Deposition of Sibel Edmonds

August 8, 2009

This is an HTML version of the PDF transcription available online at BradBlog. The HTML has several advantages over the PDF: it’s easier to read, faster to open and search, and easier to copy text from. Before we get to it first a little background. Sibel Edmonds is a former translator for the FBI. While at the FBI she discovered that one of her co-workers was spying for Turkey. Later it became apparent that this involved widespread U.S. government corruption, not merely foreign spies. Because of this corruption Turkey and Israel clandestinely influenced U.S. foreign policy, and acquired U.S. nuclear bomb technology they eventually sold on the international black market. Ms. Edmonds’ attempt to speak out in a legal venue about these matters was defeated three times. When she brought suit against the FBI the government used State Secrets Privilege to get it thrown out. Her testimony before the 9/11 Commission was omitted from the final report. When her deposition was subpoenaed in a lawsuit brought by family members of 9/11 victims, the FBI and DOJ went to the judge and asked him to quash it, again based on State Secrets Privilege, which he did. The springboard for her public testimony transcribed below was a minor lawsuit brought by one Ohio politician against another. Knowing why she was subpoenaed to testify will help make the transcript clearer. In 2008 one David Krikorian ran as an Independent in Ohio’s 2nd district against incumbent Republican, Rep. Jean Schmidt. The incumbent was reelected. Now some background. The U.S. Congress is infested with committees advocating the interests of other countries: the Congressional Nepal Caucus, the Congressional India Caucus, etc. Schmidt was co-chairman of the Congressional Turkish Committee. After the Ohio election Krikorian accused Schmidt of accepting an unusual amount of money from Turkish interests and suggested it was in return for her helping Congress avoid a resolution that would have declared the Turks’ massacre of Armenians during WWI a “genocide.” The 1915 massacre may not seem important today, especially in the U.S., but it’s important to promoters of Turkey and Israel. (Why Israel? Perhaps because Israeli leaders want the Jewish holocaust to be unique, and because the Armenians were Christian and the instigators of the Armenian massacre were the “Young Turks” – Donmeh or Dönme – descendents of Jewish converts of convenience, who by 1908 had overthrown the Ottoman sultan and established a government of their own. For a sympathetic history of the Young Turks see The Dönme: Jewish Converts, Muslim Revolutionaries, and Secular Turks by Marc David Baer, Stanford University Press. Soon after the Russian Revolution of 1917 the Bolsheviks further helped establish the new Turkish government.) For suggesting that she had conducted her campaign improperly Jean Schmidt sued David Krikorian before the Ohio Election Commission. In order to defend his statements about Turkish influence in Congress Krikorian asked the hearing committee to subpoena Sibel Edmonds, who had been outspoken against such influence. This time she was not blocked by the DOJ. Such is the genesis of her deposition. She testified under oath. To date, as might be expected from their past behavior, the FBI, DOJ and Congress have done nothing about her revelations, and the major media pathetically little. You won’t hear about her case from the so-called “Ayn Rand Center for Individual Rights” either. Here then is the transcript, all on this one webpage, after a few explanatory remarks on the text. Pagination follows the PDF. Line numbers have been removed. Inconsequential spacing, margins and indentation may differ from the original. Bolding has been added to emphasize some headings, color highlighting has been added to distinguish the labels identifying who’s talking, color dimming has been employed to de-emphasized page numbers. Three obvious transcription errors have been silently corrected, one of spelling and two of capitalization: “benefitted”; “... to do it. they had ...”; “... so many ways. it’s a very complicated ... .” One missing closing double-quote has been added in square brackets. For those unfamiliar with hearing transcripts, in the Examinations:

BY MR. ‘X’ on a line by itself identifies the attorney ‘X’ questioning Sibel Edmonds.

Q indicates a question by that attorney to Ms. Edmonds.

A indicates her answer.

MR. ‘X’ indicates speech by attorney ‘X’ to another attorney.

THE WITNESS indicates speech by Ms. Edmonds not (formally) answering a Q.



on a line by itself identifies the attorney ‘X’ questioning Sibel Edmonds.indicates a question by that attorney to Ms. Edmonds.indicates her answer.indicates speech by attorney ‘X’ to another attorney.indicates speech by Ms. Edmonds not (formally) answering a Q.

page 1

BEFORE THE OHIO ELECTIONS COMMISSION



DEPOSITION





IN THE MATTER OF: JEAN SCHMIDT, Plaintiff,



v.



DAVID KRIKORIAN, Defendant.



Case No. 2009E-003

SIBEL DENIZ EDMONDS

page 2

On Behalf of Plaintiff Jean Schmidt:



BRUCE FEIN, ESQ.

Of: Turkish American Legal Defense Fund

Suite 1000

1025 Connecticut Avenue, N.W.

Washington, D.C. 20036

(202) 370-1399, ext 3

Web: bruce@thelichfieldgroup.com





On Behalf of Defendant David Krikorian:



DAN MARINO, ESQ.

