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ELIZABETH SEXTON TESTIMONY

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in by the organization, broken out by analysis in a course, stretching back to the late seventies and eighties. This organization, and this entity, this movement, this caucus, this attempt to further a political movement, could have been, the evidence will show, sustained in a way that would have permitted it to meet its obligations had there not been this interference. The Government's own evidence will show that these people, who are brought before you today, had a reasonable expectation of that result.
At the end of this case, I, too, will ask you to return a verdict of not guilty against Mr. Spannaus and the other defendants here.
THE COURT: We will take a short recess. Then we will hear the Government's first witness.
(Whereupon, at 3:57 p.m., a short recess was taken.
THE COURT: Call your first witness.
MR. MARKHAM: The United States calls Mrs. Elizabeth Sexton. Whereupon:
ELIZABETH SEXTON was called as
a witness in behalf of the Government, and having been first duly sworn, was examined and testified as follows:
MR. MARKHAM: Your Honor, I will be asking her about various exhibits. May the Marshal place these in front

of her in a stack?
THE COURT: Yes, sir, MR. MARKHAM: Thank you.
THE COURT: Can you give defense counsel the exhibit numbers or have you already?
MR. MARKHAM: Your Honor, they have the exhibit in front of them. I will.be asking her about the Exhibit Series 1, 1-A through 1-W, which are in the first part of the first book which we provided to them.
DIRECT EXAMINATION BY MR. MARKHAM:
Q Would you tell the jury your full name, please.
A Elizabeth A. Sexton
Q And -- just one moment until we get the acoustics.
A Thank you.
Q Where do you live, Mrs. Sexton?
A I live in Connecticut, Town of Suffield.
Q How long have you lived there?
A Twelve or 13 years.
Q Mrs. Sexton, have you ever lent money to anyone?
A Yes , I have.
Q To whom?
A I have lent it to GDI.
Q What is GDI?
A Caucus Distributors, Incorporated.
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A Several of the members of that group, but the one that got through to me was
Q Have you ever seen personally?
A Yes, I have.
Q Where did you first see her?
A In my home.
Q Do you see her here in the courtroom today?
A Yes .
Q Would you point out where you see her?
MR. WILLIAMS: Your Honor, we have no objection. The witness can identify my client,
THE. COURT: This thing of going through with the witnesses identifying defendants and asking them let the record show them, unless there is some issue oĢ identification, I won't reguire that of the Government. MR. MARKHAM: Yes, Your Honor.
THE COURT: If the defendants want to make an issue of whether they recognize somebody, that's fine. Otherwise, we don't need to go through that.
MR. MARKHAM: Yes, Your Honor. BY MR. MARKHAM:
Q How much money did you lend Caucus at the reguest
of ?
A In total, $112,800.
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Q May I ask you, itia'am, to turn to Exhibit 1-A. There are two pages in that folder, are there not? Can I ask you to turn to the second of two pages.
A Yes.
MR. WILLIAMS: Your Honor, I object, unless I can see the original. All I have is a xerox copy. I have never seen the original of this document.
MR. MARKHAM: Your Honor, the original was filed a week ago pursuant to your order and has been in the courtroom from 9:00 to 5:00 pursuant to your instructions.
THE COURT; I am not going to reguire that each of you be shown not only a copy but also the originals. BY MR. MARKHAM:
Q What is the second page of Exhibit 1-A? Have you seen it before?
A Yes, I have.
Q When did you see it?
A I saw it when I wrote it. It's a check.
Q For how much?
A $5,000.
Q Payable to whom?
A GDI.
Q Did you write out that check?
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A Yes, I did.
Q After you wrote it out, what did you do with it?
A It was picked up by a runner of GDI.

Q When?
A That same evening.
Q Do you remember the date?
A February 22nd, 1985.
Q And prior to your writing out that check, did you
have a discussion with ?
A Yes, I did.
Q Do you remember what she said to you in that discussion?
A She asked for this loan. It was to be a loan, and she asked for it because I was interested in helping with the promotion of their book, Dope, Incorporated.
Q And did you and discuss when you
would be paid back?
A Yes.
Q What did she say about when you would be paid back for this loan?
A In one year.
Q And after you wrote out that check, did you receive
anything back from Caucus
Distributors? A I received a promissory note.
Q Take a look at Exhibit 1-A. What is that?
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A It's a promissory note. Q
For how much?
A Made out to me for $5,000, signed by . Q And does that promissory note indicate when you would be repaid

this $5,000?
A It says payable as follows: one year. Q
One year from when? A From the date
that's above. Q What's that date?
A February -- this is a copy, and it's difficult to read. It's February, 198 5.
MR. MARKHAM: Your Honor, I would offer 1-A and 1-B into evidence.
THE COURT; They will be received in evidence. MR. MARKHAM: I'm sorry. It's just 1-A, page 1 and 1-A, page 2. I apologize.
(Government's Exhibit 1-A was received in evidence.) BY MR. MARKHAM:
Q I would ask you to put 1-A aside, please, and turn to 1-B.
Now, after you lent the $5,000 that you have just
testified about, did you have additional conversations
with ? A Yes.
Ill
Q And in the conversations that you had after lending the $5,000, what did you and she discuss?
A We discussed money. She wanted more money.
Q And what did she ask you for?
A She asked for as much money always as I could get; and she asked if I didn't have any investments that were

coming due, investments that I could turn into cash, and there did happen to be another one of $5,000 coming up; and I was very interested in educating, helping to educate this country in the problem of drugs. And that's what this book was about. All of this money was to be, to get the book published. That was Dope, Inc.
Q And did you agree to lend her more money?
A Yes, I did.
Q Would you tell the jury what is in Exhibit 1-B, pages 1 and 2.
A It's a check made out to GDI, February 26th, 1985, for $5,000.
Q Whose check is it? Whose check is it?
A It's a check I wrote. My signature is on it. Q Did you give that to someone after you wrote it out? A Yes. A runner came and got it at my house. Q What else is there in the folder, which is Exhibit 1-B"?
A This is a promissory note, written to me, February
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23rd, 1985, signed by and payable in one
year from the date that's written above here, February 22nd, 1985.
MR. MARKHAM: I would offer 1-B into evidence at this time, Your Honor.
THE COURT: It will be received in evidence. (Government's Exhibit 1-B was received in evidence.) BY MR. MARKHAM:

Q Now, did you and ever discuss the
likelihood of your being repaid on these two loans which are now in evidence, these two $5,000 loans? A She assured me that I would be repaid. Q Did she make any further assurances to you about how safe your money was invested with her?
MR. 'WILLIAMS: Your Honor, objection. He is leading the witness.
THE COURT: Objection overruled. BY MR. MARKHAM:
Q Did she make any further assurances to you as to how safe your money was?
A J assured me that my money was safer with GDI than in my bank or in any of my investments.
Q Did she indicated to you that there was anything that might happen to Mr. LaRouche or anyone else that would
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prevent you from being repaid? A Never.
MR. WILLIAMS: Your Honor, I would object again, as leading the witness, suggesting the answer to the witness he wants.
THE COURT: Objection overruled. BY MR. MARKHAM;
Q Where did the money come from that resulted in the two $5,000 loans that we talked about so far1.

Q Did you explain — did you ever discuss with where the money came from?
A Yes, I did.
Q What did you tell about where this
money came from?
A I told her that it was money that my husband had left me. It was what I considered by working capital. It was the money that I invested and lived on on the returns from it. I also had told her that I needed to help ray daughter and three grandchildren, because she is a single parent and needed help.
Q After you told her these things, what did she say to you?
MR. WILLIAMS: Your Honor, I object. This
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conversation has no time. It's a general conversation that they are discussing here on the stand. They have not pin- . . pointed the time.
MR. MARKHAM: I will withdraw that and ask another guestion, Your Honor. BY MR. MARKHAM:
Q How many times did you tell that
you wanted this money to support yourself and to help your relatives?
MR. WILLIAMS: Objection, Your Honor. That doesn't cure my objection. I am talking about a specific conversation .

THE COURT: Objection overruled. BY MR, MARKHAM:
Q How many times did you tell that you
wanted this money to help your family and to live off of? A I don't remember how many times I told her, but she certainly knew that I could not afford to live without it.
MR. REILLY: Your Honor, objection. BY MR. MARKHAM:
Q Why do you say she certainly —
THE COURT; Wait just a minute. When there is an objection, don't ask any more questions until it's ruled
This is -Mr. — ,1 realize this is a conspiracy count here, but I think this ought to be Mr. Williams' witness
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If he doesn't adequately express your objection, you can tell him.
MR. WILLIAMS: Your Honor, she as I understood her
testimony testified as to what Mrs. n or
knew. She can testify to what the conversation was but not what she knew.
THE COURT: I think that's correct. The objection was that we didn't pin these conversations down in time. I think that's a valid objection. You haven't cured it yet.
MR. MARKHAM: Yes, Your Honor.
MR. WILLIAMS: Your Honor, could I have that

stricken, that last answer about what she knew?
THE COURT: Yes.
Objection sustained to it, and it will be stricken. BY MR. MARKHAM:
Q Mrs. Sexton, do you remember approximately when it was
that you had discussions with about what you
were going to use this money for?
A talked to me nearly every day, and we spoke in a very friendly terms. She knew a lot about me, and I learned a lot about . e knew — no -- I'm not supposed to say that —
THE COURT: The guestion is when, not what she knew What did you talk to her?
THE WITNESS: I talked to her in January, February,
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March, April, May, June and all that year. BY MR. MARKHAM:
Q What year?
A 1985.
Q And during the time period of January to June, 1985,
did you ever tell what this money was going
to be used for by you?
MR. WILLIAMS: Your Honor, I object. January to June of 19S5 is a six-month period now. I object to that kind of —
THE COURT: Objection overruled.
MR. MARKHAM: May the witness answer, Your Honor? THE COURT: Yes. BY MR. MARKHAM:

