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< Testimony of Charles Tate -November 2, 1987 | Trial Transcripts | Testimony of Charles Tate -November 4, 1987 >

Source: Federal court testimony of former LaRouche security aide Charles Tate at (D. King) (1,767 Kb) (1,628 Kb)
Note: we have replaced the German spelling of FRANKHAUSER into his American name FRANKHOUSER




Courtroom 14 U.S.P.O. & Courthouse Boston, Massachusetts Tuesday, November 3, 1967
John J.E. Markham II,
Mark Rasch, D.O.J. Attorney
Owen Walker, Federal Defender
Linda MacDonald, Reporter Computer-Aided Transcription P.O. Box 210 PO 6 CH, Boston, MA 02101 (617) 336-6761

THE COURT: Are we ready for the jury?
MR. MARKHAM: There is one very minor matter. I believe your Honor has it within your power to very easily right an injustice. The Marshals will not keep the Men's Room door on this floor unlocked unless you direct it. They say if you direct that it remains unlocked, they will have it unlocked. But otherwise, we have to come to them for the key. They are not always there —
THE COURT: Well, what is the reason? I want to find out why. I don't want to be ruling on something without knowing the reason for the decision.
I will take it up with the Marshal's Office and find out what their reasons are. If there are good reasons, then I may not override them. If there aren't, then I'll have it done.
All right. Are we ready for the jury?
MR. WALKER: Well, don't you want to rise the question —
(Counsel conferring)
MR. KARKHAM: We're ready, your Honor —
MR. WALKER: One other — no, I can wait, your Honor.
THE COURT: All right. The jury may be brought in.
(The jury entered the courtroom at 9s35 a.m.)
MR. MARKHAM: May I get the witness, your Honor?
THE COURT: Good morning, members of the jury.

You may. The witness may be called back to the stand. Thank you for being prompt.
MR. MARKHAM: May the witness take the witness stand
again, your Honor?
THE COURT: Yes. Charles Tate, resumed.
Q. Good morning, Mr. Tate.
A. Good morning.
Q. Do you understand, sir, that you're still under oath?
A. Yes, I do.
Q. How, yesterday you indicated that you had observed the
fundraising activities in the national headquarters as they
existed before the 1984 campaign, correct?
A. That's correct.
Q. And did you observe what entities money was being raised
A. Well, for a variety of different entities. They would
include Campaigner Publications, Executive Intelligence Review,
the National Democratic Policy Committee, Fusion Energy
Foundation, the Schiller foundation or its — I forget its
precise name. Those would be some of the entities for which
money would be raised in the period before 19 in the 1983
Q. All right. Let's take these one at a time.

Tell the jury briefly what Fusion was — is or was.
A. Well, the Fusion Energy Foundation is purportedly assigned to the organization devoted to political organizing on behalf of fusion power, nuclear energy, advanced technologies and the like. It serves as kind of the scientific front group, if you will, for the LaRouche organization. It would be used, for example, to facilitate contacts with scientists and other such persons.
Q. What is Executive Intelligence Review?
A. Executive Intelligence Review is a weekly publication put out by the LaRouche organization in which they publish articles with their analysis of the way the world works and things of this nature, economic analysis, descriptions of the various conspiracies that they see unfolding about them and against them and so forth.
Q. All right. You mentioned NDPC.
A. Yes.
Q. What is that?
A. That's the National Democratic Policy Committee. This is the political action group with which the LaRouche organization seeks to intervene into Democratic party affairs, thus the intentional similarity between the name of the group and the Democratic party.
Q. Do you know whether there is any affiliation between the national Democratic party and the NDPC?

A. Absolutely no affiliation between bhe two whatsoever.
Q. Lastly, I think — well, there are two more. Schiller, what is Schiller?
A. Well, the Schiller foundation or institute or whatever — I'm not really certain of its present name, and I'm not certain if it had precisely that name at the time — is what might be described as a cultural group which, unfortunately and really inexplicably, seized upon the name of Frederick Schiller, a very marvelous and wonderful human being and poet, as a sort of focus for the organization's cultural activities, which had about as little to do with Frederick Schiller as could be imagined; but, nonetheless, that's what it is. They gave concerts and lectures and things of that sort under the rubric of this organization, the Schiller Institute or whatever.
Q. The last group for which you indicated the money was raised before 1984 was Campaigner. What's Campaigner's full name, do you know?
A. Campaigner Publications is, I believe, the full name of the business entity.
Q. And what was its function?
A. It was the publisher and distributor for a variety of the LaRouche organization affiliated publications, including Hew Solidarity, which is a biweekly newspaper, and a number of other such publications.
Q. Now, did you ever have any discussions with anybody during

the pre-1584 period in which it was discussed which of these entities money would be raised for on a particular day?
A. Well, seldom, if ever, was there such a specific focus in the pre-1984 period on the entity for which money was to be raised. That was much more rigorously defined after 1984.
Q. All right. Starting in 1984 with the campaign, did you observe the fundraisers raising money for entities other than these five?
A. Yes.
Q. Which entities were added?
A. The principal entity added was The LaRouche Campaign. And although I don't know that it's quite accurate to describe there as other entities, there were two other motivating features of fundraising aside from the political campaign, The LaRouche Campaign. Those were described on one hand as infrastructure, meaning effectively the day-to-day payment of the organization's bills and so forth, and also expansion for the move that the organization was then undertaking down to Leesburg, Virginia. So there were the sort of three general areas of fundraising.
Q. All right. Now, can you compare the amount of fundraising that went on based on your observations before the campaign and then during the campaign?
A. Well, the level of fundraising during the campaign was much, much greater, both in duration, intensity and finally in the number of persons devoted of the organization's troops to

Q. Now, during what part of the 1984 campaign were you in the
national headquarters on a daily basis?
A. I was in the national headquarters almost all the time
except when I was doing security shifts in Leesburg, Virginia
from January 1984 until August 17, 1984.
Q. Well, for example, how many days during 1984, approximately,
were you in the national headquarters observing the fundraising
A. Any day that I was in the national headquarters I would be
observing fundraising activity. I guess it would have to be
something like 175 to 200 days.
Q. was it always the.same?
A. Yes.
Q. Describe for the jury what you would observe about
fundraising on the days that you were in the national
headquarters during the campaign.
A. Okay. The fundraisers — basically everyone in the national
office would be — would have a meeting starting at 9 a.m., in
the morning. There would be a roll call. Each person's name
was read off. In fact, if they weren't there, they were sent
home. They received instructions from Will Wertz, as I
mentioned previously, about the quota to be raised, what entity
or for what purpose or for what particular business they would
raise that quota. That is, were they today going to be raising

4-8 money as The LaRouche Campaign or as some other entity?
They were to — they were specifically told how much money they were to raise, what kind of issues they would raise in their discussion of fundraising with contacts. They would then break, go to their offices, perhaps have short meetings with their other people in their sectors.
And then they would take out contact cards, which would have the names of the persons that they were planning to call. They would call those persons and solicit the funds. This would proceed until a certain point where there was a brief interruption for lunch, and it would continue until dinner. And then there would be another meeting to discuss the day's work in fundraising, to discuss progress toward quota, to ventilate Will Wertz's anger and outrage if enough money hadn't been raised, to congratulate the members if they had been raising the appropriate amount of money. And then this process would continue until late in the evening until finally the entire national quota for the whole country was raised. That was basically the daily cycle.
Q. All right. And do you have any knowledge of what activities were going on in the regional offices while this activity that you described was going on in the national office?
A. Yes.
Q. Tell the jury how it is that you have that knowledge of what was going on in the regions.

A. One of the major topics of the discussion that Wertz led —
Q. I'm sorry. That who led?
A. I'm sorry.
— that Will Wertz led during these two meetings that we had daily in the national office was. How are the regions doing and what are the regions doing? And he would motivate this discussion using a blackboard with a grid of projected quotas of income actually raised and so forth broken down on a region-by-region basis. So you would actually see Baltimore is doing great or, you know, Chicago is leading the way in this respect or the other respect. And he would give us vignettes of the organizing experiences, vignettes of the organizing experiences that would be useful for fundraisers to, you know, maybe to try out themselves in their contacts and so forth.
So there was an ongoing discussion on a daily basis not only of the national office fundraising but also in the regional component of the fundraising.
Q. One more time, if you could repeat for me, tell — what cities were encompassed in the New York region?
A. Okay, well, cities encompassed in the New York region were New York City and the metropolitan area, New Jersey where the regional headquarters was at various times, and Boston, Massachusetts encompassing, of course, the New England area.
Q. Did you ever hear Will Wertz in these discussions that you have described speak about the New York region's fundraising?

A. Yes.
Q. How frequently?
A. Virtually every day would include some discussion of the regional fundraising that would at least touch on either in some detail or simply in passing New York's role in the overall effort.
Q. Now, how often did you physically observe/ Mr. Tate, fundraisers from the Labor Committee actually in the process of raising money?
A. Well, during this period I observed such fundraising every, single day.
Q. And what method did the fundraisers use to try to solicit money from individuals?
A. How do you mean, what —
Q. How did they do it? Describe how they did it.
A. Well, what .they would do is they would have at their disposal a bunch of contact cards. The contact cards would have the names and phone numbers and other information. They would call up the contacts, and then they would try to motivate the discussion based upon the briefing that they had during the morning or afternoon meeting to raise money.
Q. Let me interrupt you for a second to slow it down a little bit.
How often was it that you observed money being raised by telephone as compared to going out and meeting people

individually to solicit money?
A. Well, the national office fundraising was almost exclusively
by telephone, and what I observed were individuals calling
people up on the phone and seeking to get them to give money by
these telephone conversations; specifically, seeking to get them
to make contributions by credit card over the telephone.
Q. All right. How often when you observed people attempting to
raise money by telephone did you observe them to be using
contact cards?
A. Almost invariably. Only in a very few cases would someone
not be calling directly from a contact card.
Q. And approximately how many times during the 1984 period did
you physically observe fundraisers on the phone using contact
A. I can't count. Hundreds of times. This was what almost
everyone in the national office was doing.
Q. Did you ever observe how these contact cards were initially
A. Yes.
Q. Describe to the jury your observations in that regard.
A. Well, sometimes contact cards would be sent to the national
office by regional centers. One of the things that the
organization did was seek to meet people at airports and other
public places. Typically, persons met in these places would
have their names sent, prepared on contact cards, to the
4-12 national office or other centers for follow-up.
Also, contact cards were prepared off of lists of subscribers to the organization's publications or other publications or professional or fraternal or other groups that the organization thought for some reason would have an interest in its political activities. So those are the basic means by which contact cards were initially prepared.
Q. And after they were prepared — well, did you ever receive any instructions from your superiors in the organization as to what to do with contact cards after they had been prepared?
A. Yes.
Q. How often did you receive such instructions?
A. Well, I think probably only a few times in the beginning of the 1904 period. It's a fairly simple and straightforward procedure. After that, I think everyone followed it pretty much as a matter of course.
Q. Do you remember who gave you these instructions?
A. No. I can't actually tell you a specific name. It was the practice that we all followed in our fundraising to maintain contact cards in a certain way, and I don't recall really who told it to me first.
Q. All right. Well, would you describe the practice as to how these cards were maintained?
A. Sure. The card would characteristically include the name, the address, phone number of the contact, very often also the

credit card authorization number, and expiration date of the credit card. There would be a summary of each phone call to the contact, including the amount of money raised, for what purpose, what the discussion was that led to the raising of that amount of money, and special interests that the contact might have in certain political areas that might be fruitful to exploit in future phone contact with the contact for future fundraising. Those were, you know, the essential pieces of information that contact cards contained about any fundraising contact.
Q. Did you ever observe any fundraisers doing anything with the contact cards while they were on the phone?
A. Yes. Fundraisers characteristically would make note of any money that was given or any responses made to the fundraising conversations so that, for example, if somebody did give $500, that would be written down. If somebody said, "Call me later, I'm interested in the problem of drugs," or something like that, that would be written down. So that there would be some kind of capsule summary of the results of each discussion with the contact.
Q. All right. And did you, yourself, ever raise funds, sir?
A. On a few occasions.
Q. And when you raised funds, did you ever raise them by telephone?
A. Yes.
Q. And describe what you would do when you raised funds by

A. Well, I did much less fundraising than most of the persons in the national sector, so I was not as familiar with the procedures. So, in fact, what I had to do was check with the national finance office as to the correct procedure and —
Q. Who did you talk to, do you remember?
A. I'm not absolutely certain. I'm not absolutely certain. It was whomever was functioning — there was sort of a system sometimes of runners who would go to the sectors and see how they were doing. I think I grabbed whoever that person was on that day, and what I was told to do and what I did was the following:
When the person had indicated a willingness to give a certain amount of money, I impressed upon this person the importance of giving it by credit card rather than by, let's say, sending a check. They agreed. I got a credit card chit, a Mastercard or Visa credit card chit, and made the appropriate entries. These included, of course, the authorization number, the date, the expiration date, something indicating my sector, which is the Security staff, my initials, the amount contributed, and I'm — I don't remember what else exactly. The date probably.
Then I prepared my contact card for this person with the information which I indicated before. I don't want to, you know, necessarily go over that again, but name, address, phone

number, the rest/ and a summary of what he discussed, the amount of money that this person had agreed to give and so forth, so that there would be a record of this person's interest, you know, for future fundraising attempts.
Q. All right. Now, Mr. Tate, I'm putting in front of you and the jury a document which I will mark as, if I can since I'm not going to be admitting it, as Government's 1A for identification.
Can you see that from where you are, Mr. Tate?
A. Yes, I can. It's very clear.
THE COURT: Can the jurors see it?
Q. Now that I've shifted it, can you see it?
A. Yes.
Q. Have you ever seen any document that looks like this document before?
A. Yes.
Q. How often?
A, Well, hundreds of times.
Q. All right. What is this?
A. Well, this is a contact card. It's the type of document that I was describing previously.
Q. All right. Now, I notice that in the upper left-hand corner of Government's 1A for identification there is the name Mary O'Reilly, correct?
A. That's correct.

Q. And how many times did the contact cards that you observed have the name in that approximate location on them?
A. I would say invariably.
Q. All right. How about the address and the phone number? Were they usually on the cards that you saw?
A. They were always on the cards and in approximately those positions.
Q. All right. Now, how many times did you actually use contact cards when you were fundraising?
A. Well, any time that I was fundraising I would use contact cards or prepare contact cards if I was, let's say, calling off of a cold list, off of a list which had not previously been called for which there were not already contact cards prepared. So that any time I did it, which is to say probably about a dozen times during that year, uncharacteristically —
(Off the record)
A. I was just trying to clarify that a dozen times for a person in the national office — to fundraise only a dozen times between January and August of 1984 is very, very low. Almost nobody else did it so seldom. But on those dozen occasions invariably I either called from contact cards or prepared contact cards after my phone call.
Q. Did you ever actually raise money by telephone when you solicited by phone?
A. Yes.

