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< Testimony of Charles Tate -November 3, 1987 | Trial Transcripts | Personal Financial Disclosure for Lyndon H. LaRouche Jr. (D-Va) >

Source: Federal court testimony of former LaRouche security aide Charles Tate at (D. King) (815 Kb) (1,235 Kb) (2,019 Kb)
Note: we have replaced the German spelling of FRANKHAUSER into his American name FRANKHOUSER




Courtroom 14 U.S.P.O. & Courthouse Boston, Massachusetts Wednesday, November 4, 1987
John J.E. Markham II,
A. Hark Rasch, D.O.J. Attorney
Oven Walker, Federal Defender
Linda MacDonald, Reporter Computer-Aided Transcription P.O. Box 210 PO & CH, Boston, MA 02101 (617) 338-6761

(Court convened at 9:32 a.m.)
THE COURT: Good morning.
MR. MARKHAM: Good morning.
THE COURT: wait a minute. Did Mr. Walker step out?
MR. MARKHAM: Yes, I believe he did. I know where he is. May I go get him?
THE COURT: All right.
MR. MARKHAM: Your Honor, there are two very brief matters that we'd like to raise. I have one and I believe Mr. Walker has one. Mine is in trying to determine order of witnesses and questioning, I would like, if I can, to know if the Court is inclined after reviewing Judge Young's order and the memorandum submitted yesterday by Mr. Moffitt to order delivery of the notebooks because —
THE COURT: All right. Mr. Moffitt is present. I will tell you both that I expect to have — I do expect to allow the order. I will have a memorandum available sometime today. If I have an opportunity to —
MR. MOFFITT: Your Honor —
MR. MOFFITT: I don't mean to interrupt the Court. I'm sorry. I'll let you finish. But in light of Mr. Tate's testimony yesterday with respect to certain aspects of these

notebooks, I would like the opportunity to-be heard for about ten minutes.
THE COURT: Well, all right. Now, we have some other motions scheduled for 2:30 today. I think they are not — as I understand it, they are not substantial enough to occupy our entire time. So I would suggest that I hear you at 2:30, and I will withhold the entry of the order until I have heard you. I will probably have it prepared and ready to enter unless you persuade me —
MR. HOFFITT: I understand that, your Honor. But I —
THE COURT: So I'll see you at 2:30 on that.
MR. MOFFITT: Okay. Fine.
MR. MARKHAM: That's all that I had, your Honor.
MR. WALKER: Yes, your Honor. Mr. Harkham kindly enough brought to my attention in connection with our question of the juror who had had the conversation with a friend that in a recent Washington Post — yesterday's, was it?
MR. WALKER: — apparently there was a statement that said something to the effect that — maybe Mr. Markham could state it, but that Government officials said something to the effect that if Mr. Frankhouser pleaded guilty, he would get a reduced sentence if he told what he knew or something — I'm sorry. I just can’t recall the —
THE COURT: All right. Now, let me make a suggestion

to you, that if you both wish it, I will say to the jury that it has come to my attention that there has been substantial publicity about this case, including some statements reported as fact that are absolutely incorrect, and that this illustrates why I give an instruction not to receive information about the case from any other source. So that if it happens that anybody has received any information, they will also be alerted to the fact that there is some false information out there in the press.
THE COURT: Now, if both of you are satisfied with my doing that, I will do it and am happy to do it first thing this morning if you wish it before we —
MR. MARKHAM: Could we confer about that over a break before you do it? I know you're going to talk to them at the end of the day, and it's safe that between now and the end of the jury day they won't listen to anything else in the press. I'd like to talk to Mr. Walker about a proposal for the wording on it and see if we can agree on it.
THE COURT: All right. Do you have any problem with that, Mr. Walker?
MR. WALKER: No. Pine, your Honor.
THE COURT: All right. Are we ready for the jury, then?
MR. MARKHAM: We are.

THE COURT: Let's check. One juror was still missing a moment ago.
You may return to the stand.
(Mr. Tate resumed the stand.)
THE CLERK: The juror is not here.
(Court conferring with the Clerk)
MR. WALKER: Your Honor, I have another very minor matter.
THE COURT: All right.
MR. WALKER: As the Court knows — maybe the Court does not know — Mr. Frankhouser is being lodged by Pretrial Services at the Coolidge house. a halfway house for federal prisoners. Frankly I haven't had time to complain about that and indeed, Mr. Frankhouser at the moment just doesn't want to — want me to complain about that. They put him on a work detail in the afternoon, keeps his mind off the case. There is a matter of his getting lunch. And I have been actually making when I make a sandwich for myself in the morning an extra one for Mr. Frankhouser in the last couple of days.
Could somebody give him — could Pretrial Services provide him with — he has $14, he tells me. He needs that to get back and forth on the subway and that kind of thing. Could somebody give him —
THE COURT: Certainly. Why don't you confer with the

Pretrial Services. If you have any difficulty about it —
MR. WALKER: All right, your Honor.
THE COURT: — then bring it to my attention and I will give them any necessary order.
MR. WALKER: Thank you, your Honor.
MR. MAKKHAH: Hay I raise another matter?
MR. MARKHAM: I don't believe this has to be raised out of the presence of this witness, does it, Mr. Walker?
MR. WALKER: I think maybe it should — it doesn't really matter as far as I'm concerned.
THE COURT: All right.
MR. MARKHAM: All right. The United States proposes after Mr. Tate and after one very brief witness next in order this morning to call three victims of the credit card fraud who will testify that they did not lend monies which were taken by — one by Gelber, one by Park and one by Sanders, And we will be introducing the fraudulent credit card slips having their initials on them. I alerted Mr. Walker of this and he has stipulated to the authenticity of the credit card slips but he, I believe, has a question about the relevance of those witnesses to this trial. And I thought since we're waiting for a juror we could take care of that matter because if for some reason they are not allowed, they are elderly, I'd like to tell them not to

THE COURT: Yes. All right. Mr. Walker, do you want
to be heard on that?
MR. WALKER: Yes, your Honor. Well, a lot of this case — Mr. Small, as I understand it, Mr. Daniel Small, is going to be here to testify that as a result of complaints received, an investigation started into the fundraising and alleged fraud in the fundraising by The LaRouche Campaign. The Court itself admitted the — or said the other day that it would admit certain documents showing — that tended to show the large-scale extent of the matter.
THE COURT: Just a moment.
THE COURT: All right. Go ahead.
MR. WALKER: I don't see what is to be gained in this trial other than possible prejudice to Mr. Frankhouser , who is admitted to have nothing to do with this by the Government. I don't see what the gain is of having three elderly people come in to give — to make the Government's case more sympathetic.
THE COURT: Well/ not just more sympathetic; more
compelling on the evidence. The Government, after all, has the burden of proof beyond reasonable doubt. It seems to me it's quite relevant and quite material. So if the objection is on grounds of lack of relevance or lack of materiality, I have to

overrule it.
MR. WALKER: Well, your Honor, it's alsq a — what I'm trying to get at is what I understood the Court's ruling to be in relation to the WBZ-TV program, that the Court said that — which is the same type of thing.
THE COURT: Very different problems there. There is inadmissible evidence involved there.
MR. WALKER: Well — your Honor, I think that the — in the sense that it was hearsay?
THE COURT: Mr. Walker, if you're raising a 403 problem, I understand that. But I just find that the probative weight of the evidence in relation to the issues in the case very significant in order to strengthen the Government's case, as they're entitled to do, and the risk of any unfair prejudice is quite minimal here. The only risk you have suggested is sympathy for —
MR. WALKERi Yes, your Honor.
THE COURT: — the victims.
MR. WALKER: Which are not the victims of this crime.
THE COURT: I understand.
MR. WALKER: Your Honor, the other — and finally, your Honor, if the Court — the Court having indicated its position, I don't see — I can stipulate as to what their testimony would be. It would save us time.
THE COURT: Well, I'll consider that. I'll consider

that. We'll take it up at the recess. It may be that if you ~ I'm not sure about a stipulation as to what their testimony is. If you stipulate the issue out of the case to which this is quite relevant and material, that's a different matter. The juror is here now, so we'll proceed and I'll give you an opportunity to offer any stipulation that you wish to stipulate to see whether that deals with the problem.
All right. The jury may be brought in.
(The jury entered the courtroom at 9:46 a.m.)
THE COURT: You may be seated.
Good morning, members of the jury.
THE JURY: Good morning.
THE COURT: You may proceed Mr. Markham.
Q. Mr. Tate, do you understand that you're still under oath?
A. Yes, I do.
Q. Mr. Tate, did you ever observe any of the Security staff to take any actions after Mr. Frankhouser had called in with one of his reports?
A. Yes, I did.
MR. WALKER: Objection, your Honor.
THE COURT: Ground?
MR. WALKER: Well, your Honor, "after" is a — that's a

fairly vague question.
THE COURT: Read the question back to me.
(The record was read as requested.)
THE COURT: The objection is overruled. You may answer it "yes" or "no.n
A. The answer is yes.
Q. All right. And how frequently did you have this observation?
A. Many times.
Q. Can you describe one such occurrence where Mr. Frankhouser called in and, after he called in, somebody on the Security staff did or said something?
A. Well, the last such occurrence that I recall was on the last day on which I was a member of the organization.
Q. when was that, again?
A. That was August 17, 1984. I received a phone call from Jeffrey Steinberg —
MR. WALKER: If your Honor please, may we approach the
THE COURT: All right.
MR. WALKER: If your Honor please, I don't know what this is, but if it's 404(b) material, I should have been told about it long before today.
MR. MARKHAM: It is not 404(b). I plan to as my last

area of inquiry establish through this witness that when Mr. Frankhouser would call to tell him certain things, that he would take certain actions based on what he said. And the reason I'm doing this is because it's relevant to show —
THE COURT: What is the expected answer?
MR. HARKHAH: Well, the expected answer, I believe, has to do with somebody trying to assassinate LaRouche and they had to go and do something because Roy had called in to ask for an assassination. I believe that's the last —
MR. WALKER: "To ask for an assassination"?
MR. MARKHAM: No. To warn them about an assassination attempt. He was constantly worrying about it.
MR. WALKERi Oh, all right.
THE COURT: All right.
MR, MARKHAM: I believe that that's the one — there's no 404(b).
Q. Do you have my question in mind?
A. Yes, I do.
Q. All right. What is the answer?
THE WITNESS: May I continue with the answer to the previous question?
THE COURT: You may.
A. Let me start from the beginning, for clarity. On the last

day which I was a member of the organization August 17, 1984, I received a phone call from Jeffrey Steinberg. Jeffrey was in Leesburg, Virginia or thereabouts and I was in the New York City office. And Mr. Steinberg told me that he had received a call from Mr. Frankhouser with the information that the brother —
MR. WALKER: I'm going to object, your Honor.
THE COURT: Overruled. You may answer.
A. Mr. Steinberg told me that he had received a call — I'm sorry, that he had received information from Mr. Frankhouser to the effect that James Earl Ray's brother was involved in an assassination plot against Mr. LaRouche. James Earl Ray, of course, was the person who assassinated Martin Luther King. And Mr. Steinberg instructed me to make a series of undercover phone calls and whatever inquiries were necessary to establish the whereabouts of the Ray brother to determine whether this was true and so forth. That was only the final in a long series of such — the organization would call deployments — such assignments made on the basis of information received from Mr. Frankhouser .
Q. How frequently did you observe the Steering Committee give assignments such as the one you have just described based on what they said was information they had received from Mr. Frankhouser ?
A. Oh, very often. At least several times a week.
Q. Now, did anybody on the Security staff ever use with you the

term "security screen"? A. Yes, they did.
Q. Who used that term in conversations with you?
A. Well, most members of the Security staff at one time or another, most specifically persons on the Security Steering Committee, discussed with people such as myself, who were doing shifts, the level of risk alleged to be involved for Mr. LaRouche.
Q. I'm sorry. Did anybody on the Steering Committee ever tell you who had told them of this security screen?
A. Yes. We were told by members of the Security staff Steering Committee that the security screen, which was, we were explained, a protection offered to Mr. LaRouche and his wife, Helga Zeppe LaRouche, by various intelligence agencies, including the CIA, was variously up or down or was halfway up or was curtailed or was completely shot or whatever it might be.
This alleged screen was basically the description given to us by Mr. Frankhouser of the degree of protection that other agencies were providing to Mr. LaRouche sort of behind the scenes while we were, you know, standing around the house with guns and stuff.
Q, Now, Mr. Tate, were there times when you were told that the security screen was at a higher level rather than a lower level?
A. Oh, yes. It was constantly going up and down like the curtain in the theater.

Q. Did you ever get any explanations as to why the security screen was down when it was down?
A. Well, the — typically if it was — if the screen was down — that is to say/ if Mr. LaRouche was receiving enhanced protection from our nation's intelligence services — it was because they had/ according to Mr. Frankhouser , received reports of impending terrorist or other activity against Mr. LaRouche.
If the screen was removed or was permeable at a given point, we were sometimes told that it was because U.S. intelligence was tied up with some other assignment, perhaps protecting the Secretary of State on a European visit or something of that sort. So there was usually some sort of explanation that accompanied the ebb and flow of the so-called security screen.
Q. And specifically, did you ever speak to Jeff Steinberg about the security screen?
A. Yes.
Q. Did he ever tell you personally who had informed him of this screen?
A. Well/ in the reports —
MR, WALKER: Objection, your Honor.
MR. WALKER: I object, your Honor. Hearsay.
MR. MARKHAM: It's not offered for the truth.
THE COURT: Objection overruled.