Q Between January and June of 1985, did you tell
what this money was going to be used for by you?
A Yes .
Q What did you tell her?
A I told her it was money I needed to live on.
Q Did you tell her anything else about the money, other than that you needed it to live on?
A I told her I was in the habit of helping my daughter.
Q And after you told her -- how many times did you tell her that? Do you remember?
117
A No, I do not remember. Q Was it once or more than once? A It was more than once,
Q And after you told her that, did she say anything to you about whether you would get the money back?
A She told me my money was safer with her than in the bank and 1 would have- it back in a year. Q Now —
MR. MOFFITT: Your Honor/ first of all, safer with her or safer with the person that was borrowing money?
was not borrowing money herself. THE COURT: What she said was her. BY MR. MARKHAM:
Q Now, let's back up very guickly and tell the jury

what the date of the first $5,000 loan check was and the date of the second $5,000 loan was. THE COURT: She has already testified to that. MR. MARKHAM; I apologize, Your Honor. BY MR. MARKHAM:
Q May we go then to Exhibit 1-C. Do you recognize Exhibit 1-C?
A Yes.
Q And what is that?
A It's a check made out by me to GDI, April 5th, 1985, for $25,
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Q Who asked you to write that check out?
A
Q And as of the time she asked you to write that check out, had you met her?
A Yes.
Q When did you first meet her?
A Just prior to this.
Q Prior to this third check?
A Yes.
Q And how was it that you and she communicated on the times that you communicated before in connection with the first two loans?
A We communicated only by phone, and I indicated to her that if she wanted me to loan her this amount of money, that I knew her only by voice; I would like to have met her. I would like to get to know her. I wanted to know what

she looked like and wanted to spend some time with her.
Q By this amount of money, what do you mean?
A $25,000.
Q And where did you meet her?
A In my home. I invited her to my home for lunch.
Q How long did she spend with you?
A She was there several hours.
Q While she was at your house, did she discuss the
subject of money with you?
119
A Yes.
2
Q And what did she say?
3
A She indicated how much they needed the money for the loan of
4
the book and was very appreciative that I was interested in
5
helping.
6
Q After that occasion where she came to your home, did
A Yes.
9
MR. WILLIAMS: Object, Your Honor. He is leading the
10
witness again. He is implying that she wrote it out exactly at the
11
time. She has already testified to that. She said she wrote it at
12
some time after her meeting with J
13
THE COURT: Yes. When she wrote it. BY
14
MR. MARKHAM:
IS
Q When did you write this check out?
16
A April 5th, 19 85.
17
Q And how long after your meeting with in

18 your home was it that you wrote this check out?
19 A I don"t remember.
20 Q Well, can you approximate? What is your best
21 approximation?
22 A It was quite soon.
23 Q_ After you wrote the check out, what did you do with it?
24 A It was picked up by a runner.
25
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Q Now, take a look at the second page of Exhibit 1-C. What is that?
A It's another promissory note.
Q And what is the amount of the promissory: note? A
The amount of the promissory note is for $25,000. Q
And whose signature is on it? A
Q And did you receive that? Have you ever seen that before?
A It arrived by mail. Q
When?
A Following April 5th. I don't have the envelope here MR. MARKHAM: Your Honor, at this time I offer 1-C into evidence the check and the promissory note.
THE COURT: It will be received in evidence. (Government's Exhibit 1-C was received in evidence-) BY MR. MARKHAM:
Q Now, may I ask you to turn to Exhibit 1-D. Would you tell the jury what exhibit 1-D
is. A It's -

Q Have you ever seen it before? A Yes, I have, because I wrote it. • Q What is it?
A It's a check written out to GDI, again dated
121
April 5th, 1985, for $25,000, and this time the interest rate -- had me write in the memo column each time the amount of interest she was going to pay. This check here --Q Could you refer to the number of the envelope. A 1-C.
Q That is the April 5th check for $25,000? A For $14,000 -- for 14 percent, excuse me — at 14 percent. This one is at 15 percent.
MR. WILLIAMS: Your Honor - THE
COURT: What is your objection?
MR. WILLIAMS: My objection. Your Honor, is we were talking about 1-D and then Mrs. Sexton just mentioned 1-C with regard to something.
THE WITNESS: I mentioned it because I wanted to show the difference in the amount of interest being offered. BY MR. MARKHAM:
Q Was there a difference in the interest on 1-D compared to 1-C? A There is.
THE COURT: She just testified to that. MR. MARKHAM: I'm sorry, Your Honor. I got —(Pause) BY MR. MARKHAM:

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supposed to earn on this second check for $ 2 5,0 0 0 ?
A The second check, yes, we did.
Q What did she say?
A She said, I will raise the interest rate to 15
percent.
Q Did she say why?
A Well, apparently the more money that I could lend them ~
MR. WILLIAMS: Objection, Your Honor. They are now peering into my client's mind again. I object to that. THE COURT: The question was did she say why. THE WITNESS: Yes. The more money that I would lend them the higher the rate of interest I would receive. BY MR. MARKHAM:
Q Did you give this second $25,000 check to anyone
after you wrote it out?
A It was picked up by the runner, and it was dated
April 5th, the same as the other, but I didn't have the money to give her at that time. They held it. They held it for several days until the money was in my account.
Q Did you discuss with holding this
second$25,000 check?
A Yes.
Q Did you tell her why — what did you say to her, and what did she say to you?

123
A That the money would be available in a few days,
Q Did you tell her where the money was coming from?
A Yes,
Q And what did you tell her?
A One of my investments that would become due.
MR. MARKHAM: I offer 1-D into evidence, Your Honor The check.
THE COURT: Be received in evidence.
(Government's Exhibit 1-D was received in evidence.) BY MR. MARKHAMs
Q Can we turn to 1-E, please.
What is the first page of 1-E, Mrs. Sexton?
A It's a check that I have written.
Q For how much?
A For $25,000.
Q What is the date on the check?
A April 12th, 1985.
Q Who is it payable to?
A CDI.
Q And what is the — is there any notation on the memo?
A The notation is again at 15 percent.
Q And who reguested that you write this check out?
A

124
Q And after you wrote it out, what happened to it? Do you know?
A It was picked up by a runner.
0 Now, the second -- what is the second page of Exhibit 1-E?
A It's a promissory — it's a loan transfer form. Q
Have you ever seen that document before? A Yes .
Q When did you first see it? A When she mailed it to me.
Q And when does the loan transfer form say? A It's a rollover. It's going to be a consolidation for the checks that I had sent before, to consolidate them into a $100,000 loan if I could come up with — I'm sorry --it s so faint. It's a copy.
MR. MARKHAM: Your Honor, I would offer the first page of that Exhibit 1-E into evidence, the check for $25,000 THE WITNESS: But it's a rollover. It's a rollover that if I came up with $100,000, it would be a rollover, and the interest rate would then be increased to 17A percent. THE COURT: 1-E, first page, will be received in evidence.
(Government's Exhibit 1AE, first page, will be received in evidence.

125
BY MR. MARKHAM:
Q Now, as of the time, Mrs. Sexton, that you wrote out this $25,000 check, which is on the first page of 1-E, can I ask you to turn back to the first page of 1-E, which is the exhibit right there in front of you.
A Yes .
Q How much money had you loaned the organization as of the time you gave them that $25,000 check?
A $85,000.
Q All right. And did you have any discussions with anyone about what would happen if you lent additional moneys?
A Yes .
Q With whom did you have those discussions?
A With
Q What was it that she said would happen if you lent additional moneys over and above this $85,000 that you had already lent?
A If X could make it $100,000, she would pay me 17% percent interest.
Q And what did you say?
A So, I thought I could get hold of — I came short of $500, I think of coming to the $100,000.
Q And after you got that money, did you have a
discussion with Mrs. about that?
A Yes. It was agreeable with her to make the

126
1 promissory note out for $100,000 at 171/2 percent.
2 Q I ask you to turn to Exhibit 1-F.
3 Can you look at the first page of Exhibit 1-F,
4 please.
5 A Yes. It's a check that I made out to GDI, April I9thr
6 1985, for $14,300-
7 Q After you made that check out, do you know what
8 happened to it?
9 A Yes. It was picked up by a runner,
10 MR. MARKHAM: Your Honor, I offer Exhibit 1-F into
11 evidence.
12 THE COURT: Be received in evidence.
13 (Government Exhibit No. 1-F was received in
14 evidence.) BY MR. MARKHAM:
15 Q Now, I ask you to take a loo]: at Exhibit 1-G. Have you
16 ever seen Exhibit 1-G before?
17 A Yes.
IS Q What is that?
19 A That's a promissory note made out to me and I asked to
20 have my daughter's name put on this because it's for the sum of
21 $100,0007 and because it was that amount, if anything should
22 happen for me between that year, I wanted my daughter to be paid.
23 Q Where did you first see this promissory note,
24
25
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which is Exhibit 1-G?
A It was mailed to me.
Q Does Exhibit 1-G specify an amount of raoney that is owed to you?
A $100,000.
Q Does it specify an interest rate?
A 17-1/2 percent compounded quarterly.
Q Is it signed?
A it's signed.
Q By whom?
A By J
MR. MARKHAM: I offer this into evidence, Your Honor THE COURT: Be received in evidence. (Government's Exhibit No. 1-G was received in evidence.) BY MR. MARKHAM:
Q Now, after you received that $100,000 note, which is 1-G, did you lend additional moneys at the reguest of n?
A Yes, I did.
Q And can I ask you to turn to Exhibit 1-H. Do you recognize Exhibit 1-H?
A Yes, I do.
Q What is it?
A It's another check made out by me to GDI, 55,
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Q Did you and have a discussion about
the interest rate in connection with this $5,000?
A Yes, we did. She said, because I was starting over again, that my interest rate would drop.
Q Did she tell you what she meant by you were starting over again?
A Yes. I was maybe building up to another amount.
Q Had you been repaid the first $100,000?
A No.
MR. MARKHAM: I offer 1-H - I'm sorry, Your Honor. MR, WILLIAMS: I object, Your Honor. I didn't hear . that last guestion. Was the guestion —
THE COURT: It's not a valid ground for objection, but I will ask you to repeat it.
.MR. MARKHAM: I think it already left my computer, Your Honor. ' ' -> BY MR. MARKHAM:
Q Had you already been paid the first $100,000, which
A No.
Q — which is the first $100,000 before you made this additional $5,000 loan? A No.
129
1 MR. WILLIAMS: Your Honor, I would object to that.
2 The testimony is that she consolidated all the previous
3 loans into this $100,000 note and then the note was written
4 payable in one year. The note that she has just put in