Q. When you did so, did you ever make any entries on contact cards?
A. Oh, yes.
Q. How often?
A. Well, every time I raised money.
Q. What specific entries did you put on the contact cards on the occasions when you were successful at raising money?
A. Well, the entry that I would put would include the date, the amount of money raised, the purpose for which it was raised.
Q. What do you mean by "the purpose"?
A. When I say "the purpose for which it was raised," if it was for The LaRouche Campaign or if it was for Campaigner Publications or for Fusion Energy Foundation, whatever the specific entity was to which the person had agreed to give the money, that would also be indicated on the card; the subject we had discussed, whatever it might have been, the threat of KGB takeover; whatever it was that got that person to give money I wrote down. And together with it I would write down whether they gave the money by Mastercard or Visa or whether they agreed to send a check or what means was used for making the financial transaction.
Q. All right. How often did you observe other fundraisers engaged in activities similar to that which you have just described in connection with the contact cards?
A. Every, single day —

Q. All right.
A. — people were doing precisely that kind of procedure.
Q. Can you tell by looking at Government's Exhibit 1A based on your experience what the entry — the first dated entry means on this contact card, which is Government's 1A?
A. Okay. It means that on 8/9/84 this individual gave S100 to the Independent Democrats for LaRouche, and this individual, Mary O'Reilly, gave it on a Visa card.
Q. All right.
A. Then, as I look at this, it appears to be a summary of a conversation and personal background on the individual. It says, "Going to Ireland. Speaks German." That's a very big point with the LaRouche people. They like Germans. "Has pro-beam pals." That means people who like Star Wars is what that means in LaRouche parlance. "Pro-beams" means like Star Wars.
Then there's a later entry indicating a subsequent contact on I guess it says 10/18. "45" would mean that she was hit for S45 at that time. This time she gave it as NDPC. I realize this is like an alphabet soup. The NDPC is the National Democratic Policy Committee. It's a group that I mentioned before. The "NDPC/NS/SUB" means that she gave 545 to purchase a membership in the NDPC and a subscription to the New Solidarity that I mentioned before. And she says that she is horrified at Greens. Greens are not a vegetable. Greens are a West German

political party that's kind of ecologically-oriented, kind of left wing. The organization was in a big upheaval against the Greens at the time —
Q. All right.
A. — et cetera. I don't mean to — but that's — anyway, that's what — if you will, that's sort of to decode what's there in terms of what it means.
Q. When were you last in the national office?
A. On August 17, 1984.
Q. Why is it that you remember that day so specifically?
A. Oh, I mean, in my life that was a signal date. That was the last day I had to put up with these people and this kind of procedure. So I'll never forget that date.
Q. And on that date or as near to that date as you can recall, approximately how many contact cards were there like that on the premises?
A. I would have really no way of counting. What had happened in 1984 was that every, single person in the national office with very few exceptions was assigned to carry out full-time fundraising activities, and each such person maintained contact cards essentially like that for everybody that they spoke to who proved to be of any possible value. So each of these persons, more than a hundred persons in the national office, maintained hundreds of cards just like that. So I can't even begin to estimate just how many there were.

Q. You mentioned credit card chits, correct?
A. That's correct.
MR. MARKHAH: Can everybody see —
Q. Can you see this?
A. Yes.
MR. MARKHAM: Your Honor, may I ask through the Court if the jury can see this?
All right.
Q. What is this?
A. Well, that's a credit card chit.
Q. Now, you testified that when you were fundraising, you prepared these slips, correct?
A. Yes.
Q. And on what occasions would you actually write out credit card chits like this?
A. Well, when I — when someone I had called had agreed to give money by credit card for one or another of these entities, these businesses, then I would get a credit card chit like this and fill it out.
Q. All right. And what information did you put on the credit card chits when you filled them out?
A. Well, the information that I put on was the authorization number, which is the number — I believe it's the number in the

upper left-hand corner. That's the general type of number. The date, the expiration date of the credit card. As I mentioned before, the sector that I was in, which in my case was Security, would be entered on the credit card under the — in the little box that says "Department." I'm not sure if that's clearly-visible to .everybody, but there it is. Of course, I put my initials in that box. The date. I believe I entered the date. The purpose for which the money was raised, the amount and the total.
Q. All right. And was there ever an occasion on which you raised money by telephone by credit card that you did not do what you have just described in connection with the credit card slip?
A. No. That's precisely what I did. The one thing which — the one entry I didn't make — at least the one entry I didn't make was the authorization number. That was handled in a separate team in my case. Someone else called in the credit card through the clearing agency and entered the authorization number.
Q. Do you know whether they did that before or after you had filled out the rest of the card — the rest of the chit?
A. I had filled out the rest of the chit, whatever the organizer was supposed to fill out, those categories, before I handed it over to them for clearing.
Q. And what did you do with the credit card slips after you had

prepared them as you have described?
A. I gave them to the national finance office.
Q. is that in the same building?
A. yes.
Q. And who was in the national finance office that you gave them to?
A. You know/ the truth is I don't remember to which individual I handed the one or two credit card chits that I filled out. I know the people who were there who might have gotten it, but I don't know which one specifically I handed it to.
Q. Mr. Tate, during the 1984 campaign what were you doing if you weren't raising money?
A. Well, during the 1984 period I was still, as I mentioned before, on the Security staff of the organization.
Q. And how long had you been on the Security staff?
A. I joined the Security staff in 1981 and I had been working with them informally for several years prior to that.
Q. All right. Prior to starting to work on the Security staff, what activity were you engaged in at the Labor Committee?
A. Prior to my being put on the Security staff, I worked in the organization's press staff, sort of a — well, actually there were two things.
l worked in the organization's press staff, which is sort of a -- I guess I'd have to sort of describe it as a public relations arm of the organization. It contacts reporters. It

puts out press releases, et cetera. And then I went front there to working with the organization's publications —
Q. If I can interrupt you to tell you that I think you're speeding up.
A. Okay. Thank you.
Subsequent to working on the press staff, I worked on the organization's publications, writing for New Solidarity, Campaigner, which is one of its magazines, and so forth. Those were my principal assignments before I joined the Security staff.
Q. You indicated that during that time period before you started working with Security you actually had some contact with Security?
A. yes. That's right.
Q. What kinds of contacts did you have during the period immediately before you started working for Security?
A. Well, they were two-fold. One is that I was among a number of persons pulled in to augment the Security staff's sort of physical security component. That is, I would be assigned to do security shifts at the LaRouche residence or other places where the organization felt that there was some threat of attack by possible forces. There were a number of persons not formally assigned to the staff who were pulled in to help Security do that kind of thing, and I functioned in that capacity.
Secondly, because of the work on the press staff, I

worked closely with the Security staff in monitoring reporters and other people in the media who might be inclined to write articles about Mr. LaRouche which would be unflattering and which he wouldn't want to have appear. So in these two capacities I would work with the Security staff for some time before actually joining the staff.
Q. And before joining the staff, did you have any discussions with anybody about joining the staff?
A. Yes.
Q. With whom did you have those discussions?
A. Chiefly with Robert Greenberg.
Q, And as of the time you had those discussions, what was Robert Greenberg's function?
A. Robert Greenberg was then a member of the Steering Committee of the Security staff, which is the group which sort of runs the staff on a day-to-day basis and the group which most directly comes into contact with Lyndon and Helga LaRouche.
Q. Did you actually join the Security and Intelligence staff after those discussions?
A. Yea.
Q. And when was that, again?
A. That was in 1961.
Q. Do you remember when in 1981?
A. I believe it was in June — somewhere between June — I think in June.

Q. When you joined this Security and Intelligence staff, were you on its Steering committee?
A. No.
Q. Were you ever on its Steering Committee?
A. No.
Q. Who was on the steering Committee besides Robert Greenberg?
A. Okay. The members of the Steering Committee were Paul Goldstein, Jeffrey and Michele Steinberg, Robert Greenberg, Robert Kay; at an earlier point, also Zeke Boyd.
Q. was there a person on the Steering Committee that was overall in charge?
A. Yes.
Q. Who?
A. Paul Goldstein was the director of the Security staff. He worked in that capacity in very close association with Jeff Steinberg.
Q. And after you came on board the Security and Intelligence staff, how long did you stay on the staff?
A. Until I left the organization in August 1984.
Q. And where did the Security and Intelligence staff have its offices?
A. The offices were in the national office complex on 56th Street.
Q. And how many — well, was it a separate area, or was it coming led with everybody else?

A. Well, it was a small suite of rooms at one end of the — basically at one end of a long hall that led to most of the national office. In total, it comprised four small connected rooms.
Q. All right. Did you have your own private office?
A. No.
Q. Did you have an area where you normally worked from?
A. Not really. Everyone was sort of all over — all over the place. There were occasional efforts — there were occasional campaigns to assign people desks and things of this nature, but these broke down very, very quickly.
Q. How much of the day during your daily activities at the Security and Intelligence staff were you physically able to observe other members of the Security staff and what they did?
A. Pretty much all the time. The rooms were connected; and except in the rare circumstances when the members of the Steering Committee closed their door — they had basically two rooms for their use — you could see and hear practically everything that was going on.
Q. Now, after you got on the Security and Intelligence staff, what is the first activity that you engaged in, do you remember?
A. when I first joined?
Q. Yes.
A. Well, I don't remember the very first. I know that the — I remember what the usual entry-level assignment was, which was

to function as what, was called the Officer of the Day.
Q. What is —
A. The Officer of the Day —
Q. Did you ever function as the Officer of the Day?
A. Yes.
Q. Who told you to function as the Officer of the Day?
A. One or another of the members of the Steering Committee, usually Jeff or Michele.
Q. What did they tell you to do as Officer of the Day — well, before you state that, how often did you function as Officer of the Day during your three years with the Security staff?
A. I'd have to estimate that I performed that function somewhere in the area of a hundred times.
Q. were the responsibilities of the Officer of the Day usually the same?
A. Yes.
Q. What did you do when you were Officer of the Day?
A. You prepared a press report, which is a sort of summary of what the newspapers had in them of interest to the Security staff that day. You answered the telephone, basically took incoming calls, saw to it that everybody's reports were collated into a final intelligence packet that could be submitted to Mr. and Mrs. LaRouche and to the National Executive Committee at the conclusion of the day. Those were the essential functions. And also, to handle some of the logistical matters; that is to

say, getting money if the staff needed money, seeing to it that essentials were purchased and stuff like that.
Q. When you came on board the Security staff, did anybody tell you what its functions were?
A. Well,.at the point at which I joined the staff I had been a member of the organization either for eight or ten years, depending upon how you start counting, so I knew at that point very well what the functions of the staff were without being expressly told.
Q. And how is it that you came to know that?
A. Well, through descriptions ongoing about the function of the Security staff beginning in 1973 and increasing in 1974 which were disseminated to all members about what its role was to be within the organization. And then, of course, through my interaction with the Security staff from the period 1978 or so when I was kind of pulled in as an auxilliary I was able to participate in many of these functions and, therefore, I knew what they were first hand.
Q. And was there any change that you noticed in the functions of the Security staff from the time you got on it in 1981 until the time you left in August of 1984?
A. No. I would say throughout that entire period the functions were the same.
Q. What were their functions?
A. Well, I would say that they were the following: First, to

act as Lyndon and Helga LaRouche's eyes and ears; that is to —
Q. What do you mean by that?
A. Well, by that, I mean to collect intelligence — I use that word advisedly — about what was going on in the world situation, about what happened domestically, particularly with respect to such areas as espionage, international arms dealing, international strategic policy and things of that nature.
Secondly, it was their business to find out about any possible situations which might be to the general detriment of the LaRouches, articles in the press that were critical of LaRouche, government or other investigations of LaRouche and his organizations that might prove to be detrimental. In other words, they were sort of to function as — well, as a, you know, kind of a first line of defense of the organization against these kinds of attacks. In tandem with that, if such attacks, articles in the press, government investigations, whatever loomed or were thought to loom, it was the Security staff's function, role and responsibility to — the word that we used was counterpunch against persons who were so venal as to criticize Lyndon LaRouche in any way by counter- — well, I can describe what I mean by counterpunching in more detail.
To sort of finish off the other functions, the Security staff also acted really as kind of a household staff of Lyn and Helga. At this point they did the shopping! they did the cooking; they provided for the physical comfort, wants and well-

4-30 being of the LaRouches personally.
They also carried out physical security assignments. They would, you know, stand around the house with guns and other weapons to defend the LaRouches, who believed themselves always to be the targets of innumerable assassination conspiracies emanating from all manner of people. So the Security staff was supposed to guard the LaRouches against these assassination plots — these purported assassination plots.
Then the Security staff had as its responsibility acting kind of as —c acting as sort of an internal — well, you might say order guard within the organization; in other words, seeing to it that any dissent in the organization was quickly picked up, dealt with and either quenched, you know, before it got to the flaming stage or else was expelled. In other words, if the Security staff got wind that somebody was disaffected in some way, if they didn't agree with something, it was their responsibility to see to it that the appropriate individuals intervened real fast before it became a problem. So that was another function of the Security staff.
So basically, it had a variety of functions, most of which can be summarized as acting as the personal and direct arm of Lyndon LaRouche and the organization; intelligence gathering, you know, group for Lyndon LaRouche in the outside world, especially in those areas which I indicated, strategic policy, intelligence and espionage and so forth. So those were the

essential functions of the — and, you know, tunning the organization's internal affairs and guarding LaRouche physically and providing for his physical well-being. Those really were the functions of the Security staff.
Q. And those were the functions that you observed them carrying out during the three years that you were on the staff?
A. Yes. I not only observed them but also took part in these functions.
Q. I think I have five, but let me see if I got all the ones that you mentioned.
The first one you mentioned was acting as Lyndon LaRouche's eyes and ears?
A. That's right.
Q. The second was discovery of any potentially detrimental situations existing in the press or wherever?
A. Right.
Q. Third was what you called counterpunching?
A. That's right.
Q. Four is acting as household staff?
A. Right.
Q. And five is what you called internal monitoring?
A. That's right.
Q. Now, did anybody provide physical security for Mr. LaRouche at any time?
A. Yes. I believe I touched upon that. The Security staff

provided physical security for Lyn and Helga LaRouche and other — chiefly them, but also other persons in the organization. It was the LaRouches' constant belief —
Q. well —
A. All right.
Q. — let me —
A. Yes.
Q. Let me ask you this question.
Did you ever hear Lyndon LaRouche — well, have you ever met Mr. LaRouche?
A. Oh, of course.
Q. How many times have you seen him?
A. Hundreds Of times.
Q. How many times have you heard him speak?
A. Dozens — I mean, speak publicly or speak personally —
Q. How many times have you heard him speak publicly?
A. Scores of times.
Q. How many times have you actually participated in conversations directly with Mr. LaRouche?
A. Dozens of times.
Q. Rave you ever had conversations with Mr. LaRouche about his belief as to why he needed security?
A. Yes.
Q. And what did he tell you in that regard?
A. Well, in that regard he said very expressly that all manner

of persons were out to kill him.
Q. Did he ever tell you — express the belief as to who he
believed was out to kill him?
A. Well, there were different persons at different times but,
yes, he had a number of candidates for this role.
Q. Can you think of any?
A. Sure. Henry Kissinger was often top of the list. The Queen
of England had a hand in it. So did Gorbachev. Various and
sundry former members of the organization, you know, surely were
implicated. All manner of persons on the far right, on the far
left. Let me see. I think Jimmy Carter was involved at one
time. It's so hard to, you know, remember all the names. There
were — the Baader-Meinhof gang.
Q. Can you spell that for the Reporter?
A. Yes. I'm sorry. It's B-a-a-d-e-r-K-e-i-n-h-o-f,
Baader-Meinhof gang, a West German terrorist gang. There are.
others. I can go on almost indefinitely, but these are some of
the individuals who were involved in these assassination plots
at various times.
Q. Now, did you ever have any discussion with any members of
the Steering Committee as to their belief with respect to these
assassination plots?
A. Yes.
Q. Specifically, did you ever have any discussions with Jeff
Steinberg on this subject?