Q. Did Mr. Steinberg ever tell you who was the origin of this
security screen advice?
A. Yes.
Q. Who?
A. Mr. Frankhouser .
Q. How frequently did he do so?
A. We received such advisements about as often as you listen to
the weather report. Every day for an extended period of time we
would be told, "The screen is up," "The screen is down," et
cetera, et cetera.
Q. Now, did you ever observe anybody on the Steering Committee
of the Security staff take any action on the basis of having
heard that the security screen was either up or down?
A. Yes.
MR. WALKER: Objection. Asked and answered.
THE COURTj Overruled.
Q. What actions?
A. Well, in some circumstances if we had received word that the CIA, NATO and everybody else was momentarily not paying attention to Lyndon LaRouche, we would sometimes add people to the security shifts. We would do more patrols in the perimeter of Mr. Larouche's residence. We would, you know, carry out a yet redoubled effort to seek out the sinister forces that were out to get Mr. LaRouche if we thought that the CIA was asleep at

the switch.
Q. Mr. Tate, was there one — well, what was the most important concern of the Security staff while you were a member?
MR. WALKER: Objection, your Honor.
THE COURT: Sustained.
Q. Did the Security staff — well, let me start again.
Did you ever hear Lyndon LaRouche at any time speak of this security screen?
A. Yes.
Q. Do you recall the conversation?
A. Well, I recall a number of such conversations. They would usually take the form of Mr. LaRouche asking, "What do we have from Roy on the status of the security screen?"
Q. And —
A. "Is it up? Is it down?"
Q. And how often did you hear Mr. LaRouche ask the Security staff what they had heard from Roy on the subject of the security screen?
A. I can't quantify it. Half a dozen times perhaps. A number of times, a good number of times. It was a standard question. It was something of which he was to be informed whenever we had a new thermometer reading.
Q. Setting aside how many times you heard Mr. LaRouche ask about this subject, were there other times when you heard individuals of the Steering Committee communicate to

Mr, LaRouche on this subject?
A. Yes.
Q. How frequently did that occur?
A. Well, I think — I think we're pretty much talking about the same times. Half a dozen times or so. I think pretty much any time such a briefing took place in my presence. Particularly when Mr. LaRouche was in Europe, this was one of the big issues; "Is the screen up? Is it down?" et cetera, et cetera.
MR. MARKHAM: I have nothing further, your Honor.
THE COURT: You may cross-examine.
MR. WALKER: Yes. Thank you, your Honor.
MR. WALKER: May I stand back here so Mr. Tate can talk towards the jury, your Honor?
THE COURT: Yes, you may.
Q. Mr. Tate, Lyndon LaRouche was in complete charge of this
organization, was he not?
A. Absolutely.
Q. He was a — he acted virtually as a dictator, did he not?
A. I wouldn't use the word "virtually." Yes, he did act as a
Q. All right. Is it also true that Mr. LaRouche concerned
himself on a — excuse me for moving around like this — on a
day-to-day basis with the intricate details of his organization?

A. Yes, every detail.
Q. So if any decisions were made in his organization of significance, he was the one that made them, is that not right?
A. That's absolutely correct. Moreover, he said that if important decisions were made and he wasn't informed of them, the persons who made those decisions could be expelled, could be removed from their positions and would certainly be subject to his intense criticism and scrutiny.
Q. Do you recall him sending out a briefing at one point which had the statement, "I am the boss," in it?
A. Yes.
Q. And 1 show you a document marked for identification — I show you a document and ask you to look at it —
MR. WALKER: If I may approach the witness, your Honor,
THE COURT: You may.
MR. WALKER: And if I may just show Mr. Tate the front cover of it or the front page of it and then turn over a couple of pages and ask him if — I want to point a part of this out to
THE COURT: You may.
MR. WALKER: And ask him if he has seen this document
THE WITNESS: Yes, I have.
Q. And could you describe ~
A. Yes, I have.

Q. Could you describe what that document is?
A. Well, the complete document is a daily briefing. I mentioned this earlier in my testimony. This is an internal organizational communication produced on a daily basis for members. The particular section to which you refer is an internal memorandum, what that really means is this is sort of for the eyes only of the membership. I have seen it. I remember it.
MR. WALKER: May I ask that that be admitted into evidence, your Honor?
THE COURT. The entire document?
MR. WALKER: Yes, your Honor.
MR. HARKHAM: No objection.
THE COURT: All right. It may be received in evidence. In order to avoid duplication of numbers, I want to start high enough that we're certain that we have reserved enough numbers for the Government. If we make this 201, will we be safe?
THE COURTi Yes, your Honor.
MR. WALKER: I hope so, your Honor.
THE COURT: All right. It will be Defendant's Exhibit 201.
(Defendant's Exhibit 201 received in evidence)
Q. Could you read to the members of the jury the particular

part that was pointed out — that I just pointed out to you, the
three or so paragraphs with the date and the heading.
That is an acronym for International Caucus of Labor Committees.
"NOVEMBER 3, 1981.

Q. And just out of curiosity, did anyone ever tell Mr. LaRouche they were better qualified than he was, and get away with it?
A. Well, no. No, no one did.
Q. This memo was written, was it not, in response to somebody
that Mr. LaRouche thought had betrayed him? t"'
A. That's correct.
Q. And this fellow's name was Ken something, was it not?
A. Ken Dalto.
Q. Appear who was Ken Dalto?
A. Ken Dalto was a member of the National Executive Committee of the NCLC. He was the leader of the midwest region of the organization, which region had been held up for many years by Mr. LaRouche as the model of organizational functioning and was the region which all members were to emulate in their daily activities, thoughts and deeds. And Mr. Dalto one fine day decided he didn't want to continue his association with Mr. LaRouche and quit, bringing with him 120 very, very relieved members in the midwest region.

Q. And if you will refer to the bottom of the right-hand part of that same page, is there not a paragraph which begins:
A. Yes, that's exactly what it says.
Q. And that's also a memo from Mr. LaRouche, is it not?
A. That's correct. It's signed by Mr. LaRouche, dated November 2nd.
Q. And are there in this memo various references to sexual aberrations or sexual misconduct of Mr. Dalto?
A. Yes, there are.
Q. And indeed, there are quite a few of them, are there not?
A. Very few memos by Mr. LaRouche would be complete without at least one such characterization, but there appear to be a fair number of them here, yes.
Q. And just to characterize it, they're rather nasty and unpleasant, are they not?
A. Yes.
Q. Extremely nasty?
A. Extremely nasty and unpleasant. He has a real talent in making such observations and characterizations.
Q. Thank you. Now, turning to Mr. Larouche's lifestyle, I think you testified yesterday or the day before that he until about 1983 lived in New York City?
A. That's correct.

Q. And I think you said he lived in an area called Sutton
A. That's the very area/ yes, Sutton Place.
Q. And could you describe — did you ever visit?
A. Yes, I did, I was on duty there many times.
Q. All right. And what is Sutton Place?
A. Sutton Place is one of the most exclusive neighborhoods in
Hew York City. It's the kind of neighborhood — I believe there
is a novel called "Sutton Place" exploiting exactly the glamour,
wealth and so forth of this location.
Q. Does it look over the river or something?
A. Some — Mr. Larouche's particular abode on Sutton Place was
referred to as a shack, I might add. It did not happen to look
over the river, but that area does look over the east river.
Q. And was it — did he live in splendor or did he have fairly
— did he live in the manner that one might live if one were
living in Sutton Place?
A. Well, he was living extremely well. I'm not an expert on
interior design, so I don't know that I characterize it as a
splendid manner, but he — he was doing very nicely. He
wouldn't be ashamed to invite someone into his living room.
0. Mow, at some point he moved down to Virginia?
A. That's correct.
Q. And that was in 1984, did you say?
A. 1983 I believe was the year — was the year of the move. I

don't remember the exact date.
Q. And where did he move to in Virginia?
A. He moved to a residence called Woodburn Farm.
Q. And could you describe that for the members of the jury?
A. Woodburn is a beautiful Virginia estate, many rooms, many bedrooms, three-story house, 30 acres, I believe, of property/ a bunch of smaller houses associated with the property, a little stream, absolutely gorgeous kind of place. It's pretty much what comes to mind when you think of Virginia: land of aristocracy, horses and the rest. Beautiful place.
Q. And it's fair to say that if Mr. LaRouche wanted something, he got — he could ask for it and it was immediately provided to him by his staff?
A. That's correct.
Q, Did he also have a — did he move somewhere after — did he move somewhere from Woodburn Farm or Woodburn estate? A. Yes, he did. I didn't have the privilege of being in the organization when he did, so I have to say that on the basis of news accounts and stuff.
Q. I see. Did he have an abode in — out of the United States?
A. There was a home maintained for him, yes, in West Germany. Q, And where was that in West Germany?
A. It's in a suburb of Maintz, a little town called Stadechen-Elsheim.
Q. And did you have occasion to visit that house?

A. Yes.
Q. Could you just describe that briefly.
A. I should say just for the record, since we seem to be describing this as Mr. Larouche's residencef that another couple lives there apparently full time. However, when I was serving my tour of duty in West Germany and he/ Mr. LaRouche, was in West Germany, the house was treated as his house and his wife Helga's house. But there is another couple which lives — who lives there.
I'm sorry. I interrupted your question just to make a clarification. Could you repeat it?
Q. No. I think that — well, could you describe the nature of the house or estate?
A. Well/ that's quite a nice house. It has an indoor swimming pool. It's got several stories, whole bunch of bedrooms. They
both have studies. It isn't quite on the scale of Woodburn, but it's quite comfortable.
Q. Now, turning to another topic, Mr. Tate, yesterday you
described at some length the moneyraising that went on by
Mr. LaRouche's organization, and you said that at least during
the campaign of 1984 there were some — how many people were
there in New York raising money?
A. In the national office or —
Q. Right.
A. — or in the New York —

Q. Let's say the national office.
A. I don't know the exact number. I think it was about 100,
120 persons raising money.
Q. And how many did you say there were around the rest of the
country in these various local regional offices?
A. I think the total membership at that time was about four to
five hundred. And after 1984 virtually every other function, as
I think I described earlier, stopped cold except for security
and administration so that all members could devote their full
attention to raising money.
Q. And is it true, also, that moneyraising had taken place
during previous presidential campaigns that Mr. LaRouche had
been involved in?
A. Yes, that's true.
Q. And was that also on a large scale?
A. Not on as large a scale, but significant sums were raised
for both of the proceeding presidential campaigns.
Q. Now, between in the intervals — the four-year intervals
between the times Mr. LaRouche was running for president, was
there also moneyraising done?
A. Yes. It was an ongoing activity, yes.
Q. Was that also done at least in part by telephone?
A. Yes.
Q. All right. And that was to gather money for Mr. Larouche's
— people were told it was to gather money for Mr, Larouche's

party, is that —
A. Well, when you say people were told, just to clarify, are you asking the persons who were asked for money were told they were giving money for the purpose of Mr. Larouche's sundry activities?
Q. Yes. Thank you.
A. Not necessarily, no. Sometimes they were told they were giving money for other reasons.
Q. I see. At any rate, moneyraising was an ongoing activity of this organization?
A. Yes.
Q. And I think you said yesterday that one of the — the chief technique and one that was referred to in the bulk of the phone calls, if not almost all, was the threat of the KGB, the Russian secret police, taking over the United States?
A. Well, we're talking now over an extended period of time. Mr. LaRouche has seen/ I mean, many, many different disasters as threatening the United States over the years. Earlier in his career he thought that the CIA was about to take ov er the United States. This is before he decided that the CIA liked him. So I'm just — to give you the correct answer, there were many different calamities which were due to fall all of us any moment and they sort of changed with the seasons, so that I'd have to say no, the KGB was not always the reason to give Mr. LaKouche money. Sometimes it was the CIA or something else.
Q. I see. When did the KGB technique begin?
A. That seemed to become more and more prominent after President Reagan's election, the first election, and I think it was in full swing — by about 1983, the KGB had become the biggest of all bugaboos.
Q. I see. So what you're saying is that on a day of fundraising in the LaRouche organization there would be at any given time perhaps 200 people on the telephone calling people and asking them to give money because the KGB was going to be taking over the United States?
A. Well, that would be a fair, if somewhat overly broad, characterization of the 1984 period. Prior to that I think that there would be probably something like that number of persons raising money, but fewer of them would specifically be on the telephone and they would have other particular pitches to make.
Q. But apparently the KGB technique was fairly successful, is that —
A. Evidently, yes, it seemed to be extremely successful.
Q. And did Mr. LaRouche — he was also — he did have a — one of his platform positions has to do with drugs, does it not, and his opposition to drug pushers?
A. Yes, that's one of his positions.
Q. And that, of course — did his campaign workers mention that? A, Certainly. The campaign workers were more than happy to,

depending upon how you look at it/ either tailor their pitch to the perceived interest of the person who was being hit up for the funds or to try to speak to the person’s interest. However you want to look at it, they were more than happy to shift the focus of the KGB if that didn't seem to be the right button to push for the particular fundraising situation.
Q. Did you mention yesterday that Mr. LaRouche had an organization called Drugs — some reference. Coalition Against Drugs or something like that?
A. Yes. At one point the organization created a group called War Against Drugs.
Q. But I think — did you say yesterday that that sort of disappeared at some point?
A. Yes, it disappeared very specifically after the state of Illinois began to investigate the group for false representation in charitable fundraising. And then the group, War On Drugs, which I believe — well, War On Drugs ceased to exist shortly thereafter.
Q. What year was that, do you recall?
A. I believe it was 1981 or '82. I don't remember a precise year. The organization never said, By the way, you caught us guys. We're not going to do this anymore. Change your scam. It sort of like was dropped. And then ex post facto there was the explanation that the dope lobby — this was before the KGB. One of the bugaboos was the dope lobby — had ganged up on the

organization and had destroyed War On Drugs in some v/ay using corrupt law enforcement officials.
Q. Now, the persons — you described yesterday a gentleman that came in and ran the .84 fundraising like Patton's Army. His name was again wirtz?
A. Will Wertz.
Q. And is it fair to say that Mr. Wertz worked up the fundraising activity into what might be characterised as an almost hysterical activity?
A. Well, again, I wouldn't use the word "almost," but yes, it certainly was a sort of mass enthusiasm and hysteria that entered into the organization's activities around fundraising at that point.
Q. And people on the bottom, lowest level people in the organization, felt under an extreme amount of pressure to meet the quotas?
A. Yes.
Q. Is that not correct?
A. That's correct.
Q. How many hours a day were worked?
A. As many as would be required to meet the quota. That could be until 10:00, 11:00, 12sOO at night. Q, And starting at what time?
A. 9:00 in the morning.
Q. Now, would it be fair to characterize — well, strike that.

You said that Mr. LaRouche was involved in the intimate details of running the organization.
A. Yes, that's correct.
Q. And did he ever get involved in the personal details of the lives of the members of the organization?
A. Yes.
Q. And could you describe how he did that and for what purpose?
A. Well, the usual circumstance was one in which an individual member had expressed uncertainty about the complete accuracy of whatever Mr, LaRouche said. I mean/ you had to believe and you had to believe a hundred ten percent in everything that Mr. LaRouche said. If someone expressed some doubt and they were important enough, Mr. LaRouche would want to know what was going on in their personal life and would make a very direct intervention into that person's personal life, very commonly bring them to his home and peppering them with some of the epithets that you have seen here in this memo which I shudder to read to the jury — but in any event, the — I mean, we know what we're talking about — until that person either said, "I've had it. Good-bye," and quit the organization or else recognized the error of his ways and saw the wisdom of, you know, Mr. LaRouche and once again got back on track. So he was very, very interested in the intimate personal details of his members1 lives.
Q. And did he ridicule people that didn't agree with him?

A. Yes.
Q. And could you give us examples of how he did that?
A. He would — well, his favorite example was to raise questions about whether or not people's sexual lives were in accord with what he thought was the correct sexual life. He would accuse them of homosexuality. He would accuse them of bed hoppingf things of this nature.
He would accuse them of pederasty. That became actually increasingly not so much for the membership but for his other enemies. That became increasingly an association in his mind that was an appropriate epithet.
Q. Now —
A. So he would use these kinds of terms to describe people in the organization and without who disagreed with him.
Q. Not to be vulgar, but "pederasty" means?
A. Child molestation.
Q. Were there occasions when, for example/ he would talk about — let's say there was a man in the organization. Were there instances where there were married couples who were both members of the organization?
A. Yes. It was virtually taboo to be married to someone who was not in the organization. So yes, anyone who was married was likely to be married to someone in the organization.
Q. And were there occasions when he would refer to, let's say, Mr. X as Mrs. X's wife or husband — Mrs. X's husband?