5 evidence says payable in another year. So why would
6 she have been paid the $10 0,000 at that time?
7 THE WITNESS: That's true. I had not expected - THE COURT:
S Wait just a minute. MR. WILLIAMS: It's misleading the
9 jury. THE COURT: Objection overruled. BY MR. MARKHAM:
10 Q Were you ever paid any part of that $100,000 con-
11 solidated note that was just referred to, one penny? A No.
12 Q Ever? A No.
B Q Could you take a look, please, at the second page of
14 Exhibit 1-J — I'm sorry — Exhibit 1-H. Do you recognize
18 that?
16 A Yes, I do.
17 Q Where did you first see it?
15 A When it was mailed to rae.
^ Q Would you tell the jury what it is, please.
20 A It's a promissory note made out to Elisabeth Sexton
21 and Deborah O'Callahan, my daughter.
22
23 24 2S
130

1 Q And what's the amount on the promissory note?
2 A $5,000.
3 Q What's the interest amount?
4
5

7 Q Looking back just very briefly, what is the date on
8 this $5,000 check?
9 A June 21st, 1985.
10 MR. MARKHAM: I offer this into evidence. Your Honor
11 THE COURT: Be received in evidence.

12 (Government's Exhibit No, 1-H was received in
13 evidence.) BY MR. MARKHAM:
14 Q After you lent the $5,000 that we have just talked
15 about, did call you and ask you for more
16 money?

17 A Yes, she did.
18 Q Can I ask you to take a look at Exhibit 1-1. Do you
19 have that in front of you?
20 A Yes, I do.
21 Q What is it?
22 A It's a check made out by me to GDI, July 26th, 1985,
23 for' $2,000.
24 Q Did you -
25
131

1 2
3 and 4

13 14 15 16
17
jg could dig up.
19
20 Q Where did you dig it up?
21
22 A From interest in my bank account.
23
24 Q After you wrote out this $2,000 check on July 26th, 1985,
25
what did you do with it?
A I mailed this to her1 It was not picked up.
MR. MARKHAM: I offer that exhibit. Your Honor, 1-1, into evidence.
(Government's Exhibit No. 1-1 was received in evidence.) BY MR. MARKHAM:
Q After you lent her the $2, 000, which is referenced in Exhibit 1-1 - the $5,000 -I'm sorry, the $2,000 - did you ever have discussions with her about lending more money?
A Yes.
Q And did you in fact lend more money?
132
A Yes. I wrote another check. Q For how much? A $500.
Q And why is the amount — why did you only lend $500 on the next occasion that you lent money?
A The barrel had run dry. I was out of money.
Q Did you ever discuss that with ?
A Yes -
Q And what did you say to her at or about this time

about your financial situation?
A Well, I told her I couldn't lend her any more money, My money was gone.
Q What is Exhibit 1-J?
A A check that I wrote out to GDI, September 17th, 1985 for $500, again 13 percent.
Q After you wrote it out, what did you do with it?
A I mailed it to her.
MR. MARKHAM: I offer 1-J into evidence. Your Honor THE COURT: Be received in evidence. (Government's Exhibit No. 1-J was received in evidence.) BY MR. MARKHAM:
Q Now, after you told her that you ran out of money, did she reguest that you lend more money?
A She asked me to go to the bank and get a loan for
133
1 $50,000.
2 Q Do you remember when she asked you to do this?
3 A It was in September, 1985, shortly after I had
4 written this check for $500.
5 Q When she asked you to go to the bank and borrow
6 $50,000, what did you say to her?
7 A I laughed. I mean, excuse me, I was shocked. She laughed
8 at me.
9 Q What did you say to her?
10 A 1 said I couldn't do it. And she laughed at me. She said,
11 "You New Englanders are all alike. You are afraid of borrowing

12 money."
13 Q Did you tell her why you couldn't do it?
14 A Simply out of fear. Yes, out of fear of owing money
15 Q And did you and she have any further discussion about
16 her request that you go off and borrow $50,000?
17 A She told me to think about it and she would call me back.
18 Q Did she in fact call you back?
19 A Yes, she did.
20 Q When she called you back, did you have further
21 discussions about this $50,000?
22 A Well, she said that I shouldn't have any fear of being
23 in debt, because I wouldn't be the one to be in debt. GDI would
24 be. GDI would meet all payments.
25
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Q And what did you say?
A I reluctantly agreed to do it. And I went to my bank.
Q What bank did you go to?
A Camden National Bank in Rockland, Maine.
Q Now, if you live in Connecticut, why did you go to a bank in Maine to try to-get this money that she reguested?
A Because I have a cottage in that area.
Q And did you — what did you do when you went into the bank?
A I went to the loan department.
Q And what did you do?

A And asked if I could have a loan of $50, Q Did you provide the person at the bank with any information?
A When he said naturally, "This is a lot of money. What do you have for collateral?"
And I said, "I have a summer home, a little cottage," and then he wanted to know what the money was going to be used for.
MR. WILLIAMS: Objection, Your Honor. This is all hearsay. I object to that.
THE COURT; Objection sustained. BY MR. MARKHAM:
Q Did you give the banker any information in
135
connection with your reguest to borrow money?
A I gave him the address of my summer home, and he said that if" —
THE COURT: Wait just a minute. THE WITNESS: If the -
THE COURT: I don't want you to testify to what he told you. BY MR. MARKHAM:
Q In addition to giving him the address of your summer cottage, did you give him any other information?
A He wanted to know what the money was going to be used for.
Q And without saying what — what did you say to him? A I said it was going to be an investment for my grandchildren.

Q And in addition to talking about what it was going to be an 'investment for, did you give him any other information?
A Yes, I did.
Q What?
A I told him that the investment was going to made
through , and I gave him her name and
telephone number in New York.
Q After you gave the banker in Maine the name and
telephone number of , did you have any
136
discussions with her about the banker?
A Yes.
Q When was that? Do you recall?
A After the banker had — well, she called to see if I had gone to the bank, and I said yes, and that she would probably hear from him.
Q Did you have another conversation with her about this bank after that one?
A Yes.
Q Approximately how much later?
A Well, she called me every day.
Q Do you remember how much later it was that you had a second conversation about the banker?
A She called me as soon as she had heard from him.
Q And what did she say?
A She said she had heard from him.
Q Did she say anything else?

A Not until the second time he got in touch with her. Q And so I gather that there was yet another call from
discussing the banker? A Yes.
Q And in this third call from , what
did she say about the banker? " A She said call him off. Q Did she tell you why?
137
A Yes. You know banks are our enemies, and he is
getting too inquisitive.
3
Q Did she tell you what he was getting too inquisitive
4 about?
0 MR. WILLIAMS; Objection. Hearsay, Your Honor.
6 BY MR. MARKHAM;
7
Q Did she tell you —
3 MR, WILLIAMS: It was the he that he said.
THE COURT: The question is what did Mrs. ID
MR. REILLY: I object as to adrnissibility as to
12 1 • 4-
my client.
B THE COURT; Objection overruled. It will be ;
14
received conditionally. BY MR. MARKHAM:
15
Q She said the banker was getting too inquisitive,
16
correct?
17
A Right. And to call the banker off.
18
Q Did she elaborate as to why he was being too
19

20 A Except that banks were their — GDI's enemy. ZL Q Now, when you went in —
22 MR. ANDERSON: Your Honor, may we have an
23 instruction to the jury in terms of the litigations which
24 this evidence is being admitted at this point in time?
25
THE COURT: No. I am not going to instruct the jury — the condition was that some prima facie case be made of the Count I to warrant its use. I don't think the jury need concern itself with adxaissibility of evidence at this stage. BY MR. MARKHAM:
Q As of the time you went into the bank in Maine, were you willing to put up your cottage as collateral?
A That's the only way i would have been able to have borrowed the $50,000.
MR. WILLIAMS: Object. It's not responsive to the guestion. The guestion calls for a yes or no answer.
THE COURT: Objection overruled. BY MR. MARKHAM:
Q Were you willing to put up your house as collateral, your cottage?
A Not really. But that's the only way I would have been able to get $50,000.
Q And how long had that cottage been yours? MR. WILLIAMS: Objection, Your Honor. THE COURT: Objection sustained.

THE WITNESS: The cottage was -
THE COURT: No. You shouldn't answer that question. THE WITNESS: The cottage has meant a lot to me. It's been in our family for years.
139
THE COURT: Objection sustained.
MR. MARKHAM: I don't think she understand, Your Honor, the difference betweeen overruled and sustained. Could I ask the Court to instruct her.
THE COURT: When I sustain an objection, don't answer it.
THE WITNESS: Thank you. THE COURT: Don't answer the guestion. The jury is directed to disregard the last answer. BY MR. MARKHAM:
Q Now, after told you what she told
you about this bank, did you and have
other discussions about loans? A Yes.
Q And what was the next discussion you had? A
When I returned to Connecticut*
Q Do you remember when that was? First of all, what year was it that you went to the bank in Maine? A 1985.
Q During the summer?
A September, I was rounding out my summer and returned in October to my winter home in Connecticut.
Q After you got back to Connecticut, what did you and discuss about loans?