A. Oh, yes.
Q. Did he ever express any beliefs to you on this subject?
A. Yes, constantly.
Q. What beliefs did he express to you?
A. Well, he always expressed the conviction and belief that whatever assassination plot Lyn had announced was ongoing had to be deterred by whatever means or else — I'm — you know, I'm sorry, it's almost too silly to restate. But basically, Steinberg would always say that whatever assassination plot was currently believed to be unfolding had to be stopped, and he expressed the sincerest conviction that, you know, it was going ahead full steam.
Q. Did he ever express to you his view on whether or not this was silly?
MR. WALKER: Objection.
THE COURT: I sustain the objection.
Q. All right. Did he ever express to you any belief as to whether or not he thought these plots were credible?
A. Oh, absolutely.
MR. WALKER: Objection.
THE COURT: The objection is overruled. The question and answer may stand.
MR. MARKHAM: I'm sorry. I just heard the objection. I didn't hear the answer.
THE COURT: The objection is overruled. The question

4-35 and answer may stand. The answer may be read back.
(The record was read as requested.)
Q. Okay. What was his belief in that regard?
A. His belief —
MR. WALKER: Well, objection, your Honor. That — what was Mr. Steinberg's belief?
MR. MARKHAM: As expressed by Steinberg. 803(3).
THE COURT: Well, there is a problem with the form of the question.
MR. MARKHAHt Let me start over, if I may.
THE COURTi All right.
Q. Did you ever have any discussions with Jeff Steinberg in which he expressed his belief on the subject of assassination attempts of Lyndon LaRouche?
A. Yes.
Q. How many times did you have such discussions?
A. Scores of times.
Q. What did Mr. Steinberg express as his belief?
A. That these persons, the ones that I named, and others were involved in a conspiracy to assassinate Mr. LaRouche.
Q. All right. And did he ever express to you his belief as to whether or not he thought these plots were genuine or credible?
MR. WALKER: Objection.

A. Yes.
THE COURT: Objection overruled. The answer may
Q. The answer was "yes," again?
A. Yes.
Q. And what did he say in that regard?
A. Well, many things. He would give instructions based upon
this belief to me and others to write press releases exposing
the various and sundry sinister conapiracies which he and others
believed to exist.
We would be instructed to call the offices or homes of various of the principals believed to be participating in these assassination plots and confront them with the evidence which we had accumulated of their perfidy. We, you know, were carrying out other activities at his direction such as — or the direction of other members of the Steering Committee to augment physical security at Mr. and Mrs. LaRouche's premises in anticipation of these coining waves of assassins. So that not only, you know, did he tell me expressly that these things were going on and that he believed them, but he told me and others to go and do things on the basis of this belief expressly to counter these threats.
Q. Did you ever have any such discussions with other members of the Steering Committee?
A. Yes.

Q. With Paul Goldstein?
A. Yes.
Q, How frequently did you have discussions about his beliefs in these assassination plots?
A. Well, these are hard to quantify, but certainly, you know, a dozen times, a score of times.
Q. And describe generally what Mr. Goldstein would express to you as his belief about these assassinate plots.
A. Well, he expressed conviction that these plots were underway, and usually he would do this in the form of expressing outrage that you and others weren't doing enough to keep these plots from succeeding. So you usually would — he would say literally, "Lyn's life is in danger and you're not doing —" I don't want to use the expressions "— about it."
I don't want to use the language he used. He was somewhat —
Q. Well —
A. Hm?
Q. well —
A. All right. He would usually motivate — try to motivate us to do things by using vulgar and violent language in which he would emphatically state his belief that Lyndon LaRouche's life is in danger and we weren't doing anything about it.
Q. Did you have discussions on this subject with Michele Steinberg?

A. Yes.
Q. And with Robert Greenberg?
A. Yes.
Q. Now, let's go to the first of the topics that you mentioned, that the Security staff functioned as LaRouche's eyes and ears.
Describe what you observed members of the staff doing when they were performing that function.
A. Well, they did a variety of things. Probably most of their time was used in placing phone calls on pretexts. That is, they would call up and say, I'm a reporter for the Boston Globe, for the New York Times, for the Financial Times of London, what do you think about whatever the subject of Mr. Larouche's interests might be, usually Mr. LaRouche. So you would call up and you would say, "I'm from the Financial Times of London and what do you think about Lyndon LaRouche?" And you would get some kind of answer. And this pattern of responses would be written up as, you know, part of the day's intelligence product.
So I would say, first of all, most of the people in the Security staff in seeking information would make direct phone calls of this sort or other contacts under these false pretexts to get information.
Secondly, the —
Q. Well, now, if I can —
A. I'm sorry.
Q. If I can interrupt you for a second.

How frequently did you observe members of the Security staff calling up to make these pretext calls that you have just described?
A. Hundreds of times.
Q. Did you yourself ever do this?
A. Yes.
Q. How frequently?
A. Hundreds of times.
Q. All right. Now, when you observed the other members of the Security staff undertaking these calls/ did you observe them doing anything after the calls with the information they had obtained?
A. Well, yes. Well,, first of all, during the call they would write down what they were hearing on the other end from the person to whom they were speaking. And then if there was any usefulness in it according to their view, they would report on the substance of the call either immediately to the leaders of the Security staff, the members of the Steering Committee I've already mentioned, or they would report it at the twice-daily meetings the Security staff held.
Q. Now, did you ever observe members of the Steering Committee make these pretext phone calls?
A. Yes.
Q. And what did you observe the Steering Committee members to do while they were making these phone calls?

4-40 .
A. Well, again, the Steering Committee members when making these kinds of pretext phone calls would typically write the substance of what was being discussed in their notebooks. Very often, also, not only Steering Committee members but also the regular members of the Security staff would tape-record these conversations, so that there would be a record of their undercover call, as we liked to call them.
Q. Now, how many times did you see Jeffrey Steinberg on the phone making pretext calls?
A. Hard to give a precise number. Scores of times perhaps.
Q. How about Michele Steinberg?
A. She — again, I guess I'd have to say a dozen times or so.
Q. How about Robert Greenberg?
A. A dozen times. Hard to give a number, but they made such calls in my presence. I can remember maybe in each half a dozen occasions or so specifically that they were doing it, who they were talking to, why they were doing it and so forth.
Q. And how about Jeff Steinberg?
A. Jeff Steinberg, yes. Also Jeff Steinberg.
Q. How often when they were doing these types of calls did you
observe them to write in their notebooks?
A. Pretty much invariably. If they had -- I guess I should
add, though, that if they were tape-recording the phone call, they might or might not be so punctilious about the entry in the notebook; after all, there was another record. Most commonly if

there was a tape-recording of the phone call, they would type it up at a later point. They would produce a transcript at a later point. But there would still usually be some record that a phone call was made.
Q. On occasions when they were not taping the phone call, how frequently was it that these pretext calls were the subject of a notebook entry?
A. Invariably. I think invariably in any case because even if it were taped, they would want something off of which they could make a verbal briefing either to Lyndon LaRouche and/or to the Security staff about their call.
Q. Now, apart from these pretext calls that you have described, did you ever observe Goldstein or the Steinbergs or Greenberg on the telephone speaking to other people where they were not acting under pretext?
A. Yes.
Q. How frequently?
A. On a daily basis.
Q. How frequently on a daily basis?
A. Hard to give an exact number. There were a fair number of persons who were maintained as sources or paid as consultants providing information on topics of interest to the LaRouches, to the Security staff.
Q. And did you personally ever call those consultants or sources?

A. Now and again.
Q. Did you ever observe Jeff Steinberg, Michele Steinberg, Paul Goldstein or Robert Greenberg making such calls?
A. Yes.
Q. Did you observe them to make those calls more or less frequently than you?
A. Oh, much more frequently.
Q. Why was it that you didn't make those calls as frequently?
A. Well, they were further up in the organization's hierarchy and on the Security staff hierarchy. They were the members of the Security steering Committee, and they were the persons who most commonly would have the direct responsibility for communicating the information to Lyndon LaRouche, So that they would be most commonly the persons directly to have dealings with these sources and consultants.
Q. Now, how frequently did you observe these four Steering Committee members to be making calls to consultants and sources as compared to the calls that they made under pretext as newspaper reporters or whatever?
A. Or whatever. I think that they were making the balance of their phone calls to the consultants and sources rather than to — rather than in an undercover pose. They devoted more of their time to maintaining contacts with the sources and the consultants than they did, you know, calling people on pretexts.
Q. What did you observe them to be doing when they were on the

telephone speaking with their sources or consultants?
A. Well, especially when they were speaking to sources and consultants, they wrote down very, very carefully what it was being said to them by these sources and consultants.
Q. Specifically, did you ever see Jeffrey Steinberg speaking on the telephone when, by what he was saying, he indicated he was speaking to a source or a.consultant?
A. Yes.
Q. How frequently?
A. Hundreds of times.
Q. How often when he was doing that was he writing in his notebook?
A. I'd say every, single time, 99 percent of the time.
Q. How often did you see Paul Goldstein speaking to sources or consultants on the telephone?
A. Scores of times.
Q. How frequently on those occasions did you observe him to be using his notebooks while he was in the conversation?
A. Well, he was always writing things down. He was less punctilious in — all right. He was always writing something down.
Q. I'm not — I'm going to — would you describe to me what you mean by "punctilious"? I'm sorry, you've used that twice, and I let it go by the first time.
A. All right. He — all right. He entered in less detail in

his notebook and, you know, was somewhat more impulsive about making his entries than was Jeff, who was very, very careful and was always writing as he was talking. Is that a — that's what I mean by "punctilious."
Q. Thank you. I just didn't understand what the word meant.
A. Okay. Sorry.
Q. All right. How about Michele Steinberg? How frequently did you observe her on the phone speaking to sources or consultants?
A. Whenever Michele was on the phone speaking to a source or consultant, basically she would be making a notebook entry almost invariably.
Q. How about Robert Greenberg?
A. Once again, it was — it's the same. He would also make notebook entries when talking to sources or consultants.
Q. Mow, did you ever observe — going back to the beginning to Jeff Steinberg again.
Did you ever observe Jeff Steinberg to do anything with the notebook entries after he had written them from the phone calls?
A. Yes.
Q. What did you observe him to do?
A. Well, he would use the notebook entries as the basis for briefing other persons.
Q. Who, specifically, did you see Jeff Steinberg using his notebooks to brief?

A. Okay. He would be briefing most typically either Lyndon LaRouche, whether in person or on the phone; sometimes other members of the National Executive Committee; and members of the Security staff in our Security staff meetings. And he would use his notebooks — he would basically be reading from his notebooks or summarizing the entries in his notebooks during those meetings.
Q. Did you ever speak to Jeffrey Steinberg about his notebooks?
A. Yes.
Q. Did he ever tell you what he was using these notebooks foi?
MR. WALKER: Objection, your Honor.
MR. HARKHAM! I'll withdraw the question.
Q. What did he say about his notebooks when you spoke to him?
MR. WALKER: Objection, your Honor.
THE COURT: Ground?
MR. WALKER: Well, I'm not sure what — hearsay, your
THE COURT: Objection is overruled.
A. Well, in our discussions about the notebooks he would sometimes —-
MR. WALKER: If your Honor please, excuse me, can I just make a further point? could we ask for the date of these discussions?
THE COURT: All right.

Q. How often — I'll do it this way. How often did you have occasion to speak with Jeff Steinberg about his notebooks?
A. Maybe half a dozen times.
Q. Do you remember the dates on which you spoke to him?
A. I'm afraid not, no.
Q. Do you remember whether it was before or after you arrived on the Security staff in 1981?
A. It was certainly after I was on the Security staff.
Q. Was it before or after you left the organization?
A. It was before I left the organization.
Q. Can you pinpoint any more directly when the conversation took place during that time period?
A. Well, one that strikes — that I remember somewhat more vividly.
Q. To start, just say — if you could answer that one "yes. or "no."
A. All right. Please excuse me. Yes.
Q. All right. When can you pinpoint it to?
A. It was sometime I think in 1983. I can tell you why I think it was '83 if you like.
Q. That was going to be my next question.
How do you know it was 1983?
A. I believe it was after the purchase of the Wang computer which, as I remember, was in 1983. And the reason why I remember this is that Jeff Steinberg asked me to write a press

release or a memo on some topic foe which there was information in his notebook, and he had he handed me his notebook and said, "Write this up. These are the facts that I want in the nemo, write this up." And I remember going with the notebook to the Wang computer and sitting down. And that's how I remember that it was in that time period. But I'm afraid I just don't recall the date.
Q. All right. Now, you recall the other conversations you had with Mr. Steinberg on the notebooks to be within the period of '81 and '84, correct?
A. Yes.
Q. And do you recall anything else during that period that he said to you about his notebooks?
A. Ohm —
MR. WALKER: Well, if your Honor please, I guess I will — I will object.
THE COURT: Ground?
MR. WALKER: Hearsay.
THE COURT: What exception do you rely on?
MR. MARKHAH: state-of-mind exception.
MR. WALKER: Well, I guess I'll withdraw the objection.
THE COURT: All right.
A. I'm sorry. Could you repeat the question?
Q. Yes. What was it Mr. Steinberg said to you on these occasions about his notebooks?

A. Well, in some cases when I would be giving him information or someone in ray presence would be giving him information, he would say things like, "Slow down a second. I've got to get this down in my notebook." Or he would — we sometimes would exchange sort of, you know, jocular asides about how carefully his notebooks were kept and how orderly, you know, he maintained his notes and things of that nature. Those are a couple examples that come to mind of discussion of his notebooks.
Q. All right. Now, did you ever observe Jeffrey Steinberg speaking directly face to face with Lyndon LaRouche?
A. Yes.
Q. How frequently?
A. Dozens of times.
Q. And did you ever observe him in — well, do you remember any of those conversations? A, Not offhand.
Q. Do you remember the general subject matter of any of those conversations?
A. Yes.
Q. What were they?
A. Well, the general subject matter is — fell under the areas of reports from sources, appraisals of international or domestic situation, internal developments in the organization that seemed worrisome or important to Mr. Steinberg that he felt Mr. LaRouche should know about, and then, of course, a certain

amount of, you know, casual back and forth.
Q. Now, how frequently did you observe Jeff Steinberg giving Mr. LaRouche reports of sources?
A. Perhaps half a dozen times.
Q. Did you ever observe him to be doing that over the telephone?
A. Yes.
Q. How frequently?
A. Scores of times. I answered the first question as to when I saw it with my eyes. I heard it much more often over the phone.
Q. All right. On the occasions when Mr. Steinberg was briefing Mr. LaRouche on a report from a source, how did you observe him to do that?
A. Well, invariably he would have his notebook open and he would clearly be going down the columns in the notebook reading off or summarizing what he had written in his notebook. Essentially, it was his "aide memoire," if you will, for briefing Mr. LaRouche, the notebook.
Q. Did you ever observe Mr. Steinberg face to face briefing Mr. LaRouche about a report from a source when he did not have his notebook?
A. NO.
Q. Did you ever observe Jeff Steinberg speaking on the telephone to Mr. LaRouche and giving a source report when he did not have his notebook?

