~-.e
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p~~pcse of those payments coming through M~. Hoc~man
was so tta~ you could not be identified with A~r?
A. T~at/s correct.
Q. When you state in the second paragraph of
-- ~" .~X ... 2.Dl:' 13 " .r:...s AFSC operates the most import.ant
a:-::i-apar:..heid c1rganizati()n in the northwes~/" how
d~~ you make that dete~mination?
A. =n lieu of the face that there were no other
o~ganizations of equal stature.
()'x:: • How d~d you learn that?
..u. . By looking at the left-wing papers which were
ava~:able a~ the books~8re; that is,
The Porcland Alliance.
(') . What. what bookstore is that?
On I I don't know. One of the bookstores ~~at I
v::.s:'ted.
Just a regular co~mercial bookstore.
~
~ l 1G. n..L .....
o~ the front thev had magazine or a :~ee
magazines, including ~~e Portland Alliance.
..=\J. 2. right.. So ~~ making this investigac:c~ or
DOQ~st.ores, it was wha: you found in the book3:~~es
~~3: lei y~~ to t~~s c2~clusion?
::1 tnaK:r;.-g a:1 ::-:~..r~.3:~~gat.ion of booksc-:Jres?
\~ . :. ~l a t. ~N h a :. "t"'" ~" said?... \~';.......4"
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A. No, I did not.
I said I visited -- yC)U aye using "visit" and
"investigation."
The two terms
Q. All right.
A. are not synonymous.
Q. Thank you.
In visiting the bookstores, was that the sole
purpose of the first statement in Paragraph 2 of this
statement?
A. I visited the bookstore. In the front of the
bookstore were a number of free tabloids, including
The Portland Alliance. Pick:ing up
The Portland Alliance, I flipped through it and some
other copies and made my determination.
Q. Did you make your determination from anything
else
.~ . No .
Q. than that paper -
A. No.
Q. with respect to this statemen:?
A. No.
So based on looking at one papey in one
bookstore, you reported to the ADL that the
American Friends Service Committee operates the most
important anti-apartheid organization i~ the
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nort.hwest?
A. No, I did not.
Q. W~at other basis did you have for that
statement?
A. Your statement said I reported to the ADL.
This report was never given to the ADL.
Q. How do you know that?
A. (Indicating. )
Q. How do you know that?
A. Because I generated the report, so I know to
whom it goes and to whom it does not.
Q. Who did it go to?
A. (Indicating. )
Q. Who did it go to?
I would I sent that to the South African
ageY1t.
Q. Pardon me?
A. I sent that to the South African agent.
Q. Did you give any reports to the South African
agent that you also gave to the ADL?
A. There might. hav~ been some overlap.
Q. Why?
TA. A~ che moment C3.I1not tell you with.o~t..L
whac the reports are.
Q. 3u~ th:s partlc~:3r report, you're absc~~~ely
c ~ r :. 3 i:1 ~/ 0 U cr a ~J e on ~ \/ tje South African?
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A. Absolutely certain.
Q. And this was an intelligence age~t ~o
South African Governmer1t, was it not, Slr-?
A. Uh-hu'm.
Q. To yo~r knowledge?
A. Yes, to my knowlecige.
Q. You were here when Mr. Gerard gave tis
deposit.ion ..
.~ . Uh-hunl.
Q. Mr. Gerard stated that he never received any
money from for the South African reports.
Do you recall that testimony?
A. I believe I do.
Q. D~d you give My. Gerard money tha~ you rece~~ed
~rom the South African intelligence agent?
A. Yes, I did.
Q. How much?
A. I don't know that amo~n~ either.
It was minuscule, IJut nc)netheless, I sharecl
whateve~ it was.
Q. Didn't you tell the F.B. I. yo~ had rece~v~d
around $16,000 from the Souch Afri2an inte:l~genc~
..~ . I might: have .
~ , ..... g a l n , I don't ~emembe~ the exac= f:gure.
T3.3 say, it would be mi~uscule.
~ .... ... ~:5,800, over :.h~ee years, divided .... a ,
3 A~e~ yo~ ~ece~ved ~he money from the
i:1t.ell:'gE~nt a~3ent , was it In cas~?
Yes .
6 ,,,", x . •4.. n d w:~ e :1 you g a vet h E~ a 1: e 9 e d hal f oft:: 3.:' rn :; :"'.. e \P
7 :'0 ~:-. Gera.:-d, was ':hat ir1 cash?
s Yes.
9 Do you know any reason why Mr. Gerard would wa~~
::. 0 J..:.e u:lde~ oath he has not received that.
:;l~:1ey, M~. Bullock?
I do n,'ot.
MR. GOLDSTEI~r: Let me object.
Lacks foundation.
tBy Mr. McCloskey) You do not?
do not.
J. You had indica~ed ~~a~ you had lied to th~
to protect Mr. Gera~d.
::. 9 Do you recall t~a: testimony?
:2 0 l · C'" ...::> correc~ .
'~ . :~ty di:=i you li~?
T:J :J~otect to D~:-C)tec+: GeraYd, of cO·J~se.
.;.-: [::-:a: ~':me :~=~ !:J~lng exposed as scrne:='rle .... ~ .. _
2.l1telligence agen~.
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intelligent agent that you wouldn't wan~ the F.B.
to know, sir?
A. I ~hlnk his problem was that the C~~y had sc~e
ordinance banning any City official from mee::.i:lg ar:\l
South African official in any capacity.
Q. Is that the sale reason you lied to F . B . : . ?
A. I can think of no other.
Q. You took money from the F.B.I., didn't you?
A. One time they offered me a $500 payment for
services rendered.
Q. You knew you were an informant for the F.B.I. I
did you not?
A. (Indicating.)
Q. You knew you were an informant for the F.B.I. I
did you
A. An informant, yeah, yes, uh-hum.
Q. You were a paid infor~ant, were you ~oc?
A. On one occasion I received a $500 check.
Q. And on how many occasions did you give
information to the F.B.I., sir?
A. I don't know.
There were many times.
Q. Who was your supervi5~ng case office~ ~::~ =~2
F . 3 . I . ?
7\ n. The I don': believe there was any su~h
designate or term.
rernembe~ t:~e first time t~at }' 0 '.1
ar: i:::o!~mant capacity?
7
}--'1 -'-Tc~ may be ccrrecc in his narrative on t~a~, )..., ....
!1C~
y~~ were aware ttat Tom Gerard was in e~£ec:
F . E3 . I . so that instead
~e~~g a~ In:orma~t for the San Francisco Police, you
9 2~~_a be a~ l~=o~ma~t ~or the F.B.I., did you noc?
TA. ..L. do noc believe that to be a correct
c~a~acte~ization.
r, pu:-pose, as you understoodx .
,t~a= f~~s~ ~eet~~g you had with the F.B.I. ana
.,...., ~ -;. . ~e ~erely wanted to introduce me to the .r . .:) • l. .
r, 'X. • A~d when did that occur approximately?
hQ T~~a: is wheneve~ T~m said is t da~e, - I
=~3~~~Y, do no~ recall.
r\ A~ any time did you run a string of age~ts :c~\X:.
-~ . Po. sc~~e.:: 0:
S:~l~g, S-T-~-=-~-G.
T will object as vag~e 3~~
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question?
I understand the question.
THE WITNESS; Am I to answer now?
.MR. G008:N: Yeah, you can answe~
you understand it.
'rhe problem i.s the word "agents."
~rHE WITNESS; y E~ S •
~1R . GOODIN; WhcLt you mean by "agerlCs."
~IR. PATTERSOr~: I don't know whac you mean
by "string."
MR. GOLDSTEli\T: "String" as well.
Q. (By Mr. McCloskey) Well, you understa:1d that lS
sort of a C.I.A. term OJ~ F.B.I. term, isn't it,
M~. Bullock?
A. I am not familiar with it but
Q. I see.
At one time did you feel thac Mr. Gerard was
exchanging information with the C.I.A.?
A. I believe he inferred that.
Q. And from what did you reach chat inference?
7'\ .~ . A -- merely his inference.
be:ieve o~e ~ime ne me~:io~ed a:ce~ we
t~e meeting wit~ c~e South A~~ican that he \vas
t~ see his C.I.A.
Ea:-:dler, would that be a proper word?
) ..~ . It wasn't che word.
~la}'be Just C. C~ . I . A .
':ase :;:f:"ce~?
_-\ 22 K :1 ~~ \v t~2 auv i :-:t t 11 is area ....I ...
:-ie di':1:: I L. use any suc:h words
I II+- ;h~"-4. .....~-: e _ '-4 '-- use 1.-.l..I._ wor-d case off lce::- , "
II :-: a :: ~ -: e ~ If ?
..~. No, r:o.
'\ "St.:per':"cr"?
~c, he tlsed no sucl1 w()rd.s.
3 ~.
Q. Let me show you an exhibit.
Ml~. McC~OS}~3Y': I will ask it be ma~kej as
WITNESS: Uh-hu.m.
(Plainti~~/s Exhibit No. 14 was marked ~O~
MR. GOOD:Ll~: :'}:at (indicating) is t~e one
~/cu .
TH,=:: WIT~JESS: :iah.
MR. McCLOSKEY: This one is headed
T H S WIT :~ c s S : ~';h - f1UITl.
Is this a repor~ geD~~a:ed
.;.. ~ s .
reco~d
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Mr. Patterson and Mr. I:;oodin.)
MR. GOLDSTEI1~: Well, I am sorry, can we
have that question back, please.
Q. (By Mr. McCloskey) Who is Joe Fields?
IIA. Wher e is" Mr. Fie 1. d s ?
Q. First sentence.
~1R. GOODIN: Th:'s (ind':'cat:'ng) is
covering up.
MR. PATTERSO!'J: Take off the cover-up.
MR. GOODIN: ·Uh-hum.
(Counsel complies.)
THE WITNESS: Joe Fields is a neo-Nazi who
has over the years hosted the Adolf Hitler memorial
birthday at German Village. He is embroiled l~ a
number of anti-semitic right-wing groups,
organizations and for a short time headed
Willis Carta's Populist Party i~ Los A~geles. He lS
also active in a number of other neo-Nazi
organizations, including the
lnstitute of Historical Review and was well known as
a friend and colleague of Tom Metzge~ o~ the
~hite Aryan Resistance.
(3y Mr. r~cCloskey)
MR. GOODIN:
THI:: WITNESS: I ca~not :ell you.
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tviR. GOODIN: I instruct you net to tell.
Iv1R. McC~O.sK:::Y: Pardon me?
GOODIN: I we object on
~our~alis: privilege gYounds.
I i~s~~uc~ h~m not to answer.
(~iscussion off the record betwee~
M~. Pa==~rso~ and Mr. Goldstein.)
'l<:,\ • ',3y Mr. McCloske1") Was Scout an inf~~ma~t
you?
T .Q. wonn Ha2.e r~cGee I now becomi:l.g a regu2-a::-?
? . :!::::n:1 I-rale r~cGee.
1\ \~ . Second paragraph.
Jot~ Hale McGee was a an alcoholic
a~ci-se~itic peYsona~i~y who has bee~ on the fy~~ges
c~ t~e neo-Nazi movemenc in Los Angeles for a n~~be~
(~iscussio~ of= the record betwee~
>~~. Patt.erS():"l and Mr. Gc)ldstein.)
(3y Mr. McCloskey) Yc>u state "F~om Of:':'C:3="
: ~
::.- =- e :;. '::1 .,
S I w~ ~.l. a ~l e tl1e rally, as
·..;a 5 a
O:bj ect ion.
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l'1R. GOODIN: Instruct him not to answer.
Q. (Ey M~. McCloskey) Were they police officeYs?
i'1R. GOLDSTEIl'J:
Journalist privilege.
rvrR. PATTERS01'J: Same objection.
I would take it the capacity of the
identity of these people would identify them, and we
are not going to allow him to answer.
M.R. McCLOSKEY: ~et me show you an exhibit
tha: I ask be marked as No. 15.
(Discussion off the recoyd between the
w~~~ess and his counsel.)
(Plaintiff's Exhibit No. 15 was ma~ked for
ide!1tifi.cation.)
Q. (By Mr. McCloskey) Would you acquaint yourself
with No. 15, Mr. Bullock, so -
MR. GOODIN: D() Y() u h a vee 0 pie s 0 f t his '?
Or is this the only one?
MR. McCLOSKEY: Yea11.
MR. BLANKFORT: There is a couple of them
ar-ound.
i'y1R. McCLOSKEY: I passed two.
v ' ~'1R . GOODIN: ... ean.
~?.. McCLOSKEY: And I got
It'.R. GOODIN: Okay.
., 1. Take that (il1dicating) .
['v1~. GOLDSTEI~J: Gt~t this one (indi.cacing l
3 1'11R. GC)ODIN: You and I can share t~is.
T:iS WITNESS: Ur1-rlum.
s (By ~=. McCloskey) Did you generate t~is ~eDor~
abou~~ Octobe~ 10th, 1990, Mr. Bullock?
I did.
3 (),<. Whic~ American Friends Service Committee of~ice
a~e you ~efe~~~ng to here in the first pa~ag~aph?
(Discussion off the record between
Ms. Mille~ and Mr. Goldstein.)
Tl~S WITNESS: I am not certain.
PYobably from the Portland group, yes, tha:
.... s where t.he I would have picked up some
l:terac~~e dealing with the Coke Boycott Campaign
~ w~:c~ ~ ~ad not previously heard of.
- -: \ x::. (3y Mr. McCloskey) You have invest~gated t~e
~ ~~eyican Friends Service Committee here in
:9 Sa~ Francisco, have you not?
We::, ~ave yo~ as~ed for information abo~~ the~?
..~....
J. Is
;..Jo
:~eYe some
:1~~d t.o.
r~~son wty you have~'c?
..... ':<)~.'
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I
None indeed why, why should I?
I went to a public meeting sponsored by
American Friends Service Committee.
Q. Here in San Francisco?
A. Yes.
Q. But you have asked no questions about them?
A. I have no interest in knowing about them or
their personalities.
Q. Why would you be interested in the Portland
group but not the San Francisco group?
A. Only inasmuch as they were a focus of the
anti-apartheid and also the pro-Sandhinista
activities in that area.
Q. All right. In your second paragYaph here in
Exhibit 15 you mention that national headquarters df
AFSC is located in Atlar1ta I' Georgia.
A. Um-hum t yes.
Q . You i n ci i cat e t hat T h e~ [1 ire c tor i s1'1
Tandi Jcabashe, a South African woman whose father
was a Nobel Prize winner. She carries membership in
the ANC."
That is the American National Congress, isn't
it?
A. Uh-hum.
Q. How did you learn that informatio~?
A. That was part of her official biography that was
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attached to the Coke Boycott Campaign.
(j'" . And where did you get that biography?
A. That was part of the free literature from the
f~ee literature at the
American Friends Service Committee.
Q. You didn't go to Atlanta to get that
A. Of cou.rse not.
r-...v.. Did you call Atlan~a to get the information?
No.
I made no other further contacts whatsoever.
Q. So all of this information is the information
you obtained from the American Friends Service
offices in Portland, Oregon; is that correct?
That's correct.
In fact., I think yC)U w'ill see one, two,
three, four, five six lines down, "Periodically,
Coca Cola Campaign newsletter is also discribu~ed,
see attached."
Q. Did you talk with Lew Church?
A. Dld I talk with?
Mr. Lew Church, the marl mentioned in
?aragraph 4.
I rne:. Lew Church, l"es.
'~ . In ~hat capacity?
.;.. . ~e ~as a: a meet~ng o~ the Sharp Ski~s a~j scme
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of the John Brown Anti-Clan Committee and the
Revolutionary Communist Par~y which was going to
stage a series of protests at the time of the Metzger
trial.
Q. How did you learn the information related here
about Mr. Church?
A. Almost all Mr. Church gave me.
Q. Was the purpose in making this report to give it
to the South African intelligence agent?
A. That's correct.
Q. Did you give this report to the ADL?
A. No, I did not.
Q. Okay. On the second page of Exhibit 15,
Mr. Bullock.
A. (Witness complies.)
Uh-hum.
Q. You talk about a man named Carlton and the
Revolutionary Communist Party.