A She wanted me to borrow from the bank where I was
140
where my account was, where I was well known.
Q And did she tell you anything about what amount she wanted you to borrow?
A She wanted me to get as much as I could without any guestions being asked.
Q Did she tell you why she didn't want any guestions to be asked?
A I don't remember that conversation.
Q After she asked you to go in and get as much as you could without guestions being asked, what did you do?
A I went to my bank where my account is and where I am known.
Q And did you in fact borrow some money?
A Yes. I found that without any guestions being asked, I could borrow $4,000.
Q Did you in fact borrow that money?
A Yes, I did, but I would like to say something here. I didn't borrow it —
MS. WILLIAMS: Objection, Your Honor. There is no guestion pending on that.
THE COURT: Well, she was asked if she borrowed it, And she said -- now she is getting ready to say she didn't borrow it, so I think maybe we had better find out —'the objection is overruled.
MR. MARKHAM: May I put another guestion to the

141
1
witness. Your Honor, on this subject? THE COURT: All
2
witness. Your H
right.
3 BY MR. MARKHAM;
Q Did you borrow any. money from the bank? 5 A Yes .
C
Q How much? 7 A $4,000.
Q
Q Did you have any discussions with
about that $4,000 loan that you had made?
10
A Yes, I only borrowed it with the idea that they
would make all payments.
12 Q Who is they?
13 A GDI.
14
0 Who told you they would make all payments?
15 A
Q After you got this $4,000, what did you do with it?
17 A I sent it to GDI.
10
Q And then did the bank start -- did the bank start
19
charging you the interest on the loan?
20 A Yes.
21
Q And what was the agreement between you and
22
about who would pay that interest?
23
A They would pay the interest each month.
24 Q And did they? A They made —

142
THE COURT: We are talking about GDI.. That's who she means by they. BY MR. MARKHAM:
Q Did anybody — may I withdraw that question, Your Honor?
THE COURT: All right. BY MR. MARKHAM:
Q After you gave the $4,000 and after you had the
discussion with that CBI would pay the
interest, did interest become due?
A Yes.
Q Did anyone pay that interest?
A Yes.
Q How much of that interest was paid?
A $250. That was the bill - the first bill. And it was paid.
Q And then did you get a second bill?
A Yes.
Q Did anyone pay that second bill as of the time you got it?
A No.
Q And what did you do as a result of the fact that the bill wasn't paid?
143

A I wrote to J
Q After you wrote to J — where did you write?
A Chicago.
Q Why is it that you wrote to Chicago?
A She had been transferred,
Q How did you know that?
A She had told me:
Q Before she had been transferred to Chicago, did she tell you where she was working from?
A I don't think I understand your guestion. 11 Q Well/ it's probably my fault. U MR. MARKHAM: May I try again, Your Honor? THE
13 COURT: All right. BY MR, MARKHAM:
14
Q Did ever tell you where she was
15
working before she got transferred to Chicago?
16 A Yes. 17
Q Where did she say she was working?
1Q
A Palisades Park, New York — New Jersey-
19
Q And did she tell you when it was that she trans-
70
21
ferred from New Jersey to Chicago?
A Not until she moved.

22

Q And moved to Chicago?

23

A Urn hum.

24
Q When was that? When did she tell you that she 25

144

A After she had moved, but do you want the date?
2
Q Approximately.
3
THE COURT: Does it really make any difference when she
4
moved?
5
MR. MARKHAM: Your Honor, I believe it will become
6
relevant, because there are some Chicago conversations coming up
7
very guickly.
8
I will withdraw that for now.
10
Q Take a look at Exhibit 1-K. Do you recognize that check?
11
A Yes, I do.
12
Q Is that the check that you wrote?
13
A Yes.
14
Q How much is that check for?
15
A $4,000.
16
Q This is the $4,000 that corresponds to the loan that
17
we have been talking about?
IS
A That was the loan I had taken from the bank.
19
Q And this check is payble to whom?
20
A GDI, and it's made out 15 percent to be paid in 12
21
months.
22
Q Why — did you ever have any discussions with
23
about why this loan was to be paid in 12 months?
145

3 Right.
4 MR. MARKHAM: I offer 1-K into evidence, Your Honor
5 THE COURT: Be received in evidence. MR. MARKHAM:
6 The first page of 1-K.

7 (Government's Exhibit No. 1-K, the first page, was received
8 in evidence BY MR. MARKHAM:
9 Q Can you take a look at the rest of 1-K, the second
10 page of '' 1-K. What is that?
n A Oh, tliat's a note from George Canning acknowledging
12 the loan and admitting that they owed me $4,000 for that
13 loan. Q What date is on that acknowledgement? A November
14 18th, '85,
is Q And does the document indicate what company George
16 Canning is writing on behalf of?
17 A The head of the paper is GDI.
18 MR. MARKHAM: I offer this second page of 1-K into
19 evidence, Your Honor.
20 THE COURT: Be received in evidence.
21 (Government's Exhibit No. 1-K, the second page, was
22 received in evidence.) BY MR. MARKHAM:
23 Q Now take a look at the third and fourth pages of
24
25
146
Exhibit 1-K- Do you recognize those documents?
A That's the document from the Suffield Savings Bank that made the loan.
Q Made the loan to you?

A Yes.
MR. MARKHAM: I offer that into evidence. Your Honor, as well, as part of 1-K, pages 3 and 4 of 1-K. THE COURT: Received in evidence. (Government's Exhibit No. 1-K, pages 3 and 4, were
received in evidence.) BY MR. MARKHAM:
7
Q Now, you indicate that when — you indicated
3
previously that when you did not get the second interest
9
payment that you owed the bank, you did not get that
10
interest paid back to you by GDI, you wrote
11
12
A I wrote to her.
13
Q After you wrote to her in connection with that
14
late interest payment, what happened?
IS
A I was sent a check -- no. I beg your pardon.
U
-y-j Nothing happened.
-10 Q And did you have any further conversations with -iq anybody from Caucus Distributors?
20 A Yes '
01 Q What was the next conversation — who did you have
22 the conversation with?
23 24 25

147

Q Now, was there ever a time that you got additional interest checks —
A Yes.
Q — let me finish my question.— any additional
interest checks to pay back this $4,000 bank loan?
A Yes,
Q How many additional interest checks did you get?
A The second and third were paid in the same check, at $500.
Q Can I ask you to take a look at Exhibit 1AM. Do you recognize the document which is the first page of 1~M?
A That's the first check 1 was paid for the interest on the loan, December 13th, '85.
Q What is the amount?
A $250 made out to me.
Q Is the check titled? Is it a particular company's check?
A Yes. Caucus Distributors, Inc.
MR. MARKHAM: Your Honor, I offer the first page of Exhibit 1-M into evidence.
THE COURT: I think that you can probably save up and offer four or five of them at the same time. These checks are not being objected to.
143
MR. MARKHAM; Very well, Your Honor. THE COURT: We are going through a Lot of motions. MR. MARKHAM: Very well, Your Honor. BY MR. MARKHAM:

Q May I ask if you recognize the second page of Exhibit 1-M? What is that?
A 1-M, you are asking for?
Q Yes. The second page. Is there a second page of Exhibit 1-M?
A Yes, but this is a check. Q
All right. What is it?
A It's a check made out to me for $500, February 18th, 1986.
MR. ANDERSON: Your Honor. I object. That's not the way it's been presented to us by the Government in the exhibit book.
THE COURT: Is that all you have to say? MR. ANDERSON: He is asking her about an exhibit that doesn't exhibit according to the production. Your Honor. THE COURT: 1-M doesn't include two checks? MR. ANDERSON: No, it does not. MR. WILLIAMS: It was 1-N, was it not? MR. MARKHAM: Your Honor, I apologize. It's the confusion M and N.
THE COURT: Which are you referring to?
149
ME. MARKHAM: I am now referring. 1-M is the first check she identified, which is the $250. 1-N — I believe I may have misspoken — 1-N is the check I would now like her to address.
THE COURT: Mr. Anderson -
MR. ANDERSON: That's a different exhibit. I have

no problem with that. BY MR. MARKHAM:
Q What is the amount of that check in 1-N?
A 1-N?
Q N as in Nancy.
A $250 - December 13th, 1985.
Q Can I ask you to take a look -- what exhibit are you reading from?
A I am reading from 1-M as in Mary.
Q All right. Now, can you turn and read from 1-N, which is Nancy?
A A check for $500.
Q What is the company name on that check?
A Caucus Distributors.
Q What is the date on that check?
A February 18th.
Q Do you —
A I was just going to say no check came in January.
Q After — do you remember getting this check in or
150
around February of 1986? A Yes, I do.
Q What did you do with the money on both of these checks ?
A Paid the bank.
6 Q After you received this check for $500 to pay the 7 bank, the two interest payments, did you receive any S additional moneys to pay that bank loan?

9 A No.
10 Q Did you receive any additional moneys at any time
11 from anyone?
12 A No.
13 Q With respect to the loans that you had outstanding,
14 the $100,000?
15 A No.
16 Q The $4,000 loan -
17 A No.
18 Q — that you made afterwards?
15 A No.

20 Q The $5,000 loan?
21 A No.
22 Q The $2,000?
23 A No.
24 Q . The $500 loan?
25
A No.
151
Q Did there come a time when those loans became past due.
A Yes.
Q What did you do?
A I wrote a letter to
Q May I ask you to look at Exhibit 1-0.
MR. WILLIAMS: Your Honor, unless they can show that my client received this letter, I would object to her reading from this letter.
THE COURT: Objection overruled.