A. NO.
Q. Did you ever observe Michele Steinberg to brief LaRouche?
A. Yes.
Q. More or less frequently than Jeff Steinberg?
A. Less frequently than Jeff.
Q. When she briefed him, did you ever hear her brief him about
source reports?
A. Yes.
Q. And how did she do it?
A. Well, again on the basis of notebook entries.
Q. How about Paul Goldstein?
A. Yes. I also heard Paul Goldstein brief Mr. LaRouche.
Q. And how did he do it?
A. Well, to the best of my recollection, he would have a
notebook or notepad with him and he would be briefing off of his
notebook or notepad. As best I can determine from the tenor of
his voice and the attitude of his body and stuff, he was a
little more inclined to wing it than Michele and Jeff Steinberg
with respect to, you know, following strictly the notebook
Q. All right. How about Robert Greenberg?
A. Robert Greenberg also used his notebook in briefing
Mr.. LaRouche and others.
Q. Now, did you ever have occasion to physically look into the
notebook' of Jeff Steinberg?

A. Yes.
Q. How frequently?
A. Several times. Half a dozen perhaps.
Q. Did you ever, in addition to those times, observe him writing in his notebooks?
A. Yes. I observed him writing in his notebook on a daily basis.
Q. All right. And how often did you get close enough to actually observe the writing itself?
A. On roost occasions when we had staff meetings we were sitting around in a circle, and I could easily see — it was inescapable to see his notebook and, also, even to see the entries on the pages.
Q. All right. So how many times is it that you have observed the notebook entries in Mr. Steinberg's notebook?
A. Well, including casual observation and actually looking or reading the notebook for specific information, I probably would have to say a score of times.
Q. What do you mean by "a score of times"?
A. Twenty times, twenty-five times. These, of course, are hard to — I wasn't ticking off, you know, how many times have I seen Jeff's notebooks when I was doing this, but something in that order.
Q. How many times have you had an occasion to observe Michele Steinberg's notebooks?

A. Well, again, whenever the Security staff had a meeting, Michele was making entries in her notebook; and whenever she was on the phone, she was making entries in her notebook. So in that sense I saw her notebook hundreds of times.
Q. All right. And how often did you get an opportunity to observe her handwriting in her notebooks?
A. I don't think more than two or three times. I had other occasions to observe her handwriting, however. But in her notebooks per se a couple times, two or three times.
Q. Incidentally, apart from Jeff Steinberg's notebooks, did you have occasion to observe his handwriting at other times?
A. Yes.
Q. How frequently?
A. Hard to say. A dozen times perhaps.
Q. And how about Michele Steinberg? Overall how many times have you seen her handwriting?
A. Perhaps a dozen times.
Q. And how about Robert Greenberg?
A. Well, I think, you know — well, there again — are you asking about the handwriting?
Q. Yes.
A. A dozen times or so, maybe more, twenty times. Robert Greenberg's responsibilities somewhat more directly guiding, you know, sort of guiding the staff in its specific work, he would sometimes write things out that you would have to read, little

notes or a list of people to call or something of that sort. So I perhaps saw his handwriting a bit more often than Michele's, Michele Steinberg's.
Q. And how about Paul Goldstein?
A. Well, I saw Paul Goldstein's handwriting on a number of occasions. I don't remember precisely how often. And I must say that I chiefly saw his handwriting when I was working in New Solidarity and he would hand in articles and he would have things written in the margins. So I saw his handwriting less often, I guess, than the others.
Q. All right. Now, did you, sir, keep your own notebook?
A. Yes, I did.
Q. And what reason did you have for keeping notebooks?
A. Well, the reasons were several. No. 1, everyone on the Security staff was at all times supposed to be acquainted with what was going on in the world of the organization, to be abreast of these source reports and so forth. So one way we did that was by keeping all these entries in our notebooks.
Secondly, now and again we would be assigned to brief individuals on the contents of some of these. And then, of course, we would be responsible occasionally to write articles and press releases and so forth on the basis of these entries, so that we also had a motivation for maintaining notebooks and keeping information in our notebooks.
Q. Let me show you, sir, what I have marked for

4-54 identification —
MR. MARKHAM: I have shown these to Mr. Walker, your
Q. — as Government's 65, 66 and 67 for identification.
Putting these three documents in front of you, do you recognize any of those Government's exhibits for identification?
A. Yes, I do.
Q. What are they?
A. These are xeroxes of three notebooks that I maintained while I was on the Security staff.
Q. All right. Now, approximately how many notebooks did you maintain for your entire time on the Security staff?
A. I'm not certain. I'd have to guess. Perhaps twenty notebooks or so.
0. And you recognize each of these three as notebooks written in your hand while you were on the Security staff?
A. That's right.
MR. MARKHAM: Your Honor, I'd like to introduce these at this time. May they be marked as Government's 1, 2 and 3 in evidence?
MR. WALKER: I object, your Honor, and I'd like to be heard on this.
THE COURT: All right.
MR. MARKHAM: Well, that's all right. For now I'll mark them by way of identification. I'll come back to them.

THE COURT: All right. Now, Mr. Markham, we need to have a little consultation about the numbering system. I do not want two documents in this trial with the same number even though one is in evidence and one is for ID.
MR. MARKHAM: Yes, your Honor.
THE COURT: We will not use but one number sequence, and that is for — one number sequence. Now, I have no problem with your marking for ID; and if it doesn't come into evidence, we simply have a gap in the numbers. But I do not want two number sequences. That is a recipe for confusion.
MR. MARKHAM: Then if these were to come in, then I would mark them by the same numbers they have been identified
THE COURT: All right.
MR. HARKHAM: All right. But I'm not going to do it —
THE COURT: I take it you have already marked some item as one, two and three, haven't you?
MR. MARKHAM: One, two and three for identification, yes, your Honor.
THE COURT: Well, all right. Now, I think we had better just use the same number sequence both for ID'S and in evidence.
MR. MARKHAM: Yes, your Honor.
THE COURT: And so you marked these as 65, 66 and 67
for identification.

MR. MASKHAM: I won't offer them at this time. THE COURT: All right.
Q. Now, you mentioned that the organization had sources or
consultants, correct?
A. Yes.
Q. And you mentioned that some of those were paid?
A. That's correct.
Q. How frequently did you observe Jeffrey Steinberg to be
speaking to these paid consultants or sources?
A. Well, on a daily basis.
Q. And how about Paul and Michele and Robert?
A. Well, I think most commonly one of those persons would be in
contact with certain of the key consultants and sources over a
determinate period of time. But as long as — whenever they
were in the office, I think it's the case that — when they were
in the office, they were being contacted, one or another of the
sources or consultants.
Q. Now, have you ever met a man by the name of Roy Frankhouser ?
A. Yea.
Q. When did you first meet him?
A. I met Mr. Frankhouser in 1975.
Q. Where?
A. In Reading, Pennsylvania.
Q. And after you met him in 1975 in Reading, Pennsylvania, how

often was it that you saw him?
A. inclusive down to —
Q. Yes, up until you left the organization.
A. Thirty times —
Q. Do you —
A. — perhaps.
Q. Do you see that Mr. Roy Frankhouser here in the courtroom today?
A. Yes, I do.
Q. Would you point him out, for the record?
A. He is the gentleman there at that table (indicating).
Q. All right. Well, there are two tables and three gentlemen. Can you be more specific?
MR. WALKER: I agree that he has identified Mr. Frankhouser , your Honor.
THE COURT: All right.
Q. Was there ever a time that Mr. Frankhouser worked —
MR. WALKER: Objection, your Honor. It sounds — it's a leading question.
Q. All right. Where were you specifically the first time you met Mr. Frankhouser ?
A. I was on The Mall in Reading, Pennsylvania, a public shopping area sort of in the center of town.
Q. Did you speak to Mr. Frankhouser on that occasion?
A. Briefly, yes.

Q. And did you approach him or did he approach you?
A. He approached me and the persons with whom I was standing.
Q. And do you recall what he said?
MR. WALKER: Objection, your Honor. May we approach the bench?
THE COURT All right.
MR. WALKER: I have a feeling we may be getting — I don't know what the testimony is, but other bad acts of Mr. Frankhouser that the Government has never told me about, so I'd like to —
MR. MARKHAMs I anticipate the answer to be that Mr. Frankhouser said he wanted to work with the group. That was his initial contact with the group. I have instructed my witness to avoid the part of the answer which would indicate that Mr. Frankhouser was making the approach as a member of the Klan, so in a sense the answer is only a partial truth. But I believe the answer to be — and I have worked carefully with the witness on this. The answer would be that Mr, Frankhouser approached and indicated that he wanted to work with the group.
MS. WALKER: And that's basically the extent of the conversation?
MR. MARKHAM; Well, then he says something about his intelligence function or lack thereof, and it goes on from there.

MR. WALKER: Sure. Okay.
MR. MARKHAM: perhaps it would be appropriate, your Honor, since the witness has been on the stand for the morning, for us to take a very short break and call the witness over just to make sure that now with you up there and Mr. Markham over here, since we have had this objection, he knows that he is to avoid any part of the answer —
MR. WALKER: Maybe it could be by leading question, your Honor. In other words, did he —
THE COURT: I think the best way is for me simply to ask the witness to step over here now for me to give him an instruction.
All right. Will the witness please step over here for
a moment.
MR. WALKER: I won't object to Mr. Markham leading him through this testimony.
MR. MARKHAM I'd like to —
(Counsel conferring)
(The witness came to the side bar conference.)
THE COURT: Mr. Markham has advised me that he has talked with you to instruct you not to make any references in your answering questions here about anything Mr. Frankhouser may have said regarding his connection with the Klan at any time.
THE WITNESS: Yes, sir.
THE COURT: And so you will understand that neither

attorney means to ask you a question that would call for that information, and you are not to say anything about that in any of your answers.
THE WITNESS: Yes, sir. Thank you for reminding me.
MR. MARKHAM: We also covered other hate groups.
THE COURT: Yes. Yes. The same instruction applies.
MR. WALKER: Incidentally, your Honor, in the absence of the witness just one other point.
THE COURT: You may step back.
(The witness resumed to the stand.)
MR. WALKER: There was all kinds of news reports last night and this morning. Some I heard — most of the reports had nothing about the Klan membership. But I would ask the Court at some point during the day to indicate there were news reports, ask if anyone has read them. I think I heard about one thing mentioning the Klan either on TV or somewhere. I'm sorry I'm so vague about it —
THE COURT: Hell, all right. Just before we break I will make an inquiry.
MR. MARKHAM: When will we be breaking, your Honor?
THE COURT: In another 15 minutes or so.
Q. What was it that Mr. Frankhouser said to you when he

approached you in Reading back in 1975?

A. He said that he was not affiliated with either the FBI or
the CIA and that he was interested in working with us.
Q. Okay, And when you were there, were you there with other
Labor Committee members?
A. Yes.
Q. Now, did you say anything back to him?
A. If I said anything, I simply exchanged a pleasantry. "Oh.
Q. All right.
A. Okay.
Q. Now, did he say anything else that you can recall during
that conversation?
A. Well, he continued a bit along the same lines saying that he
had some agreements and some disagreements about certain things
but that he felt that he could work with us in some way.
Q. Agreements and disagreements with whom?
A. With the Labor Committee, with the organization of which I
was then a member.
Q. Did any other Labor Committee member say anything to him
after he said what you have indicated?
A. My recollection is that they also were pretty bland in their
responses. "Oh, it's interesting to hear that you're saying
that." You know, "Well, thanks for telling us." You know,
"Well, we'll have to talk about this sometime," that kind of

Q. After that conversation, did you relay the substance of that conversation to anyone?
A. No, I did not.
Q. Do you know if anybody else did?
A. Yes.
Q. Who did?
A. I believe the person who — well, I know the conversation was relayed because I later heard back about it. But the person who was responsible for those kind of contacts with the organization center was a person named Michael Brennen.
Q. Do you know if subsequent to that time Defendant Frankhouser started to work with the Labor Committees?
A. Yes, he did.
Q. Do you know when he started to work with the Labor Committees?
A. Well, he began to have meetings with members of the Labor Committee about two or three weeks following this conversation, so I would say in the late summer of 1975.
Q. incidentally, what were you doing in Reading in 1975? Were you a Labor Committee member at that time?
A. Yes, I was.
Q. What were you doing there?
A. Well, I was a field organizer at that time. I was one of the persons who would sell the newspaper or pass out leaflets and things of that nature. And at that point the organization

saw itself as on a sort of massive expansion drive so that it established a plethora of regional centers, each of which had satellites. Just in that particular case Philadelphia was the regional center; Reading was one of five or six smaller towns in the Pennsylvania area which was under the aegis of the Philadelphia organization. And I was sent from Philadelphia to Reading to organize in this way.
Q. How long did you stay in Reading to organize?
A. Three or four months, I believe.
Q. When during this three- or four-month period was it that you had the additional encounter with Defendant Frankhouser ?
A. I'm afraid that I don't remember the exact date. I do recall that it was in the middle or late summer of 1975.
MR. WALKER: If your Honor please, could Mr. Markham refer to Mr. Frankhouser as "Mr." rather than "Defendant" or just plain "Frankhouser "?
MR. MARKHAM: I'll say "Mr." if you wish.
THE COURT: All right.
Q. When was the next time that you personally observed Mr. Frankhouser after this occasion?
A. Well, I observed him maybe half a dozen other times in Reading having meetings with other members of the organization; specifically, members sent from the Philadelphia regional headquarters. So I observed about half a dozen such contacts

throughout the rest of the time that I was in Reading. And then later in the fall or winter of 1975 he also came to my — as I recall, on one occasion to the Philadelphia office.
Q. Now, during these conversations — well, during these meetings that you observed in Reading that took place after the first meeting with Mr. Frankhouser —
A. Yes.
Q. — did he say anything that you overheard?
A. In his conversations with me personally he tended to exchange pleasantries.
Q. Did you ever overhear any of his conversations with others that took place in Reading?
A. Well, it all took place in whispers. There was a great deal of secrecy about them. The substance of them was communicated to me, but I was not present for them, the conversations in Reading, themselves.
Q. All right. Who communicated the substance of those conversations to you?
A. A number of persons. The first was a person named Steven Douglas.
Q. All right. Who else?
A. Subsequently details of those conversations a number of years later were communicated to me by various persons on the Security staff.
Q. All right. Did Steve Douglas ever express a belief to you

as to who Mr. Frankhouser was?
MR. WALKER: Objection. 1 think I have to object to that, your Honor.
THE COURT: Sustained.
Q. Did you ever discuss with Mr. Douglas who or — did you — well, let me go forward in time.
After you left Reading, did you ever have any conversations directly with Mr. Frankhouser ?
A. Yes.
Q. How often?
A. Well, I'd have to put this in two phases, if I may. Initially while I was still in Philadelphia, I saw Mr. Frankhouser perhaps once or twice? and on those occasions we exchanged, you know, "Hello. How are you?"
Subsequently when I joined the Security staff in 1981, from the period beginning in 1981 to my leaving the organization I saw Mr. Frankhouser scores of times. I'd have to say 40 times or so, I think. And since I left the organization I have been contacted by Mr. Frankhouser twice by telephone.
Q. All right.
A. So that's my association with Mr. Frankhouser .
Q. Do you know whether Mr. Frankhouser ever commenced working with the organization?
A. Yes.
Q. How do you know that?