Was that a party of your inquiry?
A. I assume this individual was at the meeting that
I attended of which was held a public meeting,
incidentally held at the University.
Q. Of Portland?
:A.. Yes.
Q. In you~ next paragraph, at the top of Page 2,
you remember -- you name two men, Selaelo,
233
S-S-L-A-E-L-O, Maredi, M-A-R-E-D-I,
A. Uh-r.t:m.
Q . a~d Desmond Sm~t, S-M-I-T.
..~. Uh-hum.
Q. Whe~e did you obtain the information about those
two men?
A. Both of that was a public information ~~om the
newspaper racks of the
American Friends Service Committee.
Q. Your next paragraph states that Mr. Church told
you he maintained correspondence with severa:
anti-apartheid groups.
A. Uh-hum.
Q. Do you see that?
A. Yes.
Q. That carne from information that he gave you; lS
tha:. cor~ect?
A. As I mentioned, he told me quite a bi~ about
l1irr.self.
(Discussion 0:£ the record between
r.l1~. Soldstein and Ms. M:.~~ler·.)
MR. 0'1 eeL 0 S l( :::"O{ : All right.
n\xl . ;,3y Mr. McC~oskey) And chis information dld not
to the best of your recollec~~on?
A. ~~ey would be no need for them .
.;~th()ug~, as "lOU ca::. see, there lS S:~:'Tle
284
c~~ss-me:j~~; between anti-apartheid groups,
7. -3 \ .. C ~ ~--.: -: :.::;:: a ::- y ': 0 mm~ n i s t ? art y, J 0 h n Brow n
~~:~-:13~ :=~~~ttee, pro-Sandhinista.
3'~::' n'0, :::.:::'s d:'dn't go.
Mark the next exhibit as
!'Jeea Dne back. Ex:cuse me.
MR. GOO:J:N: Need one back, okay.
1 -, MR. McC:'OS?::::Y: Just one.
M~1.K. GOODI~:
(Cou~sel co~p~ies.
MI(. G000I~: She lS going to 3ive you the
:::::'ci.al O:1e.
is THE ~'J:TNESS: Oh, cia you want ttis o::e
~et me have that one.
Okay'" .
Post-It off, so you can read
Okay.
(C=O~Tlpl :.~S .
)
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A. Yes.
Q. Where d~d you get the informa:~o~ =~0m :~:s
repor~, sir?
A. Everything from public information. Sorne :~om
the pages of The Portland Alliance. S(Jme frorn
leaflets and material generated by the organiza:lon
thernselves.
(Discussion off t~e record betwee~
Mr. Bla~kfort and Mr. McCloskey.)
Q. (By Mr. McCloskey) Now this is dated
November 1989.
This is an earlier tr~p to Port~and ~hat you
made, I take it?
A. Possibly.
Q. Where did you get the informacion for this
report?
MR. GOLDSTEIN: Well, objecti(~r~.
Asked and answered.
MR. McCLOSKEY: No, no.
It is a differen: report.
MR. GOODI~: He d~d answer :he ques:~o~.
."A.re you askirlg
M?,.. rvlcC~OSKE)::: We:l, I
1. t: .
(3y Mr. McC~osKey)
ge~e~a~ed In Novembe~ 1989,
2
~~:s in:o~~ation?
~h~ so~~=~ was the newspapers like
7 .~ .
Do
~o.
:t
you remembey when you got that informa~~cn?
~~s~ have bee~ ~oughly this tiMe, I am s~re.
did llOtl ge:: the information tha: tl1e
9 .~.. 'r~::ere is it?
:0 can tell you.
i j P'!R. GOODIN: It is
~R. McCLOSt:~Y: Next about the fourt.:h
pa~3.grap~ down. ;···~·£<r~.'/f,(I
" 14 ....t"i.::. WI~NESS: Uh-hum .
~R. GOODI~J: (:=ndica.ting.
WITNESS this case, I ,probably
17 ~la \"e I ~ave take~ :~e name from one of t~e p~bll~
=- 3 s c·, ~ 2..- :: e s .
=- 9 S~~ce they spc:lighted him, I assumed he
'..;as a, qU8t.e, leadi:1g 3.c:lvist . I do not be =- i e've
.2\1.1 :right.
Where d~d you ge~ tj~
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MR. GOODIN: (Indicating.
T~E WITNESS: Uh-hum.
That also would have come probably f~om
The Portland Alliance which had a great deal 0:
material on such groups.
Q. (By Mr. McCloskey) For this
Excuse me.
A. Uh-hum.
Q. For this report did you interview any
individuals?
Absolutely not.
Did you do anything more other than read
The Portland Alliance?
J.~ . No. That's it.
Q. And did you give t ~i. 8 reE)ort t (~ the .P-..DL?
A. No, I did not.
Q. Did you give any reports to the ADL a.boll t :=r-:e
American Friends Service Committee, to your
krl0wledge?
A. With the exception of a public meeting wn~=~
attended in San Francisc8, j () n 0 ~ bel'::" e ~l e so.
n-e:.' All right.
A. Could be wrong, bu: I dCh't tjink 80.
~hey weren't on the l~s: of organ'::"za~ions ~~a=
you we~e inv~stigating?
-~ . ~ d:d ns~ ~ave a ~~S:.
I
,"""'" '~ .
Let me mark t~e next
1 ex~~~~: 3S No. 17.
(:)iSC'..lssiO:1 record bet~Neen
6 t?la~nt~££'s Exhibit No. 17 wa.s rnar-Ked
3 lv:R. (;OOD:r N :
9 MR. McC~OSI(E'Y: Excuse me.
(3~l Mr. McCloskey) Can you look a ..· L. 17, s:'r.
•"A. . (W~~~ess complies .
C2 . th:.s a repo~~ generated by you,
::'3 l~·j. . No, it is not.
(j )~ . ~o you know the source of it?
No, 1. do not.
I~ is da~ed 6-3-87
- I :s :ha~ a Deriod j~ying which you were
=-.:-:·... :::s:i.,.;a~i::,9" t~e .~:~:..=3rl National Cong:-ess7
.., a A.. ?ossible.
2 ,] () ~ . Whe~ did you f~~s: meet che South A~~~~3n
i~~2~~igen: agent?
I am su~e it was scmetlme in '87.
~~e wo~~ chac yell iii fo~ chat South A~r~ca~
~ :-'. -= ~ ~ ~ .:... (~ e !""... : age r1 t:. c:: ..r e :- .~ d. 'w hat. per i 0 d ?
'3: , 9 J early
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I can't quite remember .
From looki.ng at t~is !"epc~t, loS t:-:ere
you can tell who generated it?
A. No.
I am not it does not look famlliar to me.
Q. You don't recognize the typeface~
A. No.
All new to me.
Q. All right.
MR. McCLOSKEY: T11at is 17.
MR. BLANKFOR T :: (I:'1dicating.
MR. McCLOSKEY: I am going to give you now
a document, mark it as 18.
(Plaintiff's Exhibit No. 18 was marked ~O~
identification.)
THE WITNESS: IThank you.
(Discussion off t~e record be~ween
~[r. Patterson and Mr. Goc)din.)
Q. (By Mr. McCloskey) Who is Betsy Rosenthal,
Mr. Bullock?
A. Betsy Rosenthal was :he Di~ector ~n ~~e
~os Angeles of:ice.
These expenses that she is submit~i~g :0
~~. Irwin Suall on Augus~ 25th, :989 indica:e a VlS::
en you~ part co inte~~i~w Dave ~3zzel:a.
Who is Qave Mazzella?
A. Jave Mazzella was a skinhead active in the
~hlte A~yan Resistance and was used by Metzger as
o~~a~~ze~ cf skinheads throughout the West Ccas:.
(~iscussion off the record between
Ms. !V1iller and ['is. Mel.t.zer.)
~~ I TNE S S : He later broke wich ~e+:zge~
a~~ wa~=ed co ~ake a c:ean break of it.
MR. McC~OSr~:::'Y':: A.II right.
c. (By Mr. McCloskey) The next item is a v~sit to
?o~~land to meet Reverend Ted Pike.
W~O is
(Discussion off the record betwee~
f'1:-. ?at:t:erson and Mr. C30odin.)
MR. GOLDSTEI1~: I am sorry, ca.rl we go 0';::;=
:~e record for a mi~ute.
Yeah.
(Discussio~ af: ~he record.
-.c:. 113y Mr. McCloskey~) Have you had a chance
__ (~()K a~ Exhibit 18, til?:. Bullock?
TUh-hum. ha 'T.Je, "1' e s .
Q. W~O is Reverend ~ed ?~ke?
>1R. GOODI0J:
fv1 R . Oka:l· I am gO:l.ng
t~at would re~e3_
to go
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after name after name and if your quest::"on "who is
this person" is going to d~aw a:1 ar:.swe!~ tha~ t ~.. a +:
ide~:ifies t~e person of con:idential so~~ce, ~ wc~~j
object.
MR. McCLOSK:EY: I am not asking h~m t~e
confidential source.
I a m jus t ask i n g II i S k now 1 e d 9 e 0 f t l1 e .~ 2 ~ .
MR. PATTERSON: Continuing objection if
MR. GOODIN: (;0 ahead. You can answe~ who
Ted Pike is.
THE WITNESS: Okay.
Ted Pike is a ministe~ of the Identity Sec~
which is an extreme right-wing group anti-semicic
conglomerate.
In this particular case, Mr. t)ike was
putt~ng out a number of anti-semitic films and
publications.
(Discussion off the record between
Mr. Patterson and Mr. Goldstein.)
MR. GOLDSTEI~r: Pete, I want to lS the~e
any way you can tell us whe~e this document. ca~e
froIn,
MR McC~OSl{EY r~o
MR GOLDSTEI~' .hOtN you got ahol.,j c:
t. ')...
r~R McCLOSKE"{ ~J 0 I rl c:~
'~.: ;1
1 :::
1 ::
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~~hat I have done we can put this O~ the
l:""ecor:i ~s I would guess in the last year and a
~a~: we have ~eceived from perhaps 200 sources
i~format~on or documents which that person who wrote
lTI be perti~ent to this case.
And I am not sure where this one came
fl:""::m.
I can try t 0 fin d () u t, but I don' t k n 0 \." .
I br8ught my copies today of each document
we have been furnished.
013. M!LLER.: We would like to know.
MR. GOL:JST2:N: Well, I think we would like
MR. McCLOSKE"Y: All. right. I will try ':0
: i no ou t .
But I don't k~ow at this point.
I have culled these from a whole ser~~s c~
S8t.:rces.
(Discussion off the record between
i'ls. Miller and Mr. GolcistelIl.)
And the Portland Gang
rrasK ?orce, t1lho are t::ey?
r"1?. GOOD=~J: Dan/e identify i~divid~3:3.
3 ge~er3l desc~~p:~Qn of who they are.
'leah.
Portland
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Police Department, a task force dealt with monitoring
rancorous skinhead gangs .
MR. McCLOSKEY,: .~l.l right.
Q. (By Mr. McCloskey) Was this visit in
July 1989, was that the visit from which you
generated the 1989 report on the
American Friends Service Committee?
A. What was the date?
Q. Exhibit:
MR. GOODIN: That w'as dated
()ctober 10th, 19- -- nc), excuse me Nc)vembe r 19
MR. McCLOSKEY: That is Exhibi.t 16, is
dated November 1989.
MR. GOODIN: 19- right.
This one here~ (ind':'cating).
And he's aski~g you if you can tell whether
"r't.~ ... :'S visit in July was the S01.lrCe of the i~forma:.·ion
fo~ the November report.
If you know.
THE WITNESS: I don/t think so.
MR. McCLOSKEY: All right.
Q. (By Mr. McCloskey) How many times dld you viSlt
Portland during the period of time you were gat~eri~g
i~~ormation for the South African intell~;ence
se~v:'ce?
(Discussion off the record bet~een
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Mr. Gold.stein and Ms. rvliller.)
T:iE WITNESS: When I was gather~ng
i~~c~~ac~on ~cr the South African intelligence
~8
Q.
A.
Q.
lD
A.
Q.
MR. GOODIN: This would be from 1987 then
1991 or '92.
M"l Tc)McCLOSK:C:Y' : '92.
~n~ ~~ITNESS : I clc)n't think ()ve r twice.
( By Mr. McCloskey) Ove:r twice?
Not o\re r twice.
Well, you generated one report in 1989 and O:1e
1990.
0h-tum.
And tten you visited them in a third occasion
.iK.
he~e ~n 1989.
Un-hum. In when?
Q. Well, this would indicate July 1989.
(:Jiscussion the record between
>1 s. fl1 i 2.1 e ~ and Mr. Gold s ~ e :. n ,. )
Q. (By Mr. McCloskey) That: your bills'?
...~ . Yes . " ~ :.,,~..,.,-o..:"nci you scayed \..... ... "'- .-..- - a T..J.wreek .
.;:.. . Un-hum .
C2 . J~ring that week, d:.d you do any i~vestiga:~Gn
c: C~2 Amer:can Fri~nd3 Seyvice Committee?
aDd
.:=: ::'"":1 e () f tr:e 1 i t era -: '-': ::- e
....... 5 say,
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public racks, period.
(Discussion off the record between
Ms. Miller and Mr. Pattersorl.)
Q. (By Mr. McCloskey) Now did you ever bill the
ADL for travel expenses in connection with the
gathering of information for South African
intelligence?
A. Never.
Q. Whose handwriting is on the bottom of this
sheet, if you know?
Second sheet of Exhibit 18.
MR. GOODIN: For which portion?
It looks like there might be two different
types of handwriting.
MR. McCLOSKEY: Ma~i be. I dorl' t K:10W.
THE WITNESS: Whatever i~ is, I haven't
knowledge of either one.
MR. McCLOSKEY: You have no knowledge.
(:d . (By Mr. McCloskey) Have you seen Exhibit 18
before, Mr. Bullock?
A. I have never seen it.
Q. When you submit~ed your bills for expenses, to
whom did you submit it?
A. I submitted them to Betsy Rosenthal.
Q. Directly to her?
A. Since this was a West COdS~ t~ip, yeah.
296
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Q. Did you submit any expenses to Mr. Hirschhaut's
of~ice here in San Francisco?
A. Yes, the~e would be expenses on occasion.
Q. What would be the reason for sending some
expenses to San Francisco and some to Los Angeles?
A. I think because the Los Angeles office was
larger and handled most of the financing.
Q. But some was handled through San F~ancisco; is
that correct?
A. Oh, minor amounts, yes.
Q. You received cash from the San Francisco office
to pay your string of informants from time to time,
(jid you not, sir?
No.
(Discussion off the record between
Ms. Meltzer and Mr. Goldstein.)
Q. (By Mr. McCloskey) Who did you get the cash -',- v -
pay the informants from?
1\ . I didn't get cash from anyone.
C~ . How did you get re~mbursed from what you pald
your informants?
A~ I ~ecei'.Ied a check
Q ?rom Wh()ffi ?
.,." ... Or a mor:ey order~.
Q ? rom whom?
-h~ .~ 7'\
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Q. From Mr. Hochman or from an office of the AD~?
A. From an office of the ADL.
Q. Which office?
A. The San Francisco office.
Q. All right. So for informants that we~e working
for you, you submitted your expenses to
Mr. Hirschhaut, I take it?
A. Not to Mr. Hirschhaut.
He wouldn't have any reason to
Q . To whom?
A. have it.
Probably I gave them to Sue, who handled all t~e
financial transactions.
Q. All right. So the money you received from the
ADL for your informants
A. Urn.
Q. carne from the San Franc~sco off~ce; is that
correct.?
,A. I would take it that most of them clid, yes,
·uh-hum.
Q. Well, where else would ~hey have CG~e frc~?
A. Well, sometime if I was In Los Ange:es ~~ 3
I 'It .., ~
specific trip, then it. migtJ.t be r~.:.mbursea t::'-:Jl:"'.
Los Ange~es office.
Q. We~e these by cash or money orde~s?
A. These we~e always mcney order.
c. A:ways mo~ey o~~e~?
:~; a .s : ~ e :::- e a r.j' :. :: C1 i cat i c) n 0 f who h a. j c b ~ a :. :-: e d ": ~ e
~c~ey c~de~ when you received this money?