BY MR. MARKHAM:
Q May I ask you to take a look at Exhibit 1-0.
A Yes.
Q Do you recognize Exhibit 1-0?
A Yes. It's a letter I wrote to on April 25th. The loan was due April 13th.
Q Let me interrupt you if I may.
A This date is the 25th.
Q What loan?
A $100,000.
Q That was due when?
A April 13th, 1986. This letter is dated April 25th, 1986.
Q Do you know who prepared this letter?
A I wrote it.
Q And after you wrote it, what did you do with it?
A I mailed it to in Chicago.
Q How is that that you happened to know her address?
A She had given it to me.
Q Did you write it to the address that she gave you?
A Yes, I did.
Q And -
MR. MARKHAM: Your Honor, I would ask this be received, 1-0, and that she be allowed to read this letter to the jury.
MR. WILLIAMS: I would object, Your Honor, on the

152

basis that it's not received and the address — I can do that in cross examination. The address was a business address, as I recall.
THE COURT: Objection overruled. BY MR. MARKHAM:
Q Mrs. Sexton, after you sent this letter, did you receive a telephone call from anybody about this letter?
A Yes, I did.
Q And who did you receive a telephone call from?
A
Q Had you ever talked to before?
A Yes.
Q The call where he talked to you about this letter?
A Yes.
153
Q Did he tell you where it was he was working?
MR. REILLY: Objection, Your Honor, to the foundation of her ability --
MR. MARKHAM: I am laying it, Your Honor. THE COURT: Objection overruled. BY MR. MARKHAM:
Q Did tell you where he works from? A
Yes.
Q Where did he say he worked from? A
He was in the Chicago group-
Q When called you and mentioned this
letter, did you recognize his voice? A Yes, I did.
Q What did tell you about this letter

when he called you after you had sent it to Chicago?
MR. REILLY: Objection. Foundation for this identification of
THE COURT: She said she recognized his voice. MR- REILLY: From another conversation evidently, Your Honor. THE COURT: Objection overruled.
BY MR. MARKHAM:
Q What is it that told you about this
letter that you sent to after you sent it to Chicago where he worked?
A He told me had received the letter and that she cried when she read it.
Q Did you ever hear from after you
sent this letter? A No.
MR. MARKHAM: Your Honor, I would like her to read 1-0, if she may.
THE COURT: Yes. BY MR. MARKHAM;
Q Could you read to the jury letter 1A0.
MR. WILLIAMS: Objection, Your Honor. This is self-serving. This has nothing to do —
MR. MARKHAM: I object to that characterization, Your Honor, it is not self-serving.
THE COURT: Settle down. Don't get all up tight about it.

MR. MARKHAM: Yes, Your Honor.
THE COURT: A simple objection will do,
MR. MARKHAM: I object.
THE COURT: And your objection?
MR. WILLIAMS: My objection. Your Honor, is it's purely being admitted — it was written by the witness — as a self-serving statement made to, presumably made to my client, and it's not shown that my client even received it. It speaks for itself. Your Honor. I don't see why it should
155
be read.

2
THE COURT: I think there is a sufficient showing
that she probably received it has been made. But I don't want to start reading exhibits. We have got a lot of exhibits here and if we start reading them all- I will admit it into
evidence* You can refer to it in closing argument, if you 6
want, or on cross examination of some other witness. I don't
want to start reading exhibits. BY MR. MARKHAM; &
Q After you wrote this letter to Mrs. ,
9
you receive any moneys? 10
A No. 11
Q Did you write any other Letters? 12
A Yes. 13
Q And who did you write to?
14
A I wrote to Mr. Lyndon LaRouche.
15
Q Can I ask you to take a look at Exhibit 1 -P. Do
16
you recognize Exhibit 1 -P? 17

IS A Yes.
19 Q What is Exhibit 1-P?
20 A It's a letter that -
21 THE COURT: Wait just a minute.
22 MR. ANDERSON: I am prepared to stipulate to the
23 sending and receipt of the two letters written by Mrs.
24 Sexton and the two responses to those letters authored by
25
156
Mr. LaRouche.
MR. MARKHAM: If it please the Court then, at this time I would like to offer into evidence Exhibits 1-P.
THE COURT; Are these the letters -
MR. MARKHAM: Yes, Your Honor.
THE COURT: -= from Mr. LaRouche, or the letters to and from Mr. LaRouche?
MR. MARKHAM: Yes. 1-P is the first letter to Mr. LaRouche. 1-Q is the response and 1-S is the second letter to Mr- LaRouche, 1-S as in Sarah, and 1-T is the second response by Mr. LaRouche. So I would offer those four at this time, and since I am doing that, Your Honor, may I at this time offer Exhibits M and N into evidence,
THE COURT: Yes. The four, P, Q, S and T, are the ones you stipulated to, Mr. Anderson?
MR. ANDERSON: I do, Your Honor.
THE COURT: They will be received in evidence, as will be M and N.

MR. WILLIAMS: Your Honor, wait a minute. There was no testimony as I recall about one of the pages, 1-L, I believe it is. I think that slipped into these exhibits.
MR. MARKHAM: I didn't offer that, Your Honor.
THE COURT: I don't think 1-L has been referred to yet.
MR. WILLIAMS: Very well. Your Honor. I thought it
157
(Government's Exhibit Nos. 1-M, 1-N, 1-P, 1-Q/ 1-S and 1-T were received in evidence.) BY MR. MARKHAM:
Q Now, what was the purpose for which you wrote the
letter to , which is 1-0? Why did you write
the letter?
A I wrote the letter because I had not received any money, the due date for my note had come and gone, and no one had called or written to me about why; and it was ray life's savings. I needed that money. And I had been promised it in a year.
Q Did you communicate to anybody that was your life's savings? Did you tell anybody that that was your life's savings?
A J knew it was.
Q How did she know it was?
A I told her.
Q Now, when you got your first letter back from Mr. LaRouche —

A Yes.
Q — did it contain any money?
A No.
Q When you got your second letter back from
158
Mr. LaRouche, did it contain any money?
A No.
MR. ANDERSON: Your Honor, that is clearly leading. It didn't contain any paperclips either, I assume.
THE COURT: Well I think you have established that at least three times that she never got any of this money from anybody.
MR. MARKHAM: Yes, Your Honor. THE COURT: Except the interest payments. BY MR. MARKHAM:
Q May I ask you to take a look at Exhibit 1-U. Do you recognize Exhibit 1-U?
A Let me find it- I have it.
Q Have you ever seen Exhibit 1-U before?
A Yes, I have.
Q And where did you see it? Where did you first see
A It came to me in the mail.
Q And whose letterhead is it on?
A GDI.
Q And who is it signed by?
A George Canning.
Q Tell the jury briefly what 1-U is.

159
testified it came to her in the mail.
THE WITNESS: You notice the name Sexton is on it, don't you?
THE COURT: I will rule on the objection, Mrs. Sexton. You just answer the questions you are asked. Objection overruled.
THE WITNESS: My name is Sexton. My name is Sexton It is written to me. BY MR. MARKHAM: Q And you received it? A I received it.
Q And would you tell the jury what the title of this document is, where it says "Re:" in the upper right-hand corner,
Q All right, and what is the loan amount that is referred to in this letter, which is entitled "Renegotiation of loan?"
A Principal amount of loan, $100,000-
Q Now prior to your receiving this -- what is the date on this again?
A January 14th, 1987.
Q Did you receive it at or around this time?
A Yes.
Q Prior to receiving this renegotiation of loan

160
statement, did you have any discussions with anybody about it?
A Yes.
Q Do you remember who?
A cloret Carl (phonetic) had talked to me several times.
Q Did she make a request of you?
MR. MOFFITT: Objection, Your Honor. MR. REILLY: Objection.
MR. MARKHAM: Not offered for the truth, Your Honor, just for the fact that she made the request.
THE COURT: I haven't enouqh evidence concerninq that witness to know what her status in all this is. I am unwillinq to let it in even on your representation at this staqe that it's not offered for the truth of it. Objection sustained. BY MR. MARKHAM:
Q Do you know a person by the name of Cloret Mack?
A Cloret Carl.
Q Cloret Carl. Do you know a person by the name of Cloret Carl?
A She talked to me several times on the telephone.
Q Did she ever identify who she worked with?
A Yes, GDI.
Q Did she ever indicate that she knew anythinq about you or your financial relations with GDI?

161
MR. MOFFITT: Your Honor, all this is hearsay.
THE COURT: I don't think she can establish this witness1 complicity in any conspiracy as a coconspirator by Mrs., whatever her name is — own statement through this witness. Objection sustained.
MR. MARKHAM: Very well. Your Honor. I will move on to another area. BY MR. MARKHAM:
Q What does Exhibit 1-U indicate? VThat does it say? A It says they will try to clarify the amount of money they owed
Q And what else does it say?
MR. ANDERSON; The document speaks for itself.
THE WITNESS: That wanted me to write "satisfied in full" under —
THE COURT: Wait just a minute.
MR. ANDERSON: We are just getting back into that same area, reading from the document, Your Honor. It speaks for itself. It's going to go into evidence.
THE COURT: It isn't in evidence yet.
MR. ANDERSON: It hasn't been offered. I'm sure it will go right in with no objection.
MR. MARKHAM: Then I offer it into evidence.
THE COURT: Be received in evidence.
(Government's Exhibit No. 1-U was received in evidence.)
162

1 BYMR.MARKHAM:
2 Q May I direct your attention to a portion of the
3 letter.
Q Down towards the bottom of the last paragraph, it says, quote "Satisfied in full," end quote, does it not? A Right.
Q Now, as of the time you that you received this, had your 3100,000 loan been satisfied in full? A No.
Q Now, there is a place at the bottom for you to sign this, is there not? A Yes .
Q Did you sign it and return it? A No, I did not. Q Why not?
A Because I took it to my lawyer, and asXed his advice And he -
MR. MOFFITT: Objection, Your Honor. MR. WILLIAMS: Objection, Your Honor. Hearsay. THE COURT: Objection sustained. BY MR. MARKHAM:
Q After you went to your lawyer, did you make the
decision as to whether or not to sign this?
A Yes.