A. Yes,
Q, Excuse me. I have this wrong. Can you explain what —
A. I understand what you're saying. I think — he thought it was — he — what he thought about it I won't speculate.
He said on various occasions that so-and-so, a man, was his — his wife's wife. He thought that was a way of getting at that person.
Q. So as well as bringing up ancient history about individuals that might embarrass them?
A. Mm-hm.
Q. Whether true or false. In other words, if a person was a homosexual — if he accused a person of being a homosexual, it wasn't necessarily the case?
A. Oh, there was no necessary relationship whatsoever between any factual basis and his allegation. I mean, if that was the case, so much the better for him. If he happened to have some dirt on somebody — and he made a point of accumulating personal information about everybody he could — then sure, he would ventilate that. But if he didn't have it, he would invent something. He never found the lack of real facts an obstacle to making assertions he wanted to make.
Q. Now, you have described at some length his total — hi: total preoccupation with assassination.
A. Yes.
Q. And this was a subject of comment and conversation and

statements and discussion every day?
A. Every, single day — well, I'm sorry, I can't really say it was — it was a constant preoccupation. Maybe a day passed when he didn't talk about it. I can't say for sure.
Q. And one of the people that was out to get him was Queen Elizabeth, is that —
A. Just one.
Q. Just one.
A. There are hundreds of others.
Q. Now/ Mr. LaRouche has an obsession, does he not, with spying and counterspies and that type of thing, does he not?
A. Yes.
Q. And with the Central Intelligence Agency?
A. Yes.
Q. With agencies of the Soviet Government, isn't that correct?
A. Yes.
Q. Such agencies of other Governments, as well?
A. Oh, yes, absolutely. The Israeli Government, the — all the European Governments, Latin American Governments. He has a whole sort of realm of his fantasy life devoted to his role as a master player behind the scenes in political intelligence, and he supposes himself to have a direct influence on the U.S. intelligence community and the intelligence communities of all the major nations of the world such that they almost never do anything without considering the import for Lyndon LaRouche of

what they're doing. So yes, he has such a perception.
Q. And is he up on all the language that one uses about spies such as moles and infiltrators and this kind of thing?
A. Yes. He peppers his — his table talk with a lot of those kinds of expressions.
Q. And what is it? What does a mole mean?
A. Well, a mole is an intelligence term, I guess, for double agent, someone who is burrowed into a hostile intelligence agency to get information presumably in order to surface later. That’s the analogy of the mole.
Q. And did he worry about moles within the LaRouche — his own organization?
A. Now and again, yes.
Q. And I'd like to show you another document, if I could, and ask you to identify it.
MR. MARKHAM: Mr. Walker.
MR. WALKER: I'm sorry,
MR. MARKHAM: Excuse me, your Honor.
(Counsel examining document)
(Witness examining document)
Q. Could you identify it?
A. I'm sorry. identify the document?
Q. This document.
A. Yes. This is a document of the same general type as the one which I described previously. It's an internal document. This

one says specifically NCLC/A11 U.S. POINTS. It's dated October 21st, 1981; that's to say, a little bit before the other document that I read. And it's addressed to Detroit, the local organization in Detroit, and also with a carbon copy to all members. And there is another document on the other page- I donft know if that's also what you're concerned with at this point.
Q. I'll get to that in a second.
MR. WALKER: I would move that this be admitted, your Honor.
MR. MARKHAM: No objection.
THE COURT: All right. It's received in evidence as Defendant's Exhibit 202.
(Defendant's Exhibit 202 received in evidence)
Q. With respect to the item on.the left-hand side of the first page, could you tell us exactly who that's from and to whom it's directed and the date?
A. Okay. It's from LaRouche, Lyndon LaRouche, to Detroit, the Detroit organization, with a carbon copy to all members. It's dated October 21, 1961.
Q. And the first paragraph refers again to the Detroit situation?
A. Yes, that's correct.
Q. And could you read to the jury, the second paragraph?

A. The second paragraph reads:
Q. Excuse me?
reads. I'm sorry, I'm saying that to the Court Reporter.
Q. So this is an example of Mr. LaRouche's concern that there
is a mole in his organization?
A. Yes.
Q. And —
A. A dirty Judas.
MR. WALKERj May I have a just a moment, your Honor?
THE COURT: You may.
(Mr. Markham examining document)
Q. He was also concerned, was he not, that various governmental
agencies might be playing so-called dirty tricks with him?
A. Yes, constantly.
Q. Planting evidence on him, that kind of thing?
A. Yes.

Q. And showing you another document, that's an edition of the LaRouche magazine, New Solidarity newspaper for November 12, 1984, is that not right?
A. Yes, that's what it is.
MR. WALKER: And I ask that this be admitted, your Honor.
MR. MARKHAM: No objection.
THE COURT: Defendant's Exhibit 203 in evidence.
MR. WALKER: Thank you, your Honor.
(Defendant's Exhibit 203 received in evidence)
Q. And specifically, on the first page on the bottom left of the first page — maybe I'll just hold that up so that everyone can see it — there is an article entitled "FBI Throws Dirty Tricks at LaRouche Campaign"?
A. (Witness nodding head up and down)
Q. And is it fair to say that's Mr. LaRouche saying that the investigation of the alleged credit card fraud or the credit card fraud in 1984 was actually an FBI dirty trick?
A. Excuse me. Are you asking me if that's a fair characterization of this article?
Q. Yes.
A. I haven't read this article previously. If you like, I'll take a moment to read it. It seems on the face of it that that's a plausible summary, but —

Q. Why don't I withdraw the question and just ask you to read
the first paragraph of it.
A. Okay. Are you asking me to read this out loud or —
Q. Yes, if you would.
A. "In a pattern of political dirty tricks more
outrageous than Watergate or Abscam, the FBI this week launched a political operation of sabotage against the presidential campaign of Lyndon H. LaRouche, Jr.
Q. And I'm also going to show you a copy of New Solidarity that
was introduced yesterday — that is. Government Exhibit 4 — and
ask you if on the second page — that's dated February 8th,
1985, is it not?
A. Yes, that's correct.
Q. And on the second page there's an article entitled — well,
why don't you read the title of this article here.
A. The title is "U.S. Att'y Weld Goes Fishing With New
Q. All right. Why don't we just show that so the members of
the jury can see it.
And that also appears — who is that article by?
A. That's by Edward Spannaus.
Q. And Hr. Spannaus, again, is who?
A. Mr. Spannaus is a member of the organization's National
Executive Committee. He is the person who runs the
organization's legal activities. He, as I mentioned before, had

significant responsibilities in moving the organization to Leesburg, Virginia. He is a very long-time member of the organization, and he is one of Mr. Larouche's closest associates.
Q. If you would — could you read us, let's say, the second —
well, could you read us the third paragraph of that article?
A. "Observers are viewing the issuing of the broad-
ranging subpoenas as an indication of weakness, demonstrating that Weld has been unable to obtain any testimony which would support his public allegations of wrongdoing against The LaRouche Campaign organizations. Informed sources have confirmed that Weld and the FBI have no worthwhile evidence to support the charges of 'credit card fraud1 they made last November, and that therefore they are attempting to use the document subpoenas as a fishing expedition to obtain or manufacture evidence to give them a pretext to go after LaRouche personally."
Q. So was it characteristic of Mr. LaRouche to think that or to say, rather, that his enemies might be manufacturing evidence to get him?
A. Yes.
Q. Now, you testified, did you not, that at one point you were involved in patroling Mr. Larouche's estate down in Virginia?
A. Yes.

Q. And how many times did you do that?
A. Scores of times, I don't have an exact number. Many times.
Q. You were mostly in New York, however, were you not, when you
worked for the organization?
A. Well, as a member of the Security staff I constantly had the
responsibility maybe every other week to do a security shift.
So after Mr. LaRouche's move to Leesburg, those shifts were, of
course, in Virginia; and during that period of time I had to fly
down to Virginia. And so that I spent a good portion of my time
down there. So during that period I was sometimes in New York
and sometimes in Leesburg.
Q. And could you describe in detail how these security shifts
A. I'm sorry. Could you clarify — when you say "describe in
detail" how they worked —
Q. Well, how many people were involved?
A. In Mr. Larouche's security altogether?
Q. Well, specifically with respect to maintaining security of
his estate down in Virginia, how many people — let me ask you
this. Were there people with arms and guns?
A. Oh, yes, yes. I think I get your drift. There were — if I
don't, please — well, there were five or six persons on each of
two shifts, morning and night,, all of them armed, sunumber of
them retired or in some cases active New York City police
officers hired through a personnel agency that hires those kind

of people. And those persons would assume positions in the house and on the premisesr on the property of the house, to ward off any and all potential assassinations from the Queen of England to Raisa Gorbachev who might come storming through at any moment to kill Mr. LaRouche.
Q. And were there patrol cars or how did people — how were people deployed around this estate as part of this —
A. Usually on foot. There would typically be a car which would sometimes, you know/ go for what we describe as a perimeter check so that we could have a little more advance notice of these sundry assassins.
Q. Were most of the people stationed right in the house with guns, or were they walking around or —
A. Well, there would usually be a couple in the house, let's say, one with a dual responsibility of answering the telephone, watching the video screens. Also, there were, you know, some electronic communications kinds of devices that they would monitor. And the balance of them would be out on the grounds.
At Woodburn in particular — I don't know what the present arrangements are at all, but at Woodburn in particular there were a bunch of guard houses; and when it was cold or raining, the guards, of course, would be in the guard houses. At other times they would be on the property. They would have a definite area that they were supposed to watch. Now and again they would volunteer to do a perimeter check and they would walk

around the property and, you know, see if there happened to be any assassins nearby and come back if there weren't.
Q. Was there any barbed wire?
A. Well, yes, I think there was barbed wire. I don't believe at the Woodburn site in any case that the barbed wire was installed by the Security staff. I think it was just part of the farm's protection because the farm abutted a cattle field with cows and stuff. So that I think they wanted to — I think that actually most of that was done by the previous tenants and the farmers.
Q. And were there booby traps of some sort?
A. Well, not at Woodburn. There was — the fence had sort of an electronic monitoring device so that presumably if somebody tried to jump the fence, that the monitor device would go off. It was useless because every time the wind blew, a branch hit the fence and the alarm went off; and we began to just routinely ignore it. But that was, I think, about the limit of the electronic devices at Woodburn. There was also spikes in the driveway so that if cars attempted to enter the premises without permission, they would get their wheels blown off. And there was a gate. It was guarded — I should mention, I guess, there was a guard, of course, at the front gate who would clear people for entry and so on.
0. Did you say there was a video surveillance inside the house or screens or something of some sort?

A, Yes. There were — you know, Ifm trying to think now if those were — if we had those up at Woodburn. I remember them actually more distinctly in West Germany, come to think of it. There was a video screen. I don't remember, quite frankly, if it was working when I was there. Electronic surveillance is really not their strong point.
But there were screens there. I forget whether they were up and running at the time. Of course, when I was on duty I looked at them. I didn't really have the impression that I was going to see the Queen of England on television at any moment, so I have to say I'm not really too sure if they were working.
Q. Well, it sounds like you didn't take this altogether seriously.
A. Well, initially I took it very, very seriously. That is absolutely the case. I was as determined as any of those people that were there that even if each and every one of myriad assassination plots that we said existed might not quite be as
serious as they are cracked up to be, that Lyndon was an extremely important person and a very valuable person and that his life should be preserved at all costs. And early on I believed that there might be persons who indeed wanted to get him out of the way, thought he was a political nuisance.
Later on when I was actually made a member of the Security staff and had the opportunity to meet Mr. LaRouche and

interact with him on a daily basis over a period of years the realization came to me rather suddenly and demonstrably and obviously that the man was a paranoid schizophrenic, that he had delusional fantasies of his own importance and delusional fantasies that he was the target of all manner of enemies. It was a very standard and very obvious kind of pattern.
I remember when I was at Woodburn one of the gifts that somebody gave Mr. LaRouche was a copy of the Encyclopedia Britannica, and there was an article on paranoid schizophrenia. And I was on duty at night, had nothing better to do, and I took the volume down from the shelf. I looked it up and I read it. And I kept going, "Oh, my God. This is a character sketch of Lyndon LaRouche." And at that point I realized that everything that I had been thinking at that point for some years about how this man's mind worked was correct and undeniable and that the only real question was, given how — given how unstable he was, how unstable his followers were, the fact that at the time he was beginning to have contacts with people who really were important in the intelligence community, the only question for me at that point was how was I to get myself near enough to an exit door that I could get out in one piece.
Q. If I could just bring you back to the — thank you — the patrols on the estate. You stated that there were a bunch of retired or active New York policemen that were down there on so-called paid details?

A. Paid by the organization, not by New York — not by the New York police.
Q. I understand.
A. Yes.
Q. This was when they had time off from the police department, they were allowed to make money on the side?
A. I don't know what their moonlighting regulations are. I know that they were there. I don't know what — I don't know if they were there in accordance with NYPD regulations.
Q. Did they take Mr. LaRouche altogether seriously, according to your observations?
A. Some, I believe, did. I know that most of them considered him a joke. There were a number of occasions when I had breakfast with them after a security shift and they would be a little tired and they would begin to joke about Mr. LaRouche. And they would stiffen up and say. Wait a minute. Some of his followers are having breakfast with us. Be nice now. Don't start any trouble.
Q. And Mr. Frankhouser, did you observe him from time to time in this security operation down there?
A. Yes, that's right.
Q. And was Mr. Fick down there?
A. Yes. Mr. Fick was also part of this.
Q. Now, with reference to the so-called Security staff, the members of it, once again — who was in charge of it?