Of: Luque, Geragos & Marino, LLP

Suite 800

910 17th Street, N.W.

Washington, D.C. 20006

Tel: (202) 223-8888

Fax: (202) 223-8677

Web: dmarino@luquegeragos.com





On Behalf of Deponent Sibel Deniz Edmonds:



MICHAEL D. KOHN, ESQ.

Of: Kohn, Kohn & Colapinto, LLP

3233 P Street, N.W.

Washington, D.C. 20007

Tel: (202) 342-6980



page 3

TABLE OF CONTENTS

WITNESS DIRECT CROSS REDIRECT RECROSS Sibel Deniz Edmonds 6 105 190 212

Ex.

NO. DESCRIPTION IDENTIFIED Edmonds Deposition: 1 . . . . . . . . Subpoena . . . . . . . . 7

page 4

P R O C E E D I N G S



(10:32 a.m.)

VIDEO OPERATOR: Will counsel and others present, please introduce themselves and state whom they represent?

MR. MARINO: Dan Marino here on behalf of Mr. Krikorian.

MR. FEIN: Could I interject an objection here?

Is Mr. Marino admitted in this case to practice before the Ohio Elections Commission?

MR. MARINO: Why don’t you --

MR. FEIN: What is the answer to that question, sir?

MR. MARINO: Why don’t you go ahead and identify yourself?

MR. KRIKORIAN: David Krikorian.

MR. MARINO: Do you want to? Who’s the next gentleman?

MR. ELWOOD: Phil Elwood. I work at KL.

page 5

MR. MARINO: I’d like to have everyone identify themselves.

MR. FEIN: Sure.

MR. MARINO: And you’re Mr.?

MR. FEIN: I’m Mr. Bruce Fein. I’m counsel for Jean Schmidt in this proceeding.

MR. MARINO: Okay.

MR. KOHN: I’m Michael Kohn with Kohn, Kohn & Colapinto, representing the witness Sibel Edmonds, and with me are three law clerks. That’s it.

VIDEO OPERATOR: Thank you.

Will the court reporter please swear in the witness after which we can begin?

THE REPORTER: Would you please raise your right hand?



Whereupon,

SIBEL DENIZ EDMONDS

page 6

DIRECT EXAMINATION

BY MR. MARINO:

Q: Okay. Good morning, Ms. Edmonds. I introduced myself to you off the record. My name is Dan Marino. I represent Mr. Krikorian with the law firm of Luque, Geragos & Marino here in Washington, D.C.

MR. FEIN: I’m going to interpose an objection to Mr. Marino asking the question because there’s no showing that he has been authorized to participate in the proceeding at issue in this particular matter.

MR. MARINO: I want to thank you for coming this morning.

MR. FEIN: Does Mr. Marino have -- Mr. Marino, do you have any proof that you’ve been admitted to practice in the proceeding before the Ohio Elections Commission in the case of Jean Schmidt v. David Krikorian?

BY MR. MARINO:

Q: I’d like to show you what’s been marked --

page 7

MR. FEIN: I interpose a standing objection, and I will to every single question Mr. Marino asks until he establishes and testifies or otherwise documents that he is authorized to participate in this proceeding, and that if he continues to do this, we will consider seeking sanctions, including the unauthorized practice of law in Ohio.

BY MR. MARINO:

Q: -- to show you what’s been marked as Exhibit 1 to your deposition. I only have one copy of it. It purports to be a subpoena from the Ohio Elections Commission for your testimony today.



Have you seen that before?

A: My attorney’s office received it. I believe I have seen the PDF version of that.

(Whereupon, the document referred to was marked as Edmonds Deposition Exhibit No. 1 for identification.)

BY MR. MARINO:

page 8

Q: Okay, and I take it that you’re here in response to that subpoena today, correct?

A: Correct.

MR. FEIN: Now, I interpose an objection again because the documentary evidence shows the Ohio Election Commission communicated to Mr. Marino that they had no intent of enforcing their subpoena beyond the territorial jurisdiction of Ohio, and that Ms. Edmonds was under no compulsion to attend today, and that was made abundantly clear, and that’s a misstatement of the record made by Mr. Marino, and I highly object to that mischaracterization of why Ms. Edmonds is here today.

MR. KOHN: Let me clarify. Ms. Edmonds is here today with respect to that subpoena as a courtesy rather than traveling to Ohio.

MR. FEIN: That is simply a simply misstatement of the record in this case,

page 9

That is not what happened in this particular case. That is a misstatement of the record.

MR. KOHN: Well, I guess you don’t understand “courtesy” within the legal community --

MR. FEIN: You don’t understand there are documents that have been issued in this particular case. In particular, the document issued by Mr. Phil Richter, the counsel for the Ohio Election Commission, said there was no jurisdiction, and they did not intend to enforce this subpoena in the District of Columbia, and that there was no compulsion on Ms. Edmonds to attend this

page 10

MR. MARINO: Okay. Kind of makes you wish you went to law school, right?