163

Q I gather your decision was not to?
A I did not sign it.
Q May I ask you to take a look at Exhibit 1-V- We are coming to the end here, Your Honor.
Have you ever seen Exhibit 1-V before?
A Yes.
Q Where did you first see it?
A When it was mailed to me.
Q And would you indicate to the jury the corporate title or the business title that is at the letterhead of this letter?
A Yes. PGM.
Q Is there an attachment — this is a one-page letter, correct?
A Yes.
Q Is there — approximately when did you receive this?
A End of February, 1987 -- first part of February, 1987.
Q And is there anything — do you remember receiving anything with the letter?
A No.
Q Just the one-page letter?
A Ys .
Q Take a look at pages 2 through 5 of Exhibit 1-V.
A Yes.
164

Yes.
Q When did you: see those? A They were mailed to me.
Q Do you know if they were mailed to you with anything else?
A I don't remember that anything else came,
MR. MARKHAM: In any event, Your Honor, I would offer 1-V, pages 1 through 5 in evidence,
THE COURT: Be received in evidence. (Government's Exhibit No. 1-V was received in evidence.) BY MR. MARKHAM:
Q Take a look at the last exhibit on that stack, Exhibit 1-W. A Yes .
Q Have you ever seen that before? A Yes.
Q When did you see that first? A Well, that was mailed to me in February 1987.
MR. MARKHAM: I would offer that into evidence, Your Honor, as 1-W.
THE COURT: Be received in evidence.
(Government's Exhibit No. 1-W was received in evidence.)

165

this money to GDI at the request of
did you have an irnpre/ssiqn; as to how safe that money was? MR. GETTINGS: Objection, MR. WILLIAMS: Objection, Your Honor.
THE COURT: She testified as to what Mrs.
told her. That is was safe as in the bank or some such thing as that. That's presumably safe. BY MR. MARKHAM:
Q At any of the times that Mrs. was asking
you to lend money, did she tell you that your money might be at risk because the organization was being attacked by National Broadcasting Company?
A No.
MR. WILLIAMS: Objection, Your Honor. It's leading. I would ask that Mrs. Sexton's answer be withdrawn and stricken.
THE COURT: This is your testimony, not hers. I have given you right much leeway on leading questions, but I think this goes a little far. Objection sustained. BY MR. MARKHAM:
Q At any time did she articulate, tell you, that there was any risk at all?
A Never.
166

THE WITNESS: I would like to tell the Court what she did tell me. BY MR. MARKHAM:
Q Well, maybe I will ask a question. What did she tell you?
A She told me my money was safer with GDI than in any bank or with any investment.
MR. MARKHAM: I have nothing further, Your Honor.
THE COURT: How do you gentlemen want to proceed? I am going to ask that the lead counsel not have his questions repeated by subsequent counsel and when I saw lead, I mean the first one who examines a witness with the understanding that as long as there is a conspiracy count, there may be interest of others that are not adequately covered by the first examiner. But with that —
MR. WILLIAMS: Yes, Your Honor. I would proceed first, but I would like to approach the Bench, just a moment, if I could.
THE COURT: All right.
(Whereupon, a conference was held at the Bench with Court and counsel, out of hearing of the jury, and reported
167
as follows:)
MR. WILLIAMS: Your Honor, this is just a matter with regard to Jencks. It's my understanding and I have talked to the prosecution about that, that this lady testified in the Grand Jury in the State of New York about similar matters. I

asked the Government for that Jencks, but they say that it's not in their possession and because it's a State Court then they do not consider that Jencks under the Jencks Act.
Your Honor, there is a case in the Fourth Circuit
and Silva says that in situations like this where you have a Federal and State prosecutors, that the Jencks Act does not apply unless there is I think the term that they use in that is close cooperation between the two jurisdictions, the two prosecutors.
The only evidence I have of close cooperation is as follows: that it's my understanding from defense counsel in New York that they have been receiving a lot of evidence in discovery up there of late that is the same evidence that is in this Court. And too, I notice that this morning the prosecutor in New York was here in the audience- I don't know if she is here now or not. She is still here taking notes.
THE COURT: That's not enough in my opinion.
I will not consider that as a Jencks Act statement.
168
MR. WILLIAMS: Very well. Your Honor.
MR. REILLY: Your Honor, just to answer the other guestion we have agreed with the Court with an order amongst ourselves as to counsel to follow in the examination.
THE COURT: My only reguest is that the same guestions not be asked more than once.
MR. WILLIAMS: Your Honor, it will take me just a

minute to get set up with my stuff here.
THE COURT: All right. We will take a minute, (Whereupon, the conference at the Bench was concluded, and the following proceedings were held:)
CROSS EXAMINATION BY MR. WILLIAMS:
Q Mrs. Sexton, when was it that you first came in contact with any member of the National Caucus of Labor Committees or what's called the NCLC?
A In June of 1984.
Q And do you recall the circumstances under which you came into contact with those persons?
A Yes , 1 do.
Q And what were those circumstances?
A I was on my way to my summer home in Maine, and I stopped at the New Hampshire liguor store on my way up to buy
a few supplies for the entertaining during that summer, and there was a table outside with some of the young men with
169
their literature.
Q And you struck up a conversation with those young men, is that right?
A Yes, I did.
Q In that conversation, did you discuss current topics political topics or things like that?
A Yes .
Q Do you recall which topics you discussed on that

occasion?
A It wasn't a very long conversation because I was in a hurry and rather than detain me, they loaded me down with literature to take to the summer home and read.
Q You took it and read it that summer, didn't you?
A I read some of it,
Q Now, on that same occasion, did you also subscribe to any literature?
A No.
Q Did you do that later on?
A Yes.
Q And was that in July of 1994 that you subscribed to some of the literature?
A No.
Q Do you recall when the first time was that you

170
one of these exhibits. It was for an introductory subscription to E1R*
Q Are you sure that it was June that you first met these young men up there near the liquor store in the shopping center?
A Yes. That's when I opened my cottage.
MR. WILLIAMS: Your Honor, could I have this marked as Defendants' Exhibit --
MR. MARKHAM: May the Government examine it first?
MR, WILLIAMS: Yes.

THE WITNESS: Would you introduce yourself to me? MR. WILLIAMS: Williams. Edwin Williams. THE WITNESS: Thank you.
THE COURT: Do you have any other exhibit you want to ask her about, so we can mark them all right now? MR. WILLIAMS: Yes, Your Honor. I have some. {Handing documents to the Clerk) (Law clerk handing documents to the witness) BY MR. WILLIAMS:
Q You have been shown, Mrs. Sexton, I believe it's Exhibit No. 1. It's a subscription form to New Solidarity, is that right? A Yes.
Q Isn't that dated July 26th, 1984? A Yes.
171
Q Now, does that refresh your recollection as to when you were first, or you first talked to somebody from --A I talked to them in June. That's before July, Q All right. But you then subscribed to New
A i didn't subscribe — I think they -- I don't remember whether I gave them any money for it or whether they just started sending it to me.
Q Well, would you look at that form there. It's marked as Defendants' Exhibit Wo. 1. Up in the upper right-hand corner doesn't it have the box saying "new" checked?
A Yes .

MR. MARKHAM: Your Honor, I object to this. There is no foundation she has ever seen that document before or that she signed it.
MR. WILLIAMS: I am just trying to refresh her recollection. I am not impeaching her.
THE COURT: If it was important whether it was June or July, I am perfectly willing to let you.
THE WITNESS: He asked me when I first met them and I said June. And I still say it was June. This says July. July follows June. BY MR. WILLIAMS:
Q I understand that but that says July 26th was the date of the sale down there in the lower right-hand corner,
172
doesn't it? A Yes.
Q And it also mentions that the total, there was $15 cash --
MR. MARKHAM: Objection. If he is using it to refresh her recollection he shouldn't publish it to the jury. She has never seen it before, I don't believe.
THE COURT: I think you will have to ask her
whether it refreshes her recollection. If it doesn't, let's move on to something else.
MR. WILLIAMS: All right. Your Honor. BY MR. WILLIAMS;
Q Would you look at that form, Mrs. Sexton?

A Yes.
Q Completely. And reading everything on it that's in writing, does that refresh your recollection of when you first subscribed — Mrs. Sexton, would you please let me finish my guestion. Does that refresh your recollection as to whether you first subscribed to New Solidarity?
A Yes.
Q And what is that?
A July 26th, 1984.
Q You paid $15 for the subscription?
A Yes .
Q Now, and you read, had you read New Solidarity
173
before that?
A Yes, what they had donated to me in June. Q You had been given issues of — excuse me — let me hold up. Your Honor, what is marked as Defendants' Exhibit B-552, which is a copy of New Solidarity dated July 20th, 1984 July 20th, 1984 -
THE COURT: What is the relevance of this? To show she was a supporter? I assume she is a supporter or she wouldn't have been giving this money, Why would we need to go into this? BY MR. WILLIAMS:
Q This is the newspaper —
THE COURT: Ko. Why do we need to go into that?
MR. WILLIAMS; I think we need to show. Your Honor, that she was a supporter, that she read the literature.
THE COURT: She said she was a supporter.
KR. WILLIAMS: That she read the literature, and

that she made the contributions. That's what I wanted to show.
THE COURT: And so what?
MR. WILLIAMS: Your Honor, we will follow that up later on. I don't want to reveal my entire cross examination at this point.
THE COURT: Well, you have got to convince me that there is some relevance of whether she read New Solidarity
174
'84 to what the basis of her testimony here. If that requires you to reveal some of your cross examination, you have qot to reveal some of your cross examination,
MR. WILLIAMS: Your Honor, in our openinq statements we indicated that the people who made these contributions were supporters, were political supporters of this orqaniza-tion.
THE COURT: She said she is a supporter — I don't Know whether she is a political supporter.
MR. WILLIAMS: We are tryinq to find out what is the extent of their support, because I think that bears on the —
THE COURT: I am not sure it does, but I will let you -- we are not qoinq throuqh all of these issues of New
MR. WILLIAMS: I don't intend to qo throuqh all of the issues, Your Honor. I just want to show how much she knew about the orqanization, about the literature and about

the issues that the NCLC and its members were involved in, what they were involved in.
THE COURT: I will let you go into that to a limited extent. I am very doubtful that it bears a great deal on what we have here.
MR. WILLIAMS: Thank you, Your Honor. BY MR. WILLIAMS:
Q Mrs. Sexton, you can put that down. I don't want
175
1 you to have to — this is the newspaper, New Solidarity, is it not?
2 A Yes.
3 Q You were getting that newspaper?
4 A Yes.
5 Q In the summer of 1984 on? Is that right?
6 A Yes.
' Q And you read it, when you say that you read some
8 of this -
9 A I read some of it.
10 Q You read some of the literature, you read some of
11 it, isn't that right?
12 A Yes.
13 Q You were in agreement with some of the statements
14 in this literature, weren't you?
15 A Yes.
16 Q Now, Defendants' Exhibit No. 2,1 believe, if you
17 will look at that

IS

A Yes.