A. Well, Paul Goldstein was the person who was director of security. Just immediately alongside him virtually as security director was Jeffrey Steinberg. And I mentioned the other two persons who were on the Steering Committee who ran — actually three other persons on the Steering Committee who ran the staff
Q. All right. And was that Michele Steinberg?
A. That's right. Michele Steinberg was one of those other persons.
Q. And Robert Greenberg?
A. Robert Greenberg, yes.
Q. And these are four of the people whose notebooks you were identifying yesterday?
A. Yes, that's correct.
Q. And whose handwriting you were identifying?
A. Yes, that!s correct.
Q. And are any of those people in court today or not?
A. Jeff and Michele Steinberg, Robert Greenberg and Paul Goldstein?
Q. Right.
A. No, none appear to have come today.
Q. They had, I think you testified yesterday, four or five different functions, depending on how you count the functions?
A. That's correct.
Q, And one of those functions was to receive intelligence from — so-called intelligence from around the world about things

that were going on and, in particular, things that were going on that might be negatively directed towards Mr. LaRouche, is that correct?
A. That's correct.
Q. Is it true that most of the day the members of the Security staff would be on the telephone talking to so-called informants or gathering information from sources?
A. Well, that's substantially correct. I just wanted to be precise —
Q. Clarify, if you would.
A. — if I may.
Some members of the Security staff were doing physical security, so they, of course, were not on the phone. Other members were calling persons under pretext. They were pretending to be, you know, priests, ministers, rabbis, newspaper reporters, you know, doctors, lawyers, Indian chiefs, in order to secure information from people. And then others were talking to sources and consultants.
Q. And so, for example, Mr. Goldstein or Mr. Steinberg, who were the two sort of leaders of the Security staff, they would actually be going around with guns, as well, and doing all of — doing this perimeter physical security check?
A. They would seldom undertake personal responsibility for physical security. They did like to work around the house and and they did so, but they didn't do the perimeter checks and

stand out by the south forty and stuff like that.
Q. But how much of their day, then, aside from that function, would they be on the telephone talking to people?
A. Oh, they were on the phone constantly, all the time. You know, the staff joke was that Jeff Steinberg was born with a telephone in his ear.
Q. And who would Mr. Steinberg, for example, talk to?
A. Well, Mr. Steinberg talked to many different sources. Some of these were retired military officers or the like who he cultivated relationships with. Some were among the paid or unpaid sources who — consultants the organization had maintained over a period of time. There were many such people.
Q, And these are the people, are they not, who gave information that was recorded in these notebooks?
A. That's correct.
Q. And did they operate under code names and that kind of thing?
A. Yes, commonly. Well, when you say they operated, I don't mean to be too picky. Whether or not they operated, I can say in some cases/ not in others. Mr. Frankhouser operated under a code name. Some sources probably had no idea what codes were used in describing them within the staff. We described them by code names.
Q. And what was the point of your describing them by code names?

A. Weil, remember, the staff believed or had to act as though they believed that these persons in many cases were really heavy hitters in the intelligence community, and they had top-level secret contacts, all very, you know, hush-hush, and that it was necessary, you know, in order for us to protect their covers and be good sports about our role in the intelligence game not to bandy about their names and let people know who they were. So we described them by code names.
Q. So in other words, if the person's name was John Smith and, let's say, Mr. Steinberg called up John Smith and Mr. Smith agreed to talk to Mr. Steinberg, then for some reason or other because of this — or afterwards they would write down the substance of what John Smith had said, but they would use a completely different name?
A. Well, they might use — it would vary. I don't think this really can be described as a consistent practice. The organization, whatever virtues it may have, consistency is not one of them, and that pertains both to their political beliefs and also the way they do little things, like make entries — you know, like characterize their sources. So if there were a John Smith, he probably would start out being "John Smith." The
organization would deduce he was the most important intell.^6 operative since Kim Philby. He would cease to be "John Smith" and he would become "John" or he would become "JS" or he would become, you know, the ice man or whatever it might be that

seemed an apt characterization for this person. And then that would sort of become the staff way of describing him. That's, of course, a totally hypothetical example.
Q. Right.
A. That's the way it worked. Sometimes he might be "JS"; sometimes he might be "John"; sometimes he might be "Mr. Smith"; sometimes he might be "the ice man."
Q. Could you tell the members of the jury who some of these people were that Mr. Steinberg and others would get information from and what names were used for them?
A. Well, the example closest at hand, of course, is Mr. Frankhouser . .I'm glad to describe others, if you wish.
Q. If you would.
A. Would you like Mr. Frankhouser’s code names?
Q. I think you mentioned a name — well, yes, go ahead.
A. Well, there are a number of them. Again, this sort of became a matter of fashion, if you will. He was referred to as Frick and Frack, as I mentioned. Sometimes that would be written down as F and F. He was referred to or his source was referred to as — his purported source was referred to as down the way, sometimes abbreviated as DTW. He was referred to as Roy. Sometimes simply that was you know written down as R or RF or F. He was Mr. Clay, sometimes Clay.
Sometimes discussions with him would be set down as Green/Clay, referring to Dr. Green, who is Jeffrey Steinberg, or

Greenjeans. I have no idea what that means. If anybody knows, I'd be more than glad to find out. Greenjeans was another acronym sometimes used to describe conversations between Mr. Steinberg and Mr. Frankhouser .
Those are the major ones. There may be one or two others that I don't think of at the moment.
Q. Now, if you would go on to some of the others.
A. Well/ there is a gentleman named Dan Murdock. He was referred to usually as Dan any or DM or as The Major. That was the big one. I think beforehand he was The Captain. I'm not really sure about that. I think he got a promotion somewhere along the line either in real life or in the organization's mind. But those were some of his acronyms.
Q. And what role did he play?
A. He played a role which I'd have to characterize from the — you know, the staff's standpoint as being not unlike Mr. Frankhouser 's role. That is, he would be called and asked to provide information on, you know, various intelligence topics and he would give the organization this kind of information. He had apparently had some position in U.S. intelligence and bandied this about a great deal, sort of, you know, intimated that he was, in fact, something more than you might think, that he was, in fact, some kind of government agent, much the same impression that we had about Mr. Frankhouser . And therefore, his information was considered very much in the same way that we

considered Mr. Frankhouser 's information. And he, again, was somebody who had apparently in fact been some kind of government agent or intelligence agent at one point or another. He is another example.
There was a person named Mordechai Levy. Mordechai Levy is the head of a group which I believe is called the Jewish Defense Organization. And I'm not sure whether or not one is supposed to confuse that with the Jewish Defense League. I don't know. It's some kind of militant organization like the JDL, I guess. He was a source for some period of time. He was referred to as Levit, as Morty. Sometimes — well, he was also referred to as The Furry Creature, so sometimes he was set down in notebooks, I believe, as Furry.
Those are simply three examples. I'd be glad to name more if you want. I hope that that's instructive of the kind of way that —
Q. Just a particular couple of ones. Was there somebody called Juval, J-u-v-a-1?
A. "Juval,11 yes. I believe — I'm not absolutely certain that Juval refers to someone from a company called Interfor. I could be mistaken about that. He — I think the name — the full name I believe is Juval Aviv, A-v-i-v. He was yet another one of these persons who characterized himself or at least I was told that he characterized himself as an intelligence source having ties to Israeli intelligence, which made me immediately wonder

why he would want to have anything to do with this organization, But in any event, he did indeed have some dealings with Fir. Steinberg and others for some period of time. I really don't know what about. He was a pretty carefully-concealed secret even within the Security staff. But yes, he is another one of those persons. I believe he is usually set down as Juval. I don't recall offhand another acronym describing his pearls of wisdom, and I'm not even a hundred percent sure that that's who Juval is.
Q. Just one more.
A. Sure.
Q. Was there somebody called The Baron?
A. Yes, yes. The Baron is a gentleman named Ed Von Rothkirk, I believe that's R-o-t-h-k-i-r-k. Baron Von Rothkirk. Ke is apparently some sort of a baron. I don't know. I don't really care. But that's why he is referred to as The Baron. He is a freelance journalist, I guess is the most polite way to describe him, living in Washington, DC. He runs a news agency, the precise name of which escapes me. The organization sometimes uses his news agency as a cover in the manner I described before. In other words, he would accredit somebody with a press card to appear as though he was a real reporter working for real newspapers so that he could do interviews. Did I make that clear?
Q. Oh, I see. In other words, he has a press —

A. He has a press service of some sort. And he/ you know — he accredits reporters as stringers for his press service. And in the U.S. that doesn't do you any good because sooner or later people find out who it is. But in Europe, for example, people would say, I come from whatever the name of this news service is and this would be accepted by most people as reasonable. They would begin to talk then with the Labor Committee member acting as though he were a legitimate newspaper reporter for some regular publication.
So that's Mr. Von Rothkirk. And he represented himself as having all kinds of Government contacts. And I think he also had some kind of old OSS ties. That is the Office of Strategic Services, the predecessor of the CI
Q. Were any of these people other than Mr. Frankhouser — and you've testified about that — paid for their services, if that's the proper word?
A. You know, I'm not sure. I think Mr. Von Rothkirk may have been now and again, but I don't believe that any of the others that I mentioned received regular payment. In fact, I'm reasonably certain that none of the others that I mentioned received regular payment in the way that Mr« Prankhauser received it. They may have gotten an occasional commission or, you know, money to tide them over or money per assignment.
Mr. Murdock, I gather — but I say this on the basis of, you know, press reports and stuff, not on the basis of

personal knowledge — may have had some business dealings with the LaRouche organization at a subsequent period.
Q. Moving on to one of the other activities, I just want to cover the other topics that the Security staff was responsible
You mentioned the counterpunch activity, the household
— providing for Mr. Larouche's personal needs and
Mrs. LaRouche"s needs, and then the coping with internal dissent
within the organization.
A. Yes.
Q. All right. Incidentally, you mentioned — when these
people, these sources, would be talked to — well, let me ask
you this. Strike all that.
The Security staff operated in New York, you said, down the hall in its own little suite of rooms away from the moneyraisers and all those — the other people.
A. Well, they were in a separate bunch of offices, but all around them would be moneyraisers.
Q. Oh.
A. And again, during the period I guess that we1re most expressly discussing, the 1984 period, the Security staff did indeed do a certain amount of fundraising.
Q. I see. Now, did they discuss the information that they — or supposed information that they were being fed by various people? Did they bandy this about or did they discuss this with

the other people in the organization that were raising money?
A. Oh, no. These were the organization's equivalent of state secrets. I think that people occasionally told others, you know, as a sign of how important they were, but they were not supposed to talk about anything like these things with other people. And in fact, I was sort of shocked at one point in roughly 1982 that a member walked up to me and asked whether or not we still had any dealings with Roy Frankhouser . She v/as a member of the Latin American organization. They didn't like Roy Frankhouser for various reasons, and they were concerned about the idea that we might still have such dealings. And I, of course, said something noncommital, as I was supposed to, and changed the subject.
Q. The —
A. So they didn't know, is the point I'm trying to make.
Q. And did the Security staff in dealing with these sources think of themselves as a kind of mini-intelligence organization; in other words, something like the CIA?
A. Yes, precisely.
Q. Or a law enforcement agency that was getting information from people about various activities?
A. Well, at a certain point Mr. LaRouche put forward the conception that the organization had to build a sort of parallel CIA for the reason that when Admiral Stansfield Turner, who was director of the CIA under President Carter, took office, he

fired a very, very large number of CIA operatives. Mr. LaRouche took this as his cue to do the Government a service by offering the good offices of the Security staff to take the place of ail of these laid off CIA agents. So very expressly the Security staff was to function as an intelligence entity.
Q. So this was his, Mr. Larouche's, contribution or one of his contributions to the country was to provide a replacement for the CIA, so to speak, with his Security staff?
A. Yes, That was to be one of its functions.
Q. Right.
A. Replacement may not be the word. Supplement.
Q. Supplement?
A. Just so long as we understand, I'm not suggesting that he was advocating that the Security staff storm Langley and take over. I just mean that we were to aid and abet the CIA and other intelligence agencies which had taken a body blow from Stansfield Turner.
Q. By "Langley" you're referring to —
A. To the CIA headquarters in Langley, Virginia,
Q. So is it fair to say that, according to the — it was — the way the Security staff operated was to listen to the information that came in from the sources and to record that information?
A. I'm sorry. Excuse me?
Q. Well, I guess what I'm saying is they didn!t with one source start telling one source what another source was saying or give
out lots of information to other people?
A. Oh, I see what you're saying. Well, no, I think that would not be a correct characterization of the practice. Very commonly sources kind cf bid up against each other about how much they knew about a situation in the following way.
Somebody in the Security staff would call
Mr. Frankhouser and report what Mr. Levy had told them without saying it was from Mr. Levy. And Mr. Frankhouser , of course, in order not to be shown — to show that he was not caught napping, would have to augment this fantasy with, you know, yet more. If there were five assassins according to Mr. Levy's account, there had to be six according to Mr. Frankhouser's account. And this would go back to Mr. Levy, who would, you know, have a dozen. And so it would go. So the point is, yes, you did take i information that you received from one source and bounce it off of the other sources.
Q. But the purpose of all this activity was to accumulate — to give to Mr. LaRouche, that was —
A. Yes, absolutely. He was the intended recipient, the person for whose eyes and ears this information was received. You know, there were other people who might be considered important such as the CIA, they should find out, too, maybe. But Mr. LaRouche was the person for whom this was collected. And the information was to be used to whatever end and in whatever way he saw fit.

Q. Now, could you tell us just a little bit more about just the different members of the Security staff? Mr. Goldstein, had he gone to college? Do you know anything about his background?
A. Well, I gather that he went to — I don't know if it's the University of Indiana or Indiana University. I don't know if he received a degree or much about his studies there.
Q. And did you say that — yesterday you used the word foul language full of violence, something of that sort.
A. That's right.
Q. Is he always like that or can he be —
A. Well, gee, I thought I made that — that's a fair characterization very often of Mr. Goldstein. My recollection, I could be wrong, is I thought I said that about Mr. LaRouche. And correct me if I’m wrong, but if you're asking to be characterized — I'm sorry, I should let you do the asking.
Q. Well, is that the case with Mr. Goldstein, that his language is full of violence?
A. Well, very often Mr. Goldstein seems to have a great deal of difficulty restraining his temper and when he loses it, he becomes extremely intemperate in speech and not — he doesn't restrict his displays of anger to speech.
Q. Well, that's — then as far as Jeffrey — well, Michele Steinberg, did you say yesterday that she basically was the strongest believer or something in the organization or that she believed everything that Mr. LaRouche said, had no skepticism

about it?
A. Well, I'd say certainly that that's true; she had no skepticism about anything Mr. LaRouche said. I don't know if I would characterize her as necessarily as the absolutely strongest believer as though she was more of a believer/ let's say, than Helga Zepp-LaRouche or Mr. Spannaus or somebody else. But she would be certainly right up there at the very top rank of, you know, the deluded. I don't know if that's — but yes, she certainly believed everything.
Q, When you were asked about her handwriting yesterday, you said you recognized her handwriting because you had received some sort of communication from her at one point or seen a communication?
A. Well/ I said that was one of the reasons. Over a period of many years during which I worked with Michele and others, I had seen occasionally their notebooks for the purposes as I indicated, you know, for the purposes of looking at a briefing that they had received and I had not gotten that I was supposed to become cognizant of or to write up in a report in some way or a list of instructions or something of that sort. And I also received a little note at one point from Mrs. Steinberg and so from all these sources I was able to have some recollection of her handwriting style.
Q. And what was the note in question? A, Well, it was a — I wish I had it to read because it's very

difficult to characterize. It's a very — it was a very strange and insulting sort of little thing that she gave me during a period of time in which I think the Security staff was very — was correctly considering whether or not I was still in the
game,, whether I still believed in this whole thing. I mean, I'
be glad to describe it in more detail, but really it's actually
a fairly — it includes so many internal references to kind of
silly organizational details that it would take me a long time
to describe what it was about.
Q. Well, I'm not — you said it was unattractive — or if you
said it was unattractive, what did you mean by that?
A. Well, let me see. To begin with, it addressed me as
"Dr. Tit." I mean, I could go on from there.
Q. All right. I don't think you have to.
A. I think that characterizes Michele's — what she considered
to be an appropriate way to, you know, write a note to a
Q. Now, you say that nobody in the Security staff would have
expressed skepticism about Mr. LaRouche or anything that he
said/ expressed skepticism with each other?
A. Oh, no. Mo.
Q. But towards the end at least you were, in your own mind,
very skeptical about a lot of things about Mr. LaRouche —
A. Absolutely.
Q. — as you just described?