BY MR. MARINO:

Q: All right. I do want to thank you for coming today, Ms. Edmonds, and I did talk to your counsel before the deposition and asked him to communicate and I’ll tell you the same thing. I just became involved recently in this case, and I’m going to be asking you a series of questions about -- some about your background and some about some of the things that we’ve seen in the press in connection with some of the issues you’ve had with the U.S. government, et cetera.

And I do want to sort of advise you that until the last couple of days, I really had heard nothing about this case, and so some of my questions are going to seem somewhat elementary, and it’s not because I’m playing Colombo or anything like that. It’s just because I really don’t know the

page 11

And in a sense, I think that will be good because what we’re hoping to do with your testimony is provide some education to the folks involved in this thing. So in the process of educating me, maybe we’ll be educating some of the listeners, people who will see your deposition testimony.

Have you had your deposition taken before?

A: In business maybe.

Q: Okay. Then you understand the process. As I said, I’m going to be asking a series of questions and I’m just going to ask you to answer them to the best of your ability. You’ll maybe see objections from people from time to time, and unless someone tells you not to answer the question, it’s okay to go ahead and answer it. Okay?

And of course, you can take your guidance from your counsel on when to answer a question and when not to.

page 12

If at any time you want to stop and take a break, talk to your lawyer, get a drink of water, whatever, just let us know, and we’d be happy to accommodate that.

I’d like to start if we could with just a little bit of your background, just for the record. I understand from some of the reading I did that you, I think, were born in Iran; is that correct?

A: Correct.

MR. FEIN: I object. This is the standard that Chris Finney asserted in Mr. Krikorian’s deposition when the question was raised this fall to Mr. Krikorian, and I’m reading from the transcript of his deposition, page 9.

“Are you a lifetime Cincinnati area resident or did you move here at some point?”

Mr. Krikorian’s attorney, Mr. Finney, “Objection. What does this have to do with the case?”

page 13

And the statement that we agreed to with Mr. Finney, that unless there’s a particular question that goes to the allegations of falsehood and intentional falsehoods in this case, it is off limits. That’s the standard that Chris Finney, counsel for Mr. Krikorian, established in his deposition, and it applies here in the same way.

Whether she was born in Iran has nothing to do with the allegations that I can see that Jean Schmidt has lodged against Mr. Krikorian. Unless there’s some demonstration of some relevance, then I object to answering that question the same way that Mr. Finney objected to Mr. Krikorian answering whether he was a lifetime Cincinnati resident.

BY MR. MARINO:

Q: I think you answered that, yes, you were born in Iran.

A: Yes.

Q: And you ultimately moved to Turkey

page 14

A: Correct, because I --

MR. FEIN: And I also have a standing objection on relevance for the same reasons.

BY MR. MARINO:

Q: I’m sorry. I didn’t get the answer.

A: Yes, because I was always a Turkish citizen because my parents were Turkish. So we were there because of my father’s job, and then we moved back to Turkey.

Q: All right, and I understand you speak a number of languages in addition to English, correct?

A: Correct.

Q: What are --

MR. FEIN: Objection.

BY MR. MARINO:

Q: -- those languages?

A: Turkish is my primary, my mother

page 15

Q: Okay.

A: After that, Farsi. That’s the language spoken in Iran.

Q: Okay.

A: And I also have conversational abilities in Azerbaijani.

MR. FEIN: I just interpose a standing objection so we can move along on relevance grounds that I don’t believe that there’s been any establishment that the witness knows anything about the allegations in the complaint. So just to speed things along, I’ll have a standing objection on relevance to every single question asked until there’s some connection between her knowledge of the complaint and the question that relates to the facts in the complaint.

BY MR. MARINO:

Q: And at some point you moved to the United States, correct?

A: Correct.

page 16

Q: And when was that?

A: 1988, July 1988.

Q: All right, and can you just tell us about your educational background, please?

A: Sure. I have a Master’s degree in public policy from George Mason University. I have Bachelor’s degrees in psychology and in criminal justice from George Washington University. I have a AS (phonetic) degree from Northern Virginia Community College in biology, and I finished high school in Turkey. I graduated in 1988 in Istanbul.

Q: And I understand, again, just to move things along a little quickly, that at some point you became a contract employee with the Federal Bureau of Investigations; is that correct?

A: Correct.

Q: And when was that?

A: I started working for the FBI on around September 15, 2001.

Q: And when you became employed at

page 17

A: Yes, I did.

Q: And how did it come to be that you were working for the FBI?