Is a check, is it not, for $65?

20 A Yes, it is.
21 Q That you have already testified about?
22 A Right.
23 Q And it indicates that you subscribed to EIR, which
24 is this magazine?
25
1 A Right.
2 Q January of 1985, is that right?
3 A Right.
4 Q January 22nd? Or the 16th. I' m sorry, January 16th
s is the date of that check, is it not?
6 A That's right.
7 Q And it's Check lĢo. 1287 on your account?
_ A Right. o
Q Now then, when in relation to that check on January
16th, '85, did you first talk to , if you
10
recall? 11
A I spoke to prior to writing that check.
Q Do you know about what date? 13
A Approximately one month before. 14
Q In December of 198 —
A No. February. Excuse me. I spoke to her around that 16
time, around that time. 17
Q Which time? Around the time of this check? 18
A Around the time I wrote this check. 19
Q In late January 1985 --
20 *
A Yes.

176

22
23 reularl is that our testimon? 24
25
21 Q -- is what your recollection is, is that right? A Yes. ' Q And thereafter, you talked to her fairly regularly, is that your testimony:

177
A Very regularly.
Q And you say that these telephone calls between you and her occurred almost every other day or more than that?
A More than that. Usually every day*
Q And how long did these calls last?
A A long time.
Q And during that, time you talked about issues, ddid you not/ political issues?
A Yes.
Q And you talked about a lot of the things that are expressed in these newspapers and magazines —
A Yes.
Q — and that kind of thing that you got, is that
A Yes.
Q And you were particularly concerned, were you not, about the drug problem, weren't you?
A That was my main and only concern, really.
Q You had no concern for the SDI?
A I was mainly, because I have three young grandchildren, and Nancy Reagan had asked everybody to get involved, I thought this was one way I could get involved and in my own

mind the way you handle something is to educate people. Well, to print a book and have people read a book that is opposed to drugs, I thought was the way to go.
178
1 Q And had you received a copy of that book?
2 A No, it was not in English. That was what I was
3 supposed to be helping, was to get it printed in
4 English. It had been printed in Spanish and was in South
5 America.

6 Q And you never have seen a copy of that book?
7 A Oh, yes. Certainly, after it was published, I did,
8 but that was after I loaned the money to have it done.
9 Q And it was published, was it not?
10 A Yes, it was .
U Q Now then, you also were concerned, weren't you, with
12 regard to this dope and narcotics trade of banks in the
13 United States laundering money, didn't you discuss that
14 with Mrs . ?

15 A We discussed it. We discussed it, yes.
16 Q And you were also interested in the tie between
17 the banks and the Rockefeller money, weren't you?
18 A This has nothing to do with the lending of my money
19 to -- you are not asking me anything, the reason I loaned
20 the money was for drugs, to the opposition of drugs, and
21 getting that book published. All of my checks, if you
22 notice, have "book loan" on it. They have nothing about
23 bank laundering.
24 o All of them have "book loan" on them?

179
"book loan" on them?
A I don't know, but that was the purpose. had me put "book loan" on a good many of them, and then it got just so I just put the interest paid on it, but that was the supposition.
Q As a matter of fact, there are only about two of your checks that had "book loan" on them.
A Then they were the first ones, weren't they?
Q Mrs. Sexton, didn't you just testify that almost all of your checks had "book loan" on them? Wasn't that your testimony?
A If only two of them have it on —
Q Mrs. Sexton, please answer my guestion,
A Yes.
Q Wasn"t it your testimony —
A Yes, I did, I said that.
Q Now you are saying that maybe only two of them had "book loan" on it, is that right?
A I don't know. I haven't counted them. You said that.
Q Well, as soon as I said it, you agreed with me.
A No, I didn't.
Q Now, after you wrote the check on February 22, 1985, for $5,000, which is Government's Exhibit 1-A, Page 2, I believe. You testified that you wrote another check on

180
February 26, 1985. Is that right?
A That is correct.
Q And it was only those two checks, the $2,500 check that you wrote in late February 198 5 that have "book loan" written on the memoranda?
A Okay. I don't know what your point is.
Q Is that right? .
A That is correct. But I don't know what your point is .
Q Mrs. Sexton, if you will just answer my guestions, we will speed this thing along a little bit. I am just trying to ask some guestions. You are supposed to answer the guestions.
A I will do that.
Q Now, you have accepted then that only the first two checks —
THE COURT: (Interposing) I think we have spent enough time on whether it was two checks or four checks or no checks. BY MR. WILLIAMS:
Q Now then, in April of 1985, you lent $25,000 on April the 5th -- well, there were two checks on April 5th, dated April the 5th that were for $25,000, is that right, Mrs. Sexton?
A That is correct.

181
1 Q And then there was —
2 A But you will notice, there is a discrepancy in the
3 bank numbers, in the check numbers?
4 Q Mrs. Sexton —
5 THE COURT: Mrs. Sexton, if you will just answer the
g questions.
7 MR. WILLIAMS: Let me ask the questions, will you,
8 please?
9 THE WITNESS: Okay.
10 BY MR. WILLIAMS:
H Q And then on April the 12th you wrote an additional check
12 for $25,000, is that riqht?
•13 A Correct.
•14 Q And your testimony, I believe, was that soon after that
15 these five checks, the two $5,000 checks and the three $75,000
16 checks were consolidated in a note, and you testified that there
17 had only been $85,000 lent at that time, consolidated in a
18 $100,000 note. Is that riqht?

19 A Not quite.
20 Q At least those five were consolidated in a
21 $100,000 note, isn't that riqht?
22 MR. MARHAM: Objection. Asked and answered. The
23 answer was not quite.
24 THE WITNESS: The $100,000 note was not written
25 until I sent another $14,300. That is when the rollover

took place, on April 19, 19B5, there was a $14,300 — that is when the rollover took place.
MR. WILLIAMS: Mrs. Sexton, there is no question pending, please. BY MR. WILLIAMS:
Q Your testimony was, wasn't it that there was an additional amount of $14,300 that was added to the previously w-ritten checks that composed the $100,000 note; is that
A That is right.
Q And the $100,000 note was for the payment of interest to be compounded quarterly, and then the entire $100,000-plus interest was to be become due at the end of a year, is that right?
A That is correct.
Q So you were not due any interest payments during that year, is that right.
A That is what we agreed.
Q You say that because you had agreed to consolidate all these notes, you were given 17-1/2 percent interest. Is that right?
A Yes.
Q And thereafter you loaned other sums of money —
A That is correct.
Q — to GDI. And is it your testimony that all the

at least every other day?
A Correct.
Q And those conversations not only discussed money, did they not, but they discussed issues almost all the time, didn't they?
A Oh, yes.
Q And that these issues that were discussed dealt

with either the publication of the book as the first two
loans dealt with but with other crises that were facing GDI
32
and the political organization that you were contributing —
B
I mean that you were lending money to? Is that right?
14
A I wasn't sending money to any other.
35
Q This political organization, the political
16
movement that you are talking about --
17
A I listened to their other causes, yes.
18
Q And there was no- . guestion in your> <mind, was there,
35
that this was a political movement that you were lending
20
money to. Isn't that right?
21 A That is right.
22
Q And in making these loans, you did not seek any
23

form of collateral for the loans, did you? 24 25

A Putting up some assets.
Q -- to insure payment of those loans. You didn't seek that, did you?
A No.
Q You didn't ask or anyone else you
talked to during the time you were lending this money for a financial statement of the corporation, did you?
A Only verbally.
Q Did you ask for a sworn financial statement of the
A No.
Q And you didn't do any independent investigation on your own of the ability of GDI to pay back these loans, did you?
A Only verbally.
Q Independently, other than or somebody
from the organization, did you talk to a third party with regard to these corporations?
A No.
Q And you knew from talking to that
these corporations didn't have any assets other than the books they were publishing and incidental office supplies like computers and desks and whatever that was, books and
1 magazines, and that was about all the assets they had,
2 wasn't it?
3 A Only what she told me. She told me that people, because of
4 the interest they were paying people were standing in line to

5 "give them, to loan money to them.
6 Q She also told you that they were selling books, didn't
7 she?
8 A Oh, yes. I knew that.
" Q And she also told you that this corporation that she was
10 representing was a growing corporation, was a growing political
H movement, didn ' t she?
12 A Yes.
13 Q At the time you were lending this money, you
14 believed in that political movement, did you not?
15 A I believed in her and what she told me, yes.
16 Q And you believed in America, don't you?
17 A Yes, I do.
18 Q You believe in the principles of the United States as you
13 interpret them that were established long ago?
20 A Yes, I do.
21 Q And that -
22 THE COURT: (Interposing) Mr. Williams, all you need to
23 do is show she is a supporter* We really don't have to delve into
24 the flag waving.
25
BY MR. WILLIAMS:
Q You not only were lending this corporation money, but you were lending this corporation money because it was something you believed in, or stood for something that you believed in, didn't you ?
A I believed in what they were doing in their fight

for drugs.
Q Now, then, you say that in March of 1986, you were unable to — well, April of '86, was it not, mid-April of "86, April the 13th, 1986, your $100,000 note came due, didn't it?
A April 13th, yes.
Q And you did not receive anything at that time, did you?
A No.
Q And by that time you knew that had been transferred to Chicago, didn't you?
A Yes, I knew that before.
Q In fact she was transferred to Chicago in late 1985, wasn't she?
A Yes.
Q And had you talked to her very much in Chicago?
A Yes.
Q How often would you talk to her?
A Not as often as when she was down in the New York-New Jersey area, but freguently.
Q Now you said that you wrote this letter to her?
A Yes.
Q And I believe the letter was dated April the 25th, was it not?
A Or 23rd - 25th, I think you are right, 25th.
Q April 25th, 1986. And did you write that letter from your home there in Suffield, Connecticut?
A Yes, I did.