A. Absolutely.
Q. But you didn't go around making this fact known to the others on the Security staff?
A. No. On the contrary.
Q. Did all of you make these pretext calls, all of you on the Security staff, pretending that you were this, that and the other thing?
A. Yes, we did.
Q, And you yourself would pretend that you were a rabbi or —
A. Well, no. I wasn't — I didn't pretend that I was a rabbi. I did on one occasion represent myself as a minister.
Q. All right. But usually you said you were a newspaper reporter, is that —
A. Well, newspaper reporter was actually not considered a very good cover, but that was another one that was sometimes used, that's correct.
Q. Now, yesterday you said that Mr. Frankhouser until sometime in 1983 was a prime source of information. Was there some change in 1983 or did somebody else come into the picture or did I mishear you?
A. I'm sure that I didn't say that he ceased to be a prime source in 1983 or I certainly didn't mean to imply that. In 1983, additional — more figures came into play. I think that the individual Danny Murdock who I mentioned before — I don't remember precisely when he surfaced, but in 1983 his star was

5-64 riding high with the Security staff as a source.
Also, in 1983 the organization began to have — actually, it began earlier. Let's say in 1982 or so the organization began to have a series of meetings with bona fide actual real intelligence operatives whose, you know, identities are probably known and whose role in the intelligence agencies is well known. So I think that, you know, it may be true to say that in 1983 there were more players in the game. But Mr. Frankhouser continued to be a valued and important source for the organization in its mind as long as I was around.
Q. Now, could you describe these meetings in some detail with these actual important Government officials?
A. Well, I have difficulty in describing them first hand because I wasn't present in the meetings. In one or two occasions I was part of the entourage which accompanied Mr. LaRouche in meeting with these various people, so I know who they were. I received phone calls in some cases from them.
Q. Why don't you describe —
A. I had interaction with them.
Q. To that extent why don't you describe who they were, when these meetings took place, where they took place.
A. Okay. At least one but I believe two meetings took place with Admiral Robert Inman. Robert Inman is the former deputy director of the Central Intelligence Agency. Before that he was director of the National Security Agency, which chiefly handles

electronic wiretapping and stuff like that, electronic surveillance, satellites, computers, all that kind of stuff.
Inman met with Mr, LaRouche on one occasion in Washington, DC, in a little house on F Street or I guess I should be very, very explicit and say that I was told that that's why we were going there and he was who we were going to meet with.
On another occasion I believe Mr. Inman met with Mr. LaRouche in his house in Sutton Place. I wasn't there. I can't vouch for it. That's what I was told was happening. And I received on two occasions in the national office in my capacity as Officer of the Day as I described phone calls for Jeffrey Steinberg from Admiral Inman.
Q. Now, Admiral Inman, was he second in command at the CIA?
A. That's correct. During this period — well, during the period of the first meeting he was still second in command of the CI
A. During the time of the second meeting if it indeed took place and the time of the telephone calls which I know for certain took place because I received them, he was a private citizen working for, I believe, a Texas computer company or I think he actually owns the company.
Q. So that's during the Sutton Place visit he was a private citizen, if it — or during the time —
A. I believe so. Yes, I believe so.
Q. The F Street meeting in Washington was when he was the

deputy — Admiral Inman was the deputy director of the CIA?
A. At that time he was the deputy director. And my understanding was the facility — well, the facility which we were meeting was very obviously an official Government facility. You were challenged when you showed up. Official Government cars were there. People were getting in and, you know, going off and stuff like that. So it was an official — the meeting took place at an official Government facility while I knew just from general knowledge that — and, of course, we were watching the intelligence community very closely. It was a big preoccupation that Admiral Inman was the No. 2 man and, in fact, was being bandied about as the future director.
Q. And who else besides Mr. LaRouche from the LaRouche organization met at F Street with Admiral Inman?
A. I don't recall if anyone else accompanied him. I'm sure someone else was in the meeting with him. I don't recall who that was and I don't recall if anybody else accompanied him in any capacity other than as a security adjunct. Q. Other than Mr. Inraan, were there meetings by Mr. LaRouche with high Government officials?
A. Yes, a number of them.
Q. And who were those officials?
A. Well, there was a meeting described to me when I was on duty with the organization as a member of the Security staff with the — with John HcMann, who I believe was subsequently the director

of the CIA in Langley, Virginia at the CIA headquarters in Langley. I'm not sure if that meeting was actually with HcMann
1 or with an assistant to him. I was told that it was with McMann. Subsequent accounts I've heard it described as a meeting with an assistant.
Another Government official of some rank who met with Mr. LaRouche is the former National Security Council director for long-range planning, I believe was his title. His name was Norman Bailey. He is now a consultant, not any longer in the U.S. Government.
There were others. There was a man named Pollock from the National Security Council. I don't recall if Mr. Pollock met expressly with Mr. LaRouche or only with, you know, with his underlings. But that was another person who met on a high level in the U.S. Government with Mr. LaRouche. There were others, but those are some of the most conspicuous who come to mind.
Q. Now, when you're talking about Mr. Pollock, that's the National Security Council?
A. Council, that's right.
Q. That was headed by Mr. MacFarlane at one point and
Admiral Poindexter?
A. Yes, that's right, the people — well, I won't characterize
what they did.
Q. Now, you said that yesterday that during 1983 or 1984 one of
your primary activities for the LaRouche organization was to be

involved in the so-called HBC case or litigation.
A. Yes, that's correct.
Q. Is that correct?
A. That's correct.
Q. V7hen did you start working on that case and how long did you work on it?
A. I don't remember precisely when it started. Somewhere in 1983. I'll take a stab at it. I'll say June of 1983, but I'm not certain — NBC began to or a particular reporter from NBC began to call the national office and request an interview with Mr. LaRouche and, you know, make very clear that she was putting together a show on the LaRouche organization. And immediately thereafter the Security staff was notified that a slander was being prepared by NBC. There was never any doubts in anybody's mind the content of the show, of its being favorable or unfavorable to Mr. LaRouche. That was a given. And therefore, at that point the Security staff began to collect the information which would be necessary to counterpunch against this, you know, new threat to Mr. Larouche's reputation and well-being,
Q. So when you say you were involved in the NBC case, were you involved in the counterpunching activities arising from this reporter's investigation or were you involved in an actual lawsuit?
A. Well/ I had — for some reason I drew the short straw on

this one and I was involved on pretty much every aspect of the NBC case from the preparing of background information on the reporters to discussion with legal counsel about possible strategy and, you know, information and tactics, things of that nature, to preparing the subpoenas for service of witnesses to getting witnesses served. The people that we were going to draw into the case had to be served with subpoenas, and I would try to locate them, get the subpoenas drawn up, get somebody to go serve subpoenas on them. There was, you know — I delivered the paper to the attorneys1 offices. Pretty much I functioned in every possible capacity from, you know, investigator to what would be kind of like a paralegal capacity, I guess, in the course of this charade.
Q. Now, the name of the reporter at NBC?
A. Was Pat Lynch, Patricia lynch.
Q. Tell us what the litigation was about. Did somebody sue somebody else?
A. Mr. LaRouche after careful consideration himself sued NBC for libel.
Q. And what were the — what were the allegations of libel? In other words, libel, he said that NBC had said something bad about him?
A. That's correct.
Q. And therefore, they owed him some money to make up for this slander or libel?

A. That's correct.
Q. All right. And what was it as you understood working for this that the libelous statement was?
A. Well, you know, you ask the question in such a way that you make me kind of ratify the idea that they were libelous statements. I know you didn't mean to do that. I can teil you what was described in the suit as libelous statements. At the time I could vaguely see a problem technically with one or two of the things that they said, but I didn't — I mean, nothing that they said was libelous in any sense of the term that I understand either legally or in casual use.
However, what was upsetting to Mr. LaRouche was that NBC had allowed a number of former members to appear on the television with their identities disguised describing various organizational practices. One young woman described the organisation's practice of telling its members — its women members to get abortions because having children would be deleterious to their political work and would take their time away from their ability to do nice things/ like raise money. At the time that this broadcast was aired, the organization, which was now trying to court the right wing, was portraying itself as a pro-life organization, and this was embarrassing, to say the very least. So that disturbed the organization. And that was one of the counts.
Another thing which was disturbing to the organization

was that Mr. LaRouche in West Germany was said to have beenf as he sometimes does, ranting and raving about the need to see to it that the organization had the capability of killing Jimmy Carter if anything happened to Lyndon LaRouche. I subsequently discovered or it was told to me by other persons working on that case that Lyn in fact had said such a thing and, of course, he didn't really mean or at least I'm saying my impression is he didn't really mean the organization should kill Jimmy Carter. But as I said, in previous statements he liked to use violent language. He liked to say, Let's get that one; we're going to destroy this one; or we're going to hang that one by the sour apple trial, whatever.
So I discovered subsequently that he had made such a statement. That was what was being characterized. And I discovered this in the context that we were trying to determine whether or not a former member had been present when he said it. So that was another one that they were very angry about, that NBC reported that Mr. LaRouche had made these kind of suggestions that Jimmy Carter should be, you know, gotten rid of. They didn't like that very much for the obvious reason. I ceased to regard that as libelous as soon as I heard about the fact that it was actually taking place and that, moreover, it was a big problem for us whether or not the — whether or not a certain person no longer in the organization was there and had heard it.

There were other characterizations, characterizations , about involvement with criminal underworld, which characterizations I knew were true. Everybody in the organization of any significance in any, you know, length of membership knew they were true; allegations about the organization's having uttered anti-Semitic statements, which I knew were true.
Well, right along down the line these were the kinds of characterizations which the organization objected to, and I would object to them, too, except for one thing. -
Q. Well —
A. They were true.
MR. WALKER: Your Honor —
A. I'm sorry. You asked for the allegations. And I have to — I want to state them not as though they were true •—
Q. I understand.
A. — but as they ought to be characterized, not as though the organization's belief that they were libelous was true but how they ought to be characterized.
THE COURT: Mr. Walker, we'll need a recess sometime soon. Is this an appropriate place?
MR. WALKER: I think this might be a good time.
THE COURT: All right. Members of the jury, we'll take a 20-minute recess. You may go to the jury room.
(Morning recess at 11:30 a.m.)

(Court reconvened at 11:56 a.m.)
THE COURT: Did you want to confer about any of the other matters before we bring back the jucy?
MR. MARKKAM: Your Honor, I just don't believe that a stipulation is appropriate because of the various issues that will have to be stipulated to.
THE COURT: All right. You may be seated.
Mr. Walker, how much longer do you expect to be on your examination of this witness?
MR. WALKER: Fifteen minutes, your Honor, fifteen or twenty minutes,
THE COURT: All right. How much time do you expect on
MR. MARKHAM: Five minutes.
THE COURT: All right. I think we better face the other matter, then. I take it —
MR. MARKHAM: We have the witnesses here,
THE COURT: All right.
MR. MARKHAM: I have one other witness that will come on before those anticipated witnesses, but I anticipate my direct of him to be no more than three or four minutes. And that sets up Mr. Rasch's examination of the credit card victims involved,
THE COURT: All right. Now —
MR. WALKER: Could I find out who that is, your Honor,

just —
MR. HARKKAM: Yes. Merrill Worthen and Paul Corkery,
both named in the indictment.
MR. WALKER: Well, your Honor, just as a matter of procedure, I mean, I know Mr. Markham has been helpful. I just
— I never heard of Paul Corkery before, I don't think, and I
thought he was going to tell me the witnesses — are those the
— excuse me, your Honor. May I ask Mr. Markham —
THE COURT: Yes, you may.
MR. WALKER; Are those the victims or —
MR. WALKER: Ohr I'm sorry. I'm sorry. I thought this was somebody else you were talking about.
THE COURT: All right. Well, Mr. Walker, unless you have some proposal for a stipulation that you are willing to make that would change this issue as I have indicated to you, I think I have to overrule the objection and allow these witnesses to testify.
MR. WALKER: Well, frankly, your Honor, I really don't know what they'll say. I gather they're going to say that they didn't agree to have money charged to their account or something like that, and I would be prepared to stipulate to that fact.
MR. HARKHAM: The anticipated testimony is, your Honor, that they were approached by LaRouche organizers in Boston, that money was solicited from them, in essence they gave a small

contribution or one contribution and at a later time they received a bill for a much larger contribution. They will be shown the credit card slips which represent those larger contributions as to which there is a stipulation that the slips were deposited into TLC's account or IDL's account. And they will be asked if they authorized those items/ and they will say, it is anticipated, that they never did and, in fact, that they had told the group they didn't want to contribute in one case.
That's important for several reasons, not the least of which is to establish the motive of certain people who we have alleged are coconspirators of Mr. Frankhouser to, in fact, leave the jurisdiction. The credit card slips involved, which we will show these people and which they will say are fraudulent, although they won't characterize it that way but I will argue it chat way; they will just say they're unauthorized — the credit card slips have the initials of the coconspirators on them, MG, RS or CP, depending on who the perpetrator was. And after these fraudulent slips were filled out, Frankhouser , it will be shown, said, Get these people out of the country, and these people left. This will show that they had a motivation for taking his advice. That's the Government's theory, and I think it's relevant for that theory.
MR. WALKER: Your Honor, of course it's relevant if Frankhouser said. Get these people out of the country. That's what this case is about. The case is not about, I would

suggest, primarily — and I'm prepared to stipulate to what Mr. Markham said. I assume — I mean, I —
MR. WALKER: I don't see the point of putting these people through the — through this exercise. I know Mr. — a lot of yesterday's — I don't mean to make a sort of a — I mean, this shouldn't be practice for the main trial, see how everything's going to go, because I'm confident the main trial is going to be rather different.
MR. WALKER: And I just — indeed, I think it's
probably a little — I'm not going to ask these people very many questions.
THE COURT: I don't want to be taking time to work out the terms of a stipulation. Are you saying that, for example, that you would be willing to have read to the jury as a stipulation the statement that Mr. Markham has just made as to what he expected — well, he has included some things in there about his argument — but the statement of the expected testimony of the witness?
MR. WALKER: I have forgotten -- I'm willing to do that, your Honor. I don't know how the Court phrased the question. I think the answer is yes, I am willing to.
THE COURTS Mr. Markham, if he is willing to stipulate to everything that you would get from the witness, why shouldn't

I accept the stipulation instead of having you call the witnesses?
MR. MARKHAM: Because he is not going to do that when he wants to call a witness and get something from the life blood of a witness. A stipulation goes by fast. A stipulation doesn't make all the same points. A stipulation isn't going co embody ail of the testimony they had about who called them or how they identified themselves. And I don't see why the Government should have to have its evidence, which is highly relevant, reduced to the insipid form of a stipulation.
Mr. Walker in his opening statement in essence said that Mr. Frankhouser is a joke and he wasn't taken seriously and that this wasn't a serious matter, and the Government has to prove that this is a serious matter. And I respectfully submit that the Government should not have to be reduced to insipid forms of proof when the evidence is relevant. There's nothing highly prejudicial about this. I said in my opening statement Mr. Frankhouser was —
THE COURT: Well, now, I don't agree that a stipulation is an insipid form of proof. On the other hand, Mr. Walker, I think there is a point that there are details that would be given in the testimony of the witness that it's difficult to reproduce in a stipulation and which have a bearing on the cogency and weight of the evidence, given the fact that the Government has the burden of proof beyond reasonable doubt. And

especially when the proposal comes at a time when it would delay the trial for me to wait to see if a full stipulation can be worked out, I am not inclined to allow it. So I will overrule the objection,
MR. WALKER: Your Honor, could I ask the Court to give an instruction after these witnesses testify if indeed it's necessary — after they testify to remind the jury that Kr. Frankhouser is not charged and never has been charged or is not charged — is not charged —
THE COURT: No. I don't think that's appropriate. I will, of course, give appropriate instructions in relation to that question in my charge to the jury. I don't think I should be commenting on the evidence as it goes along. I will not do that.
MR. WALKER: All right.
THE COURT: All right. The jury may be brought in.
(The jury returned to the courtroom at 12:04 p.m.)
THE COURT: You may be seated.
You may proceed, Mr. Walker.
MR. WALKER: Thank you, your Honor.
Q. Mr. Tate, I think you said first met Frankhouser back in the 70s in Reading, Pennsylvania, and he indicated he was interested in working for this organization.
A. Yes, that's correct.