A. Well, several ways, for several reasons. No. 1, the organization sent money on a weekly basis to Mr. Frankhouser as his retainer as a consultant.
Q. Wellr how do you know that that occurred?
A. Well, because, among other things, I did that. I was one of the persons who had the responsibility from time to time of getting the money from the finance office, going to the post office, buying a postal money order, putting it in the envelope and sending it to Roy Frankhouser .
Q. And do you know how long Mr. Frankhouser was on the payroll?
A. well, I don't know when it began. I certainly recall that by 1982 or so one of my duties was from time to time to send Mr. Frankhouser his check.
Q. And you say that's one of your duties. Who instructed you to do that?
A. Well, the instruction came from the Steering Committee, from Jeff, Michele, Bob Greenberg, Paul Goldstein, depending upon who was in — who was running the show on a given day.
Q. Do you recall how much money Mr. Frankhouser was paid on each of these payments that you made to him?
A. During the last period of time —
Q. Now, what period is "the last period of time"?
A. In 1984 — I say that because at a certain point he received a raise. I remember that before he got less money, and then in 1984 or thereabouts he began getting $500 weekly. I don't

remember what the previous amount of money was, but the final amount was $500.
Q. $500 —
A, The highest amount that I ever sent him on a weekly basis was $500.
Q. Do you remember sending him $500 on a weekly basis for a short period of time towards the end or for how long?
A. This was ongoing. I would have to say — and I'm not — I just don't remember when the $500 started, but I was sending him checks for at least a year and a half, two years.
Q. All right. And what form did those checks take that you sent him?
A. They were postal money orders.
Q. How would you arrange to get those postal money orders to send them to Mr. Frankhouser ?
A. Well, the procedure would be that I would be told or whoever was the Officer of the Day — I have mentioned that category before — would be told to go to the finance office, get the requisite amount of money, take the money to the post office, buy the postal money order and send it to Mr. Frankhouser .
Q. And what service did Mr. Frankhouser perform for this money?
A. His services were two-fold. First, he provided ongoing information to the organization concerning really all manner of subjects, strategic affairs, espionage activities, operations against the organization, which information he represented to

the organization as coining, you know, variously from his own investigations or from intelligence community sources who were using him as a conduit for information to the organization.
Q. You heard Mr. Frankhouser say that?
A. Yes.
Q. I —
A. Well, let me clarify. I heard the reports say — maybe I should let you ask the question here, but I heard the reports that came from Mr. Frankhouser which characterized the information as emanating from the intelligence community or specific intelligence agencies.
Q. And how often did you hear that type of report?
A. We got such reports almost daily.
Q. And did you ever observe Mr. Frankhouser face to face make such reports to members of the Security staff?
A. Most commonly not. I did observe, you know, from time to time a portion of such a discussion or something that would come up in other conversations. I usually wouldn't be the primary person to receive the reports. Maybe I'm making too fine a distinction.
The answer is yes, I heard portions of such reports, but he wouldn't come to me and tell me from top to finish his report for the day. He would go to someone else.
Q. Who did he go to, to give these reports?
A. He would go to a member of the Steering Committee. I have

named those persons. It would either be Paul Goldstein, Jeff or Michele Steinberg or Bob Greenberg. They would be the person who received the reports or would be in contact with Mr. Frankhouser on a daily basis.
Q. When Jeff Steinberg received a report from Mr. Frankhouser — well, did you observe him doing this personally face to face at any time?
A. Yes.
Q. Did you observe him doing this any other way?
A. Also by telephone.
Q. Did he do it more or less frequently by phone than in person?
A. More frequently by phone. Mr. Frankhouser 's base of operations was Reading. The national office where the member of the Security staff Steering Committee would be located would be in New York. So usually they talked by phone unless Mr. LaRouche were on tour somewhere, in which case very commonly Mr. Frankhouser would have as one of his assignments to come and participate in providing physical securely for Mr. LaRouche wherever he might be. And under those circumstances, obviously, the Security staff and Mr. Frankhouser would be in the same place and the information would be communicated, you know, directly.
Q. When you were Officer of the Day, what were your functions?
A. Well, the other functions included preparing a press

summary; you know, handling the logistical details such as, you know, getting money for any purpose, including this purpose that I mentioned, sending money to Mr. Frankhouser ; and also, answering the telephone, taking all incoming calls and channeling them to the person who was to receive them.
Q. Did you ever receive any incoming calls from Mr. Frankhouser ?
A. Yes.
Q. How frequently?
A. very frequently. Almost any time that I was Officer of the Day.
Q. When Mr. Frankhouser would call in, who would he ask for?
A. He would ask usually to speak to Mr. Green.
Q. Did you have a Mr. Green on your staff?
A. No one whose real name was Mr. Green, no.
Q. Did you ever hear anybody identify who Mr. Green was?
A. Oh, yes.
Q, Who?
A. He. Green was Jeffrey Steinberg.
Q. Did you ever have any discussion with Mr. Frankhouser as to why he was calling in and asking for Mr. Green rather than Mr. Steinberg?
A. Well, no. I didn't need to discuss the matter with Mr. Frankhouser . I knew what the reason was.
Q. All right. How many times do you recall Mr. Frankhouser
calling in and asking for Mr. Green?
A. This is one of those things that has to be in the order of a j
hundred times or more.
Q. And was there something that you did when you got a call
from somebody whose voice you recognized as Frankhouser asking
for Mr. Green?
A. Yes. Ke would also identify himself by a specific name so I
would also know who he was when he called in. What I would say
is — what any Officer of the Day would say is, "Mr. Green or
Dr. Green," sometimes we called him, "Dr. Green is not available j
at the moment. Is there a number where Dr. Green or Mr. Green
can contact Mr. Clay?" which was our name for Mr. Frankhouser in
this procedure. And then the number would be given. We would
write it down. We thanked the operator very much. We would go
to Jeffrey Steinberg or whoever the member of the Steering
Committee on duty was, give him the number and say, "Roy called.
He's at a phone booth. He wants a call back."
Q, And did you ever observe what Mr. Steinberg did after you
gave him this message?
A. Yes. He or —
Q. How many times did you observe?
A. Well, again, this is — this is something which took place
virtually on a daily basis. The procedure was always the same.
One or another member of the Steering Committee would pick up a
notebook, go out the door and proceed to call Mr. Frankhouser .
Q. Didn't you have phones in the office?
A. Well, yes, of course.
Q. Did you ever have any discussions with anybody as to why they went to a phone not in the office to call Mr. Frankhouser ?
A. Well, the reason was well known to all of us. We never needed to discuss it. It was assumed that because the organization was so tremendously important and because Mr. LaRouche was so tremendously important that all of our phones were tapped by hostile and sinister agencies; and therefore, to avoid the interception of our intelligence communications, we had to use clean phone lines. So the procedure was that he would call on a public telephone, leave the public telephone number with the Officer of the Day and the Security staff Steering Committee member would call him back, thus eliminating or minimizing the possibility for tapped telephone.
Q. Now, you mentioned that when Mr. Frankhouser would call, he would identify himself in a particular way.
A. That's right.
Q. How do you know that this person was Mr. Frankhouser if he didn't say, "I'm Mr. Frankhouser "?
A. Nell, we all knew that his code name was Mr. Clay. At some point, I don't really remember precisely when or by whom, I was told when I joined the Security staff, "Mr. Clay" means Roy Frankhouser . And then, of course, in my case since I had met

Mr. Frankhouser previously, I could recognize his voice most often.
Q. Did you ever refer to Mr. Frankhouser as "Mr. Frankhouser "?
A. Oh, never on a telephone and certainly never in a situation where he might be — there might be any monitoring of the conversation.
Q. Did you ever refer to Mr. Frankhouser at any time as anything other than "Clay"?
A, Well, there are various other names used for Mr. Frankhouser in the staff.
Q. What were those?
A. Well, Mr. Frankhouser and his then colleague, Mr. Lee Pick, were referred to as Frick and Frack.
Q. Which was which?
A. I — I never really made a particularly careful effort to determine which was which/ but I believe Mr. Frankhouser was Mr. Frack and Mr. Frick was Mr. Fick. That makes most sense to me. If somebody has another solution to offer/ I won't quarrel with them.
A. We refer to him as Roy. We refer to generically his communications as information from down the way. Sometimes we refer to his information as information from the cookie farm. I can't explain why. And other similar rubrics.
Q. All right. Did you ever have any discussions with anybody

about what was meant by "down the way"?
A. Yes.
Q. With whom?
A. With members of the Steering Committee and other members of the Security staff.
Q. Did you ever use the term "down the way"?
A. Certainly. Q, How often?
A. Well, I frequently wrote it in my notebook because we frequently got reports described as coming from down the way, and sometimes in describing these I would say, you know, here we have this report from down the way that says, you know, the ' Israeli government is trying to assassinate Lyn or whatever it might be. So I don't know how often I used it, but I used it on a regular basis.
Q. Did you use it to refer to a particular person giving you information?
A. Well, to be precise, it referred to information coining from a presumed source through a particular person.
Q. Who is the particular person that it came through?
A. The particular person was Roy Prankhauser.
Q. And who was the source that he was getting this information from?
A. The source was believed to be the intelligence community at large and the CIA in specific.

MR. WALKER: Objection, your Honor to the answer. "Believed to be" is a fairly vague —
THE COURT: I sustain the objection and strike that portion of the answer. You may inquire further. BY MR. MARKHAM:
Q. Who did you believe — you personally believe the source was from whom Mr. Frankhouser was getting this information?
A. Well, I didn't — personally, I was somewhat more skeptical than others. I didn't know for sure from whom it was coming. I believed it to be from the intelligence community, linked persons who were involved in — who were maybe among those persons who had been fired from the CIA during the Stansfield Turner purge of 1977 and thereafter. That's more or less who I believed it was; in other words, former CIA operatives and operatives from similar agencies who continued to have an interest in intelligence jockeying.
Q. Now —
THE COURT; Mr. Markham, we need to break soon. Is this an appropriate place?
THE COURT: All right. We'll take a 20-minute recess, members of the jury. You may go to the jury room.
(The jury left the courtroom at Ili20 a.m.)
THE COURT: We'll be in recess.
(Morning recess)

(Court reconvened at 11:44 a.m.) (SIDE BAR CONFERENCE....
MR. MARKHAM: I wish to clear this with your Honor before the jury comes in. It is my intention, unless directed otherwise, to elicit from this witness the stated belief as expressed to him by Steinberg, Goldstein and the others their belief as to Mr. Frankhouser 's sources of information. And I believe the testimony will be that they believed that his source was the intelligence community and the CI
THE COURT: In other words, this witness's answers as to what they stated to him to be their beliefs.
MR. MARKHAMj Their beliefs. 803(3)
THE COURT: All right. Do you have any objection to
MR. WALKER: I'm not sure I have an objection, but may
I look at 803(3), your Honor?
MR. WALKER: Well, your Honor, I'm not going to — there may be an objection — in fact, I think there is, but I'm not going to make it. I'm not going to.
THE COURT: All right. The jury may be brought in.
MR. WALKER: Your Honor, are we going until 1:00 or
1:15 today?
THE COURT: Well, Iil5 is what I had planned.
MR. WALKER: All right. I just wanted to know.

THE COURT: Actually/ I'm going to be 15 minutes late for a meeting in order to do that; so if you both wanted to quit at 1:00, I'd probably allow it today so I could make a meeting.
THE COURT: Would you rather stop at 1:00?
MR. MARKHAM: Done, your Honor. Yes, we would.
THE COURT: All right. We'll stop at 1:00 today.
(The jury returned to the courtroom at 11:47 a.m,)
THE COURT: You may proceed, Mr. Markham.
MR. MARKHAM: Thank you.
Q. Mr, Tate, you're still under oath.
A. Yes.
Q. You understand that?
A. I understand.
Q. Okay. Now, from the time you got on the Security staff in 1981 until you left in 1984, how frequently was it that Mr. Prankhauser would call in/ in the way you described before
the break?
MR. WALKER: If your Honor please, that's asked and
THE COURT: I believe that's so.
MR. MARKHAMJ All right
Q. Was there ever a time during this period that he did not

call in on a regular basis?
A. Well, there was no — since I was not always in the office and was not always the recipient of those calls/ I'd have to say that there was no gap of more than several days between my hearing about his reports so that —
Q. All right. Now, you were in the New York office headquarters for, I think you said, something like — how many days during 1984?
A. Well, however many days — I haven't counted. It must be 150 or something. Whatever days there are that I was not on security duty in Leesburg I was in the office in New York from January through August of 1984.
Q. Approximately how many days was that?
A. 150.
Q, And during those 150 days that you were in the Security office, how frequently were you the duty officer on the Security staff?
A. A good proportion of that time, maybe half of that time, 75 days.
Q. And of those 75 days, on how many of those days do you recall, approximately, getting a telephone call from Mr. Frankhouser ?
A. I'd say 50 or 60.
Q. 50 or 60 days out of 75?
A. Out of 75.

Q. And in addition to incoming calls — well, were all the incoming calls as you described before with the code words and the going to the telephone?
A. The only exception was the occasional circumstance when Jeff Steinberg or Paul Goldstein or another member of the Security staff Steering Committee didn't get back to Mr. Frankhouser in a timely fashion, and then there would be another more urgent call basically along the same lines —
Q. All right.
A. — in which maybe he would say something like, .I have been waiting out here for X minutes and it's raining" or whatever.
Q. Who would say that?
A. Mr. Frankhouser would motivate the need that he be called promptly.
Q. All right. And were there ever occasions when you observed anyone on the Security staff to place telephone calls to Mr. Frankhouser that were not in response to his incoming calls?
A. On one or two occasions — well, more than one or two. Maybe half a dozen occasions I would hear such phone calls, yes.
Q. And did you ever hear reports of information that Mr. Frankhouser had conveyed to the Security staff?
A. Yes.
Q. How frequently did you hear those reports?
A. Virtually every day.
Q. And who did you hear those reports from?