- C' .., y~) den'e u~derstand your question, ..:::> .........
:tere that it an
3 ~c~ey o~de~?
9 .;. . !~ 0 .
'Joe:: • So you received a money order made out to cash
w::~ no showing of where it came from, whac it was
I had the money order made out to me.
c . You ~ad ic mac~ out to you?
.~ .
~~e money orde~ was made out to me, no: t8 cas~.
Cd . .;. :-: d who P h y s ::. c a ~ 2- y g a v e you the m0 n e 1" 0 ~ j e ~ ?
was us~al:y ~a~~ed to me .
.l.
From tho ~os A~;eles office.
e ~J e ~~ r e eel v e
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A. He?
Q. She
A. Oh, she.
Q. -- personally gave them to YOu; is tha~
correct.?
•"A. • Yes .
Q. Is there any record maintained in the A~L
offices in San Francisco of those cash payments to
you, sir?
A. I have no idea.
MR. McCLeSKEY: I dO:1't believe, David, we
have received any such records.
MR. GOLDSTEIN:: I am sorry, which records?
MR. McCLOSKEY: The records of cash
pay"ments.
MR. GOODIN: Money orders made o~c t.o
M~. Bullock.
MR. McCLOSKEY: Morley orders.
Let me go off the record for just a second.
(Discussion o~f the record.)
MR. McCLOSKE:{: Let me show you a~ exhibi~
~'11 have marked as 119 Nc. 19.
(Plaintiff's Exh~bi: ~o. :9 was ~a~k~d :~=
1je:1cifica:.ion. )
(Discussi~n of~ :he record be:ween
-: \3Qlds~e~~ and ~s. 1'v1l • ~ l...l... ~
~..,.--- _ J...l.. •
,....)~... <."'....•.•
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MR. GOLDSTEI~: Pete, once again, we' "1 , ask.l.~
\-v' :: e :- ~ './ cur e c e i v edt (t i s doc u men t fro m.
I\1R. :.1cC~OSK.:::~: : A:nd I will try
Dl:: a~ r.. ot sure.
I have no knowledge at this pci~t
l3y M~. McCloskey) Mr. Bullock, showing you
1 0.... -" , have you ever met Yaacov Se:la?
Neve::--.
')'x . Do ycu k~cw who Marvin Stern is?
Ee is the ADL di~ector in the
Pac~=ic Northwest.
r, '.:: . wten okay.
~~d you meet witi any Israeli official in the
course of your employme~t by ADL, to yo~r knowledge?
A. Never.
MR. GOLDST=::::-r: I Ci.m sorry, ca.:1 I get ::.n.e
a~J.es,:ior1 back.
M?_. McCLOSr:E~{: (In.dicating. )
(The reccrj was read by the Reporter.
MR. GOLDST~I~J: I will object ~o the use ~:
t::.~e 'Nord "employmen:.."
GOODIN: ~~~ said "never. II
~e answe~ed :~e question.
sa i(j It r1 e ~J e r . "
;''1?... McCLC\S~~".:·: Uh-r1um.
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Mr. Patterson and Mr. G;oldstein.)
MR. McCLOSKEY: Al.l right.
Q. (By Mr. McCloskey) Mr. Bul.lock, 1.[1 your
statement to the San Francisco Police, which ~s
fairly voluminous, you indicated that at the t~~e 0:
your former deposition that there were numerous
errors in that statement.
Do you remember that testimony?
.~ . Indeed .
Q. Do you do any particular errors come to your
m:nd at this point?
A. Oh, not without going through it, but there
were.
Q. You would have to look through it to
Yeah, there were errors.
MR. McCLOSKE):: For t~e record, we
stipulated that you will furnish us such a lise of
E:rrors.
MR. GOODIN: Right.
MR. McCLOSKEY: And that we may by wr::~e~
questions then direct further interrogatories
Mr. Bullock co answer.
MR. GOODIN: T11at's correct, P~~e.
I think a lot of tiese errors are err2~5 ,~
tra:1SCrlpt:.on. I don't mean to ~~p:y they'~e
-h...., '- .. a ~ .~~~o~eous statemencs of fac~sl
~~~~~ t~at is what M~. Bullock is telling you.
YyAJe wi2.1 ce~tai~ly supply tha: :'0
Some are.
M?. :.1cCLOSK~Y·: All right.
5 MR. GOOCl:N: ...' undE:rstaI1.d but
6 l~ c C ::. 0 S k. e y" ) Mr. Bullock, I want. t.::J
bac~ ~2 a p~~o~ extib~t
8 .~ .
9 ~ia= was ~~Yn~shed at your last dec
~o dep2s~=~~n which is the information furnished on
1_ Je~~Yey Alla~ Blankforc
:2
13 Q. ':'n a report dated. October ~988.
you have a copy for
., -_:J MR. GOLDSTE=~: Wh~ch exhibit is it?
., -_0 MR. McCLOSKZ":{: It. is Exhibit 7.
F.nd. I d~i ~ot bring an ex~Ya s~-
M2. GOODI!'J:
MR. But. the the 1 ' exn:..=:.::..:..s
"I : I 9 and 10 :-elated to Mr. r7~1--'"7'::'''-,.....J._ ....... '-~ __
.~..';.'"
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your recollection, I will just pass ~hem acyoss tte
table.
THE WITNESS:
Q. (By Mr. McCloskey) You indicated a~ the
beginning of Exhibit 7 that the info~mation on
Mr. Blankfort was supplied on a confident~al basis by
an official source.
And I don't want you to identify who that source
was, but where was the source located?
MR. GOLDSTEIN: Obj: ection.
MR. GOODIN: Objection.
Instruct you not to answe~.
MR. PATTERSOI'J: Objection.
Instruct you not to answer.
THE REPORTER :: I can't take all c~ you at
r.ne same time, please.
MR. PATTERSO~1 : We all said the same thi~g.
THE REPORTER: I know.
Q. (By Mr. McCloskey) Do you have any personal
~:nowledge of Mr. Blankfo~rt' s li:estyle, Mr. Bullock?
A. Personal knowledge of h~s l~festyle?
I am afraid, Counselor, the ques~ion is too
All .. :118, this repor~right. ~' da~~d
Oc~ober 1988,
_""\......... TJh-~u~.
3
:hat report was generated by you, was It
.-::... 2e~.::..e\re so.
~et rne let me put this ~~ ~ro~:
7 GCOD=N: ~etfs take a lock.
Yeah. Point it to Y8'~.
And let me ask you some questions abou:
T:iE ~~IT~ESS: Uh-h'um. Uh-hum.
MR. GOODIN: Pete f I am going to I don'~
:3 k~~~ wheye you are going with this, but I would
s~mp~y ask you t~a: to yemember the fac: t~at a:
t~e ~as~ deDositio~ vau went through this, I th~nk,
16 l~~e-Dy-~~ne asking hlm what his source of
:7 ~~~=~~a~~on was fo~ each of these statemen~s.
:. s ~;IT;JESS l-Ie did.
MR. GOOuIi'J: So I ·don't }(now I don't:
wa~= co do that agalD.
U:lderstarld.
is there a question
Or~, okay.
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had asked referred to the fourth paragraph in this
report, that Mr. Blankfort had dramatica~ly c~a~ged
his l:':estyle.
And my question tel you, Mr. Bulloc~, is s:.mplj":
Did you have any personal knowledge of
Mr. Blankfort's lifescyle when you generated that
report?
A. No.
Q. Had you met Mr. Blank~ort when you gene~ated
that report?
.~. '88?
Oh, yes.
Q. In your statement to the police you indicated
that you had, I believe the word was ingratiated
you~self with Mr. Blankfort and with Mr. Zeltzer.
Do you recall that?
A. Yes.
Q. Could you tell me precisely how you did thac.
A. I believe the first time I met the two gentlemen
was at a public meeting in .Be~keley.
Zeltzer, I believe, stoPI)ed by and calked ~.;J:':'~ 11'2,
since I was a new face in the audience.
subseque~tly I am sure we mec a number c~ ~:.~es.
Some=imes at ral:ies and a c~up:e c~ ti~es ~e i~v::ed
me ~~vited me to his no~se.
In t~e t)clice reDor': '/C)U :':-:ciica~~d :::-'.a~
- -
----_•._------ -_._----------------------------
.')i'\ l:<.;~'}!K
~~. Zeltze~ and Mr. Blankfort believed that you were
:r:em,.
yernembe r t r.:.a t ?
De_:.eve so.
~ow iid you get chern to believe that you were
C:-'.2 c: tl-:em?
~. Yc~ wo~:d generally agree with their v:.ew.
S~j yo~ do anyt~~~g else?
.~ . ~ 2a~~Qt thi~k c~ any:hing else .
Did you go to th~ir home?
.r. . T vv·e:1t to Mr. Zelt.zer's home, I belie"'v'e, twice,
C~ :~e~~ invitation.
7\ ...Q. r.na what. was of generating che
~~Dcr~ abou":. Mr. Ze~t:ze:r?
IviR.. GOOD I 1~ : l~bout Mr. Zeltzer?
MR.. McCLOS:~~"{: I am sorry.
Mr. Blant:f8r:.
THE: WITNES3 .I :hink you mean
That was
!\ :; './ Mr:-. Meel c: s k '2 .~. ~hac was t~e purpo3~?
3a=~gro~nd, ~ac~cr~u~d information fo~ che
-.c::'
.... ... ::~::~.383 ~40St. m0 S:' ~.r -= .: .:. :: e ~:- CJ II S antl-lsrae~l vc~ces
sa.y do j"OU
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anti-Jewish, anti-Israeli or anti-Israeli Government
policies?
l\ . I mean anti-Israeli.
Q. What does that mean?
pO~lclesA. To me it means he 0PI)Osed the l' . a::d
Government 0: Israel.
Q. Does it mean he is anti-semitic?
A. Sometimes the two are interchangeable.
I do not think I would characterize him as
anti-semitic.
Q. You knew Mr. Blankfort was Jewish, did you not?
A. I am aware of that.
Q. Do you characterize some Jews as anti-semitic?
A. Oh, yes.
Ml~ . GOLDSTEIN: Pete, let rn-= just. say ~;:2.S
is way beyond what this deposi:ion lS supposed co be
about and, you know, we have shown a lot of la:i:~de
over two days, but I urge you to stay In your 1798
claim and ask questions in that area, which is,
all, what the deposition is supposed :0 be l~mitei
to.
MR.. McCLOSKEY:,
deposition is limited to mig~t be dl£~erent be~3.~3~
deem ......; -\- invasior1 of ~pr i '"',lacy, as
~~ivacy as to poli:ical beliefs as occosed to
a::..ci-semi:.ism.
( ~~a: ~s what I am trying to devel~p In ~h:s
Very well.
~~e C~urt order is the Court orde~ and ~~
for itself, so let me just caution you as
your use c~ you~ time with Mr. Bullock.
<, :3 ~r Mr. Meel 0 S key) 8id you charac:er~ze ~~ :~e
=cu~se cf YOUY i~ves:~gation at any time
A... F... nri-semitic, no.
Q. So the sole purpose of investigating
~r. 31a~kfort was because of his associacio~ with
., -: causes opposed to t~e Gove~nment of Israel; is that
(.
i\ M. Tha::., and an unusual connection with
=~s~i~~~e of Historical Review.
Q. ~he Institute o~ Historical Review,
..:;. . Uh-hum .
-; ,~ ..' , lQ. is that a pO.l::.t.J.ca_ c1uestion thac yOl.: are
lS that ar: 3.!1::l-sernitic organiza:.:.::r-:
., ~ I , ~
:'5 oro 0: :3 e ij -::: .r a 1 fyonts es~aD~':".3 ..--:e:1 Cj"-:.. .
2..S re2..3tions~2-;:
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you
When
Q. between Mr. Blankfort and that institu:e?
When Zeltzer and Blank~ort co~f~o~ted me lD a
ca:e' and asked me if I was an ADL inf8'rmar:t, the
ma:erial that they used as the basis of their
accusation was a letter from the
Insti~ute of Historical Review writte~ by i~s
d':'rector, Tom Marcellis to
?Q. That was a public let~er, wasn't l' ~~.
A. That was not a public letter.
Q. Who was the letter to?
They hid that from me. They had it
Q. They hid it from you?
."4 . Well, ()bviously they clid, didn't they?
n I see.~.
But they told you that they had ~ecelved a
letteY from the Institute?
Uh-hurn. Yes.
Q. Would receiving a lette~ from the Institute,
rv1~. Bullock, fall within. your purview of
~~~escigat~on?
(Jh, yes.
~, /-1c. reSDec: WOU._IJ receivir:g a
:~e :ns:icute cause someone to be the subj~ct c: y~~~
:~~est:gation?
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That this particular letter dealt with me In
which they had asked the Institute about me a~j did
:~stit~te have any suspicions that I was a,
quote, Jew:ish agen~ I ur.. quc)te.
Q. A~d what was the Institute's response?
.~ . The Institute's response by Marcellis was that,
yeah, I was a strange bird who sat around and
obseyved but kept quiet, and watch out for me.
But in truth, in fact, you were an agent fo~ the
A~L at the time that letter was written, wasn't it?
A . That is correct.
A~d was the Institute for Historical Review the
fi~st such organization to learn that you were an
agent for the ADL?
r'1R. GOLDSTEIN:' Ttlel1, objecti()D.
Lacks foundation.
MJ~. GOODIN: You can answer from your own
k:-:owledge.
TE{E WITNESS: No.
I believe Wi~lis Carto had previously
thougtt me an agent and had wricten me up as suc~ ~~
che pages of the Spct:l3~t.
~ ......(3y Mr. McClosk~"i) Th.a t is a publicatlon -l.. • J. d. -..... ~s ge~e~~ted public:y, isn't it?
publication gene~ated
(, 1\
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Q. So when did that publication first come out that
designated you as an ADL agent?
A. I am not sure again, but I think it was in the
mid '80s.
I could probably get you the exact date.
Q. All right. So that is the first time, to your
knowledge, that your cover was blown; is that
correct?
A. I believe so.
Q. And when was it that Mr. Zeltzer and
Mr. Blankfort confronted you with the accusation that
you were an agent for the ADL?
A. I am sure he probably knows the date, but I
would -- would certainly be '90 -- was it '91 or
'92?
I am not sure.
Q. Sometime in '91 or '92?
A. Uh-hum.
Q. All right.
A. They also used the Spotlight article which means
they had read it.
Q. Well, what did you infer from the fac~ that they
had a letter from Mr. Carta confirming a public
arcicle that they had an unusual connection wi~h the
I!1scitute?
MR. PATTSRSON:
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That mischaracterizes his testimony .
~he letter was not from Carto, according to
him.
~1R . GOODIN: Ma:r-cellis.
MR. PATTERSON: Marcellis.
THE WITNESS: Tom Marcellis.
MR. McCLOSKEY": I am sorry. I
misunderstood.
Q. (By Mr. McCloskey) What was it about the letter
that they had coupled with that article that caused
you to believe they had an unusual relationship with
:he Institute for Historical Review?
A. I would say that on the basis of their
suspicions aroused by the article, someone must have
written the Institute of Historical Review and asked
the~ specifically about me.
Q. Well, there is notr1ing" 'u,nusual about that, lS
there?
l·\ . I find it rather strange that a self-professed
Jew would write to one of the notorious anti-Se~~~es
in the United States to try to learn informac~cn
abouc tnac other person.
Q. Oh.
Sut: l'OU do it a: l r.:le time, don't you?
A. Ttlho?
~~l ::- :.. t e t ':) P e 0 p ~ e t:J '.:r e t i 11 for mat ion .
3 =- 3
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clQn't think under those circumstances
,j:'dn' :. t ~y t () infiltrate t~e
~ _~st~:u:e n- His~orical Review?
=:-: : i =- ~: ~- a ~ e ?
~ a:: ~ t~ r: d. e /j 0 n e 0 f the i:r me e tin 9 s, }' e s
And y~c asked q~es:ions, didn't you?
.~ .
\Indica.:':'n3·
:""""1 ''';' . You asked ques:~ons at the meeting, did~' _ yeu?
t~ what?
\~. I)':'d:1't yOtl?