A: Okay. I will try to summarize the story so it’s not -- it won’t take too long. When I was studying for my Bachelor’s degree, criminal justice/psychology, I had applied for internship position with the FBI, and this would be around ’97, 1997, 1998, and they never responded to me and except that they were interested in my linguistic abilities because I spoke Turkish and Farsi.

And then I didn’t hear back from them, and I was contacted around September 11, 2001, and they said they had obtained top secret clearance for me, and they needed my services for translation in Turkish and Farsi, and they wanted me to start immediately, and because I couldn’t work full time, I took the contractor’s position with the FBI for

page 18

Q: All right, and so can you describe what your job was with the FBI aside from translating those languages?

A: I assisted Special Agents, both my -- the primary supervisory Special Agents in Washington, D.C. field office, but also Special Agents in charge of various counterintelligence and counterterrorism investigations around the country, and those were different FBI field offices.

Q: Now, when you refer to counterintelligence operations, can you just tell us what that means?

A: Counterintelligence operations in the FBI had to do with collecting information, monitoring -- and monitoring particular target foreign entities in the United States.

Q: And just to -- I’m probably over simplifying it, but it’s a matter of public record that the FBI may have people who listen

page 19

MR. FEIN: Leading question.

BY MR. MARINO:

Q: -- and they have translators who translate those, correct?

MR. FEIN: Objection. Leading.

THE WITNESS: Information could have been both conversational audio, but also documents, written documents, or in certain cases direct surveillance.

MR. MARINO: And --

MR. KOHN: For the record, I’d just like to note that I’ve asked the witness to limit her responses only to the information that she believes to be publicly available or she has learned from sources outside of her employment. So I just wanted that on the record.

MR. MARINO: Okay, and I appreciate that, and you know, I have had in

page 20

BY MR. MARINO:

Q: It is a matter of public record, however, that our government through the FBI primarily does do counterintelligence work with respect to foreign nationals and foreign organizations, correct?

A: Correct.

Q: And that would include Turkish organizations?

A: Correct.

Q: And my understanding is that you were terminated by the FBI or at least your contract was terminated in was it March or April of 2002?

A: April 2002.

Q: All right. And so from September

page 21

A: Correct.

Q: And, again, these were materials that were related to counterintelligence operations, correct?

A: Not limited to counterintelligence. Some of them crossed over criminal related investigations, and also counter -- I also translated for Counterterrorism Division.

Q: So all three of those.

A: Correct.

Q: Now, -- and I take it that you were translating obviously the languages that you were fluent in, correct? Turkish, Farsi.

A: Although initially I performed translation for all three languages, but within a few weeks because of the need in the FBI, urgent need, I was placed primarily on Turkish, and that became my main language that

page 22

Q: So, again, I know it sounds elementary, but just by way of background, you were translating documents and conversations that were created by and spoken by people who spoke Turkish, correct?

A: Correct, but because the targets could also speak English, and this couldn’t have been known to the FBI agents until I first went through the information, I also had to transcribe and make notes of pertinent conversation, pieces of conversation in English also. So I had to listen to a lot of English conversation and notify my bosses in the FBI of the ones that were very important.

Q: Okay. Now, let me jump ahead to April 2002, and you said your contract was terminated by the FBI. Can you tell us why that happened?

A: After I was hired by the FBI in September 2001, about a month or so later, FBI hired another language specialist for Turkish

page 23

My main primary agent for Turkish counterintelligence and I, we through various evidence and incidence became aware that she had worked for certain Turkish organizations and entities that were directly the targets of FBI counterintelligence investigations, and that she had lied in her application, and that for unknown reasons to us -- I don’t know why -- the FBI security background check had not caught that important information despite even her tax filing records.

And not only that; Melek Can Dickerson and her husband, at the time he was a major with the Defense Intelligence Agency, Major Douglas Dickerson, and he was working for Douglas Feith’s office and was a coordinator with the State Department on the

page 24

As we started reporting this to our superiors, initially there was a panic in the department, but as it went up further to the headquarters -- this is the FBI Headquarter -- they started -- the FBI Headquarter started retaliating against me and eventually they terminated my contractor.

And there is an Inspector General’s report available publicly that came out, I believe, in 2005 that confirmed all my allegations and the fact that FBI fired me simply due to my activities in whistleblowing in making this known to the FBI and later to the Congress, and that the evidence on the translator in question was supported by other witnesses from the FBI and documents.

page 25

So that’s a public document report.

Q: All right. There’s an unclassified version of that report which has been made public, correct?

A: Correct.

Q: And that report basically substantiated the allegations that you were making regarding Ms. Dickerson, correct?

A: Correct.

Q: And the concerns that you had regarding Ms. Dickerson pertained to espionage really, no?

A: Correct.

Q: And in part -- and that was in part because of the fact that she was associated with these -- she and her husband were associated with these targets of counterintelligence operations.

A: Correct.