A. It would be whichever member of the Security staff had responsibility for — whichever member of the Steering Committee had responsibility for briefing the Security staff on that day. So that it would be usually Jeff Steinberg, Hichele Steinberg, Paul Goldstein or Robert Greenberg.
Q. All right. And what types of things would — well, describe some of the things that Jeff Steinberg reported to you that he had received from Mr. Frankhouser .
A. Well, he would say that — again, he would characterize Mr. Frankhouser by one or another of the names which I mentioned previously, so that he would say something like, "Roy tells us that down the way is afraid of terrorist attacks of the U.S. Army bases in the Middle East," something like that. Q, And again, how often do you recall Jeff Steinberg giving you reports relating to what Roy had told him?
A. Again, how often had I seen Jeff Steinberg — I'm sorry. Would you repeat the question?
Q. Yes. How often did this type of report occur?
A. On a daily basis.
Q. And how- about with Michele Steinberg relating to you what Mr. Frankhouser said?
A. Well, again, it would be one of those persons, one of those four persons on the Steering Committee who would invariably be the bearer of these tidings, this report from Mr. Frankhouser . Host commonly it would be Jeff Steinberg, but also it might be

Robert Greenberg or Michele Steinberg or Paul Goldstein who would have taken the report and would relay it to the Security staff.
Q. And when was this that these reports from Mr. Frankhouser were relayed to the staff by Jeff, Paul and Michele and Robert?
A. Usually in whatever meeting of the Security staff took place after that report. In other words, if the call came in, in the morning and we had an afternoon meeting, we would hear about it in the afternoon meeting. If it didn't come in until the evening, we would hear about it at the end-of-the-day meeting or at the first meeting next morning. So we were told within hours usually of receipt of the report.
Q. Did you ever have any discussions with Jeffrey Steinberg in which he expressed his belief as to the truth of the reports he was receiving from Mr. Frankhouser ?
A. Yes.
Q. How frequently did you have discussions with Mr. Steinberg in which he expressed his belief?
A. Well, there would be some degree of evaluation accompanying the report that we received, so that there would be some attempt made to sort out what was more and less reliable in the report. So I guess the best answer to that is that on almost every occasion there were some opinions expressed as to the reliability and importance and completeness of the report received from Mr. Frankhouser .

Q. Did you ever have such discussions with Michele Steinberg?
A. Yes.
Q. With Robert Greenberg?
A. Yes.
Q. With Paul Goldstein?
A, Yes. And again, chiefly under those circumstances. The report would be read. There would be some discussion of its significance and implications. And there would be some evaluation as to its, you know, factual content, truth and completeness.
Q. Did you ever have any discussions with Jeffrey Steinberg about his, Mr. Steinberg's, belief as to where Mr. Frankhouser was getting the information that he was reporting?
A. Yes.
Q. How often did you discuss with Mr. Steinberg his belief as to where Mr. Frankhouser was getting his information?
A. Only once or twice. I think in the nature of his belief it was only necessary to communicate that idea once or twice.
Q. Well, what did he communicate to you?
A. He believed that this information came from the Central Intelligence Agency.
Q. "He" meaning who?
A, Mr. Steinberg believed that the information he was receiving from Mr. Frankhouser had its origin in the Central Intelligence Agency.

Q, And did he express that to you on more than one occasion?
A. Well, as I say, he mentioned this expressly only once or twice. It was in — the Security staff regarded this as a deep dark secret and, therefore, it was not something which was to be bandied about. But the issue of the origin of these reports repeatedly came up as they were given.
In other words, as I mentioned before, Mr. Frankhauaer sometimes reported on what he described as his own investigations. He would go to a meeting, make a phone call or do one of those kind of things, and he would pass on the information to the organization. But he also would — or at least it was communicated to me through these reports that he would characterize certain bodies of information as coming from variously Mr. Ed, down the way or the cookie farm.
Q. All right.
A. That is —- all right.
Q. Let me get all three of those. Mr. Ed?
A. Mr. Ed.
Q. Down the way?
A. Down the way.
Q. And the cookie farm?
A. The cookie farm.
Q. Now, any other labels?
A. Those are the ones that come to mind at the moment.
Q, Did you ever have any discussion with —

A. Excuse me. Sometimes Mr. Steinberg and Mr. Goldstein in particular would characterize reports as coming from the agency, meaning the Central Intelligence Agency.
Q. Now/ did anybody ever express a belief to you as to who Mr. Ed was?
A. Yes.
Q. Who?
A. Pardon me. Expressed the belief, or who he was?
Q. I'm sorry. Who expressed that belief to you?
A. Well/ on one particular occasion Nancy Spannaus expressed a belief as to who Mr. Ed was.
Q. Who is Nancy Spannaus?
A. Nancy Spannaus is a member of the National Executive Committee of the Labor Committees and she is the director of its publications. She is sort of the chief editor of all of its various publications that I have named, and she is one of Mr. Larouche's most trusted advisers.
Q. Did she ever express — well, who did she believe Mr. Ed was — let me rephrase that the right way.
Did she ever tell you who she believed Mr. Ed was?
A. Yes.
Q. Who did she say to you that she believed Mr. Ed was?
A. She said — and just to clarify, because the question asks about belief. She said that it was not her opinion but that it was a fact that Mr. Ed was Ed Knocke.

Q. Did she say this to you in anyone else's presence?
A. Yes.
Q, Whose?
A. Well, it was a meeting of the editorial staff of the -organization. I don't remember who else was there at the time. This was not a Security staff meeting. It was a more general organizational meeting. And the decision had been made for whatever reason to bring the membership, you know, a little further on this deep dark secret by revealing at least to some persons who Mr. Ed was supposed to be.
Mr. Ed, I don't — just for people's information if they don't know, Ed Knocke is the former deputy director of the CIA for — I believe for Plans, and I believe he was one of those persons who left the agency following the Stansfieid Turner cleanup or whatever — whatever it was in 1977.
Q. Did you ever hear Jeffrey Steinberg refer to Mr. Frankhouser 's source as Mr. Ed?
A. Yes.
Q. How about Michele Steinberg?
A. Yes.
Q. How about Robert Greenberg?
A. Yes.
Q. Paul Goldstein?
A. Yes.
Q. Now, did you have a belief as to who Mr. Ed was?

A. Well, I was not certain about this identification and I discovered at a later point through overhearing conversation between Mr. Steinberg and Mr. Greenberg that they weren't too sure, either. And at that point I realized that nobody knew and this was a figment of somebody's imagination. I have had various beliefs as to who it might be or whether it's a particular individual or an entity or collection of people. I could summarise those, if you want. I did not necessarily believe even when I was a member of the Security staff that because Jeff Steinberg believed something that this was a good reason for me to believe it.
Q. All right. Well, did there ever come a time when Mr. Steinberg expressed a belief to you that Mr. Frankhouser had no source from the intelligence community?
A. Oh, absolutely no. I mean, no, of course not. He was the, you know, principal doorway until sometime in late 1983 through which the organization believed it was receiving, you know, crucially important intelligence communications from U.S. intelligence agencies and most especially from the Central Intelligence Agency.
Q. Who was this doorway?
A. This doorway was Mr. Frankhouser . He was the source for this information.
Q, And did anything happen to that belief as it was expressed to you in 1984 while you were in the organization?

A, When you say happen to the belief, I'm sorry, I —
Q. Yes. Did anybody ever express a contrary view in 1984?
A. About Mr. Frankhouser .s role as providing information from the CIA?
Q. Yes.
A. Oh, no. No one ever expressed any contrary belief, no.
Q. So as of the time you left the organization, August whenever it was, 1984, what was the most recent view expressed to you by Jeff Steinberg about where Mr. Frankhouser was getting this information?
A. Oh, well, as of that time Mr. Steinberg continued to express his belief that Mr. Frankhouser was giving information and even directives to the organization from the CIA and also taking some of the organization's, you know, intelligence information and feeding it back.
Q. And what was the most recent expression of belief of Michele Steinberg before you left — as of the time you left the organization?
A. Well, it would be the same.
Q. How about Paul Goldstein?
A. Again, the same.
Q. How about Robert Greenberg?
A. Again, Robert Greenberg believed Mr. Frankhouser to have this function.
Q. Now, what was the most frequent occurrence when — well,

strike that.
Who was it that the notebooks were used to brief most frequently?
A. Mr. LaRouche, Lyndon LaRouche.
Q. And how frequently during the day would Jeff Steinberg on average use his notebooks to brief Mr. LaRouche?
A. Daily. Let me — actually, let me, if I may, withdraw that
I would say that they were probably used about equally to brief other members of the staff and Mr. LaRouche. It's a very close one-to-one correspondence, but probably most by slight plurality Mr. LaRouche.
0. well, in terms of the one individual person that the notebooks were used to brief more frequently than others, was there an individual person?
A. Yes.
Q. Who was that?
A. That person was Lyndon LaRouche.
Q. And when they weren't using the notebooks to brief Lyndon LaRouche, who were they using the notebooks to brief?
A. Well, most commonly the Security staff as a whole or the members of the Security staff, occasionally a member of the National Executive Committee.
Q. You said before you looked inside the notebooks of Mr, Steinberg.
A. Yes, that's right.'

Q. And Michele Steinberg?
A. That's right.
Q. Paul Goldstein?
A. Well, less often but, yes, I saw that he was taking notes.
Q. Robert Greenberg?
A. And Robert Greenberg, yes.
Q. And let's switch — well, do you know a man by the name of Mr. Ed Spannaus?
A. Yes, I do.
Q. Was he ever a Labor Committee member?
A. Yes, he was.
Q. And what was his function?
A. Well, he has had many functions during his experience in the Labor Committee. I think at the time — if you're asking about the time that I left the organization, he was a member of the National Executive Committee and he had various responsibilities for coordinating the move to Leesburg, Virginia, and he was responsible for the organization of his legal staff. And that basically, I think, characterizes his various responsibility at the time that I left.
Q. All right. And did you ever observe Mr. Spannaus to use notebooks?
A. Yes.
Q. And how often did you observe him to do this?
A. Well, I didn't observe Ed Spannaus as often as other

persons. I was — after all, I was on the Security staff and worked with people on the Security staff on a daily basis. I worked with Ed Spannaus much less frequently. But there again, for the most part when he was receiving information of any substance, he would write it down in a notebook in my presence.
Q. All right. Now, you saw him more or less than you saw the people on the Security staff?
A. Considerably less.
0. All right. On the times that you did see him, did he have a notebook with him on more or less occasions?
A. More often than not.
Q. How many times was it that — well, how frequently was it when you saw him receiving a briefing from anybody that he was writing in his notebook?
A. Hard to say. My recollection is that he was — he was less I guess I can now use the word punctilious about notebook entries than other — than the people on the Security staff, but I'd say half to three-quarters of the time he would make a note of his conversations in my presence. He also had his notebook at hand and made entries in it and, I suspect, somewhat more carefully when he was at meetings of the National Executive Committee. And I did indeed observe him doing that —
Q. All right.
A. — on some occasions.
Q. Did you ever see Mr. Spannaus in conversation with

Mr. LaRouche?
A. Yes.
Q. Did you ever see Mr. Spannaus in conversation with Mr. LaRouche when Mr. Spannaus was giving Mr. LaRouche a briefing?
A. Yes.
Q. On those occasions did you ever observe him to use a notebook?
A. Yes.
Q. How frequently on those occasions?
A. Cn some of the occasions he used his notebook as his source/ you know — however, I think he was a bit more likely to — I don't want to characterize it as likely. I think he followed his notebook — my physical evidence is, of course, he wasn't looking at it as closely as, let's say, members of the Security staff when they were briefing LaRouche because they tended to read it more or less or summarize more or less directly what was in the notebooks. Spannaus was not describing intelligence, world events or those kind of things so much. He was describing and discussing ongoing security, legal and organizational questions, so that it was less an issue of communicating facts. So that there was less of a need for a, you know, memoir to, you know, bone up on those facts. However, he did have the notebook. He referred to the notebook in the course of these briefings. And when he was told to do something most

importantly he wrote it down in his notebook. Q. Was it his regular practice at or near the time he got instructions from Mr. LaRouche to write those instructions down?
A. Well, I don't know what instructions may have flown from Mr. LaRouche directly to him on that question. I do know that all —
Q. I'm not asking that question.
A. Okay. I'm sorry.
Q. I'm not asking if you ever heard Mr. LaRouche instruct him about writing.
A. Okay. I'ra sorry.
Q. Did you ever hear Mr. LaRouche give Mr. Spannaus instructions on any subject?
A. Yes.
Q. How frequently did you hear Mr. LaRouche give Mr. Spannaus instructions on any subject?
A. Three or four times.
Q. All right. Did you ever observe an occasion on which Mr. LaRouche gave Mr. Spannaus instructions that Mr. Spannaus did not write those down?
A. I did observe occasions when he didn't write them down, yes. I also observed occasions when he did.
Q. All right. And how many times did you see him write down instructions from Mr. LaRouche?
A. I recall — well, I'm speaking now of three or four

occasions. I recall one clearly comes to mind when he was writing, and another clearly comes to mind when he was so aghast I don!t think he would have been able to write anything. And there are two others which I don't know.
Q, When was the one when — what was the one where you were so aghast —
A. That he was so aghast.
Q. — when he was so aghast that he couldn't write it down?
A. It was when Mr. LaRouche informed him that if the PEG investigation of Deborah Freeman began to pose serious consequences to the organization, she would be cut loose. And Ed was very surprised to hear that, and so was I. I think I was less surprised than Eld was.
Q. What did Mr. Spannaus say on that occasion?
A. He said, "We can't do that to Debby."
Q. And what did Mr. LaRouche respond?
A. He said, "I didn't order this. If Debby Freeman did anything wrong, it didn't come from me.11
MR, WALKER: Excuse me, your Honor. It wasn't clear about who said if it —
THE COURT: The answer may be read back if you wish it.
MR. WALKER: Maybe it could be clarified by Mr. Markham's question.
Q. Who were you just quoting?

A. All right —
Q. Why don't you just tell — if you could, describe the event.
A. All right. I'll describe that once again. This was in response to the question about when he was so aghast that he didn't write anything down or at least he didn't write anything down during the period of time in which I was in the room. Let me be more precise.
He was describing a situation in Baltimore, Maryland in which an investigation was underway of a woman named Deborah Freeman, who was a National Committee member of this organization. The FEC investigation I think alleged or revealed, I'm not sure if it's the correct word, possible — I'm being vague because I don't know the real legal standing of this case — possible wrongdoing on the part of Mrs. Freeman in the context of political campaign involving the Federal Elections Commission. And this was a discussion between Mr. Spannaus and Mr. LaRouche concerning what was to be done in this case.
Mr. LaRouche's response to Mr. Spannaus' summary of the situation was that if Debby Freeman had been found to have done anything wrong, she would be cut loose. Ed Spannaus was aghast, clearly, to hear this. He said, "We can't do this to Debby. B
And LaRouche's response was, "If she did anything wrong, it didn't come from me. I didn't authorize it."
Q. Did Mr. Spannaus have any further response?
A. Mot for several seconds.

Q. Well, but what did he say?
A. I don't know. I — he had nothing to say for himself for several seconds. He was — he looked to be at a loss. He didn't know how to respond. And I finished my business in the! immediate vicinity during this interchange and I left the room.
Q. All right. Now, going back to the other expressions or the other stated beliefs or references to where Mr, Frankhouser !s information came from. You discussed Mr. Ed, correct?
A. Hra-hm.
Q. You also said that people expressed the belief or the Security staff expressed the belief that it came from down the way, the cookie farm and the agency, correct?
A. That's correct.
Q. Now, did anybody ever express a belief to you as to what "down the way" was?
A. Yes.
MR. WALKER: Objection. Asked and answered, your
THE COURT: I think that's been answered.
MR. MARKHAM: Your Honor, I — well, if I may, I believe he answered who Mr. Ed — they believed Mr. Ed was.
THE COURT: No. Quite a bit earlier in the testimony.
MR. MARKHAM: Oh. All right. Then I'll go on to the next one, see if that's been asked and answered.