As to who was a~ A~L agent or not?
Q. You asked quescio~s at the meeting, didn't yo~?
No, not at all the meetings. You ca~'t do t~a~
/\'.c: • Well, what lS che dif~erence you see,
r-1:::--. 3 iJ. 1 l C) c k, l :1 :lO U ::-- 9 0 i TI 9 t () the Ins tit u :. ~ a ~. d
~ as~~~g ques~ions and Mr. Blankforc writ~na :~ t~e
~~ =~s:it~te to ask quest~ons?
Dlg di~fe~ence :0 ~e.
Wha: ~s t~e dl::e::--~nce?
~. ~~~ big a~::ere~ce lS that he is suppc3ed:y 3
them?
)
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I went on an assig~ment because I a:~eady knew
what it was.
Q. All r:'gtt. A sid e :~ r 0 :n t hat I d 0 Y0 l.: h a v e a n \r
basis for the scatement that he had an u~usual
relationship with the Institute?
."A.. No.
Q. Is there any information you had that he eve~
sympathized with the Inst~tute/s views?
A. Not with the Institute.
Q. Other than this reI)ort I Exhibi.t 7, Ex~ibit 8,
and Exhibit 9, have you wrltten any reports about
M:-. Blankf01::-t?
A. I don't believe so.
Q. When you use the te~m on Exhibit 9
"t.asking re:t:)ort," wha~ is a. tasking repor: as
opposed to
M~~. GOODIN: Better let h~m see it.
TH:E WITNESS: I have to see Exhibit 9.
MR.. McCLOSKEY: (Counsel complies.)
MR. GOLDSTEIN: Can we gee can we ta:..ce a
ten-minute break while he is doing t~at?
MR. McCLOSKEY: 5 " r~ •'-4 _~
+-r(Recess taken .Erom 2.2·: I p.:n. '-U 12
p.:TI .
~~ r. a t. was 2.as:
(-=rues~ion?
( J.. (The record was read by the Reporte~.)
2 ':'I-i=: \~ITNESS: "Tasking report" was a :e~m
M:R. GOODIN : 1:.] s e this one ( indicat:.ng)
~.,..,.~
~-lITNESS TcJm Gerard.l. ~~ ~ :
C \ by 1'vi ,...- McCloskey) I (~ it your t e S 1: i m 0:1 ~~ :l:a:l. ..... ~::;,
:~3: eX~lb~~ was prepared by Mr. Gerard, not by Y8~?
3
9
-~ " en, no"
':"'n:.s de£i~itely my typeface.
r,''wi. • What did you mea~ when you used the teY~
II :.asking reI=)ort"?
"l',
-~ . ?robably just a s~bject; I had to call
__ .5 S (J r:-. e : t:. n g, sol pro b a b 2. l r calI e d i t II t ask in g rep 0 r t . "
Tr would have gone to the South African age~t.
1', '~ .
.~ .
Wou~d it also have gone to the ADL?
No.
c. ~as you~ ~nvestiga~~on 0: Mr. Blank:oY:. :~r :.~e
~or the Scuth African intel~ige~c~
age~.:.s?
T was for the rl~L.
;~t you gave t~e ~epor~ to the South A~~~cans?
~~d you charge ~~e ADL for the repor~?
oc::: • ~~e A~~ you had made . h.-.. ' .l. .. ct '
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A. No.
Q. Well, the repo~t 'Nen~~ t.o the ADL, d:dn'+: i:?
I wro:e up t~e repo~:, placed it ~~ :he ~~:e; 3:
a later time, should the League ask for some
ir.formation., "Who is Jeff Blankfort, 11 t::en I could
take this out of the file and send it as a reply.
Q. Did you send the Ela~kforc report to the AD~?
MR.. GOODIN: And you are talki~g now about
Exhibit 9?
MR. McC1JOSKEY,: 'fha.t's correct.
T:HE WITNESS: You are talking abo~= this
or.e (indicating).
MP.. McCLOSKEY: ~{e s . Exl1ibit 9.
Tt-IE WITNESS: No.
o
Q. ( By Mr. McCloskey) Wrla t about Exhic~~ 8 ?
Kr'\ .. rMF~ . GOODIN: ~rake a look at it, '-.-/ i .
T T'r-,t':t.t., WITNESS: Which is what?
Th.e Blankfort biography?
MR.. GOODIN:
Exhibit 9.
(Counsel complies.
THE WITt~ESS: ~Wltness complies.)
Yes, I probably would have sent th~3 t~ t~e
Lea(;ue, un-hum.
Q. (3y Mr. McClos~ey) Did -- wha: abcc~
E:<:-:ibit. 7?
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( MR. GOODIN: That is the biography
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(Counsel complies.)
~E~ WITNESS: That is the one I say IT'.a~e
l~ up for the file and placed it in the file.
I don't believe that particular one ~as
It was ~o be utilized in case the ~eag~e
eve~ asked me speci~ically for biographica: de:a~ls
C~ ~e::~ey 31ank:or~.
MF(. McCLOSKEY: ~I.ll right.
Q. \By Mr. McCloskey) This file was placed ~n the
::':es l~ San ?ra~cisco that you maintained, was
i:. n.ot?
F.. Yes.
Q. Was that true 0: Ex~ibit 8 and Exhibi~ 9?
MR. GOODIN: Take a look.
THE WITNESS: Which is
MR. GOODIN: So do you
u~j~~stand what he is asking you, Roy?
THS WI~NESS: ~les, this one (in.dica:.:.r:g'
Nc). 8 .
..., tIle ADL file.
~x~ibit 9 was no~,
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f'.i1R. McCLOSKE~{: All right.
!ViR. GOODIN: And~ Exhibit
(By Mr McCloskey) So Exhibi~s 7 a~d 9 we~~
placed i~ the Blankfo~t file at :he AD~ cf~ice; ~s
t~at correct?
A. No, I don't think ,so.
MR. GOODIN: 1~ 0 .
Exhibit 8 7. Ar:d 8
THE WITN2SS: Exhibit 8 is :he Conference
for Independent Labor Political Actio~. Now it
has it mentioned Blankfort.
Might have been placed in Blank~or~'s file
or I might have made a file for the policical
I~dependent Political Confere~ce.
Ml~. McCLOSKEY: )~l: righ~.
Q . (By Mr. McCloskey) Now ~hat f~le that yc~ ~ade
u;:, \A/as it in kept l~ the A~L of~ices l~
San Francisco in the file r80~ you me~t~o~ed ea~l~e~?
l1.. Yes.
Q. And would ic have been l~ a man~:a folder?
It would have been.
c. And these manila folders were
(Discussion off the record be:ween
rvl:-. Golds~ei.:1 and r"ls. r1~~2.tzer.)
T~2 WI':'r'J~SS:
--
. -.;:.,~( 2 McCloske:/\
--.,...,c~eCite a. ...... index
F~anC:SC8 off~ce?
~
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4
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7
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pYev:c~s
. c; rne jus:
~~ h .: C ~ f 1 =- e s ?
v~ell, did you mal:1t.ain a--r••
all of the fi:es ~he
Well, I object.
you are asking "the f:.2.es
Y8U mea~ t~e administrative files?
M.E .. ~cCLOSKEY: \t-Jell, he is In his
:est~mo~y lD the earlier depositicn, he
s:.a:e8.
~a:.~:a:~:.~g
one
:~e
of
~~:es
res~)orlsibilities was
In the San Francisco o~~ice c:
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)0( •
E 'J 2- 2. 0 C k ?
that
r':'le
Do I state thac
would be correct.
~ocm app~oximately how
acc~~a~e:y,
ma:1Y ::...i.es
o~ I dor;. I ~ :hi~k :':18u:san.ds , no.
A.
~e~~ all c: t~es~ :~~es generated by you?
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A. The vast majority would have been from publ~c
sources, newspaper cli!Jpirlgs, magazine artlcles.
Q. Who cClllected those and pu: the rn In the £l~es?
A. Ar.y number of peOf)le
Q. P.ll right.
A. would have done that.
Q. SO :bu t you maintairled it, I take it?
A•. I maint.ained some.
It would be errone<)us t () say tha~ I kept all t~e
file departn1ent. I did not.
Q. Well, I believe you testified earlier in your
former deposition that you were the person in charge
of that file room.
A. I was the person that I had security over
yeah.
Q. Pardon lJ1e?
A. I had security over it.
That is I was not going to allow ahY
unauthorized person access to i~ when ~ was there.
Q. Did you have
.A. Although that was not all the time .
(J . Did you have a key to the room?
.'" • No, I1-1. did not .
~ ~ ~.., :rCr:lwe 1. .... , how did you keep ottle:-
access to the room?
J:..... ~l h e ~l I was the:-- e, I vJ 0 ~ 1 d ask I:J ~- "::: eke \'" a :: d S ~
.,..",1' -.... - - .... "'". ~
-----------------------
(
Sc)~etimes .
x:. ~~o else would go l~ with you?
I,:r .. dica:ing. )
6 'ac:. • would go .In ~Jith you?
7 Ecmeti~es the hssistant Directors would come
B -~ ask a speci~~c q~es:lon or a response to a
~ c~uesticn.
: 0 Q. Was the y e G n e !TI t: l 0 1" e eat the h e a d qua r t e r S 0 f P. DL
~~~~ had actual co~:Ycl over that room when you were
:.. C": +:he~e?
.::.::.... I t ~ i :l. k t ~ eke \' vi a s 1 e f +: wit h Sue .
Q. Wi:h
Sue yes I u~-~.. '..lrn.
Q. A~d so she had access ~o the room at any time
s~~ wa~ted, I take i~?
PE=t.e, aren't we repea::.ir:.g
~ e s -: i ITl 0 :1 1 "?
This ~ 1 l a.l..~ awfully familiar.
~ - MR. McCLCS!{~"~: 1. ar'll not clear.
The testimo~y lS a llttle diffeyen: t.ha~
... ::a.:: :.s true.
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fvIR. McCLOSKE~{: Well, that is what I would
like to try to do.
Q. (By Mr. McCloskey) This room at the ADL
headquarters
A. Uh-hum.
Q. -- when you were there, you wanted to deny
access to anyone else without your permission; iS~/:
that correct?
A. No.
Q. Well, what is
A. I said unauthorized persons. Unauthorized
persons.
Q. How much of your time in the last ten years d~d
you spend in that room?
c -)A. That i impossible to tell.
Q. One day· a
A. Impossible.
Q. One day a week?
P-•. Sometimes one day.
MR. GOLDSTEIN: Thls has been askeci a:1G
answered.
THE WITNESS : It is impossible
MR GOLDSTEIN : YC)U have gone over- t...-:.:.. s
,. ITH:S WITN~SS : I C a Tl c a:l.swer tha t K2..:-:::
~
v -..;: a.
questio:1.
MR. GOO==N:
::' "\ .~ .. ~----=~=-='"-------~--~~~
(By Mr. McCloskey) Well, let me see can.;-t=
undeystand why it was important to you on the
occas~o~s that you were t~ere that nobody entered t~e
rccm W~:~8ut your authorization
~~K . GOLDSTEIN: ',.Jell, I am going to
I:)b~ ec:..
(By Mr. McCloskey) if
M:~~. GOLDSTEIN: That mischaracterizes the
t.es~irncr:y .
Q. (3y Mr. McCloskey) if you were not t~ere
mcs:. of the t':me
A. T~at lS quite true.
C. Bu: when you were there, you wan~ed to make s~re
or:e else had access without your authorization;
:.hat r:.c~t?
MR. GOLDSTEIN: O:bjection.
M2. PJ... TTERS8N: We have got
MR. GOLDST~IN: Mischaracterizes t.je
t.es:.:':nO:1Y·
MR. McCLOSK~Y: Parclon me?
MR. GOODI!'J: Mischaracterizes his
-.i~vJha t he S a_,-,- "v; a s that it was
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defir:ition of "unauthorized person"?
A. I would say anyone who was not an employee c~
t~at ADL office or an ADL person ~ho has ccme :8
Sa~ Francisco.
C' . When you say "ADL"
.~ . Such as Betsy Rosenthal, being an ADL d~rector,
she, of course, could have access to the :i.les.
,I)x . Do you mea~ a paid employee of A~L?
I mean anybody that was an employee o~ the A~~
o::ice, uh-l""lum.
Q. What ar)out, say, a::1 AI)L volunteer?
7\ n. An ADL volunteer, I don't know what you are
talking about.
Q. Well, ~lhat about, say, an ADL trle Preside:::
0: the ADL San Francisco chapter, WDuld he be an
person that was authorized to go into thaL room?
No.
More likely he would ask a spec~~ic question anc
the question would be se'flt down to the file rOOITL, "Do
)lOU have any~~ing on this person, " ~lOU migr.. :. take au:.
~ I~~e file and look. a~ ~ -L. ar1d say "Yes, we have .it..L
~his we can g~ve. This is conflde~:~al and we cannc~
alve."
~ Q o I ,rig~.L . r~om :hese ex~~bi:s, , \..J - I
.~ . C~-hum .
• ~ I .,
j'OU :~a',Je :.::a:..catc~C1 7 9
- ....... -~
.....--..., --..,...-..",....-... ~ --~...., .......... """~ ,- -.... -, ~.,.- '-... -'
some sort of manila folder that had either
My. Blankfor~'s name on it or the Mid East
Peace Gr-oup.
r " .. Yes.
Q. Am I correct?
A. Uh-hurn. !I 'III
Q. To your knowledge, was that file sent to the I
I
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c:fice i~ Los Angeles? I
I
I
I
F.. Not that I k:1oW of, nc) . I
Q. Did
F_.. I did !10t senlj it.
Q. Did you on occasion send those files or
i~:or-mation from those to the ADL office in
Lc)s Angeles'?
A. Did I send it?
That that would not be the office routine.
~. Did you cause them to be sent?
.~ . I might leave them to to someone to c:Ycu:a~e
::. hem I b u ~ c a use 0 r c:" ~ c u 1 ate the m the ms e 1 'OJ e S I d :. dI
; I
no:..
Al2. right. And vInerl yC)U say "circulate I" to
whcm wou:d they be ci~culated?
dO:-'l' t J(:10W.
j~ ~O: k~ow t~e b~ok lis::..
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A. I do not know.
Q. Do you know if it was sent to Mira Boland?
A. I do not know that.
Q. The date on the last date that I have on that
ex~ibit is October 1988.
MJ(. GOODIN: For which exhibit?
MF(. McCLOSKEY: It is Exhibit 9.
MF~. GOODIN: l~xhi.bit 9, I belie~Je he says
he doesn't think was in the ADL files.
Q. (By Mr. McCloskey) Did you put any information
in Mr. Blankfort's file after October 1988, to your
knowledge?
A. After that last
Q. Yes.
I am sure there must have been.
Q. You have the the ones that I have, Exhibit 8,
is -- refers to a conference of the
Independent Labor Political Action Committee.
A. Dh-hum.
MR. GOODIN: What is the date of ~hat,
Pete?
MR. McCLOSKEY: Tha~ lS dated August 1992.
THE: WITNESS: l~h-!"lum.
MR. r-1cCLOSKE~-: A~d t~e earliey :~~e lS
Jef~rey Alan Blankfort Oc~cber 1988.
TH~~ \~ITNESS: lJh - flunl.
327
,MR. GOODIN:
Q. (By Mr. McCloskey) And between '88 and '90
'92, did yC)U put any i11for~mation in Mr. Blankfor: 's
file?
r ... am s~re theye was an occasional repo~t, yes.'" Q. Would you put in his file the fact that he had
c8~fro~ted you with knowledge that you were an ADL
agent?
A. No, I ciidn't w-::ite tha.t up.
Q. Why not?
? . I didn't find it pertinent to to do so.
Q. A.side from Mr. Blarlkfc,rt and Mr. Zeltzer, did
other people you were investigating learn that
you were an ADL agent during that period of time,
::-om ' 88 to '92?
A. Not that I know of.
Q. Anybody read t~e Spotlight might have so~e idea,
I take it?
A. If they read the Spotlight, they could draw
c~eir conclusions.
'J . But. n 0 Cl nee 2. sec 0 r:. :: ~ 0 n ted you ina n y 0 -: t l1 e s e
22 meeti~gs you attended?