Q: Who were Turkish entities, organizations; is that correct?

page 26

A: Yes, and certain U.S. entities who were also part of these espionage related operations.

Q: Was one of the organizations that you were concerned about the American Turkish Council?

A: Yes.

Q: Were there others?

A: Yes.

Q: Can you identify them, please?

A: Certain Turkish diplomatic community in Washington, D.C. and other locations and other Turkish cultural and business related associations and lobbying groups in various -- with various chapters in various cities and states in the United States.

Q: All right. Without asking you specifically who the targets were at this point, when you hear the term -- well have you ever heard the term “Turkish lobby”?

A: Yes.

page 27

Q: What does that mean to you?

A: Can you be more specific? It means many things to me.

Q: I mean just what comes to mind when you -- again, I came into this a couple of days ago. I’ve seen the term “Turkish lobby.” I’ve seen people referring to it. If someone uses that term, can you tell us either generally or specifically what it means to you?

A: Correct. It means two sets of things. One set is the overt Turkish lobby that is classic lobbying for its interests, governmental relationship interests, commerce, et cetera, and the other category is the covert activities and operations by the lobby that many of which may not be legal.

Q: And when we talk about the overt Turkish lobby, can you identify the organizations you’re thinking about here?

A: There are so many. American Turkish Council is the primary organization,

page 28

Q: ATAA, is that the Assembly of Turkish America Associations?

A: I believe that’s what it is.

Q: How about have you heard of the Turkish Coalition of America?

A: Just through some cursory reading recently.

page 29

Q: Okay, and are you familiar with an organization called the Turkish American Legal Defense Fund?

A: I don’t recall.

Q: Have you ever met Mr. Fein before who is present here today?

A: I haven’t met him personally.

Q: Are you aware of the fact that he’s associated with the Turkish American Legal Defense Fund?

A: I just -- I didn’t know that.

Q: The organizations you identified just now were I think you identified as -- or the ones you identified, not the ones I asked you about -- the ones you identified, I think you were listing as part of the overt Turkish lobby, correct?

A: Okay. Can you repeat that question?

Q: Yes. I’m sorry. I was asking about what was meant by the Turkish lobby, and you said that there were overt forms of the

page 30

A: They are part of both overt and covert.

Q: Okay. So when you talk about the covert Turkish lobby, what are you referring to there?

A: Activities that would involve trying to obtain very sensitive, classified, highly classified U.S. intelligence information, weapons technology information, classified congressional records, recruiting -- recruiting key U.S. individuals with access to highly sensitive information, blackmailing, bribery. These are some of the ones that just perhaps -- and there are many others that I’m unable to think of.

Q: Well, by way of example, I think you indicated that Ms. Dickerson -- by the way, is she ever referred to as Jan Dickerson?

page 31

A: Correct. That’s how she went at the FBI, and as far as I know, elsewhere she used her middle name in the United States, Jan Dickerson.

Q: Now, I read in some of the reports about an incident where Ms. Dickerson arrived -- showed up at your home unexpectedly on Sunday.

A: Correct.

Q: And can you tell us what happened when that -- when she arrived there?

A: Sure. She came to my house with her husband, who at the time was Major Douglas Dickerson, and he identified himself first as the officer for Air Force, but later said that his real task was operations involving records procurements by countries in Central Asia and Turkey, and that he directly worked with Douglas Feith and Paul Wolfowitz.

Q: Okay.

A: At the time this would be 2001, December.

page 32

Q: All right, and they came to your home on Sunday morning.

A: Yeah, social visit they said.

Q: And during that discussion, during that visit, did you come to believe that Ms. Dickerson was recruiting you?

A: Yes, I did.

Q: For what?

A: They wanted me to joint the American Turkish Council, and they told me that I would be provided with many benefits, both monetary but also prestigious benefits, if I were to enroll with them.

Q: Okay, and did you know at the time that the American Turkish Council was one of the counterintelligence targets?

A: Absolutely, yes.

Q: And did you believe Ms. Dickerson knew that as well?

A: She -- yes, and the fact because her husband associated with American Turkish Council and she worked for them.

page 33

Q: And did you report this effort to recruit you to your superiors?

A: Immediately. The next day I reported it in writing to my direct administrative supervisor, and a few days later to my agent, who was my supervisory agent, but also again in writing to the FBI’s Personnel Security Office, because I was obligated for my top secret clearance to report recruitment attempts.

Q: Now, why if you can tell me, why would the American Turkish Council be a counterintelligence target?

A: Certain individuals form that organization, American Turkish Council, certain individuals were involved with other individuals outside American Turkish Council, which includes diplomatic community and Turkish diplomatic community -- sorry -- and other subchapter organizations.

I say “subchapter” because even though it’s not known, ATA is not formally

page 34

Q: Okay. Was there -- let me be sure I have this correct -- was there a particular individual at the American Turkish Council who had connections to the Turkish Embassy in Washington at that time?