Q. Did anybody ever express a belief to you as to what the cookie farm was?
A. Yes.
Q. Who?
A. Oh, the cookie farm was —
Q. No. Who?
A. Oh. Who?
Q. Who expressed the belief?
A. You know, everyone on the Security staff expressed this belief at one time or another. The members of the Steering Committee were the first to use this expression and to explain its general significance and their — well, their explanation I'm not going to —
Q. Did Jeff Steinberg ever tell you what he believed the cookie farm was?
A. He used the expression very frequently that there was no doubt from the context in which he used it in anybody's mind what he meant.
Q. What did he mean?
A. He meant the Central Intelligence Agency.
Q. Did anybody ever express to you a belief — well, how about Paul Goldstein, Michele Steinberg and Robert Greenberg expressing a belief as to what the cookie farm was?
A. All three of those persons used that expression in a context which could only mean and did very expressly mean that they were

talking about the CI
Q. And again, these were times where they were expressing their
belief as to where Mr. Frankhouser was getting his information?
A. That's correct.
Q. And how about the agency?
A. The agency was a word used more gingerly because it is more
immediately associated — more immediately possible to associate
the word — the agency with the Central Intelligence Agency.
But that word was also used very often, and it clearly meant the
agency, the Central Intelligence Agency.
Q. Did you use that word less frequently than the other words?
Did you personally use it less frequently?
A. Yes.
Q. What was your reason for using "the agency" less frequently
than "cookie farm" or "down the way" or "Mr. Ed"?
A. I personally doubted very much that this had anything to do
with the Central Intelligence Agency per se, but I wasn't
Q. Did you ever express your belief to Jeff Steinberg that you
had these doubts?
A. NO.
Q. Did you ever express this belief to Paul Goldstein that you
had these doubts?
A. Oh, no.
Q. Why "no" to Jeff Steinberg, noh, no" to Paul Goldstein?

A Well, one just simply does not express doubt to these people. They don't understand doubt. It's not a category that exists for them. They simply believe whatever they're told by their authorities. So you just don't — unless you want to get in a lot of trouble, you don't say "I don't believe that" in that organisation to those people.
Q. Now, did you ever hear Lyndon LaRouche express a belief as to the sources of information being conveyed by Nr. Frankhouser ?
A Yes.
Q. How frequently did you hear that belief expressed by Mr. LaRouche?
A, Perhaps half a dozen tiroes in casual conversation and once very directly in the context of a discussion — perhaps not during a discussion with but in the context of a discussion with Mr. Frankhouser .
Q. And can you tell us when the first such time that you remember Mr. LaRouche expressing such a belief, when that conversation took place?
A I don't remember the first.
Q. When is the first one that you remember?
A Well, the one that I remember most clearly is probably actually the last one. I don't mean to be coy. It's just that Mr. LaRouche often alluded to his belief that he was communicating through Mr. Frankhouser with the intelligence community and, specifically, with the CIA and to Mr. Ed. Maybe

the most concrete early recollection that I have of his —
Q. Now, "his," who?
A I'm sorry.
— Mr. Larouche's acting on the basis of this belief was that he received from me one morning a transmission to Wiesbaden, West Germany characterized as an E to L memo. These raeiuos — E to L means — again, I apologize for the alphabet soup. "E to L" means Mr. Ed to Lyndon LaRouche. And this memo purportedly came from Mr. Ed to Mr. LaRouche, and it posed a series of questions and some information and so forth and so on.
Q. Did anybody ever express the belief as to who had given this memo from E to L?
A Well, E to L memos were known to come from Mr. Frankhouser . I don't think anybody specifically told me that this particular memo came from Mr. Frankhouser , but that's where E to L memos came from. It's like where reports of what down the way said came from- That was the generic name for communications from Frankhouser going back to this particular source.
Q. All right. Now, did you ever overhear any discussion where Mr. LaRouche expressed a belief as to what Mr. Frankhouser 's source was?
A Yes. In the context of the last conversation of which I am personally aware between Mr. Frankhouser and Mr. LaRouche, Mr. LaRouche expressed fervently his belief that Mr. Frankhouser had not done enough to get the agency to pressure the White

House to provide him with Secret Service protection for the 1984 presidential electionr and he expressed his misgivings about the situation in the strongest possible language to Mr. Frankhouser on the phone in my presence and in/ you know, a half hour to an hour fulmination on the subject after his conversation with Mr. Frankhouser .
Q. And during that fulmination — by "fulmination," what do you mean?
A Well, he used, you know — Mr. LaRouche's vocabulary is rich in epithets and words connoting various acts of violence. He basically said that — I don't know. He — he said that if — 1.11 say expressly what he said to Mr, Frankhouser on the phone. He said if Mr. Frankhouser didn't kill two FBI agents, he was a sodomist.
And Mr. Frankhouser quickly said, "You must mean that as some kind of a joke, don't you? Remember this is a tapped telephone line."
And Mr. LaRouche said, "I don't mean any jokes, Frankhouser . You're.,." this, that and the other thing. And he started raving and ranting about the need to obtain Secret Service protection and how Mr. Frankhouser had not used his contacts with sufficient verve to secure the Secret Service protection.
Q. Were you listening in on both ends of the conversation?
A It was on the speakerphone.

Q. And you recognized the voice of Mr. Frankhouser ?
A Yes.
Q. Okay. Apart from this one occasion, did you ever hear Mr. LaRouche express hie belief that Mr. Frankhouser had sources at the CIA or at any other intelligence agency?
A Well, again in the same way he commonly used the expressions the cookie farm/ the farm, down the way. And early onr as 1 indicated, he received memos from E to L and gave back to me among other people memos from L to E for transmission to New York to be given to Mr. Frankhouser to go to Mr. Ed, So, you know, yes, he did.
Q. Now—
MR. MARKHAH: May I approach the witness, your Honor?
THE COURT: You may.
(Defense counsel examining item)
MR. MARKHAM: In speaking to counsel, your Honor, I'm going to have him look at some notebooks. I will not be offering these into evidence at this time.
Q. Showing you what is narked as Government's Exhibit 58 for identification/ I put this book in front of you and ask you if you have ever seen books like Government's 58 for identification before.
A Yes.

Q. How frequently have you seen books like Government's 58?
A Well, I saw such books virtually every day that I was in the national office in the Security office.
Q. Where specifically did you see that — well, how many such books did you see in that particular form with that type of hard cover?
A. About 20.
Q. All right. And 20 times or 20 books?
A No, 20 — I'm sorry, 20 books.
Q. All right. And whose were they?
A They were Jeffrey Steinberg's.
Q. And is it correct that those were the books that Mr. Steinberg used to take his briefings in?
A Yes.
Q. is it correct that it was part of his regular practice to obtain briefings from Mr. Frankhouser ?
A Yes.
Q. Is it correct that it was part —
MR. WALKER: If your Honor please, I guess I think I'm going to have to object to this.
THE COURT: To the leading form of the question?
MR. WALKER: Yes, your Honor.
MR. MARKHAM: They're foundational.
THE COURT: I sustain the objection to the leading form of the question.

4-103 MR. MARKHAH: Your Honor — well, all right.
Q. Would you describe the frequency with which Jeffrey
Steinberg would write into those books when he was taking a
briefing from Mr. Frankhouser ?
A Well, he was continually making entries in these books at
any time he was talking to Mr. Frankhouser or other sources or
consultants or for the most part when making undercover phone
calls, he would make an entry in this book.
Q. Specifically directing your attention to his conversations
with Mr. Frankhouser , how frequently was it when he was
receiving a briefing from Mr. Frankhouser did he write in the
A He would always write in the notebook when he was taking a
briefing from Mr. Frankhouser .
Q. when would he write in the notebook in relation to when he
got the briefing?
A Usually at the same time.
Q. And when it was not usual, how long after the event of the
briefing was it that he wrote it down?
A Well, I really don't know of any other — any occasions
concretely when he did not take down such a briefing
immediately, so I can't answer.
MR. MARKHAM: Excuse me one second, your Honor. (Pause)

Q, Could your please, open Government's Exhibit 58.
Without specifying any of the content, do you recognize the handwriting?
A Yes.
Q. How many times before have you seen the handwriting which is in Government's 58?
A Well, very hard to say. I would have to say that I've seen it scores of times casually. That is/ while sitting in a meeting when we were all making entries in notebooks, I could see Mr. Steinberg's handwriting. I also saw it a number of more specific occasions when I had to write an article or a press release on the basis of entries in the notebook and. Also/ of course, on other occasions I saw Mr. Steinberg's handwriting in the form of notes, other things that I might be handed. So I have to say a total perhaps 20 times or more.
Q. All right. And do you recognize that handwriting in there as belonging to one particular person?
A Yes.
Q. Who?
A This is Mr. Steinberg's handwriting.
Q. And what's the number of that exhibit again, for the record? Would you, please, read it into the record?
A This is — do I call it Government Exhibit 58? It's Ho. 58.
Q. Sounds good.
A Okay.

Q. I just wanted that for the record.
MR. MARKHAM: May I approach the witness again, your
THE COURT: You may.
Q. Putting in front of you now eight separate notebooks which
are, for identification again — ^
A Hm-hm.
Q. — Government's 42, 43, 44, 45, 46, 47, 48 and 49.
A Mm-hm.
Q. Have you ever seen notebooks like those before?
A Yes.
Q. would you compare them for the record, just for the record,
with the notebook that you have identified as being in the
handwriting of Mr. Steinberg?
A Well, that's a — they have different kinds of binding.
That's a ledger book with — I'm not sure of the exact printing
term. It’s something like a perfect binding. You know, it's
bound like a leather-bound book. These are all spiral-bound
notebooks. That, of course, is much larger. These are — are
Q. Can I ask you to look inside each of these notebooks and
answer yes or no whether you recognize the handwriting of the
A Yes.
Q. You just looked in one, well, just take the one. Take the

4-106 exhibits. Do them one at a time, if you would.
What's the number that you have in front of you?
A 42.
Q. Have you looked inside Notebook 42?
A, Yes.
Q. Do you recognize the handwriting?
A Yes.
Q. How many times have you seen that handwriting before today?
A Uhm —
Q. Not that notebook but how many times have you seen the
handwriting of the type which is in that notebook?
A Right. I'd say a dozen times or so.
Q, All right. And where did you see that handwriting?
A Well, in various formats, either in — you know, again,
casually sitting around in the Security office in a circle
making entries in the notebooks, overseeing, you know, the
notebook — looking — overseeing the notebook, seeing the
handwriting, seeing short notes written, seeing lists of things
to do written, those kinds of — in one case being given a
little letter, rather unattractive little letter. Under these
circumstances I've seen this handwriting at least a dozen times
Q. Whose handwriting is in that notebook?
A This is Michele Steinberg's handwriting.
Q. Can you take a look at the next notebook. What's the
number, for the record?

A 43.
Q. Do you recognize the handwriting in that notebook?
(Witness examining item)
A I believe it's Michele Steinberg's, but it's not always as neat. But I believe it's Michele's.
Q. All right. Can you take a look at the next notebook/ please. What number is it?
A I'm sorry. The next notebook?
Q. Yes.
A No. 44.
Q. Would you open that and look at the handwriting.
Do you recognize that handwriting?
A Yes. This is Michele's handwriting.
Q. Okay. Could you take a look at the next notebook, please.
What's the number?
A 45.
Q, Do you recognize the handwriting in that notebook?
A Yes. This is Michele's handwriting.
Q. Can you take a look in notebook marked Government's 46.
A 46 is the next item. Well, there seems to be another hand
on the first page, but the — yes, the subsequent pages are
Michele Steinberg's handwriting.
Q. All right. Now, before you turn that over, could you
identify the page number in Government's 46 for identification
which you believe to contain handwriting which is not Michele

A Well, I didn't -- I can't really say that it's not Michele Steinberg's handwriting. On page 1 there is a scrawl. It's not identifiable to me as her handwriting.
Q, And apart from that one scrawl on that one page, page lr does the notebook appear to contain her handwriting?
A The pages that I looked at are her handwriting as best I remember it.
Q. And could you take a look at Government's Exhibit 47? Do you know whose handwriting is in there?
A Yes. This is Michele Steinberg's handwriting.
Q. Could you take a look at Government's Exhibit 48?
A Again, this is Michele Steinberg's.
Q. And last. Government's Exhibit 49.
A It's Michele Steinberg's handwriting. There are a couple entries that are a little sloppy and I can't quite identify them, but the bulk of the text that I see on these first few pages is Michele Steinberg's handwriting.
Q. Approximately how often did you observe Hichele Steinberg receiving a briefing from Mr. Frankhouser ?
A Well, hard to say. She was one of the four persons, as I indicated, to receive such briefings. She did so less often than Jeff Steinberg. I'd have to — to the best of ray recollection, I'd say about once a week it would fall to her to receive the briefing.

Q. On the occasions when you observed Michcle Steinberg receiving a briefing from Mr. Frankhouser / how often v/as it —
MR. WALKER: If your Honor please, the question is somewhat vague in the sense of observing. Does that mean she saw Mr. Frankhouser giving information to Michele Steinberg or heard something over the telephone? I just —
THE COURT: Are you talking about the last question or the current question?
MR. WALKER: I think probably the matter came up in the last question, but I think the current question is the same, if I heard it properly.
THE COURT: Well, all right.
MR. MARKHAM: I'll start over.
MR. WALKER: Maybe clarify — the word "observe" is a
little —
THE COURT: All right.
Q. Did you ever observe Michele Steinberg receiving a briefing from Mr. Frankhouser ?
(The witness gave no response.)
Q. By phone or otherwise.
MR. WALKER: That's my problem, your Honor.
THE COURT: Well, all right. You may answer the question.
A Weil, I'm not certain that I saw her receiving such a

4-110 briefing.
Q. You mean — what do you mean, you're not certain?
A Well, I mean to say that — I mean, she would report that she had spoken to Mr. Frankhouser and he had said such-and-such. But I can't recall a specific occasion when I know for a fact that when I was looking in that room, it was where they were working, she was on the phone and it was Mr. Frankhouser at the other end. I can make, you know — in the way that I can say that I know that this is the case in one or two of the others.
Q. When you did observe Michele Steinberg on the phone receiving briefings, how frequently did that occur, regardless of whether it was Mr. Frankhouser at the other end or not?
A Well, she would receive briefings of one sort or another on a daily basis.
Q. When you observed her on the phone receiving these briefings, regardless of who they were from, what did you observe her doing while she was receiving the briefings?
A She was writing in her notebook.
Q. How frequently was it when she was receiving these briefings from whomever was it that she was writing in her notebooks about the briefings?
A Well, clearly she was writing — well, I suppose it's possible in some cases that she was writing about something entirely different. However, in the case of these particular consultations with intelligence sources/ she would have a phone

conversation, make the entry in a notebook and then brief the staff on the substance of the conversation and, therefore, you know she was writing about the conversations she was having.
Q. When you observed Michele Steinberg to be receiving a briefing by telephone, what was she doing while she was receiving the briefing?
A She was writing down — she was writing in a notebook.
Q, And when she was receiving a briefing, was she writing in a notebook right then and there or did she do it later?
A She did it as the conversation was proceeding right then and there.
MR. MARKHAM: May I approach the witness?
THE COURT: You may.
Q. Let me put in front of you Exhibits — let me get them in the right order — 50, 51, 52 and 53. Just for the record, would you describe what I have put in front of you.
A These are spiral-bound notebooks nine and a half by six inches. They are similar in general form to the notebooks which Michele Steinberg wrote in as I just said.
Q. Besides Michele Steinberg, did anybody else on the Security staff use notebooks like the ones you have in front of you on the Security staff?
A Yes.
Q. Who?
A Well, I can't say that I have a distinct recollection of who

used notebooks of a distinctive kind aside from Jeff Steinberg. I think there was a little more hit or miss what kind of notebook people had. I remember that Robert Greenberg had in his desk in the New York City national office a store of notebooks very much like this in general shape or let's say that I remember that they were spiral bound. I remember they were this size and that they were spiral bound, but I don't remember if they were this thickness or this many pages, et cetera.
Q. All right. How, how many times have you seen Robert Greenberg .s handwriting?
A I would guess about, you know, 20 times the way I have — and I'd have to say with respect to that, that sometimes it was in the form of looking directly at his notebook entries to get information. At other times it was, you know, in the casual manner I described, sitting next to him in a briefing and seeing his handwriting. Sometimes he would give people such as myself lists of names of people to call or lists of things to do or whatever. So I'd say I saw his handwriting about 20 times.
Q. All right. Now, can I ask you to identify the first of the notebooks that's in front of you by number.
A This is No. 50.
Q. And can you open, please, Government's 50 for identification and look at the handwriting inside.
A This is —
Q. Do you recognize it?