Q On your typewriter ?
A Yes, I did,
Q And these other letters that you wrote to Mr. LaRouche later on, you wrote the same way, is that right?
A Yes. On my own typewriter. I live alone. I had no one other to help me.
Q Now when did you first become upset enough to do
something about the nonpayment of these loans other than
write this letter? Had you done anything before writing the
letter to about the nonpayment of the
loans?
A No. I just waited a few days, and then I wrote to her I thought she was the one because she is the only one I had had financial dealings with.
Q Because in February, the previous February of * 86, you had received $500 on a different loan, on that $4,000 loan?
A I have received $500, and nothing more. They left
1 me in debt. I had to pay the rest of that bank loan out of
2 my meager income.
3 MR. WILLIAMS: Your Honor, I don't believe that is
4 responsive to my guestion. Would you strike the part of the
5 answer?
6 THE COURT: Just answer the guestion, Mrs. Sexton.
7 BY MR. WILLIAMS:
Q Now, on the 18th of February, that check was
o
written on the 18th of February for $500, on that $4,

10 loan. So I guess you received that around the 2 Oth
11 of February, is that correct?
12 A They paid $250 in December. Nothing in January.
13 And then $500 in February.
14 0 The check on February indicates in the memo part
15 that this was interest for January and February of '86.
16 A That is correct.
17 Q So although the January payment was late, by the end

18 of February they were caught up on the $4,000 loan, isn't
19 that right?
20 A That is right.
21 MR. MOFFITT: Your Honor, again, I am going to
22 object to characterization of "they". I am concerned about
23 that.
24 MR. WILLIAMS: I mean GDI. I should really refer to
25 GDI, Your Honor, Caucus Distributors.
189
MR. WILLIAMS: All right. BY MR. WILLIAMS:
Q Now, when after February the 20th did you first
become concerned about these moneys to do anything other than
write ? Did you do anything between the time
that you received that check for $500 and April the 25th of 1986?
A I did an awful lot of thinking and sweating. Q
Did you call anybody? A No.
Q Did you call the FBI?
A After I — after Mr. LaRouche's second letter, I

did.
Q You first called the FBI after Mr. LaRouche's second letter? A Yes.
Q And that second letter was dated July the 5th, was it not, 198 — the second letter --
THE COURT: The witness may have the exhibit before her. If she does, maybe she can find it.
Do you have the second letter before you?
THE WITNESS: I do. I don't know which number it is
MR. WILLIAMS: I think it is T.
THE WITNESS: What is the number?
MR. MARKHAM: T, Your Honor. Mr. LaRouche's
190
second letter is Exhibit T. 1-T.
THE COURT: What is the date of that, Mrs. Sexton? MR,
MARKHAM: July 5. BY MR. WILLIAMS:
Q July 5 was the second letter. July 5 of 1986, it was after that that you say you first contacted the Federal Bureau of Investigation? .
Aim going to have to correct myself. I contacted them before that.
Q When did you first contact them?
A Give me a moment to think.
It was in July. I was not in Connecticut, I called him when I was still in Connecticut. I called them sometime around the end of May 198 6.

Q The end of May of 1986?
A Urn-hum.
Q So you contacted them after then the first letter you wrote to —
A Well, may I tell you something? The FBI wouldn't handle me. They hung up on me. So that date that I tried it, let's say I tried to contact them the.'.end of May. So I went to my own personal lawyer.
Q Wait a minute. There is no guestion pending.
A All right. I called the FBI. And they -
THE COURT: (Interposing) Wait a minute. There
191
isn't any guestion.
THE WITNESS: I hung up. They hung up. Excuse me. They hung up. BY MR. WILLIAMS:
Q You first wrote Mr. LaRouche on May 10?
A That's correct.
Q Is that right? ,
A That's correct.
Q And your testimony is that you had not at that time contacted the FBI, is that right?
A It was after his first letter that I tried to contact them, and they —
Q They wouldn't speak to you after May 10th, 1986?
A No -
THE COURT: This really isn't - call and the
attempt and the hanging up really isn't helping us a great deal. BY MR. WILLIAMS:

Q As a matter of fact, Mrs. Sexton, you had contacted the FBI in late April of 1986, long before or several weeks before you wrote that first letter to Mr. LaRouche, didn't you?
MR. MARKHAM:. Objection, Your Honor. I would like -there is no good-faith basis, and I would like to approach if I may very briefly.
192
THE COURT: I think it can be asked. Objection
overruled.
3
MR. WILLIAMS: Your Honor, could I have this marked.
4
(Defendants' exhibit marked)
3 THE COURT: Mr. Williams, how much longer is your
be a good time to break for the evening.
9 MR. WILLIAMS: Yes, Your Honor. I have -
THE COURT: If you really want to conclude this line of guestioning —
12 MR. WILLIAMS; I would like to have a little more
13
time than what the Court is indicating — maybe another 3 0
14
minutes, Your Honor. But it's already 6:00. But it is a
15
convenient place. Your Honor.
16
THE COURT: It's a convenient place for Mr. Gettings
17
anyway,
We'll adjourn until tomorrow morning at

19 10:00. Members of the jury, this case will
20 probably get some publicity.
21 Do not read about, listen to, have read to you, look
22 at, listen to or in any way allow 'yourself to be exposed to
23 any outside account of the case, newspaper or otherwise, and
24 if there is some article in the paper, you could expect to be
25 asked tomorrow morning did you read it? So avoid any
contact with any outside account of the case, newspaper, television, radio, or any other. Obviously, do not allow the case to be discussed in your presence.
MR. ANDERSON: Your Honor, could we have a few moments with the Court?
THE COURT: The jury is excused. The Court will stay in session while the jury leaves the room.
(Whereupon, at 6:00 p.m., the jury was excused to return the following morning at 10:00 a.m.) THE COURT: Counsel want to approach the Bench? (Whereupon, a conference was held at the Bench with Court and counsel, out of hearing of the jury, and reported as follows:)
THE COURT: Yes, sir?
MR. ANDERSON; Your Honor, Mr. Gettings can do it.
MR. GETTINGS: Your Honor, we would like to have a table. We thought we were going to be able to use that small table but I guess we took somebody else, your clerk s table

THE COURT: Oh, Mr. Gettings.
MR. ANDERSON: They have document control, Your Honor.
THE COURT: Where do you want to put them? MR. GETTINGS: We would like that little table
194
there.
MR. MARKHAM: Your Honor, may I interject something Based upon the experience in Boston, the case would go faster if they were around.
THE COURT: That's tempting bait.
That1 sail you needed .to tell me.
We'll see, if you don't mind working with the Marshals and see if you can't arrange a table over there. We'll do what we can to accommodate you.
MR. MOFFITT: Your Honor, may I inguire with respect to, is the courtroom going to be locked so some of this stuff doesn't have to be lugged back and forth?
THE COURT: It will be locked/ yes.
You think there will be people in here after this? It's fascinating stuff, I'm sure.
Yes, the courtroom will be locked. Nobody will be allowed access to it and you should feel free to leave anything you want in the courtroom.
MR. MOFFITT: Thank you.
MR. GETTINGS: What time can we get in in the morning, though ?
THE COURT: What time do you-want to get in?

MR. GETTINGS: 9:30.
THE COURT: All right. The courtroom will be available at 9:30.
195
MR. ANDERSON: Your Honor, I understood Your Honor this afternoon to say we could come up behind the Bench on these conferences because I am having a lot of difficulties.
THE COURT: I know. I don't have anything1 to hide up here. You can split up so that you can make sure you hear it.
MR. ANDERSON: I didn't want to be arrested if I tried.
THE COURT: Not yet, Mr. Anderson.
MR. ANDERSON; I appreciate every consideration, Your Honor.
THE COURT; Court will stand adjourned until tomorrow morning at 10;00 o'clock.
(Whereupon, at 6:02 p.m., Court was adjourned to reconvene at 10:00 o'clock a.m. the following morning.)

196
CERTIFICATE OF OFFICIAL REPORTER COMMONWEALTH OF VIRGINIA ) ss. CITY OF ALEXANDRIA )
I, EDWARD DONOVAN McCOY, Registered
Professional Reporter and Official Court Reporter for the United States District Court for the Eastern District of Virginia, appointed pursuant to the provisions of Title 28, United States Code, Section 753, do hereby certify that I was authorized to report, and did so report in Stenotype, the foregoing proceedings;
THEREAFTER, my Stenotype notes were reduced to typewriting under my supervision; and I further certify that the pages herein numbered contain a true and correct transcription of my Stenotype notes taken herein.
DONE and signed, this ,3^r—**— day of
EDWARD DONOVAN McCdYARPR Official Court Reporter

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