Q. All right. Did he mention anything to you about having worked as a detective?
A. At that time, no, not to my recollection.
Q. Did he later mention anything like that to you?
A. Well, I wouldn't characterize it as detective. He indicated at a later point that he had been involved in various kind of investigations. "Detective" I think implies police investigations.
Q. Well, maybe the word is private detective — I didn't mean governmental, working for the Government as a detective.
A. Oh, I see. Was he working as an independent — did it appear to me that he was working in an independent capacity as a private investigator? I don't mean to rephrase it — Q, Yes, exactly. Thank you.
A. No, he never said anything like that to me at least.
Q. You referred at one point to the fact this morning that Mr. Frankhouser and perhaps yesterday was referred to — one of his code names was Frick and Frack?
A. Well, that referred both to Mr. Frankhouser and his former associate, Mr. Lee Fick. The two as sort of a — the two together were Frick and Frack, that's correct.
Q. And so is it fair to say that for a period of time starting in about 1982 Mr. Fick started working in Reading/ Pennsylvania for the organization in the same capacity or somewhat the same capacity as Mr. Frankhouser together with Mr. Frankhouser ?

A. Yes. In conjunction with Mr. Frankhouser , yes.
Q. And on many occasions Mr. Fick would call up and provide or be called and provide information, is that correct?
A. Well, I don't think chat would be quite correct as to many occasions. He would be really the fall-back option. If an attempt were made to contact Lee Fick, the basic purpose of the message would generally be, Get Roy to call. There might be some exchanges/ but for the most part Lee Fick was regarded as kind of a sidekick of Mr. Frankhouser , as his assistant/ at least in the early period rather than as someone operating on quite his same level of competence. There was some — we were given to understand that he had had the same organizational affiliation in terms of intelligence agency ties as Mr. Frankhouser, but clearly he was regarded as the junior partner.
Q. All right. And I think you just said now at least in the beginning he was subordinate or worked under Mr. Frankhouser . Did he assume an increasing — this is Mr. Fick. Did he assume an increasing role as time went on while you were with the organization?
A. Well, he — once people got to know him and so forth/ I think that might be a fair characterization. But he was still always regarded really as the assistant to Mr. Frankhouser . He could be separated from him and, you know, instructed to do something separately, but he was never on the same level in the

Security staff's estimation as Mr. Frankhouser .
Q. And that was — you're talking about the time you worked foe the organization, which was up until —
A. Yes.
Q. — August 17, 1984?
A. That's correct, yes.
Q. And was Mr. Fick down there, as well, on these security patrols?
A. Oh, yes.
Q. When I say "down there," I mean in Virginia.
A. Yes.
Q. All right.
A. He was.
Q. You say you were responsible for sending payments to Mr. Frankhouser at least for a period of time.
A. Yes, that's correct.
Q. And did you also send payments to Mr. Fick?
A. Yes, I did.
Q. Were any of those payments paid — each time did you send independent payments to each one, or were they ever combined in some way or do you recall the details?
A. Usually both payments were put into one envelope. Each postal money order was separately made out, one to Lee Fick, one to Roy Frankhouser , but they were sent in the same envelope to Roy Frankhouser .

Q. Now, was there a — I think you said in 1984 at least the figure increased to $500 a week, that was the payment to Mr. Frankhouser . When in 1984 did it increase, if you recall?
A. I'm not certain, and in point of fact it may have increased earlier. I'd have to say that by 1984 there had been an increase, and the final figure of which I was aware, the highest amount of money which I ever sent was $500.
Q. And did you ever send lower figures at an earlier time?
A. I recall that there was a lower figure. I think I said this in previous testimony. I don't remembec precisely what it was. At some definite point there was a raise.
Q. And do you remember if Mr. Fick got a raise, too?
A. I don't recall if he similarly got a raise, no, I don't recall.
Q. But Mr. Fick also purported like Mr. Frankhouser to have these connections with the CIA or the Government or down the way or what have you?
A. That's a question — you're asking if he made such representations?
Q. Yes.
A. Well, as I said, it's as far as I can go, I was told that he made such representations.
Q. He didn't talk to you about that himself?
A. Ho, he did not. He did associate himself in discussions which Mr. Frankhouser was motivating in which he would use such

terms of art as "our organization," "our associates11 and so forth, and Mr. Fick was on hand nodding away and deferring to Mr. Frankhouser in his description of the intelligence items purportedly gleaned from these terms of art which we all understood to mean the CIA and/or other intelligence agencies.
Q, When you say — it sounds like — were you in a room together with Mr. Frankhouser and Mr. Fick on some occasions?
A. Sure. On a number of occasions, sure.
Q. When this type of talk about —
A. Sure,
Q. — these sources —
A. Yes.
Q. — was engaged in?
MR, WALKER: Excuse me just a second, your Honor.
THE COURT: Surely.
Q. Now, with respect to those notebooks, I guess they aren't right here this morning, but you say that the various members of the Security staff — and that included you sometimes, as well — when you had these conversations with sources would write down while the source was speaking and write down as accurately as possible what they were saying, is that correct?
A, Well, yes, when they were acting in their capacity as sources conveying intelligence. If we were standing around in a

hotel lobby shooting the breeze, then, of course, we wouldn't whip out our notebooks and write down Mr. Frankhouser 's report about his — well, whatever it might be. But just when we were receiving intelligence reports per se, then, of course, we made note of them.
Q. When the Security staff had conversations with individuals, was it just one member of the Security staff having a conversation with the individual such as Mr. Frankhouser or any of these other people that you have mentioned, or would there be more than one listening at the same time?
A. Well, most commonly — since most often, as I indicated previously, the conversations were by telephone, most commonly there would be only one person; but now and again an extension or conference line was picked up by somebody else. But still, under those circumstances we're talking about a report being received by one oc two members of the Steering Committee, so most typically it would be one person if it was a telephone report.
Q. All right. Wow, once one member of the Security staff got some information, would they ever convey that to another member of the Security staff who would then write down what they — the same information in their notebooks?
A. Yes.
Q. I see. So in other words, let's say Mr. Frankhouser called up and said, The KGB is — I've just received word the KGB has

an agent in the country and has been seen near whatever that farm — Woodburn Farm.
A. Right.
Q. So let's — Jeffrey Steinberg night write that down in his notebook. Is that a possibility?
A. Yes.
Q. If he was the one that got the call?
A. That's certainly correct, yes.
Q, And he would hang up and say, Gosh, Roy reports that there's a KGB agent in the vicinity. And maybe Mr. Greenberg or Michele Steinberg or Mr. Goldstein in their notebook would write down something to the same effect?
A. That's correct.
Q. So it may be the case that — so if there is a conversation recorded in a — what appears to be a conversation recorded in a notebook, it may very well be recorded second hand.
In other words, if Greenberg has "Roy," or "Clay" or something, "Assassination possible. Agent seen," he may not have heard that from Roy at all?
A. Directly. Yes, that's certainly possible.
Q. Now, you said yesterday that Mr. Spannaus — incidentally/ is Mr. Spannaus in court today?
A. Yes, he is.
Q0 All right. Can you just point him out just so the members of the jury —

A. Well, Mr. Spannaus is the gentleman sitting with his hand on his lips, with glasses, in the front row of the audience section.
Q. Who is smiling at the moment?
A. He is the gentleman who is smiling, yes, sir.
Q. Now, —
A. Why he is smiling is a mystery to me, but perhaps he knows and —
MR. WALKER: Your Honor, I move to strike that statement.
THE WITNESS: I'm sorry.- Excuse me.
THE COURT: All right. It's stricken
Q. I think you said that Mr. Spannaus had a function that was different from the Security staff?
A. That's correct.
Q. And his function was what, again?
A. His functions were, first of all, to serve on the National Executive Committee. Secondly, he was the person responsible for the organization's legal activities. Thirdly, I mentioned, I think, that he was a person who had a great deal of responsibility for the move from New York City to Leesburg, Virginia.
Q. And I think you said that his notebook fell into a different category from the other notebooks that you were asked about.

Could you explain that?
A. Well, the notebooks that the Security staff maintained were notebooks of source reports chiefly that came in to the Security staff.
Now, Mr. Spannaus at least to my knowledge was not dealing to that extent with sources. His functions were internal organizational, administrative and legal. And therefore, his responsibilities would be to keep abreast of source reports that would have a legal significance/ would reflect on ongoing legal cases, would, you know, lend some insight as to where investigations of the organization might be taking place and so forth. So in that sense there was a distinction in their function.
I think that certainly one of his major functions was to brief Mr. LaRouche on the areas that I described. And therefore, he would use, as I also described, his notebook as a source of information for such briefings. But he was somewhat less in the position of taking in source reports from informants and consultants.
Q. Incidentally/ would these notebooks also be used from time to time by the people that kept them occasionally just to write down their thoughts/ ideas about various things?
A. Well, I can't say that they never did it. I certainly — for example, my notebooks/ which had a somewhat different function, also included research materials and so forth which I

accumulated. Perhaps some other people, you know, made similar kinds of entries.
But for the most part the function of the report was — of the notebook was to keep a report of meetings and minutes of the Security staff and the source reports that were discussed and perhaps evaluated at those meetings. So that was their major purpose. They could have been used for something else now and again.
MR. WALKER: Hay I just speak to Mr. Markham for a second?
THE COURT: Yes, you may.
(Counsel conferring)
Q. Mr. Spannaus, where was his office?
A. Mr. Spannaus — in the West 58th Street facility in New York City?
Q. Right.
A. His office was at the other end of the hall from the Security office. Q, I see.
A. Without a floor diagram, it's kind of hard maybe to explain exactly where the two were in relation to each other.
Q. Now, with respect to your own notebook, I just want to — this was the one that you identified yesterday. I think it's Exhibit 75 for identification. You would record in here on the

times when you functioned as a member of the Security staff the same kind of thing that came — that the other members of the Security staff recorded on a more regular basis?
MR. MARKHAM: Excuse me. Is he asking whether Mr. Tate did it on a more regular basis or the others did it on a more regular basis?
THE COURT: You may clarify the question.
Q. You occasionally acted as a member of the Security staff in collecting information from these sources, did you not?
A. Well, it was not my usual function to deal directly with sources, consultants and contacts. I did from time to time. But important contacts or contacts deemed important such as Mr. Frankhouser would tend to make their reports directly to a member of the Steering Committee rather than to, you know, me, I was just a member of the staff. Now and again I'd be asked to contact a source on behalf of the organization for some specific
purpose in which I was working. And an example might be I was working on the NBC case, I'm sure I was asked — I don't have an instance in mind, but I'm sure I was asked to contact such a source. not Mr. Frankhouser as it happens but such a source to get information, you know, on the NBC case. But I would be the person who would be taking the main intelligence reports from somebody like Mr. Frankhouser on a daily basis.

Q. Well, do you remember one time, for example, when Mr. Frankhouser told you that Mr. Larouche's prestige was higher than ever on the subject of the economy?
A. Well, I don't remember the specific occasion. You've got what I guess is a xerox of my notebook. I'm sure if I looked at it I could tell you if it was my entry.
Q. Would it help you refresh your recollection if you saw this?
A. Sure. But even without seeing it, I'm sure he said things like that on many occasions.
(Witness examining item)
A. Yes. It says, "LaRouche prestige highest ever on economy and terrorism."
Q. It has the name Roy in front of it?
A. It has the name Roy and, yes, that's my entry and that's clearly what he was reported as having said.
Q. Did your notebook occasionally record Mr. Larouche's thoughts about assassinations and things of that sort?
A. Yes.
Q. All right. Well, just if this helps refresh your recollection (indicating).
A. Yes. "LHL —"
Q. I don't think you should read it.
A. I'm sorry. I thought that's what you were asking me.
Q. And just one other question on your notebook, or maybe two other questions.

Who was Mr. Blue?
A. I don't think I ever found out who Mr. Blue was. I donft
Q. All right. Do you remember Mr. Frankhouser at any point
ever telling you that organized crime, the Jewish Defense
League, the Israeli Mafia and Klarsfeld were apparently honing
in on Mr. LaRouche?
A. Yes. We received such communications from Mr. Frankhouser
very frequently.
Q. All right.
Q. Who is that?
A. He is a very well known Nazi hunter. Serge Klarsfeld.
A. He was the person who got Klaus Barbie and so forth.
Q, Now, on the subject of whether people would record their
thoughts and things other than information gotten from sources
in their notebooks, I just show you one of the notebooks, it's
Government Exhibit 45 for identification, one of the notebooks
you identified yesterday and ask you again just to tell us whose
handwriting that is.
(Witness examining document)
Q. Does it appear to be Michele Steinberg's handwriting?
A. It appears to be Michele Steinberg's handwriting.
Q. And if you turn for a second to page 119, 120.
MR. MARKHAM: Your Honor, may the document be received into evidence before the witness publishes any of its portions?