A Yes. This is Robert Greenberg's.
Q. And can I ask you to look at the next one.
A It's the same handwriting. It's Robert Greenberg's
MR. MARKHAM: I'm sorry. Excuse me. I was —
(Government counsel conferring)
Q. Could you identify the number, please?
A This is No. 51.
Q. Okay. And can I ask you to open No. 51 and tell me whether you recognize the handwriting.
A Excuse me. 51 is the one I was just speaking about. I'll just confirm that.
Yes, this is No. 51, and this is Robert Greenberg's handwriting.
Q. No, 52. I'll catch up with you. I'm sorry. Can you look at 52.
A Okay. Yes, this is also Bob Greenberg's handwriting.
Q. All right. How about 53?
A. All right. Same handwriting. This is Robert Greenberg's handwriting,
Q, Now, how often did you observe Robert Greenberg accepting briefings from sources?
A Bob Greenberg was a member of the Security staff Steering Committee, talked to sources on a daily basis and was briefed by them on a daily basis. So I observed him doing so any time I

was in the office with him.
Q. And when he was receiving briefings from sources, what did you observe him to be doing?
A He wrote down the briefings in his notebook.
Q. Okay. When did he do that in relation to the conversation that —
A Well, the conversation was ongoing.
MR. MARKHAM: May I approach the witness, your Honor?
THE COURT: You may.
Q. I'm now going to give you Government's Exhibits for identification 54, 55, 56 and 57 and ask you if you can take a look at each one of those, starting with 54, and look inside and just answer yes or no whether or not you can identify the handwriting.
A This looks to me like Ed Spannaus1 handwriting.
Q. How often before today have you seen Ed Spannaus1 handwriting?
A Not as often as the others. Three to half a dozen times, usually during a period when I was working with Ed Spannaus and the legal staff. On the basis of that I'd have to say that this is his handwriting.
Q. Are you more or less certain about this than about the others?
A Less certain about it. I have to be. I just did not see it as often. Less certain about this than those.

Q. And take a look ,at the next notebook and tell me whose handwriting you believe it is and how certain.
A It's the same handwriting as this previous book, and I believe this is Ed Spannaus' handwriting.
Q. Could you do the next one by number — well, could you do that one by number?
A This one was No. 55. The next is No. 56 which I am now looking at. And again, same handwriting. This is, to the best of my recollection, Ed Spannaus1 handwriting.
The next is No. 57, and it's Ed Spannaus1 handwriting.
Q. All right. But once again, you're not as certain about that as you were about the others?
A Speaking only to handwriting, I'd have to say not certain.
Q. All right. Mow, let me — I have one more. Let me show you what's marked as Government's Exhibit 59, which is another document. Do you recognize that handwriting?
A Well, again, speaking as to handwriting, I have to say no.
Q. All right.
A I mean, I could make an awful good guess, but as to handwriting, I don't —
Q. All right.
A I can't say.
Q. Understand, I don't want you to guess,
A I know. I just — no, I can't say on the basis of handwriting per se that I know who this is.

Q. Can you tell us the number of that document whose handwriting you cannot identify by handwriting?
A No. 59.
Q, All right. While you were working on the Security staff was there anybody who used notebooks of the type which is in front of you?
A Yes.
MR. WALKER: Excuse me, your Honor. Meaning pads of
MR. MARKHAM: I was going to get to that.
MR. WALKER: Oh. It's not — I don't believe it's a
THE COURT: All right. I sustain the objection to the form of the question for lack of specificity.
Q. Would you describe the type of document which is in front of you?
A It's a yellow legal pad.
Q. All right.
(Off the record)
Q. Was there anybody on the Security staff that used yellow legal pads like the kind you have in front of you?
A Yes.
Q. Was there one or more than one?
A More than one person used such pads.

Q. Who used such pads such as the one you have in front of you?
A Well/ there are several persons who used such pads. Paul Goldstein was one such person. Scott Thompson used such pads. I used such pads. Other members of the Security staff now and again if they didn't have their notebook or whatever would use such pads.
Q. Okay.
A I don't say that those are the only three, but it's those three plus others used such pads now and again.
Q. Now, you mentioned earlier this morning/ Mr. Tate, that one of the functions of the Security staff was being Lyn's eyes and ears, correct?
A That's correct.
Q. And basically you described how that was accomplished, correct?
A Yes.
Q. And you also indicated that the Security staff had as its function internal monitoring.
A That's correct.
Q. Will you tell the jury what it was that you did while you were on the Security staff as internal monitoring?
A Well, by this I refer to the Security staff's responsibility to ensure that the membership of the organization was loyal, that persons who disagreed with Kr. LaRouche on anything received the appropriate/ I think in their minds, therapy and

that the supporters who came around the organization — that is, people who were going to give contributions or buy or be solicited in the manner described earlier — were not trying to probe the organization on behalf of some investigation or some other bunch'of people who were against the organization. So by "internal monitoring" I mean those things.
It also was the responsibility of the Security staff to pass on a list of authorized members. They were not the persons who normally decided who was a member of the organization but it was they who were supposed to rule on whether or not members would be admitted to the organization's national conference internal session. What I mean is we would go over the list of members and say, "Is everybody on this list? How can we be assured of their loyalty?" et cetera.
Q. Now, did part of the internal monitoring function as you have described it require you to know the whereabouts of the Labor Committee members within the organization?
A In a general way, yes.
Q. And did you know the names of the people, say, in the various regions who were running the regions?
A People who were running the regions, sure.
Q. In 1984 did you know who was running the Boston local?
A Yes.
Q. Who?
A Well, that's a somewhat complicated question because the

person who was cunning it on the scene was a person named Michael Gelber. Now, Mr. Gelber —
Q. Did he have a title?
A Yes. He was a member of the Steering Committee for Boston. Maybe he was even the head of it. Of that I'm not absolutely certain. But he was the person who was responsible for Boston organizing. However, he had one problem in that he was not a member of the National Committee. This is one of the bodies that I described earlier.
Q. Why was that a problem?
A Well, because the way the organization is structured a National Committee member has responsibility for all the organization's activities. There's, you know, at least one national security member supposedly responsible for any sector or most sectors of the organization's functioning —
Q. You just said "one national security member."
A I'm sorry.
— National Committee member responsible for every sector's functioning. And every region also is supposed to have a National Committee member responsible for that region's ongoing activities.
Q. What region was Mr. Gelber's local in?
A The Boston local was part of the N7ew York/New Jersey region.
Q. Who was the regional National Committee member in charge of the New York region?

A Well, there were two at that time, Dennis Speed and Phil Rubenstein.
Q. And who was it that Mr, Gelber reported to?
A Between the two? Well, he would report to — well, I don't want to make this too complicated. He would report to one or another of them. To which/ I don't know.
Q. Now, do you know of anybody else who was in the Boston local during the 1984 campaign, by name?
A Yes.
Q. Who?
A Well, there was a Michael Billington was either in the local
— I'm not — you know, again I'm trying to be very precise.
Because Boston was a satellite of the New York/New Jersey
region, people who really lived in New York or usually worked in
Hew York were sometimes sent to Boston. But the people who
seemed to come up most often in terms of Boston were Billington
— Michael Billington, excuse me? a fellow named Chuck Parks, a
Rick Sanders, And I believe Michael Gelber also is married. I
don't remember the name of his wife. She was also in the Boston
area. I believe there was a Richard Black, come to think of it,
was in the Boston area as I recall; his wife, Mamie Black.
I don't know if that's an exhaustive list, but those are the ones who I recall.
Q. Have you ever seen Mike Gelber before?
A Yes.

Q. Have you ever seen Charles Park before?
A- Well, I can't imagine that I haven't, but I don't recall ever having done so.
Q« Have you ever seen Rick Sanders before?
A Yes.
MR. MARKHAM May I approach the witness, your Honor?
THE COURT: You may.
Q. Let me put three photographs in front of you/ to come back to the beginning, marked Government's 1, 2 and 3, and ask you if —and the numbers are on the back. If you could look at the numbers and then tell me whether or not you can identify the individuals depicted in the three photographs. A, Well, Document No. 3 is Sanders.
Q. Could you give us his full name, please?
A I don't — I think it's Rick Sanders. I don't know if that's "Richard" or whatever. "Rick," I guess, is the nickname. I don't know his full name. Rick Sanders.
This is No. 1. It's Michael Gelber.
I have an awfully good idea who this is, but I can't say that — I remember seeing this person. I can't really attach this face to a name.
Q. Which number is that?
A This is No. 2.
Q, So you identify Photograph No. 1 as who?
A No. 1 is — this one is Exhibit No. 1. This is Michael

MR. MA'RKHAM: Your Honor, may that be received as
Government's 1 in evidence?
MR. WALKER: No objection, your Honor.
THE COURT: Received in evidence,
(Government's Exhibit No, 1 received in evidence)
Q, No. 2 you can't make, correct?
A That's correct.
Q. How about No. 3?
A No. 3 is Rick Sanders.
MR. MARKHAM: All right. May I offer Government's 3 in evidence at this time as having been identified?
MR. WALKER: No objection, your Honor.
THE COURT: Received in evidence.
(Government's Exhibit No. 3 received in evidence)
Q. Did the organization have a — well, you have mentioned several publications that the organization has had, correct?
A That's correct.
Q. Can you give us a list of those publications?
A Sure. New Solidarity, Campaigner, Fusion, Executive Intelligence Review, Investigative Leads. There were a number of publications which were suspended/ one called War on Drugs. Those are the main ones that come to mind. There were other occasional publications also, publications of books and special

pamphlets and so forth,
Q. All right. Now, you told us earlier, I believe, what Fusion — well, what is Fusion Magazine?
A Fusion Magazine was the publication of the Fusion Energy Foundation, which was basically the organization — the Labor Committee's scientific front group. It advocated things like nuclear energy and stuff like that, and it was sort of under the auspices of this institution that the organization approached scientists and so on in an earlier period.
It's as the Fusion Energy Foundation that the
organization usually has its presence at airports and stuff. In other words, people from the organization will go to airport management and say, "We're the Fusion Energy Foundation and we want to be here pursuing our First Amendment rights to distribute literature about fusion energy," and then they will go do whatever they want, anyway. But that's the Fusion Energy Foundation.
Q. All right. Briefly tell us what the Campaigner magazine is.
A Campaigner is — gee, I don't even know if it exists anymore. It is a — the term of art for this in the left used to be the theoretical journal. In other words, this was where you published the heavy, serious intellectual articles about things as opposed to the popular mass circulating article. And that's what it began as, and it continued to sort of publish these theoretical cultural articles.

Q. And briefly again, Executive Intelligence Review?
A. Well, Executive Intelligence Review was a weekly
intelligence summary, if that term can be applied to its
contents, which covered world and domestic affairs, you know,
reported in exquisite detail on the innumerable conspiracies
that Mr. LaRouche was victimized with in his mind and things of
that nature. . It was a weekly publication. It was sold at something like 5500 or more per annum. It was really for quite some time the bread and butter of the organization. It was something that was targeted very often for corporate sales, and this was sort of a vehicle through which people could make contributions to the organization as a subscription.
Executive Intelligence Review was a publication which in I guess a period roughly 1981 to '84 was the most important publication in terms of how many people worked on it, how much attention was focused on it and so on.
Q. Last, New Solidarity.
A New Solidarity — gee, I don't know if it still exists. It was originally a weekly and then a biweekly publication which was in newspaper format. It had sort of a more popularized approach, I guess is one way of describing it. It had articles — the same kinds of things generally as the Executive Intelligence Review but designed for mass circulation. You could get a subscription for, I don't know, $25 or whatever as

opposed to the $400 , or $500 price tag for EIR.
Q. How many New Solidarity's have you seen in your life?
A In my life? Do you mean individual issues, or do you mean in aggregate?
Q. No. I mean how many individual issues?
A Okay. Let's see. Well, let's say about 600.
Q. Let me show you what is marked as Government's 4 for identification, having first shown it to Mr. Walker.
Have you ever seen this publication before?
A Yes.
0. what is it?
A This is New Solidarity.
Q. And is that Government's 4 for identification in the format
of the hundreds that you have seen previously?
A Well, there was a change in format. Originally the
publication was a tabloid, and then at a certain point, I forget
the precise year, it adopted this bigger format. I don't know
what the, you know, printing industry name for this kind of
thing is. But in other words, when I first saw it, it was like
this; and then later it was printed like this (indicating). So
as the format for the past several years at least, this has been
the format of the publication.
Q. All right. And you recognize that as being a New Solidarity
published by the Labor Committees?
A Yes.

MR. MARKHAM: I would offer that as Government's 4 in evidence.
MR. WALKER: Mo objection, your Honor.
THE COURT: Received in evidence.
(Government's Exhibit 4 received in evidence)
THE COURT: And are you ready to break at this point?
MR. MARKHAM: I 'm ready to break — almost -- well, I'm ready — yes, I'm ready to break. I think it's almost time to break because I think I'm through.
THE COURT: Well, I'll give you an additional minute or two to be sure that you have completed your direct examination. Is that what you're saying?
MR. MARKHAM: Is your Honor worried that I might think of something overnight?
MR. MARKHAM: No. If I could have maybe — I may take several minutes tomorrow morning, your Honor, but that would be the most.
THE COURT: All right,
All right. Members of the jury, we'll break 15 minutes early today, and I am about to excuse you for the day. I do have one matter to inquire about before I excuse you.
It has been called to my attention that there has been some publicity about the case, and so I want to ask again if any of you has seen or heard anything about this caser news reports

Witnesses Direct Cross Redirect Repress
(By Mr. Markham) 5
Numberc For ID In Evidence
Govt. 1 122
Govt. 2 122
Govt. 4 126
I, Linda M. MacDonald, Official Reporter, do hereby certify that at the time and place aforesaid I reported stenographically the proceedings had in UNITED STATES OF AMERICA versus ROY FRANKHOUSER, CR 86-323-K, and that the foregoing record is a true and accurate transcript of the proceedings taken therein, to the best of my knowledge, information and ability,
IN WITNESS WHEREOF, I have hereunto set my hand this 5th day of November, 1987.
Linda H. MacDonald Registered Professional Reporter Official Federal Reporter

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