J\ . Reach the genera: question, no one else
A~~ whe~ Mr. B~a~~~~~~ and Mr. Zeltzey
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ADL, did you not?
A. Of course.
Q. I am going to show you Exhibit 20.
(Plaintiff's Exhibit No. 20 was marked for
identification.)
THE WITNESS: Uh-htlrn.
MR. GOLDSTEIN: Do you have another copy?
MR. McCLOSKEY: Oh, I am sorry.
(Counsel complies.)
MR.. GOLDSTEIN: Thank you.
MR. GOODIN: Here are more copies.
(Counsel complies.)
Q. (By Mr. McCloskey) Mr. Bullock, this indicates
that
MR. GOLDSTEIN: Pete, I am sorry, can you
ask -- can you tell us where you got this document
from.
MR. McCLOSKEY: No. I don't know.
MR. GOODIN: Is this the same answer as the
last series of answers?
MR. McCLOSKEY: I don't know. Same.
It may have been a leak within the AD~. It
appears to be a confidential memorandum.
Q. (By Mr. McCloskey) Mr. Bl111ock, I v.-'ant to ask
you about this Exhibit 20.
Did you yeceive instructions f~om ADL in 1986 to
329
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I h '-~ -' 1
investigate the Palestine Human Rights Campaign here
in the San Francisco Bay Area?
(Discussion off the record between
Ms. Miller and Mr. Goldstein.)
THE WITNESS: I am not sure there is a
Palest~ne Human Righ~s Campaign here in the Bay Area.
Q. (By Mr. McCloskey) On y"our list of
organ~zations and from your computer, you have
numbers 444, starting with the Palestine Arab Fund,
and I am referring now to Page 16 under
"Pinko Organ.izations," the
Palestine Solidarity Committee meeting, the
Palestine Solidarity Committee.
MR. PATTERSON: What is the page again,
Pete?
MR. McCLOSKEY: It is page
(Mr. Blankfort left the deposition room.
MR ,. McCLOSKEY: Page 16 through Page 17.
MR. PATTERSON: Of 'what, is there
MR. McCLOSKEY: On the RB Pinko
organiza~ions.
MR. PATTERSON: Is this
MR. GOLDSTEI~: These are the documents
L~a~ M~. Rot~ produced?
Is t~at wha~ you are talking about?
"Yes.
3 3 ,J
3
~....•".'..Z.
" T~is IS from Exhibit 6 in the depos~ti8n
~~a~ was take~ earlier.
PA~7ERSOl\r : Are there Bates n~~De=s
~~e 50C0 se~ies or was that something else?
r-: R. tv1 c C=-O S }( E Y' :
(I:1dicating. )
MR. F~~~TERSON': Ot1, this.
s MR. GO~DSTEIN: Ok:c:ly. This appears to be
~ :~e list from the search war~ant; is that right?
MR. McC~OSKEY: It I am no~ sure.
r-r" . ~nlS was shown and identified as
~ ~ C ../ ::.~.. e ~~:.. t n e s sin the ::. a s t d E: p 0 sit ion .
MR. GOLl)STEIN: Risr ht .
And I think the~e were copies at that
t=-~ne .
(Mr. Blank~or~ entered the deposition
i ......
MF~. GOLDS~E:N: But bear with us ~or one
:is' seC8~.. a.
MR.. McCLOSK~Y:: If
M~1 .. .t( • GO~DS':':::=:-J: Ma~{be I can f ir.ci
So we a=e a:1 looking at the sa~e t~~:1g,
L~ ~~~e, =ust g~ve us a se~ond.
"v -' .A. ed.n.
':...... :J :. d y" 0 U eve r i :: .: e s :. =_ :; a ~ ~
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A. I did.
Q. And what was the nature of your investigation?
A. They held a convention, I believe in Chicago,
and I attended the public convention.
Q. And what was the purpose?
."4 . To listen to the speakers and record my
im~ressions of what they said.
Q. Was did you attend that convention in Ch~~3g0
on Mr. Suall's instruction?
A. Specifically Mr. S1~all' S, no.
Q. Mr. Hirschhaut?
A. I am not sure who would have been the
specific
(:2 • All right. If you will look at Exhibit 20,
Mr. Bullock.
A. Uh-hum.
(Witness complies.)
Q. It states "The attached lise details
contributions received by the above organization
throughout 1982."
A. Uh-hum.
Q. Did you investigate the fund~ng o~ that
orga~ization in 1982?
P•. No.
Q. Was the informa~~on Lhe~ on L~~S ~2..st,
lock at the second page.
(
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2
~
2
I ~
A. Uh-hufn.
:5 ttat you~ typing?
Yes.
T""secc~d page of t.:lis Document N.. I.....-' •
~~~cn snows Washi~g~on, Oregon and Nevada
A. Uh-[lum.
a~d a number of people and their
conty~butions, how did you obtain that informatio~?
A. ~hat was given to me by a confidential source ~~
Chicago.
Whe~?
When I attended the Chicago convention of the
Pa~est~ne Human Rights Campaign, whenever that was,
':;'0, '91, whenever.
Was t~is information about political
cc~:yibu~ions unde~stood by you to be conf~de~~ia:
~~~8rma~ion?
A... No.
Was it public informacion?
A. ~he person who gave it to me had been In t~2
Pa~estine Hu~an R~ch~s Campaign and was a disg~~~=~ed
:::l:j ec:: ion.
~ct. t.:; answer.
- ... -- - ..-.... ......... ~.,. .... ~ - - - --- --= -=- --=- - - - - - - - - - - ~
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was
MR. McCLOSKE:{:
entitled to.
I suppose I got more than I
THE WITNESS: Yes I lndeed ~/ou did.
Q. (By inter'\liew
Ye,ah, you did.
D~sgruntled ex-emplcyee.
Th.a.nk you.
Did you
But .it's okay.
MR. McCLOSKEY:
MR. PATTERSON:
THE WITNESS:
MR. McCLOSKEY:
Mr. McCloskey)
these individuals on this list?
A. Not one.
Q. Now can you tell me the reason for the delay
in did you collect this information in 1982?
A. I did rIot.
Q. When did you get it?
A. Whenever I attended the
Palestine Human Rights Campaign
Q. Do you remember?
J:.•. convention in Chicago.
No, I d<Jn't remember.
Q. You don't remember whic~ year?
A. No .
'90, '91, something like t:~at.
Q. Did you send this ih:ormation to M~. SGa~l?
A. I didn't send it to him, no.
Q. Did you send it ~o My. Hirschhau~?
.;. . ()D his desK .
1.
G
i '").1._
~~
_:.Y
I"'-:.,' . All richt. Did you maintain a file on tte
~a~es:ine Eu~an Rights Campaign?
am su~e theye must be a file on it.
-..:: . D~d you maintai~ that file?
,,"',......I'll !\.. GOOD:!'J: ~"ou rnean in the of::..ces
MR. McC~OSKEY: In the ADL office.
\"lITNESS: In the ADL office, I beli.eve
t~ere was a manila :older with the label stat~ng
"~a2.esti!1e Human Rig~ts Campa.ign. II
MR.. McCLCSKE"{: ?~ll right.
( By McCloskey) Do }!ou know what the purpose
wo~ld be to advise the civil rights coordinators of
h~L ~he names of the co~tributors to the
Palesti~e Human Rights Committee, si~?
I would not.
~. Do yeu k~ow
I do nct.
Q. Sol Kolack,
A. I believe he
De~/ond. t~at, no.
wt2 ~cm Neumann is?
K-C-~-A-C-K?
~s ~~ c~e New York office, bu~
'~ . P.la:1 Sc~wa~tz?
bel i e \¥" e he:.. s ~ ~ :: ~ e N e 'N Y 0 r k 0 f -: i- c e .
-... - - -=G ........ ..- Ga.:-.s?
A. New York office.
Q. Joel Zand?
A. A name I am not really familiar wi:h.
Q. Ken Jacobson, S-O-N?
A. I am not familiar with Jacobson.
Q. Janice Ditchek?
A. No.
Q. Sally Greenberg?
A. No.
Q. Charles Wittenstein?
A: No.
Q. Michael Lieberman?
A. I think he is in Chicago.
Q. Betsy Rosenthal?
A. Los Angeles.
Q. And Harvey Schechter?
A. Los Angeles.
Q. Aside from your collec~i~g the info~mation on
the political contributions of those individuals,
what other work did you do with respec: ~Q the
Palestine Human Rights Campalgn?
A. I believe I mentioned to you.
I attended their public convention and made my
impYessions of the speeches by the indiv~duals.
Q. And you wrote a report?
."4. Yes.
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Q. And did those reports go to the ADL?
;... Yes I t11ey did.
~. ~id t~ey go to the South African intellige~ce
age:-.+: ?
A. ~hev did not.
Chip EerIet, B-E-R-L-E-T?'I.e:: •
A. Nc= perso~ally.
C. Eave you ever worked with him in your research?
Q. Have you ever ta~ked with him?
A. Ne"ver .
To ITIY k::owledge.
MR. GOLDST===N: Cou.ld you spell "Berle~"
:C~ the Court Reporte~.
MR. McCLOS}:~Y: B-E--R-L-E-T .
(By Mr. McCloskey) In your San Francisco police
:::~e:-'\l:ew, Mr. Bullock, ~you st.ated you shredded,
q~0~e, a lc~ of sLur:, e:~d of quotes, at t:--le ."f:.... ==o:::.::e.
Gh-hum.
~. When did you do ~ha~?
MR. GOL:JST~=~: I am sorry, can ~ have the
ques~:.o~ back.
~~~e reco~= ~as read by the Repo~~e~.
?rom time to t~me
,-- _........ - -- - ~ .... - - ........ ,."- - ., - ~
" ~
material, and then I then subsequently typed it up, I
sh~edded the notes.
MR. McCLOSKEY: Okay.
Q. (By Mr. McCloskey) This was just a housekeeping
function to get rid of materials that you didn't
need?
A. That would be a correct correct
characterization.
Q. Where is the shredder located?
A. I don't know. No, I don. ,r t know. Somewhere
In -- near the office.
Q. Where was it when you used it?
A. I it moved from place to place because it is
a small portable shredder.
Q. Where was it -- was it always in the ADL off~~e?
A. It was always in the ADL office, yes.
Q. It wasn't your shredder?
A. It was not my shredder.
Q. Did you ever shred materials for any other
reason?
A. I cannot think of any reason.
Q. Did you shred any of Mr. Elank~ort's file?
A. I did not.
Q. have you shredded any file?
rl. I have not except fo~ housekeepiTIg.
You say 11' housekeepi.nSj, " removi~g duplica~e
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rnaterial
A. Tha:'s correct.
or notes that were reduced to type?
.L.. That's correct, uh-hum.
Q. ~id anybody else in your presence stred
documents at the A~L headquarters?
1', ..........
Q. Do you k~ow what the purpose for the shredder
was?
A. Purpose was to shred documents.
Q. In you:-' interview Yli th the F. B. I., you sald you
wcrked as a volunteer in the
Mobilization for Peace, Jobs ,and Justice, known as
!v10BE
A. Un-hum.
Q. in 1990 and 1991.
Is that correct?
A. That's correct.
w ..... C'"Q. ...::l\"lha t the purpose of that organiza~ion?
(Ms. Miller left the deposition roo~.
THE WITNESS: That was an umbrella
organ~za~io~ which staged an annual march for peace,
~ODS and justice.
\ ~ ''/ My. M c C ::. 0 S J.: e :V' )
~~a~ crganizat~o~ tha: yOU deemed inimica:
A. No.
Nor did I report on it to the ADL.
Q. So this was just a volunteer job you d~d for the
benefit of humanity; is that correct?
A. Yes.
It was a volunteer job I did for me.
Q. Where was that office located?
A. On some Labor Union building, I think on 8th
Street, or 9th. I am not quite certain now.
Q. Would the -- would it refresh your recollection
if it was the headquarters of the Local ILWU on
9th Avenue?
MR. BLANKFORT: Str'eet.
THE WITNESS: You are mumbling. I assume
you said
Q. (By Mr. McCloskey) 9th Avenue?
MR., BLANKFORT: Street.
Q. (By Mr. McCloskey) 9th Street?
A. That would probably be correct.
Q. Was the purpose of you working there to observe
what went on at that Labor headquarters?
A. No.
Q. Was that an added benefit for your volunteer
work?
J.... No.
Q. Did you derive any benefit foY YOUy ADL WOYK
340
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being located there, at the ILWU?
A. No, absolutely not.
Q. How many hours a week did you work there?
A. Oh, not much.
n"w!. What did
A. Maybe maybe two hourE;. Maybe one ho·ur-.
Not much.
Q. Was the ADL aware of the work you were doing
there?
(Ms. Miller entered the deposition room.)
THE WITNESS: I don't believe I mentioned
it since it was of no importance to them.
Q. (By My. McCloskey) During the spring of 1988,
(10 you remember a petition drive asking that the
Mobilization take the position on ending u.s. support
for the Israeli occupation of the West Bank and Gaza?
THE REPORTER: "Of the West"
MR. GOODIN: " Ban k a. n d G a z a . II
MR. McCLOSKEY: G-A--Z-A.
THE WITNESS: Gaza.
I don't remember the specific, bu~ I am
sure it may have happened.
Q. (By Mr. McCloskey) When those petitions were
circu:ated, did you make copies of the names on ~he
pet.itian?
No, di.d not.T
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Q. That petition was something you wo~ld have
deemed inimical to the interests of Israel, was it?
A. And if I had seen them, I might have.
Q. Do you know a FriedheIm Ernst?
A. A who?
Q. F-R-I-E-D-H-E-L-M, Ernst., E-R-N-S-T?
A. It is not a recognizable name.
Q. Did you do any research with respect to people
in the Bay Area who had come from Israel?
A. No.
Q. Did you do any research on an employee of mine
whom you believe to be of Syrian descent or was
advised of Syrian descent?
A. I did not.
Q. Do you .know the name Natan, N-A-T-J1.-N, Nastal,
N-A-S-T-A-L?
A. Not offhand, no.
Q. He is an Israeli who lives in Berkeley.
Does that refresh your recollection?
A. Not mucIl, no.
Q. Pardon me?
.~. Not mucrl, no.
Q. Have you talked
A. Did he g~ve a public speec~, or wha~?
Q. Eave you talked to f\1r. Na.tal
_................ "'-,,-.... ,.,.. .... ...
.---- '-"~- '-- '- ...
.1. cion't krlow .
x . Eave you ever talked to any Israeli livi~g ~n
~eykelel.r, to your recollectic,n, as you sit hj2~e?
1-•. ~'~ct to rr.y recollection, no.
,r"\
',-- . M~. Bu::'lock, in your list of organiza:~ons
r was a~pe~ded as Exh~bit 6 to your dec-
depos~tion ea~lier, there are a nu~~e~
~:'<::idle East orgar~izat.ions in San Francisco, but
G
.... 0
.l. \,-,
can't ~ind a~y ~n the East Bay.
~ld you do any investigation in the Eas~ Bay O~
lss~es involvi~g Israel?
.'"r ...
.... -: Q
., ,.. i\ ~ r"i
.... ::: r')x..
~ - --'
:P-.
:; f'
..... 'x:
'" C 7\ .........
,......,
'x.::
'-::. .
~he Eas~ Say being?
~as~ 0: ~he Bay Bridge.
Be~-keley.
()arc:and.
Serkeley, I bel:'eve, yes.
y~~ did ~nvestigations in Berkeley?
:.: e s .
And wha~ was eje purpose of your invest:'9a:~ons
Be~-Ke:e1r?
?~~~ayi:y to judge the organization.
:0 you know a ~a~ ~amed Scott Dry, u-~-::
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Q. You have no recollection of who Mr. Dry might be
or what he m~ght do?
A. No, not unless you can refresh my memo~y.
Q. Do you know a man named Alan Soloma~ow?
P... Solomanow, I believe he is the Director o~ the
American Friends Services Committee.
c. Have you met with him from time to time?
A. I think I met him in a grocery store line o~e
t~me, and I believe as I was leaving the build~ng
which the ADL is located in, I ran inco him in the
lobby.