A: There were several people.

Q: And again, just because I don’t know, to your knowledge, was the American Turkish Council an organization that was supported by the Turkish government?

A: I don’t know directly, but indirectly --

MR. FEIN: That’s conjecture.

THE WITNESS: -- I mean --

page 35

MR. FEIN: Object, object. Only speak based upon your personal knowledge. Conjecture and speculation otherwise, I move to strike your answer unless it’s based upon personal knowledge.

THE WITNESS: Based on --

MR. MARINO: You can answer the question --

THE WITNESS: Based on my personal --

MR. MARINO: -- just as I asked it.

THE WITNESS: -- knowledge, they were indirectly supporting it, supporting. Turkish government was indirectly supporting the American Turkish Council, certain individuals and operations and projects against.

BY MR. MARINO:

Q: Okay, and how were they supplying that support?

A: Without getting into specifics,

page 36

Q: So one of the means, basic means of support would be money, correct?

A: Money when they could, yes.

Q: So if I said that the American Turkish Council, for example, was an organization supported by the Turkish government, that wouldn’t be an unreasonable assumption?

A: Correct.

Q: What about some of these other members of the Turkish lobby that we’ve talked about? Would I be unreasonable in assuming that those organizations might be receiving support from the Turkish government?

A: They were all receiving -- the

page 37

MR. FEIN: I think the question was -- can I just clarify for my own mind? -- the question was based upon the witness’ personal knowledge, she knows that all the other organizations that were targets, they were receiving money from the government of Turkish.

MR. MARINO: Okay.

MR. FEIN: Is that the question and answer?

MR. MARINO: Mr. Fein is going to have an opportunity, I think, to ask some questions when I’m finished. Maybe now you and I will just have questions and answers.

BY MR. MARINO:

Q: So what happened when you reported to your superiors at the FBI that Ms. Dickerson were trying to recruit you for this organization, American Turkish Council?

A: At the initial stage -- this is for Washington field office before it went all

page 38

Q: Okay, and ultimately did they take any action against Ms. Dickerson or her husband?

A: Again, initially during this initial stage, they, I believe, they asked her to take polygraph, and they also -- the FBI’s counterespionage unit, they set up the date and time to have some kind of an

page 39

Q: And they also had you take a polygraph test, correct?

A: Correct.

Q: And the polygraph examiners found that you were not deceptive?

A: Yes, I was absolutely truthful.

Q: Okay. Now, in your experience both at the FBI and since then, what is it that the Turkish lobby -- what kinds of issues are they traditionally concerned about in our country?

A: Various issues that I’m aware of. Some, the more overt ones, the foreign policy of the United States. Another, the weapon procurement from the United States and the military aid, and political front is being able to secure grants from United States Congress for their operations or some of them,

page 40

Armenian genocide and preventing that from ever being brought up or passing Congress or even discussed in the mainstream media is another political objectives that they pursue very strongly. These are the overt ones. So those are -- these are the overt ones.

Q: All right. In your experience then, these are issues that the Turkish government is concerned about?

A: Not only, yes, Turkish government is concerned, but also other entities with their own special interest who are very concerned about these issues.

Q: Can you identify those?

A: Some of them are business entities. The others are more like clusters

page 41

Q: You mentioned the Armenian genocide issues. My understanding is that there have been resolutions proposed, introduced, discussed in Congress to recognize the Armenian genocide, correct?

A: Correct.

Q: And those have been controversial resolutions over the years?

A: Correct.

Q: And so when you refer to this Turkish lobby regarding that as an issue, it would be their intent to prevent such a resolution from being passed by the U.S. Congress, correct?

A: Correct.

Q: Now, am I correct that -- I know you don’t work for the FBI now, but would you consider yourself sort of still involved in some of the issues that we’ve been discussing?

page 42

A: Somewhat, yes.

Q: Am I correct that you have a blog on the Internet?

A: Yes.

Q: You post material on that?

A: Yes.

Q: One of the things that I saw on your blog is something called the State Secrets Privilege gallery. Do you know what I’m referring to?

A: That is on my personal Website that is public, JustACitizen.com, correct.

Q: Okay. And when you talk about the State Secrets Privilege, I think I know what you mean by that. Can you tell us what you’re referring to?

A: State Secrets Privilege is this arcane executive privilege that the government, United States government, invoked in my case twice in order to quash my court case, but also prevent the public knowledge of information I reported to Congress, to the

page 43

Q: Okay, and just to bring me up to date, you filed a lawsuit against the government at some point, correct?

A: Correct.

Q: And that was because of your termination by the FBI, right?

A: And my First Amendment rights, correct.

Q: And if I understand it correctly, the government used the State Secrets

page 44

A: The first invocation, yes.

Q: Was there a second invocation?