MR. WALKER: I'm not asking that it be admitted into evidence, your Honor. I'm showing it to Mr, Tate to refresh his memory about the kinds of things —
THE COURT: Well, put your question and I will find out whether there's objection to it.
Q. Does looking at that remind you or help refresh your memory as to whether the notebooks were used occasionally or on some occasions to record people's ideas and thoughts and —
A. Oh, yes. Yes.
MR. MARKHAH» Objection, your Honor.
THE COURT: Well, wait a minute, ,
MR. MARKHAM: I think the notebook should be admitted in evidence at this time.
THE COURT: No. Hot at this time. You may not interrupt the cross-examination for that purpose. When you want to offer it, I'll consider the offer, but not now.
You may proceed.
A. My answer was yes.
Q. All right. And once — you closed the — if you want to look at the notebook.
Did Ms. Steinberg from tine to time write things — well —
A. If you're asking me about this as an example if I had it

open —
THE COURT: Wait a minute.
THE WITNESS: Excuse me.
THE COURT: State your question.
Q. Did she write stuff about music, mathematics, literature, things of that sort —
A. Yes.
Q, — in her notebooks from time to time?
A. Sure. Well, I see —
THE COURT: Wait, Wait.
MR. WALKER: No, no.
THE WITNESS: I'm sorry.
THE COURT: Next question.
Q. Did the organization have some thoughts about mathematics?
A. Yes.
Q. And what was that? What kinds of things were talked about, about mathematics in the organization?
A. Well, various things at various times. About around the time when I left the organization, it had hit upon the idea of the Golden Section as having some crucial relationship to the structure of the universe. This is a characteristic idea that shows up in Renaissance and other sorts of writers, and the organization sort of hit upon it as its new discovery at that

time. So that was one of the organization's minor preoccupations.
Q. Did Mr. LaRouche think of himself as some kind of mathematician?
A. Well, Mr. LaRouche thought of himself as a universal genius; and since mathematics is a subject about which universal geniuses think, he thought himself a mathematician.
Q. Did he have any training in mathematics besides high school algebra?
A. Well, he didn't even finish his first term in college, so my guess would have to be no.
Q. But it didn't stop him from speaking about this subject at some length?
A, Nothing stopped him from speaking about almost any subject, no.
Q. And did the organization have ideas and feelings about music? Was that of special concern to them?
A. Yes, it did.
Q. And could you explain that? What kinds of music and what sorts of ideas?
A. Well, the organization valued classical music, or at least represented itself as doing so, and it wanted to associate its ideas and activities in some way with the practices and ideas and ideals of some of the greatest classical musicians.
Q. And in what way did it in its behavior follow the ideas of

some of the greatest classical musicians?
A. Well, I don't agree that the organization did that.
Q. Well —
A, But — so — I'm sorry, I'm not trying to be difficult.
Q. In what way did it claim to be doing that?
A. Well, it claimed to be — to understand the inner workings
of the mind of Beethoven or Bach and that it and it alone knew
the significance of Beethoven and Bach, that it and it alone
understood how Beethoven and Bach could be interpreted.
Unfortunately, they didn't have any people who really were good
enough musicians to do it; but if they did have such people,
that they would be the people who would really be doing the
right interpretations, that kind of thing.
They wanted to seize upon, you know, monuments of human achievement and somehow make them their own, as part of Mr. Larouche's sense that he was a universal genius. And so they would sort of like say, "Beethoven, that's us; Georg Kantor, a great mathematician, that's us; da Vinci, that's us," et cetera. So they had those kinds of thoughts about these marvelous people.
Q. And Mr. LaRouche thought of himself, did he not, as a very cultured figure, a Renaissance man, if that's the proper term?
A. Yes.
Q. Now, when you were working on the NBC case in which Mr. LaRouche sued NBC for libel, did you have occasion to read

any depositions that members — attend or read any of the depositions that members of the organization made?
A. I read a number of the depositions. I don't recall — I did not attend any of the depositions of members of the organisation.
Q. Now, a deposition, just — is a — is a — MR. MARKHAM: If —
MR. WALKER: I'm having trouble articulating the
MR. MARKHAM: I'd be happy, if I may, to offer a
Q. Well, a deposition —
MR. WALKER: Excuse me.
THE COURT: Go ahead.
Q. A deposition is usually a proceeding in a lawyer's office in so-called civil — when one person sues another or one company sues another where statements can be taken and recorded by a Court Reporter from possible witnesses in the case/ is that not correct?
A. That's my understanding.
Q. All right. Now, did you read Mr. Jeffrey — did Mr. Jeffrey Steinberg give a deposition in that case that you read?
A. Yes, he did.
Q. And were there statements in Mr. Steinberg's deposition which were false?

A. There was one that I recall. I have not reviewed his deposition. In fact, I never reviewed his deposition. I read it at that time and I base ray — my understanding of it on that one reading/ that one reading of it, yes.
Q. And so in your opinion or from what you know there were false — there was at least one false statement by Jeff Steinberg?
A. There was at least one false statement that I recall, yes.
Q. Okay. Now —
MR. WALKER: Strike the "okay," your Honor. Excuse me.
Q. Did you ever talk to members of the organization, including Mr. LaRouche, about a situation which had occurred in which there was a confrontation between a member or members of the organization and Dr. Henry Kissinger and his wife?
A. There are a number of such confrontations I recall, yes.
Q. Okay. Were you by any chance at a gathering at a high school in New York where Mr. LaRouche spoke to his followers at one point and discussed — possibly discussed this matter?
A. I was present for many conferences and other meetings of the organization in which Mr. LaRouche discussed various things. And when you say "this matter," I presume you mean the confrontation with Henry Kissinger. And I just don't know if I was there in the room when he talked about that at that time. I've heard him say things about it, but I don't know if I was there at that time.

Q. All right. What did Mr. LaRouche say about any incident involving members of his organization and Henry Kissinger?
A. Well, he applauded — well the — he was very happy to see that members were lashing out at Henry Kissinger, demonstrating hostility to Henry Kissinger and accusing Henry Kissinger in particular of being a child molester.
Q. And did he refer to a particular incident which may have happened at an airport somewhere?
A. Yes, he did, or I have heard him make that reference. Again, you mentioned this particular speech, and I?m not sure I was in the room at that time.
Q. Wellf what was the situation at the airport that Mr. LaRouche later spoke about and congratulated,somebody for?
A. A member of the organization — a former member of the organization — approached Mr. Kissinger, who was traveling at that time with his wife, Nancy Kissinger, and asked Mr. Kissinger if he was still sleeping with little boys at the Carlisle Hotel.
Q. And what did you hear that Mrs. Kissinger did as a result of that?
A. Well, according to news reports as well as what I heard/ Mrs. Kissinger turned around and hit her.
Q. Hit who?
A. Hit the member of the organization who had made this — who had asked this — who had made this remark.

Q. And what was the name of the member of the organization?
A. Her name was Ellie Fisch, F-i-s-c-h.
Q. And then did you hear that Ms. Fisch did something as a result of being hit by Mrs. Kissinger?
A. Yes.
Q. What
A. She did do something.
Q. What was that?
A. That was that she sued Mrs. Kissinger for assault,
Q. Or she attempted to have a — is it fair to say —
A, I'm sorry. That's correct. She attempted to have charges pressed against Mrs. Kissinger for assault. You don't sue for assault, I guess.
Q. And you heard Mr. LaRouche saying congratulatory things about Ms. Fisch's behavior?
A. Oh, absolutely, yes.
Q. You mentioned a fellow called Mordechai Levy, and he was one of these people that fed real or supposed information to the Security staff?
A. Hra-hm.
Q. Did you ever have discussions with Mr. LaRouche about any — about Mr. Levy's role in the NBC case as a witness or a possible witness?
A. Oh, I didn't have — I don't recall that I had any discussions with Mr. LaRouche on that topic directly.

Q. Now, is it fair to say that Mr. LaRouche's organization was fairly constantly involved in lawsuits, suing people?
A. Yes.
Q. All right. And is it also true that Mr. LaRouche felt that he couldn't trust lawyers or he could handle lawsuits better than lawyers?
A. Oh, absolutely.
Q. All right. So if there was a legal situation, Mr. LaRouche could take charge and he would do what had to be done and he thought he could do it better than the lawyer?
A. Yes, sir.
Q. Do you remember or were you present at any time when Jeffrey and Michele Steinberg discussed telephone calls that they clajin to have made to a man by the name of Charles Steele?
A. Yes.
Q. And where did that discussion take place?
A. It took place in the offices of the Security staff at the New York City office on West 58th Street. Q. And what were those discussions?
A. Well, essentially they had arrived a bit late that morning and members of the staff were awaiting their arrival to begin our daily meeting. I mentioned we had daily meetings, meetings a couple times a day.
So when they arrived, they apologized for being late; and they said that the reason that they were late was because

Mr. Charles Steels, an attorney or counsel for the Federal Elections Commission, had been receiving late-night phone calls and had received threats on his life very, very late at night; and that even though they were kind of late that day, they were sure that Mr. Steele's day was going to be even worse and that he had slept even worse and had gotten less sleep. And they made it clear by this kind of elliptical fashion that they had made these telephone threats to Mr. Steele and, moreover, that they felt that they should be congratulated and that we should be — we should excuse them for their lateness.
Q. And Mr. Steele was a lawyer for a federal agency who had been having some disagreements — which agency had been having some disagreements with Mr. LaRouche about campaign problems?
A. Yes, that's correct.
Q, And did you ever hear Mr. LaRouche congratulate the Steinbergs for their activity in this regard?
A. No, I did not.
Q. Incidentally, this kind of thing — when this sort of thing happened other than to other members of the Security staff, the Steinbergs would not go out announcing that they had made threats on people's lives?
A. Oh, no.
Q. Now, was there a time — was there a man that used to work for the organization by the name of or at least the nickname of Tony Axios, A-x-i-o-s?

A. Well, that's not his name.
Q. What is it?
A. There's a person who is — I suppose you're speaking of Gus Axios.
Q. All right.
A. Is that the name that you're — is that the person —
Q. Maybe I have the — I'm sorry. Excuse me. Was there a person by the name or alleged name of Axios that worked for the organization?
A. That was a pseudonym, yes. There was such a person.
Q. What was his real name, please?
A. Costas Kalimgtis. C-o-s-t-o-s or t-a-s, I guess. And the last name is K-a-1-i-m-g-t-i-s.
Q. So it was to everyone's advantage to call him Axios, I take it.
A. Actually, we usually called him Gus and that simplified the matter even more.
Q. Who was Gus?
A. He was the second in command in the organization. He was — he was called the organization's chief of staff and he was many, many times acclaimed by Lyn as his chief follower and supporter, as the person whose business it was to run the organization, as his very, very distinct second in command.
Q. Did he leave the organization at one point?
A. Yes, he did.

Q. And when was that?
A. I believe that was in I960,
Q. And was Mr. LaRouche happy about that fact or not happy about that fact?
A. Well, Mr. LaRouche — he left the organization after Mr. LaRouche accused him, baselessly, of stealing a million dollars, among other crimes, from the organization. So Mr. LaRouche was very, very angry with the entire situation and —
Q. Did — Ifm sorry.
A. I'm sorry. Go ahead.
Q. All right. Did Mr. LaRouche ever instruct after — excuse me. Strike that.
After Gus left the organization, did Mr. LaRouche ever instruct members of the staff or organization to contact Mr. Axioe?
A. Yes.
Q. And when did that happen and what did Mr. LaRouche tell them to do?
A. I don't recall the exact date. The general time frame was
during the period when Mr. LaRouche was very concerned about the NBC show that I mentioned previously, the NBC First Camera show, and one or another of the organization's informants had told the organization that Mr. Axios had participated in helping to make the show and had been taped for use on the show denouncing the

organization and so forth. Whether or not this is true/ I to this date do not know.
When Mr. LaRouche got this information, he — or around the time he got this information, he came downstairs to the security area in his home at Woodburn and he ordered members of the Security staff to call Gus Axios — Costas Kalimgtis — at his home and threaten his life.
Q. And what happened as a result of Mr. Larouche's order?
A. Well, several members called him up and threatened his life.
Q. And who were those members?
A. One was William Salisbury, a member of the organization's Security staff.
Q, Do you remember any of the others?
A. Yes. Another was Rick McGraw.
Q, Was Mr. LaRouche present when these calls were made?
A. Yes, he was.
Q. And did he ask you to make one of these calls?
A. Yes, he did.
Q. And in what way did he ask you to make the call?
A. He ordered me to threaten his life in ancient Greek.
Q. Now, just to go back a bit, you're a college graduate?
A. No, in point of fact I'm not. I shall be, I suppose, in the fairly near future, I hope.
Q. Have you attended college?
A. Yes.

Q. And what did you study in college?
A. My two principal areas of study were philosophy and ancient Greek and Greek civilisation.
Q. So you've studied Greek for some number of years?
A. Yes, I have.
Q. And why did Mr. LaRouche ask — well, could you have written up the words — from your knowledge of ancient Greek written up
words which would have constituted a threat?
A. I suppose I could have come up with one or two such words. It isn't really — death threats are not a staple of ancient
Greek literature except in the context of combat between heros in battle. So I would have been hard pressed to — I would have
been at a loss for words quite literally, but I could have said one or two things.
Q. Why did Mr. LaRouche ask you to threaten to kill Mr. Axios in ancient Greek?
A, Well, Mr. LaRouche believed that Mr. Axios put a great premium on knowledge of ancient Greek and had difficulty in
learning or studying ancient Greek. I don't think he IB a Greek — he is not a Greek national. He was born in the United
States, but his parents are Greek, as you might have surmised from the name.
In any case, LaRouche expressed the view that Axios would feel shamed and mortified, you know, by being confronted with someone who could speak ancient Greek and threaten his life

in ancient Greek when he had had so much difficulty learning the language.
Q. So is it fair co say not only was — Mr. LaRouche was trying to humiliate Mr. Axios because he wasn't/ I guess, when it came to learning ancient Greek, he wasn't too bright, is that — just wasn't that good at it?
A, Well, I — well, I want to point out that very bright people have difficulty in studying ancient Greek.
Q. Well, I didn't mean —
A. But yes, he wanted to humiliate as well as to frighten and punish Mr. Axios for his outrages of daring to criticize him and take exception to his conduct of the organization.
Q. And did you refuse?
A. Yes.
Q. Why did you refuse?
A. It was disgusting. I wasn't going to call Gus Axios and threaten his life. It's a crime. Gus Axios had done nothing to deserve that kind of treatment. I mean, this was long after I — this was well after I had ascertained that Mr. LaRouche was unstable, that his conception of the universe was almost entirely delusional. And I certainly wasn't going to commit crimes nor was I going to try to injure a person who would — injure someone to gratify Mr. Larouche's, you know, florid manifestations of hostility.
Q. Did you get into an argument with Mr. LaRouche?