Q. Of the ADL?
Of the A- well, the building whicl1 tIle AD~
was housed.
Q. Did you understand him to be a person who waulj
be authorized to come into the ADL file room?
~... No.
(Discussion off the record between
Mr. Goldstein and Ms. Meltzer.)
(By Mr. McCloskey) Why cio you say "no"?
A.. Because he wasn't.
Q. What were the circumstances of your mee~l~g ~~~
in the ADL lobby?
MR. GOODIN: H e did:;.' t s a ~,.
Il the F.. DL lobt,¥."
He said t::'e lct)by O~ ''tA.; r:. :.. .:: :-.
-- ~ ~".-... "...," ::- .. - - - - ..-.......... ~- . '
., 1. ~he AJL has lts offices .
M:':<. McCLOSKEY: Excuse me.
~Ey M~. McCloskey) Was your counsel ccr~ec~?
C2u~sel was correc:ed. That is what s:.a~ed.
Was he corr.ing f~,om or +-r-,L.u the ADL,
6 ~:::::wle(ise?
A. dG~'t k~cw where he was going.
Might have bee~ ~o the museum which was O~ the
... n Did yo~ obta~~ a~y information from
;'v1 ~. S ~ : c :-r, a now a tan )' ~::- TTl e i nthepa s t t e 11 yea r s ?
~ ~:: rr. M2.-. Solo ma :1 0 W, no.
.,I
~
.. S~lcma~ow, S-O-~-O-M-A-N-O-W.
14
,""j '>or::: • D~d you ask Mr. 501omanow any questions?
don't recal: asking him any questions of hiffi.
- ..,- / =8 yc~ remembe~ ~eading any publica~ic~s ~~a:. ~e
1 9 022asio~ally I wo~ld look at the
(:ClSCUSS:"8:-: ~he record betwee::..
:Jid ~lOU ever gc + r-Lv >-\., .... __ ::::
- - - ~ ---------~.
~ -0" e ~ wen tOY not.
x:" •
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up some newsletters.
Q. Okay.
A.
I am nOL even certain cf tnat.
Q. Did you write a report, to yo~~ recollec~:c~,
about Mr. Solomanow or his organization?
A. It is quite possible.
() And what file would tha~ be entitled?'lIC:. •
1\ h. Maybe "American Friends Service Commit~ee. II
Q. And that would have been in the o~fices of
San Francisco that you maintained?
P-•. That's correct.
Q. And to make sure I am correct on this,
A. Dh-hum.
Q. any r' e p 0 r t s t. hat you \~ ~ 0 t e, w ~ e t. h e ~ ~ f1 W r... .:.. :.'~
paper or pink paper, you would p~t on
TM~. H~rschhaut's desk for ci~c~lation, am
..A. " That would be correct .
Q. And the decision as to who to circulate them to
would be his decision?
That is correc~.
,"""'" . And you have no k~owledge as to wtom he~
c~~2ulated?
No.
r ~ow during the past several years ~~~~l'x::'
,.... , .,Gu~vitz was t:..re:::l, ~/cu. :a=..ked
cn a~~os: a dally bas:s t ald you not?
~
r .... No: daily, but frequently.
:3 '-:: . A~d ~~d you furnish information to Mr. G~rv~tz?
4 F.. Yes, :yom time to time.
.."D.... :1 d did j' C ~ 0 b t a i:1 i. n f 0 l:-m a t ion fro m Tv: Y. G ~ :- \r .: : z ?
r -", r r .. Fr~~ t~me t8 time
7 ~ 0 ~~ 2 U Y e c a 2. 2. i n 1 9 86m a jo( i n 9 any i n v e s :. :. g a : :. 0 :l
8 c: c:::ce?~y
,.. ,- .+= .c Tr .. no ti.me investigated your or ..... lee.
_ 'v Q. Have you ever investigated any people working
~.~."y"" me?
TJ...... F.S k.r.:.ow· I 1 ~ave never investigated a
13 working fer you.
:'4 '~. . 2:: s there a:1Y fi~e l :[1 the .~DL, to your
:"5 C!1 rne?
.~, . ~~ere lS a file on you .
17 Q. :s t~ere a file O~ my wife,
Ee~e~ McCloskey Hooper (sic)?
T~ere lS no file C~ your wife.
"-', ,-::' . ~ow do you k:1oW tt3:?
~.. Beca~se I ha~d:e ~~e files so I would k~2W
- irlvescigatio:: ::'.9 S 6
-= :--- e 3 a '1" .~ y e 3. ?
C1 ... ~ J.Ok a::' .
11 =-:-: .. ~ -== s :. .::.. g a ::. .:. () n,"
~ :: ~ '- __ : ~ ~ .. ./..;:-.. 3. := - ...- - ..-. - - _ ... 0. '-- '-"Jere.
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{Discussion off the record between
Ms. Meltzer and Ms. Miller.)
MR. McCLOSKEY: All right.
Q. (By Mr. McCloskey) Did you. ask a r: j' que s ~ ::. 0 r. s
about Arab organizations in the Bay Ayea?
To \\rho? Or of whorn?
Q. Anyone.
A. No, not that I thiI1k
Q. Were you interested in Arab-American
organizations in the Bay Area between 1986 a~d 1992?
A. I am sure it would have been a matter o~ some
interest I yes.
Q. A.nd why?
4~ Pardon?•
Q. Why?
Why?
Oh, to }cnow who the orga~li.zations were, what was
their general propaganda line a~d maybe their
e~fectiveness in the communi~y.
Q. All right. Would this be true of any
Arab-American organization?
h. 7\ I think it would only be true of chose fGu~d In
~y computer.
What. the reason tha: you wcu:j be
:~terested in the Arab-American was solely beca~se
~e was an Arab-Amer~can, wou2.d. not?
( r'".... No.
. We:l, wtat other reason would you have ~or
3
'~
lccking a: an Arab-American organization?
4 r~ 0 .
I think they would have they would have to be
c po:itically active and in the marketplace of the
7 :.jeas.
8 So a~y Arab-Ameyican organization ac~ive lD the
9 political marketplace you would want to know abcut;
lG lS that C8rrect?
1 ~.. It lS pc)ssible.
"'I -+F... nd I)Ossible, yOll would want to know 1itJho tte
i:1c.i.viduals were that mad.e up those organizat:ions?
.~. Yes.
But chat is easy to obtain.
n And would you want to know the license plate
_/ ~u~beYs o~ chose individ~als?
:~ 3 Sometimes I would.
Why?
To make sure tnat ~ave the specific
~.
T~e~e are many AYab-Americans, for ins~a~ce,
s~a~i~g a 2om~on last na~e and first initia:.
~5~~ed :0 k~cw s;e~~~ically whom
...... \.-, •• • ..l ~L2.~e a m:.stake .
wrlY ~/ou WOl:..~j
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officers or Government officials to furnish you that
informat~cn?
A. On rare occasion I received a license plate O~
a~ Arab-American, rare occasion.
Q. What about the African National Congress, theye
is a whole slew of license plate numbers here abou~
members of the African National Congress.
What was your purpose in obtaining that
information?
A. I don't recal: any.
Q. Paydon me?
A. I don't recall any license plates on the
A:rican National Congress.
You might find some on SWAPO.
Q. Driver's licenses?
A. Pardon?
Q. Driver's licenses?
p.•. Yes.
C\ . There is a listing of driver's licenses for tl:.e
A:rican National Congress?
A. Yes.
Q .. What was your purpose in obtaini~g that
i~~ormation?
Well, t~at wc~ld have been of inceYes~ to ~e ~c
k~ow the members a~d the out~age of the
~~Y~ca~ National C8~gress.
..- -- ---- -.,. ....... - ~ ........ .-.... ,--r
- =-.:::-' ~ ~ - - - -- - ~
( And was this information that you were
t~e AJ~?
No.h.
~~a: would not have been of, I think,
5 cverwhe~~ing i~te~est to the ADL, unless there was a
~ c~~ss o~ AKC with one of the other left-wing
7 a~:~-Israeli groups.
.....,8 We:l, that is my question .'x:' •
9 7~e Af~ican National Congress was an
:0 8~ganiza~ion that was opposed to apartheid In
~ .L S O.L: :. h A :: ric a, was i t not?
Tha~ was one of i.t.s purpc)ses, yes.
2.3 A~d you we~e interested on the ADL's behalf on
14 a~y o~gan~zation oppos~~g apartheid in South A~~i2a,
:= we~e you nOL?
I ~ ~idn't get the question.
''loc:••
~ '71../ Please
13 fv1R. GOODIN: Please repeat it.
1 C I thi~k he said exactly the oppos~te.
TE~ W:iTNESS: ~ think exactly ~he oppos~:.e,
:"s W::lY I :8 get that. righc.
(The record was read by the Reporter. \
23 ;.... bsolutely not.
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Q. which is your report on the
Ameyican Friends Service Committee.
A. Dh-hum.
(Witness complies.)
Q. That report you put in the files of t~e AD~,
A. Uh-hurn.
Q. did ~lOU not?
MR. GOODIN: I wait a minute.
I think he testified that he did not.
THE WITNESS: I think I said
MR. McCLOSKEY: Counsel, I would ask you
not to interrupt.
I think he said just to the opposite before
you corrected him.
Q. (By Mr. McCloskey) Mr. Bullock?
A. Yes.
Q. This article about the
American Friends Service Committee was put l~ the AD~
....f i l e,
A. It is possible that I did.
Q. Okay' . So the ADL was interested in
anti-apar~heid movements, was it not?
A . I: was lnterested in certain an~l-apa~~he~j
g:~o~ps.
Q. ?lease tell me which anti-apartheid groups :~e
AC~ was ~~:e~ested in a~d which t~ey weye ~o~.
352
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T th:nk it would be those that that shared a
far lef: agenda which ~ncluded ties with the
Sa~dhi~is:a Government, ties with other commu~ist
o~3anlzations or countries.
(D~scuss~on off the record betwee~
rV:r. Goodi:1 and f\-~r . Patterson.)
~HE W:TNESS: And other extremist
OYga~i2a~ions.
(By Mr. McCloskey) African National Congress?
African National Congress until a short time ago
was considered a terrorist organization by the
U.S. State Depaytment.
Q. Was the ADL interested in the
CongYess, Mr". Bullock?
f ... ~? . I believ'e _rom L...;..me to time they actually issued
a ~epoYt. a public ~eport on the ANC, yes.
Q. And you collected information for them t8
pub~~sh that report, did you not?
J'-::" • Nc), I di(i not on ::.hat report. I had not~1i.ng to
do with that one.
But you collec:ed ~n~ormation for the ADL C~ ~he
l:-... frican Natiorlal CongYess, diel you not, sir?
A. I ca~~ot think o~ a~y specific times w~e~ wasI
., ...do c:...a sc.
'x: • C a =-: \r 0 ute l 1 IT. e t.:~ e:1 why i n you r com p 1..: :. e r
,.-... ........ .......... .. ~
a~e so ~ ~ \ (~ _. ~." :lames 0:
.-- - _ T" - ,\ ~ ~I"''''
.........: _ ...... __ _ '4 :...= - ~ - \- .~-
("
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African National Congress?
A. Because my computer contains a great deal of
material that was never shared with the
Anti-Defamation League, never.
Q. But you collected every bit cf that i~£ormation
in your computer, didn't you?
A. Yeah.
So what?
Q. You heard Mr. Gerard's testimony -
A. Uh-hum.
Q. that all of the information in his computer
had been placed there by your roommate or by you, did
you not?
A. I heard that.
Q. Do you agree with that?
A. No.
There are entries in his computer as identified
by his typeface that are not in my computer.
Q. But the information in his computer from the
African National Congress is on your typeface, isn't
' ... ?l L..
A. Again, you are using ANC.
I think more often it is SWAPO because there was
o~e publ~c meeting in Oakland at a ch~~c~ ~n whlCj
the head of the SWAPO Government spoke.
Q. SWAPO, that is the Namibian
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A. Southwest African people's
Q. group?
' A. Uh. - n t.:m .
r'\
\c:.1. And they were attempting to fulfill the U.N.
ma~date that Namibia be cut off from South Africa and
be an independent nation?
A. Un-hum.
Q. Was the ADL interested in that issue?
A. They we:re not.
Q. Why did you collect the information on SWAPO
t:;'en?
I just mentioned I put In my computer but it has
nothing to do with the ADL.
Q. But you collected the information, did ~lOU not,
Ofl SWAPO?
F... Yes, I clid.
Q. And you collected the information on the
A~~~can National Congress, did you not?
A. ~ will say yes, but without knowing specifically
wha~ you mean by the ANC.
Q. Okay.
But oka'y.
What I am trying to go back to,
did you considey SWAPO or the
;... -: :::- :.. c a:l N a :. :.. 0 r: ale c ncr e: S 3 a s 9 r 0 ups t hat [1 a d
( ~~~e~es~s opposed to those of Israel?
Ce~:a~nly the ANC had a history of that.
(0isc~ssion 0:£ the record betwee~
.; !< 1-. G c = d. s tel n a r: d Ms. Mel t z e r . )
the record betweer.
6 Elahk:c~: ar.d Mr. McCloskey.)
7 Q. ( E '/ Mr. Me': los key" ) Do you recall telling
8 =~spec~c~ Roth that you were at the t~me ttat you
9 f:~st star~ed collectiBg information for the
Sout.h A:~2-ca::1s, the~r i:ntelligence serVlce, t::at.
~e~e a:ready collec~i~g information on the
So~:~ Af~~can commun~~y here in the Bay Area ~or
No, nc~ on the Sou~h African community l~ the
On certain organizations
("\"--..
tha~ had a crc)ss lap (indicating;.
What were the orga~izations before y()U were
~~ co~~acted by the South African intelligence a~a asked
• r" •:..:-::ormat:"O:1, the organizations y~u we~e
:ook~n9 at fo~ ~he AD~?
r .... 'wcu~ci files before
~~-- a:
l.l:::: , tell you wh e t :: e ~- C~
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didn't.
(Discussion off the record betwee~
f't.s. Meltzer- and Mr. Golds~ein.)
MR. McC~OSKEY: (C'our:sel cOlrlpl:"es.)
(By Mr. McCloskey) I a m 1 0 0 kingat E ): l: .:. t, .:.:, 6 C:1
1 ~,Page Black Muslims.
This is an Arab organizat~on.
A. lS.
Q. Is that connected with South to Yo1..:r
knowledge?
? . No, noc to my knowledge.
Q. Why were you looking at info~mation abou~
Black Muslims?
I am not sure I was.
Q. Why would it appear i~ your Arat
organizations list, M:r. Bullock?
-~ . Possibly poss~bly we a~e ~ook~~g a~
na~e appeared in some public docume~~ s~c~ as ot,
~he official organ of the A?C or some~hing.
Q. If you can look at ?aae 1. ca::':: re3.C1 t.::'e
page, but it lS u:1de~ "R3 P:':1ko Or·9ar~lza~:'cl:-:s."
Uh-hum.
(Witness complies.)
,'""'\ . You want to go a~w~ ~~:.s~
0 :: t. ~ 0 seA f ric a n c ~ 9 a :;. i z at.': C h S Y 0 '-...: \\i (:::. ~- 0 =- =-_ ~J e s ~ :. gat :. :: 9
P.. can~c: possibly tell you because I Ge):) , t k:1oW
:~e da:es o~ when this was put in (~~d~ca:~ng)
~ a~~ t~e da:es wten I flrst met the South Afr~ca~.
can p~obaD~Y say that this one (i~d~ca~~~9\
r.. ...l 2. Y i ::J I: t .
6 r .. hfrican Black Students
0:-9"0:-::.za::'0111 San Francisco State, I probably ne\re~
:. :: ~.r est .:. gat e (} i ~ c' r s h are danyin for mat i 0 :1 Wi ~ ~ the
~ So~th African Governme~t.
r my q:lestion\..:.
7' h.
r let/s set as~de the South African
GCJvernmer:t. .
'x.. •
J:... U~-hurn.
What I am drawins to is your stateme~t to
I~spector Roth that it was no problem to get
~~~=~~at~on on Sout~ Af~ican organizatio~s beca~se
you are already doing for the ADL.