A: Yes. I was -- my deposition was subpoenaed by a law firm called Motley Rice. I think it’s M-o-t-l-e-y, second word R-i-c-e, who represented thousands of 9/11 victims’ family members, and they subpoenaed my deposition, and I believe this was in 2004. That was when the government, FBI and the Justice Department, went to the judge who was sitting on my case, and asked him to quash it based on State Secrets Privilege, and they cited the State Secrets Privilege together with affidavits from the various individuals in the Justice Department, including the Attorney General, and asked the judge to quash that deposition for the second time.

Q: So these are lawyers who are representing families of the 9/11 victims, correct, who wanted to get information from you?

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A: The lawyers of the family victims, yes, victims’ families, correct.

Q: And did you understand why they thought you had relevant information?

A: Macro level, yes. I didn’t know what they were planning to ask specifically, but it has to do with certain Turkish lobby and organizations in the United States who also had certain dealings with Saudi Arabian related financial and lobby organizations in the United States and cases that would have been -- that would have involved both Saudi Arabia and Turkey jointly were doing certain things here in the United States, but also outside the United States.

Q: Okay, and I think you said earlier basically the government prevented you from getting that information to the families of the 9/11 victims, correct?

A: Correct. It’s been five years, but to my best of knowledge, they forced the party who was subpoenaing me to submit

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Q: All right. Now, on that Website and this States Secrets Privilege gallery, it seems like you have photographs of various individuals, correct?

A: Yes.

Q: Is Dan Burton one of the people who’s in the gallery?

A: His picture is there, yes.

Q: Okay. Why is his picture there?

A: I can’t discuss the details of those individuals not legal activities in the United States, but those pictures, his and others, are there because State Secrets Privilege was mainly involved to cover up those individuals illegal, extremely illegal activities against the United States citizens who were involved in operations that were, again, against order foreign government and

page 47

Q: And Dan Burton is a representative, member of Congress from Indiana; is that correct? Is that the right place?

A: I believe he is.

Q: Okay. What about -- it also appears that you have a photograph of Dennis Hastert in the gallery.

A: Yes.

Q: Okay, and why is his photograph there?

A: Again, just information that’s public, has been public, is he would be one of the primary U.S. persons involved in operations and activities that are not legal, and they’re not for the interest of the United States but for the interest of foreign governments and foreign entities.

Q: Now, again, Mr. Hastert was the Speaker of the House and Representative from

page 48

A: At the time he was.

Q: Can you tell me anything about what your concerns are about Mr. Hastert?

A: This information has been public. The concerns, again would be several categories. The acceptance of large sums of bribery in forms of cash or laundered cash and laundering is to make it look legal for his campaigns, and also for his personal use, in order to do certain favors and call certain -- call for certain actions, make certain things happen for foreign entities and foreign governments’ interests, Turkish government’s interest and Turkish business entities’ interests.

Q: Did you have reason to believe that Mr. Hastert, for example, killed one of the Armenian genocide resolutions in exchange for money --

MR. FEIN: Leading question.

BY MR. MARINO:

page 49

Q: -- money from these Turkish organizations?

A: Yes, I do.

Q: So if I were to say that a member of Congress -- if I were to just walk out on the street and say, “Gee, I think members of Congress have taken money from these Turkish organizations in exchange for denying the Armenian genocide,” would that be an unreasonable assumption on my part?

MR. FEIN: That’s pure conjecture. The individual --

THE WITNESS: No.

MR. FEIN: -- is totally irrelevant.

BY MR. MARINO:

Q: Are you aware of other members of Congress, other than Mr. Hastert, taking money from Turkish organizations in exchange for denying the Armenian genocide?

A: Yes, and not only taking money, but other activities, too, including being

page 50

Q: Stephen Solarz is on your gallery as well. I believe he’s a Representative from New York. Is that correct? I’m really guessing.

A: He used to be.

Q: Was, right?

A: Correct. He is a registered lobbyist for the -- or was registered lobbyist for the government of Turkey.

Q: And Mr. Hastert is also a registered lobbyist for the government of Turkey now?

A: That’s what I have read and it was announced, yes, he is.

Q: And why is Mr. Solarz in your gallery, if you can tell me?

A: Mr. Solarz and certain others in the gallery, as lobbyists they also acted as conduits to deliver or launder contribution and other briberies to certain members of Congress, but also in pressuring outside

page 51

Q: And Mr. Solarz and others would be doing this on behalf of these Turkish organizations?

A: And the Turkish government, correct, both.

Q: Would you say that -- would it be your opinion that the Turkish government through these Turkish organizations in the United States and otherwise has corrupted members of Congress?

MR. FEIN: Objection. She’s just asking for an opinion. This is supposed to be a witness who testifies to facts.

THE WITNESS: Absolutely, yes.

BY MR. MARINO:

Q: And is that based on you just speculating or is it based on something else?

A: Based on documented and provable, tracked files and based on facts 100 percent, documented facts.