A. No.
Q. You just refused to —
A. I just said no. He said I was a coward or something of that sort.
Q. Did you once get into an argument with Mr. LaRouche about
some subject?
A. Yes.
Q. And what was that about?
A. Weil, the topics were Mr. Larouche's beliefs about ancient Egyptian history and also about the origins of the Arian race.
Q. And did he and you have some difference of opinion about some matter —
A. Yes.
Q. — in Egyptian history?
A. Yes.
Q. And did you get into a violent argument as a result?
A. Well, I think a fair characterization is that he got into a violent or heated argument and I tried simply to call to his
attention certain facts documented beyond possible contest about Egyptian history in particular. I also asked him if he could
give me some source for his repeated assertion that the Arian race came from the North Pole in approximately the year
40,000 BC. at which point he looked at me and said I was the most blocked person he had ever spoken to or something of that
sort and left the room, psychologically blocked, unable to

think, unable to comprehend.
Q. Now, Mr. Tate, in your early days in the LaRouche organization were you — you were involved in handing out
leaflets and demonstrating against the Communist party, were you not?
A. Well, actually I was not active in the organization in 1972. This was the chief period of time during which the
organization was active against the Communist party. So as it happens, no.
Q. Well, were there situations in which people would come to
places where you were, for example, in Philadelphia, engaged in handing out literature, and accuse the organization of being
A. Yes.
Q. And what was your — what would you tell them to do?
A. Well, the people who were accusing the organization of being communists would be told to get lost. If they didn't get lost,
you know, there would be trouble and that sort of stuff.
Q. What if they didn't get lost? What if they stayed around?
A. Well, on at least some occasions or at least two occasions that I knew of in the Philadelphia area, efforts were made to
entice persons into uneven fist fights in which they would be very severely beaten.
Q. Were you involved in those efforts to entice those people into those situations?

A. As it happens, no, I was not.
Q. Well, Mr. Tate, did you testify before the grand jury in
this proceeding on September 29, 1986?
A, I don't recall the exact date, but that's probably about
right, sure.
Q. Okay.
Q. May I show you a document and ask you if this is a
transcript of your testimony.
A. Yes, this is a transcript of my testimony.
Q. Did you say on page 62 of the transcript:
"Now and again with my experience in the field working when I was in Philadelphia years ago if somebody was a persistent nuisance at a distribution site and somebody said, 'These people are communists,' et cetera, we would usually after telling them to yet lost and this and that and the other, we would usually arrange to ambush them and beat thera rather severely to keep them from doing it." Did you say that or not?
A. Yes, I did.
MR. WALKER: No further questions, your Honor. THE COURT: All' right. Redirect. MR. HARKHAM: Yes, your Honor.

Q. By "we," did you mean yourself personally?
MR. WALKER: Objection, your Honor. Leading question.
THE COURT: Overruled.
Q. By "we," did you mean yourself personally?
A. No. I meant the organization. I was told that these things were going to be done. I was aware that they had been done. The people who were selected for these victimizations — for these brutalizations didn't do it anymore. And it was on the basis of that direct account to me that I base that statement. When I say "we" in that statement, I'm talking about the organization. As it happened/ I was not involved in those incidents personally.
Q. Mr. Walker asked you —
MR. WALKER: If your Honor please, I object to that.
THE COURT: To what?
MR. WALKER: Well —
THE COURT: You mean to a question beginning "Mr. walker asked you"?
MR. WALKER: Yes, your Honor. I thought there was something in the Court's order about that, the order regulating
MR. WALKER: I'll withdraw it, your Honor.

Q. Mr. Walker asked you if it was a fair characterization that Mr LaRouche was totally preoccupied with assassination attempts
against him.
A. That 's correct.
G- Was Mr. LaRouche that preoccupied?
A. Yes.
Q. And with whom did he have most frequent discussions about
that concern?
A. With his Security staff.
Q. While you were on it?
A, Yes.
Q. And with whom did the Security staff have their most frequent discussions about that concern?
A. Well, there were a variety of people with whom the Security staff discussed this concern, but Mr. Frankhouser was certainly
a person with whom that concern was discussed most often outside of the actual organization.
Q. Now, you mentioned in answer to Mr. Walker's questions some other sources that the Security staff dealt with, is that
A. That's correct.
Q. Baron?
A. That's one.

Q. Morty?
A. Yes.
Q. Juval?
A. Yes.
Q. And Murdock?
A. Yes.
Q. Now, how frequently were any of those sources called in comparison to how frequently Mr. Frankhouser was called?
A. Well, no one was called more than Mr, Frankhouser . Mr. Murdock at his highest point might have been called nearly as often and the others only episodically, only when there was a particular topic of interest in their area.
Q. Now, Mr. Walker also asked you whether LaRouche had indicated that he sent messages to the CIA.
A. Yes.
Q. By whom?
A. The messages were communicated from the Security staff to be sent to the CIA through Mr. Frankhouser .
Q. Mr. Walker asked you if Mr. LaRouche expressed a belief that he had aided the CI
A. Yes, he did.
Q. And how did Mr. LaRouche express that belief to you that he had aided the CIA?
A. Well, he expressed the belief that, first of all, in the period in which the CIA had suffered staff diminution.

particularly in the covert operations area, that the organization — the Security staff stood ready to fill the gap by providing intelligence so-called on terrorists, leftists and other persons whom Mr. LaRouche regarded as enemies both of the United States and of himself. And this information was to be communicated to the CIA through a number of channels, not the least of those being — in fact, the most commonly approached of those being Mr. Frankhouser .
Q. Now, were you ever at briefings at which either Jeff Steinberg or Michele Steinberg were giving the daily briefing to LaRouche from their notebooks?
A. Yes.
Q. Were there ever occasions when during those briefings they did not mention Mr. Frankhouser ?
A. Yes.
Q. Did Mr. Frankhouser ever have a response on those occasions?
MR. WALKER; "Mr. LaRouche"?
MR. MARKHAM: I'm sorry.
Q. Did Mr. LaRouche ever have a response on those occasions when they had not mentioned Mr. Frankhouser in their briefing?
A. Yes.
Q. what was that response?
A. Well, sometimes if he had not gotten the report he would ask, "Get to Roy," He would say, "Find out what Roy has to say. Get to Roy and the boys."

Q. And by "the boys," did he ever communicate to you who he was speaking about?
A. By "the boys" he meant the — variously the CIA and the whole bunch of intelligence agencies which that was supposed to be tied into.
Q. Now, when you were writing in your notebooks, did you always note the source from whcm you were receiving the information?
A. As a general practice/ yes.
Q. Why?
A. Well, because, as I mentioned, these notebooks contained source reports. That was the importance of the notebooks as their primary constituent. We wanted to have actual means of having source reports prepared so that they could be communicated to Mr. LaRouche and others and so they could be evaluated as to the credibility of the source, its reliability, its completeness and so on.
Q. You indicated that some of the perimeter guards, the actual hired cops around Mr. Larouche's headquarters, made statements suggesting that they didn't take LaRouche's security threat seriously?
A. That's correct.
Q. Did you ever hear any such statements from Jeff Steinberg?
A. Ho.
Q. Michele Steinberg?
A. No. Now and again an individual threat would come on —

come up. Maybe one out of 20 which would be discounted. But no.
Q. How about the other 19 of the 20?
A. No.
Q. And did they express their belief as to whether these were serious?
A. Absolutely. The most serious possible thing in the world.
Q. And who did they turn to most frequently for advice on these
A. To Mr. Frankhouser .
MR. MARKHAM: Nothing further.
MR. WALKER: I just have one question, your Honor, just
a line of questions on that.
THE COURT: All right.
Q. Of course, Mr. Steinberg if he didn't take something
seriously — if he really thought it was a joke, this threat <n LaRouche, he wasn't about to say that, was he?
A. Well, as I mentioned, I don't really recall a specific instance/ but now and again he would discount information coming from one or two other sources. He seldom or never discounted such information coming from Mr. Frankhouser.
Q. He never stated that he didn't believe Mr. Frankhouser, did he?

A. He never stated that he —
Q. Disbelieved.
A. He never stated any disbelief in what Mr. Frankhouser said. Naturally, he sometimes stated that he felt that it wasn't adequate, that Mr. Frankhouser had not gotten enough information, that he had not done enough homework and had not talked to enough of his sources. So that he sometimes felt that it was incomplete, but he never failed to take it seriously.
Q. Did Goldstein ever make any statements about Frankhouser in which he stated he didn't take something seriously?
A. Well, occasionally one would hear Goldstein literally screaming on the telephone that Frankhouser had not done enough, that he hadn't, you know, made enough of an effort. But I mean, he never looked -- to my knowledge at least, he never expressed to me the belief that Mr. Frankhouser 's information with respect to assas'sination threats was not to be taken seriously.
Q. Was there some information that came from Mr. Frankhouser that Mr. Goldstein did say should not be taken seriously? A. Well, not so much information as analysis. Now and again Mr. Frankhouser would be reported as having provided strategic analysis in some sort of situation, and this would often be dismissed as, you know, that Roy was not a competent enough strategic thinker as opposed to field agent to provide this kind of highly sophisticated — to provide a reading on highly sensitive matters such as strategic policy or something of that

sort. So sometimes that kind of analysis would be discounted but not, to my recollection, ever anything pertaining to the —
Q. Threats?
At — to the threats on Mr. Larouche's life.
Q. On this analysis did Mr. Goldstein ever call
Mr. Frankhouser 's reports or information garbage or did he ever
ridicule them?
A. Oh, well, Mr. LaRouche calls everything — well,
Mr. LaRouche ridicules almost everything at one time or another and almost everyone around him has been the victim of his
personal ridicule. And "garbage11 is usually the mildest term. And in that sense now and again, I mean, I mentioned I think in
earlier testimony one of the characterizations he made of Mr. Frankhouser . And now and again Mr. Frankhouser was
characterized in those belittling ways as all the rest of us were.
Q, I was talking about Goldstein. You were talking about
Mr. LaRouche.
A. I'm sorry. I misheard your question.
Q. Did Goldstein ever say Mr. Frankhouser — anything on information or analysis — did he use the term garbage or other
derogatory remarks about Mr. Frankhouser 's strategic analysis or whatever it was?
A. I don't remember that specific word. But —
Q. Words of that —

A. It fits with my recollection of some of his characterizations, yes.
Q. If Mr. Steinberg, for example, or if Mr. Goldstein thought in their own minds that something that Mr. Frankhouser was supposed — was feeding him about an assassination attempt was actually a joke, he certainly wouldn't have told anybody he thought it was a joke, would he?
A. Well, I don't know. Certainly in one or two other cases with one or two other sources there would be the occasional assassination threat that would not be taken quite so seriously. And, for example, at a certain point Mordechai Levy's assassination threats became just a bit too baroque, just a bit too ornate for anybody to take too seriously; and then we sort of kidded about them. But Mr. Frankhouser •— to the best of my knowledge, Mr. Frankhouser 's assassination threats always seemed to the Security staff much more plausible and were always taken very seriously. I'm sorry. I don't mean that he made the threats, but the reports he made of assassination threats.
Q. This is despite the fact that no KGB agents ever did come into the place down in Virginia or anywhere else to assassinate Mr. LaRouche?
A. Well, it's true that these are highly credulous people; they obviously have no evidence for the conclusions that they draw, yes. But in spite of the total absence of any evidence, the lack of plausibility of these crazy ideas and so forth, in spite

of it all/ they continued to believe.
Q. But, well/ except if they didn't believe, if they actually had some — you yourself had some doubts towards the end about whether Mr. LaRouche was going to be assassinated or whether anyone gave a nickel about Mr. Larouche's — assassinating Mr. LaRouche, right?
A. That's correct. And that's why I left the organization.
Q. Right. But you didn't tell anybody when you had these doubts.
A. Well, no. That's true. I didn't tell anybody because the organization discourages doubt in the strongest possible way.
MR. WALKER: I have no further questions, your Honor.
THE COURT: Let me see counsel at the side bar foe a moment.
MR. MARKHAM: May this witness be excused, your Honor?
THE COURT: Yes. You may step down. Thank you.
(Witness excused)
THE COURT: We obviously don't have time for any more testimony. I just wanted to ask whether you had conferred about what I say to the jury about the —
MR. MARKHAM: If I could be heard very briefly. I have one witness that I am going to ask not more than 15 questions. He's been up here for several days. I thought we were going until 1:30. Is it possible — are we going only until 1:15?

THE COURT: 1:15 is our standard. And I have all kinds of other things. I can't extend it today. It's out of the question.
MR. MARKHAM: All right.
THE COURT: How, do you want me to say something about —
MR. WALKER: I would ask for what the Court suggested this morning, your Honor.
MR. MARKHAM: Well, the thing about — I would ask that the Court simply say — explain that there is a standing order not to read anything or listen to anything about the case and not that one thing was specifically —
THE COURT: I'm not going to mention anything specifically. I'm just going to tell them that it has come to my attention that not only is there a lot of publicity about the case but that some of it has included in it reports purportedly factual that are erroneous, and it simply illustrates the point that I make that it would be unfair for the jury to get any information from any other source than right here and I'm emphasizing again that instruction.
MR. WALKER: Thank you, your Honor.
THE COURT: All right.
THE COURT: Members of the jury, in light of the hour we will not start another witness today. But before I release

you, I do want to say something more about ray instructions to you about protecting your impartiality and to make a couple of additional points just to emphasize the instructions.
It has come to my attention that there has been a substantial amount of publicity about this case and that among the reports that have occurred in the press there are reports purportedly of facts that are just plain wrong. I mention it to you only to illustrate the point that, of course/ it would be totally unfair for a juror to be influenced in any way by any information about the case other than that which comes to you right here in the courtroom. And I have given you instructions before to do everything in your power to avoid hearing anything either on news reports or in comments by anybody to you about news reports or comments in any other way about the case, and I just want to underscore those instructions again.
Do not allow anybody to talk with you about the case in any way. Do not listen to, read or watch any news reports of any kind about the case. If, despite your best efforts, you do hear something about the case, then, of course, I ask you to report it to me. But do not say anything about it to any other members of the jury. Do not say anything about the fact that you have had any such information come to your attention in any way.
In other words, all I'm doing is just underscoring again how important it is to a fair trial that you learn about

the case only right here in the courtroom as you are listening to evidence received under the instructions of the Court and protect yourselves against learning anything from any other source.
All right. We will now be in recess until 9:30 tomorrow morning. You may be excused for the day
(The jury left the courtroom at 1:12 p.m.)
THE COURT: We111 be in recess.
(Recess at 1:12 p.m.)



Direct . Cross Redirect Recross

CHARLES TATE. resumed (By Mr. Markham) (By Mr. Walker)




Deft. 201 Deft. 202 Deft, 203


	For TD

In Evidence
19 36 38




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 6th day of November, 1987.
Linda H. MacDonald Registered Professional Reporter Official Federal Reporter

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