What I would like :0 have you do is starti~g
l:ere under these "R3 P:':1ko O:rganizations," st.ar:':"l1g
\V'::':'~ No. 25 1 the ft_:~lca:-'l Blac:k Students
orga~:'zat':'onsl to :'de~t':'fy which of these
you :.:-:vest.igating fora~2
ca:-: dOVv':-l one-t~/-c!"'.e
. ~ '"-' ,
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MR.. GOODIN: He can't answer the question.
TH:E vlITNESS: Thls is a fool's chase, w~~c~
~ will not indulge in.
I will say this: I attended a meeti~g a~
San Francisco State on All Africa U~ity conference
which included a number of extreme le:t-wing g~ours,
anti-Zionists, Sandhinista apologis~s and so fo~:~.
That was a that was be:ore I me~ t~e
South African.
And it is probably that more than any~hing
else that I had reference to if I said such a thing
to Roth, that, yeah, there were organizations that. ::L
looked at that were purportedly anti-apartheid and
they were engaging in other activities, such as
anti-Zionist propaganda which would have been o~
interest to the League.
But t.o go dowr1 this list (indicatirlg) O~
any other list and tell you name for name,
organization for organizatiofl, no, that is nClt
possible.
MR. McCLOSKE"f: P.ll. righ::'.
LO say
be:ore you were contac~ed by the Sout.h A:~icans, you
Q. (By Mr. McCloske~/) Would it be
Bay Area t~at were o~posed to apart~e~d
So~~h Af~~ca f~r the k~L?
..,. • - -- - ~,., I( ---.= '- - - --- _...... \.. - - '- ..... -
( Nc. That would not be a correct statement In
:2 a :-:~' way, s ~ a t) e 0 r for m .
Eow many organizations were you looking a~ ~te~
y"Cl..:. ga\'e sta~ement to M:r. Roth?
Flo . can think of nothing except th5: c~e
. "
6 mee:'lna 'vin':'C:l, ar.:ended at San Francisco S:ate.
7 c.
8 A. Tha: lS it.
9 C' . ~.. ll right.
10 A. Now it happens that there were a number of
o~aanizations there, not all of them anti-apartheid.
1: ~:;. :ac:, most 0: theIn were not.
., ....... Q.J..~ But i: was your purpose be:ore you
we~e contac~ed by Soct~ African intelligence, you
:s we~e looking ac groups opposed to apartheid l~
..,. '.-.., ..16 Sou:=.h ..~... £~:'ca for the ..'-....u L , were you not?
..L / 1-... No, it was not.
1 8 M?... GOLDSTEI!\: Pete, I obj ect.
You have asked this question 48 ~~mes.
1'1=MR. GOOD I:~ : 'Yeah I .... he said
MP,-. GOLDST===:-J: We can sit he~e un~i~ ~:o=
'::"C":"OC:<.
Yea~, this is ge:t~~g
...... ",,-.....- .... '''::U''-'',L, __ '. : he has answerej :.~~s
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M~~. GOLDSTEIN: Not only today not only
today but in the first session of his depcs~tion as
well.
(Discussion off the record between
Mr. Blankfort and Mr. McCloskey.)
MR. McCLOSKEY: I respect the better
memories of my younger colleagues at the Bar.
Q. (By Mr. McCloskey) All right, ~r. Bt:2.lock, t8
try to refresh your recollection, how much money d~d
you ever get from Tom Gerard?
From T0111 Gerard?
Q. Yes.
I received one $5,000 business loan to buy a
series of Paul Jaquilie prints.
I returned him the loan with $500 i~teres~.
Q. And that was the only money you got fro~
Tom Gerard?
A. That was the only money I received from
Tom Gerard, period.
Q. I am going to read to you from a stateme~t yet:
earlier identified as being tru~t~~l and ask you
again if it was a truthful stateme~t.
A. All righ.t.
() A:1d this is
MR. GOODIN: Is from the Ro:~ ~n=ervie~?
~.
MR. McC~OSKcY:
- -- - -- - "-.....,.. -. -, - - .... '" I ~ _____ ,,_ Jo'
.. - _ .... --~
, !'t1]~. GOOL) IN: All right.
~Ey Mr. ~cC:oskey) "And I began to get SOIT'le
:T:C:1ej/, I:ct ()r.ly :rcm Tom, but from quite a rtl..::nber c:
~ a 'w' e :: -: c r :: e IT1 e :1:: 0 -: fie i a 1 s II
~o, tha~ :s o~e of the errors lD the ~~:~C.
..,.."Mc:-:e:/" :~e word. 1. believe I cii.d nct
7 " :Tlo::e'y'. "
at no time d:'d I receive money from any
9 pc:ice officia:.
1.,] belie\le the wor~d should be "informatic:n."
l ...J.."":" Bu: that lS one o~ the inundations I wo~:d make
:2 ~~ t~at reporc.
".-...13 '~ . A2-2. righ.t. I wa~t to quote that for the record
14 so we aye clear.
lS ~.. Please d.a so.
16 Quot.e, II'.p_r:d I bega.n to get some money, c8mma,
C~::_\! :yom ~8m, CCT.rna, but fyom quite
l g end of quote.
1 0 your testlfficny you never made that
2: s:a-:.ernent:.?
~eve~ made tha~ s~atement.
said I' .:.:-:: c r rn a -:. :. C::, " not "money. II
'" ~....... ..-., ~ 0'-""" ~ ',- • 1vl~.... ...:: _ ',- .- .......... ~ • Rotrl.
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...::~
THE WITNESS: What?
M:R. McCLOSKE'y: I am sorr~l.
B}' Mr. Roth. Sorry.
TI-IE WITNESS: Yes.
Q. (By Mr. McCloskey) Did you get an oppor:~nity
to read this statement after it was typed?
(Mr. Goldstein left the deposition room.)
THE WITNESS: I have not read t~a~ spec~~~c
statement, no.
Q. (By Mr. McCloskey) I am refer~ing to Exhibi~ C
to the search warrant affidavit.
A. Uh-hum.
Q. The SFPD interview of Roy Bullock,
January 25th, 1993 and ~Tanuary 26th, 1993, :'rld:'cat':'ng
that Assistant District Attorney John Dwyer was
present, that attorney Robert Breakstone was presen:,
that attorney Don Margolis was prese~t.
A. Uh-hum.
Q. Those would be your attorneys, would that be
correct?
A. That would be corYec~.
Q. Were they paid by ~he AD~?
A.
re~~esent.a:':'O:1 tee:~Q. Has all () f your
by :he ADL?
;.... "fes.
-., .. -- - - - .. - ..- ....- - ,-~.......
( 1 You have not been paid a nickel?
A. have not been paid a penny.
3
2
..... So you~ s~ateme~t is you never got money ~Yom
q~~ce a ~~~ber 0: :aw enfcrcement of:icials; lS :~c~
5 co~rect?
,......-y~-c.r"-6 J...•• ~.t:sc =- ~:: ely' '-- '-' 4 ..I- ~ '-- '- I I did not.
7 A:l you got was lnformation?
8 ::1:crrnation.
Q c. A~d the only peYso~ you got money from was the
:0 ? B . T lS trLat correct?
Thac one-time one-time $500 payment.
Q. All ~ig.ht Who is Lar~ry Siewart, or "S':"ewart,
~3 S-:-E-W-A-R-T?
14 "Siewart. "
:5 ~arry Siewar~ was a Portland police offlcer wtc
deal= with the skinhead gangs.
(Mr. Goldste~n enteYed the deposit~on
lBy Mr. McCloskey' You got a report fro~
..~v !Y::-. Gu~vitz that was a:-'l ?B.I. report called
." ~:--_e ...N'at.:..on of Is2.am, " di.d you not?
:-:'::JW was t,hat jelivered to you?
xe~oxed a c:J;::'; se:::
but.-...--1 .....
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Q. Which groups did you investigate for the F.B.I.,
Mr. Bullock?
A. I believe the primary one was the collection o~
left-wing gas bags called "No Business As Usual. \I
Q. Did you ever advise the ADL that you were act:~~
• oFas an In .... ormant for the F.B.I.?
A. I believe I mentioned that I had contact wit~
the F.B.I., :yes.
Q. Who did you no, that isn't the question I
asked you.
A. I know.
But I don't like your use of the word
"informant," so I will use the word "contact."
-. n .....Q. You previously testified that you served as Q
informant for the F.B. I., Mr. Bullock; that is why::
used that term.
You used it, but I don't like the word.
Q. You may not like the word, but my question is
you were an informant for the F.B.I., were~'t you?
A. I gave them material o~ some o~ these left-wine
groups, yes.
Q. You were an informant?
A. I gave them material on some of t~ese le:t-wi~g
g~cups.
You ~ndeYstand t~a~ to be a~ ~~:c~ma~~, ac Y8~Q"
:-:ct?
(7. .".
2
4
I I
~ ..-/
1~
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n" . I give them material.
We may continue this charade all day, s~r.
PJ..TTERSONr: Yeah, this is staYtl~a to
~aYass ~ie wlt~ess.
MR. GOODIN: It also asks for specu~a~:2n.
~ e doe s n 't l:' key 0 u r w0 r d 0 ~ II:" r: :: 0 Y IT't d. :: ~ . "
tv:R. McCLOSY:EY: Well, he testified eayl:e~
t~ac he was a~ in£ormant and he was a paid info~mant,
and his testimony is under oath, and I think I am
e~tit:ed to use that language under the circumsta~ces
s:~ce he gave it as his testimony. He gave
MR. GOODIN: I: he supplied informat~on a~d
~~at lS aD informant he said he supplied
~~:ormation.
MR., McCLOSK:C:~": Can we scipulate, Cc)~:-~sel,
te is an informant?
MR. GOODIN: No.
We can stipu:a:e to your defin~t:"o~ 0: II i::£oYIT.ant, II ar:d tl1e~ we can go ahead and anS",jey the
That is ~~e easy way to do it.
TE~ WITNESS: Correct.
All right Le:.' s go Jo.-Jo'\-;),..
where he sta~eG ~~ W~5 a~
c: t~e
2- e t ' s t:-;'e record.
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(Discussion off the record.)
MR'.. McCLOSKEY': Let's put on the record
that Mr. Bullock has indicated he will stipulate tha:
he answe:-ed "yes" to the question as to whether he
was an informant.
MR. GOODIN: Earlier in the deposition.
THE: WITNESS: Right.
Q. (By Mr. McCloskey) And let me give you the
opportunity to state yo~r definition of what is an
informant, Mr. Bullock.
MR. GOODIN: Go ahead, say what say wha~
the definition definition of an informant was as
to which you ~3ave the answer Ilyes."
THE WITNESS: That is that I shared
information with the Bureau on a numbe~ of s~bjects
that they were interested in, primarily the left-wi~g
organization No Business As Usual, and occasionally
some of t~e violent right-wing groups, skinheads.
Q. (By Mr. McCloskey) And on one occasion you were
paid for that, were you not, by the F.B.I.?
A. I believe I have mentioned that.
Q. Now, you would also characterize wi~hin your
definition of "informants" the so-called of:lc~Lal
scu~ces you refeYred ~o that gave you in~o~mat~on,
wo~ld you not?
.~ . r~"J l t h i n my de: i nit i C) n, yes .
- \," C =- ~_. ~< ~
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Q. So that if a police officer was asked by you to
f~~~ish a driver's license or any other info~mation,
ttey wo~:d be an informant for you?
MR. GOLDSTEIN: I am sorry, can I get tha:
back.
(The reco~d was read by the Repcr:er. \
MR. GOODIN: As he uses the term ycu a~e
sa j'"l n s?
MR. McCLOSKEY: Yeah.
TH:E WITNESS: Yes.
MR. GOODIN: Correct, Pete .
T:iE WITNESS: Yes, uh-hum.
() . (3~i Mr. McCloskey) And the so-called string
people that you ran to obtain information fo~ you, to
get information for you, they would be informants for
llCU, WO':lld trley not?
A. I~ that use of the term.
C a :: you est i mat e ~n 0 vJ mu c h 0 f the AD L Tn C :1 e ~' '/ 0 '~
used to pay informants over the last ten years?
~aven't the s~~ghtest idea, but I wcu=-cl ta}~e
~- tc be minuscule.
Q. More than a thousa~d dollars?
Ce~:ainly not mo~e than a thousand.
.d. ~~e~e would t~e ye=ords of those payme:::s re
I ~ave nct tte s~~9htest idea .
- - - - - - --- -- -,~ f' -... - ..... .. .,. ....-.. -- ... ~ ~ ~ T"'"-"'I
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Q. But the bulk of them were paid to you from the
San Francisco office, were they not?
A. Either that, or the Los Angeles office.
Q. So either the San Francisco or Los A~geles
office would have given you money for your
informants
A. That's correct.
Q. after you submitted a voucher to them asking
for that morley?
A. That is correct.
MR. McCLOSKEY: Carl I ask, Counsel, can we
get those records?
MR. GOLDSTEIN: What?
MR. McCLOSKEY: They haven't been fur~ished
yet.
MR. GOLDSTEIN: I don't think they have
been asked f()r.
MR. McCLOSKEY: I think
MR .. GOLDSTEIN: And I am not sure we have
them.
MR. McCLOSKEY: All right.
We \vill go -_.
MR. GOLDSTEIN: We can address th~s a~ter
the de;;csitiofl.
MR. McCLOSKEY: Sure.
Q. (By Mr. McCloskey) My. BtllloCK, let. me ~!C bac:~,
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lot- to the exhibit on Mr. Zeltzer.
(Discussion off the record between
Mr. Goldstein and Ms. Meltzer.)
'f I rna}' I
Q. (By Mr. McCloskey) Did you maintain a file in
the ADL office in San Francisco on Mr. Zeltzer?
I d:.d.
Q. Ar:d thlS page, Exhibit 10, showing - - let me
M~~. GOODIN: Let's let him see.
MR. McCLOSKEY: Yeah, let me show J!OU
tha~.
(Counsel complies.)
(=nd~cating.
THE WITNESS: Uh-hum.
(~ . (By Mr. McCloskey) That shows a driver's
license record?
Yes.
Q. Without identifying the individual, did you
receive tha~ from what you refer to as a police
o~~~cer or a governmental source?
A. Yes.
When?
..l:.. . ~~el2., I clon't know .
Whenever the en~~y was made.
And this would have been a d8c~me~~
~laced In ~~. Zeltzer's f:le?
MR. (30LDS~:::=N:: Objection.
370
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Already asked and answered las: time.
MR. GOODIN: Object.
MR. McC'LOSKEY: I don't thi~k so. cen/t
remember asklng.
MR. GOODIN: ~his lS cne o~ the c2mpu:er
f:.l.es. That is not
MF~. McCLOSKEY: Yeah, this was fyorn tl1e
computer file.
Q. (By Mr. McCloskey) But was this put in
Mr. Zeltzer's file at the ADL?
A, I strongly doubt it.
Q. Why?
A. Because it would not have been particularly
germane at that point.
Q. What would you -
A. I left it in my computer.
Q. Why would you collec~ that information on
Mr. Zeltzer?
A. Once again, I need to know wto he was and be
absolutely correct in my identifications c~ h~m.
Q. So "}tOU w()uldn't cO:1fuse hi:n wi.th an-:i c)t~er
Steve Zeltzer; is that correcc?
A. Uh-hum. Could be.
Q. Now did you wyi~e a ye8crt of ~r. Ze:~zer ~~Y
.,..
.J.. I
.,. ..... ~- --".... '- - ~. a ____
c
- --
C. Do you know where it is?
Nr-Ii.. v .
Q. Is a repor:. )l()U gave to the ADL?
don't understand your question again.
You mea:~ does
-.::: . tha: you wrote on Mr. Zeltze:: a
rec8rt t~at you gave to the ADL?
P.. T d:.d, J/es.
Q. Do you k~ow what happened to it?
A. I do not..
Do you k~now It y.,ras circulated?
do D:)t.
Q. 80 you remembe~ whecher it was on pink paper o~
wh:'te paper?
F.. :L do not.
Q. Okay. When A:JL uses the term "official friend,"
to your knowledge, ~s that used to mean a~
Is~aeli Government off~cial?
A. Sorry about tha:.
No.
Q. What does It mea~ ~n ~he ADL parlance?
A. I believe it re~e~s to a police source.
Ha'\l'2 \'''-''''! e~JeY ~ave you ever discussed wi~h
term
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Q. Well, then why do you say that you believe it is
a police officer rather than an Israeli official?
A. Because that did come up as a perhaps in a
document I sa,w , it sai.d "police friends," anci
said or it said "officia2. friends," arld I might
ask S 0 meon e III 1sthis pol ice I" and the y say "y" e a h . "
Q. Who did you ask?
A. I have no idea at this point now or when I asked
it, or whatev"er.
Q. At any time in 1986, Mr. Bullock, did you, meet
an official of the Israeli Government here in the
San Francisco Bay Area with Sergeant Thomas Gerard?
A. No.
Q. Were you present at a meeting with
Se~geant Gerard and an official of the
Israeli Government in 1986?
A. Not to my knowledge.
MR,. GOODIN: Same
Q. (By Mr. McCloskey) Pardon me?
A. Not to my knowledge.
Q. Did you at any meeting in 1986 recelve
information from an official of the
Israeli Government about Arab individ~als O~
o~ganizations of Arab-Ame~~ca~s in the Bay Area:
A. Absolutely not.
Q. Did you do any inves~igation of a~ orga~~zatic~
"1 ., "1
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.... ..... ..... -... ,-.... .,.. or' ..,.. ... -.-- -- --~ -- ~ --- -.\.
.. ... - - ---...-
- - - -
( 1 c3~led the DFL? in 1986?
2 A. Did T do i~ves~~gat~cn?
~
4 •..:.... . 1J 0 .
--' :0id collec:: an 2' ir1formation cn the
.......
7 ?. ":{e s .
E Q. Ca~ you tel: us what the DFLP was.
G A. Democratic Frcnt fer the Liberation of-' ~ J Pa~estine, 1 believe.
Q. And wha~ was the work that you did to
1: i~ves~igate them ~n 1986?
A. No, I did not i::ves~:igate them, which is a good
~4 place to clear up tha: semantics.
Q. Whac ~as the WGyk you did with respect to :~e
~em8c~atic ?~ont for :he Liberation of Palestine In
1986?
A. I received some in~ormation as far as ~ames a~d
l? add=esses f=om Tom Geyayj concerning PFLP memneys.
never- contac:.ed sir1g.le person, Ile'ler
., . ::OtlSe, ne\"e~ mad.e a single t.E~J_epncne
~_ ca~l, never s~~ve~:~ej O~ tailed anyone.
."......, .... T ISo .t-" I that placejLA
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San Francisco Bay Area?
A. I never discussed any subject with any
Arab-speaking informants from the Bay Area.
Q. Well, let me put it thi.s way: Did you speak
with any Arab-Americans who had an Arabic-speaking
capability, to your knowledge?
A. No.
Q. Did you speak with any Arab-Americans of the
DFLP during that period of time?
MR. GOODIN: 1986?
MR. McCLOSKEY: 1987.
THE WITNESS: I dorl' t think SCI, no.
Q. (By Mr. McCloskey) Did you receive any
instructions from Mr. Hirschhaut in 1986 about the
DFLP?
A. I cannot recall any specific instruc~ion.
Q. In all of this period of time that you worked
for Mr. Hirschhaut, did he ever give you any specific
requests to obtain informacion about Arab-Americans?
A. About Arab-Americans?
No.
About organiza~~ons?
Yes.
Wha~ we~e those instruc~~ons?
l~ • Me~ely to look ac the organization and see wha~
ad'v'oca t. ed 1 what was its propaganda p:aLfo~~.
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Q. In making that investigation to determIne what
its platform was,
Cr.. -hum.
Q. and collectir1g the information ~tat you.l. .. l
d~d about the individuals that made up the groups,
:.Jh-hum.
c. did you convey that information on to
lvlr. Sua2.1?
A. I did not myself, no.
Q. Well, did you put on his desk a reporc that
cQntained that information?
That could well be.
Q. Was Mr. Suall aware then during this past pe~~od
be~ween '86 and 1992 that the informaticn ttat yo~
weye cs~lecting included driver's license
I am not sure i: any
Are we speaking of the PFLP?
Anybody.
Oh, I am sure some driver's license materlal was
p~:;tabllr i~clucied i:1 some o·c the reports, }/es.
Tha: you gave to ~Y. Hirschhaut?
'Ie s .
3u~ as a rule c= ~~~mb, that would no~ De ~~e
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fact that the information you were furnishing him
included driver's license information?
A. Not -- not as a discussion, no.
Q. Did the information that you furnished
Mr. Suall excuse me Mr. Hirschhaut during thlS
period of time include post office box information?
A. There would be an occasional P.o. box.
Q. Did you ever discuss with Mr. Hirschhau~ your
collection of the post office box numbers?
A. I did not.
Q. What was your source of information; without
identifying individuals, where did you get the post
office box information?
MR. GOODIN: I object.
Asked and answered.
He said he got some from Tom Gerard a~ the
last deposition.
MR. McCLOSKEY: Sc)me, I
MR. GOLDSTEIN: And he also said some would
be available.
MR. GOODIN: Right.
THE WITNESS: Uh-hum.
MR. McCLOSKEY: Well, tha~ is what I am
try~ng to pin down.
MR. GOODIN: Pete, Y.lhat I am saying is we
went over this last time.
(1 MR. McCLOSKEY: I was I am not clear
2 about what the sum total of his testimony is; tha: lS
3 let me clarify this.
4 ()ka:f·
5 MR. McCLOSKEY: I will be very brie~ on it.
6 THE WITNESS: Uh-·hum.
7 Q. (By Mr. McCloskey) The post office box
8 infcrmation that is reflected in these voluminous
9 computer reports, can you identify the tifferenc
10 sources from which it came?
11 A. No, not specifically.
12 Q. Not by -- not by name.
13 Some of it came from public sources; is that
correct?
l :::: A. Some from public sources.
16
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Q. Some of it came from governmental sources; is
17 tha~ correct?
18 A. Governmental sources?
19 (2 . Police officers, postal officers.
Police officers, all right.
How about postal officers?
2 D
):.. . No.22
., ...Did some of ...... come from trash bins that yc~L.2 :3
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me a rot:~.h'\,," O'U l1ave'lor;: •
""---------------------~-----'--------
I
c
( .... I
I ap~roximat~on of how much of it came from
(Wi~ness shakes head from side to side.)
,..-.., ''x:.' • governmental sources as opposed to what you
through trash or from public sour::es?
tv:R. GOLDSTEIN: Let me just objec~ as t=
6 vag~e a~a ambigu8uS.
Pete, y.,Then yOll sayr "governmental sources,"
vc~ mea~ a confide~tial confidential
MR. McC!.JOSKEY:: (:onfidential.
1 J MR. GOL:JS:'EIN: as opposed to
g~vernmentally-available sources of information?
fviR. McC~OSKEY: ~{es, that is \A/l1at I arn
13 t~yi~g to get at.
Thank you.
THE WITNESS: NO I can not really.J
(3y Mr. McCloskey) Can you tell me why those
1 -; pos= office box numbers that are reflected i~ ~~ese
~ vc~u~inous records t~a: were in your computer sho~~d
be :-emained should be retained as confide~~ial
~~ h ~/ the l' s h 0 '-..: :. d b ere t a i ned ?
Q. Yeah.
P-•. 3ec~use tho.:: :. ~.. e ~mpetere u~de~ w~~c~
t. :-: i s Tn ate ria 2. W0 l-:. ~.:1 e \/ ~ ~ h a',,· e
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been made public had it not been for the foolish
decision of the Assistant District Attorney.
n . What decision?~
A. To release them.
Q. When you collected the in:ormation on pos~
o:fice boxes, it was not your intent to make that
information public, was it?
A. I would no, that would not be my inte~t~on.
Q. And you had no reason to believe when you
collected that information that it ever would be made
public, did you?
A. That's correct.
That was merely background material.
Q. This was not information you were collecti~g :c~
a publication I:;,f ADL, was it~?
A. No.
Like any journalist, it would be material wnlC~
yeu collect but do not necessarily ever intend to
publish.
Q. Yeah.
Now w~y should that in~ormation remaln
confidential, in l'our opinic)n, Mr. Bullock?
MR. PAT~ERSON:
If you are aski~g for a ~egal conclus~o~ o~
that, you i: l'ou a:r-e talkirlg a:Ocut~
M- T.l ..I"\.. McCL(JSKEY:• ...L
( 1 :egal~y.
Is this ranked to t~e
3 ordey; aye )l()U tr'ying to set some:b.i~s
4 :.~.eYe?
5 Q. (E~/ Mr. McClosKey) I am merely ask~ng wha: ~s
'6 j'" C U :- ~ ~ a me 0 := !:" e feY e :: .= e,. ~1 11 Y i sit t hat p 0 s t c ~ fie e
7 box ~n~oYma:io~ shou~d not be made public?
8 ..l::.•• am net sure wty it should for that matter .
Q. Pardon me?
2. J cut I didn't.
\.::: '. Yo~ have no reason why that information
12 s~,:)t.;.2.ci:1't. be made pL:~olic, do you, sir?
~.. .;lt~'8ug~ it to tl1e best of my knowledge, the
:4 hSL ~eve~ did so.
lS '-!.. I u~deYstand tha~.
But I a:Tl asking
17 .~- . _7:...1l r:" g h t. .
just for you~ op~nion.
19 ~~ your opinion, ~s there any reason not. to make
~U :~~se pest office box ~~mbers public?
As ~ar as I am co~cerned?
~o.
j~es c~e fac~ that ~ pe~sc~/s
~s :a~ as I a~ =~~=~~~ed, i:. does not.
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Q. So why did you collect the information?
A. (Indicating.)
Q. Why did you collect that informa~ion on the post
office boxes?
A, Well, I didn't collect them to be a t~reat to
them.
I collected them to gather the infoYma:ion.
Q. But what what was the impcrta~ce to yeu of
post office box fi infc)rmation?
A. I: would be very germane to know who was the
holder of post office box such and such a number and
was
Q . Can you
A. was this post office box disseminating
anti-semitic material, was it the focal point cf
threatening letters, exactly who was it and whac are
they doing.
Q. So part of YO'ur job, aE; you saw ::or :~e
was to collect the post office box number of any
individual you were interested in i~ves:iga:~~g for
t~e ADL?
MP~. GOODIN: Any individual or some
ind:.viduals?
MR. McCLCISKEY:
MR . GOODIN': I your questio~ is vague.
MR. McCLOSKEY:
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TEE WITNESS: It is too broad a
c~aracterization.
MR. McCLOSKEY: All right.
D~~ ~t down.
THE WIT!-JESS: All right.
(Ey Mr. McCloskey) Each one of the names in
ycur computer has a space for the post office box
i~£o~mation.
A. Uh-hum.
Q. Why did you collect the post office information
o~ those individuals?
If the individual post office box was known,
put. l:' in.
But you keep using "post office bOJ(II and
"VClUITlinous material" as though the post office box
was i~cluded on every en~ry in my file.
is not .
Q. agree with tha+:, ~1r .
7\ .t-"•• :'hank you.
have gone have gone through with some
ca~e
Uh-hum.
the :h.cusancis n arne s that
:Jh-num.
A~d yo~ a~e cc~~e2~ ~~at not every c~e ~as ~~e
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A. Uh-hum.
Q. But everyone has a place for post cffice box
ir:formation
A. That is the
Q. on your form.
"ft•. That is the software program.
Q. Right.
A. Yeah.
Q. Why did you put into the program the post offlce
box as
A. That seems a germane
Q. as an item of information?
A. It seems a germane piece of information.
Q. All right. What is the value to the ADL of t~e
post office box information?
MR. GOODIN: I mean this has been asked a~d
answered.
I object.
THE WITNESS: I explained this once to you
a2.ready.
How many times must I go over th~s type c:
~3~ound?
MR. GOODIN: Pete, i:. lS not.
THE WITNESS: I am rea:~y tired of t~is
co~t~~ually hecto~ing now.
IMR. McCLOSKEY: COtl:-:se 2.
:3 S ~
'r"" ..-.... - _"T" ~ 'f
.. - - - . ,
( THE WITNESS: Either come up with a fresh1
2 c~es~~c~ 8~ forge~ it.
\:;iscussion O F':: ........ the record betwee:1
~:-. 3c,=":='s:.e::1 ar:d Ms. M:.ller.
5 ! rv:?.. o GOODIN: Pete.
~1cC~OSK=:1:" : )\11 right. A.re you
7 i~s~~~c:~n3 h~m not to answer this ques~ion?
8 MR. GOODIN: Well, let's take a break.
MR. McCLOSKEY: Let's be clear on this.
MR. GOODIN: Let's take a break.
MR. GOLDSTEIN: Let's go off the record.
MR. fV1cCLOSKSY: All right.
(Recess taken from 1:32 p.m. tel 1:39 p.m.)
MR. McCLOSKEY: Let's go back on the
Q. (By ~~. McCloskey) Mr. Bullock, duying t~e
re2ess, yeu have heard counsel exchange comments
~b about pest office boxes.
~o your knowledge, lS the information about a
~~ pe=so~/s post office box something that could be
:~reate~~~g to him i~ putlicly known?
depends UpO:l. t~e ,. ~
OrJ.glD O.l. that i::1!oymat.:'on.
~c~e ?o. boxes was give~ to me by con~~de~:ial
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Q. All right. That that is fair enough.
A. All right.
c' . Did you discuss that during the recess w~th
counsel?
A. No.
I had no need to.
Q. All right. That is what I was try~ng to drive
a:.
Other than perhaps giving a clue to the fact
that the information had been obtained from a
c6nfidential informant, is there anything about the
ex~stence of a post office box that is threatening tc
an individual?
A. Outside of that proviso, not that I can think
of.
Q. All right. And some Ol:4 this post o:Efice box
in~ormation that you obtained from confidential
i~~ormants was included in the reports that you gave
;:1r. Hirschhaut, was it not?
Sometimes, yes.
And I believe it is yo~r ~estimo~y earl~e~ tha~
yc~ never discussed this with ~~~; he did~'t
J-i . As a general,
discuss it with
it wouldn'~ come up In co~versat~on, no.
'.c:.' • ~id he ever mention the fac: tha: you were
... 1 ~ ...... --,..,,--\ I 'f' .......
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post office box information to him?
A. I do~'t recall any specific conversation ~hat he
C. D~d yo~ ever say to him that those pas:: off~ce
DCX numDe~s should be kept confidential beca~se the\'
~~j come ~~om offic~al sources?
J.:.. . No .
f'tlR. McCLOSKEY: I have no furthey
q--..:es::i.ons.
MR. GOODIN: Okay.
MR. GOLDSTEIN: Good. Done by lunc~.
MR. McCLOSKEY: Let's talk housekeep~ng.
GOODIN: This is off the record, Dawn.
(Discussion off the record.
(T~me no::eci:
--000-
18
ROY BULLOCK
22 S~bscyibed and swor~ :0 before me
day of 1995.
. .., -=--:-~ a :-'4 (J. ::he St.ate
Santa Cl.ara
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COMP-U-S(:RIPTS 275 Saratoga Avenue, Suite 140 Santa Clara California 95050
(408) 261-9795 FAX (4 0 8) 261 - 979 8
DATE: January 10, 1995
TO: MR. ROY BULLOCK Amour, Goodin, Schlotz & MacBride 505 Sansome Street 9th Floor San Francisco, CA 94111 Attn: Robert Allan Goodin, Attorney at Law
RE: SHABBAS, et ale vs .. ADL, et ale DATE TAKEN: December 21, 1994
Dear Mr. Bullock:
The original transcript taken in the above matter has been prepared and is available at our office for reading, correction and signature.
Your rights re signature of deposition are con~ained
in the Code of Civil Procedure, Section 2025(q).
Unless otherwise directed, your original will be sealed after thirty days from today's date.
If you wish to make arrangements to review th~s
original, please contact our office during reg~:ar
()ffice hours, 8:30 a.m. to 5:00 p.m. and IT1ake a:1 appointment to review the transcript.
Si:1ce~ely,
Camp-U-Scripts
388
~~POSI~=ON OF RCY ;~~~OC~ -