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Q: Now, are some of those documented facts that you’re referring to, are they public knowledge? Are they in the public domain, in other words?

A: Some of them through various, I guess, reporting and other sources who have been disturb (phonetic) and talk, yes.

Q: And is your opinion based in part upon your experience working on counterintelligence matters for the United States?

MR. KOHN: To the extent she can answer that question without -- why don’t we just withdraw that question?

MR. MARINO: Okay. That’s fair enough.

BY MR. MARINO:

Q: It looks like you have a photo of Bob Livingston on your gallery as well.

A: Yes.

Q: And I believe he’s a Congressman from I want to say Louisiana at some point.

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A: Correct.

Q: He was the one that was going to be the speaker, but then left.

A: Yes.

Q: Why is he in your gallery?

A: Until 1999, until he left for activities that he was engaged, not very legal activities on behalf of foreign interests and entities, and after 1999 acting as a conduit to, again, further foreign interests, both overtly and covertly as a lobbyist, but also as an operative.

Q: When you say “as an operative,” what do you mean by that?

A: In order to explain, I will give you an example maybe. Is that okay?

Q: Sure.

A: Just a hypothetical example or --

Q: It’s okay with me.

A: Okay. If an individual has companies set up and clients in offshore islands like Cayman Islands, for example, and

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MR. MARINO: All right. We’ve been going for about 55 minutes. Why don’t we take a break, ten-minute break?

(Whereupon, the foregoing matter went off the record at 11:22 a.m. and went back on the record at 11:41 a.m.)

BY MR. MARINO:

Q: Okay. Ms. Edmonds, have you ever reviewed your Wikipedia entry?

A: Once in a while I do. I don’t know when was the last time, but maybe a year

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Q: Okay. I mean, do you know have you contributed to it or do you know people who do contribute to it?

A: No. I know many people, they give me mainstream media articles or any reports. They put it in there, but, no, I haven’t contributed.

Q: When you’ve looked at it, have you thought that it’s generally accurate about most of the statements?

A: Yes, generally, yes.

Q: One of the things that it indicates in your biographical information is that you’ve made certain allegations. Some of them we’ve talked about a little bit, and I wanted to ask you about some of the others.

One of the entries indicates nuclear secrets black market, and it says, “Edmonds alleges that in the course of her work for the government she found evidence that the FBI, State Department and Pentagon

page 56

Is that correct that you’ve made those allegations?

A: That information is correct, and if ever -- you can get, I would say, those government organizations and others. There’s another place missing there. They list the State Department itself, but there is one other place that’s missing.

Q: And what is that place?

A: That would be RAND Corporation.

Q: And can you tell me about the -- give me some more information about the Turkish and Israeli run intelligence network that is referred to there?

A: This information has been public, documenting methods of intelligence gathering. Yes. Through certain U.S. officials,

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Q: All right.

A: Their operations, and some of these layers sometimes they conduct their operations independently and with the sole purpose of obtaining a profit, and therefore, the information they obtain, let’s say, the nuclear or weapons technology, weapons technology related information doesn’t necessarily only go to Turkey or Israel, but they sell it to the highest bidder. That’s how they operate. They contact their people whether it’s in ISI, in Washington, D.C. part of the military attache for Pakistani intelligence, or the certain Saudi business people in Detroit may be contacted, and they say, okay, and talk about these Turkish entities. This is we have obtained this

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So what I’m trying to say is they do it both for governments, foreign governments, but some of those operatives, they also -- they offer it in open market, and they have -- they have individuals on their payroll on almost every major nuclear facility in the United States. RAND Corporation and various -- in Midwest, various Air Force labs that develop certain weapons technology, which I am not very familiar with the technology itself.

Q: When you refer to the or when the article refers to the paid, high ranking American officials, can you identify who they are?

A: That person has been identified by others.

Q: Okay.

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A: And he has been identified as Mr. Marc Grossman, who used to work for the State Department.

Q: Right, and Mr. Grossman, I think, was also in your gallery, correct?

A: Yes.

Q: And I read somewhere that Mr. Grossman had some relationships with a Turkish organization, Turkish diplomats here in the United States.

A: Yes. He had very, very close relationship with not only Turkish diplomatic communities and entities, but business and also some of these criminal layer operatives that I told you about. Currently, that he’s nor working; he actually is working for a Turkish company called Ihals Holding.

Q: Okay. Now, was Mr. Grossman the ambassador to Turkey at some point?

A: Yes.

Q: Okay, and then what was his position at the State Department, if you

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A: He had several different positions. I believe in 1999 or 2000, was European Affairs. That dealt a lot with NATO, and afterwards during early bush administration’s stage, he was the second or the third highest person in the State Department. I’m not sure about the title.

Q: Okay, and during that time -- I’m sorry -- during that time when he was the second or third highest ranking person in State, I’ve read somewhere that you’ve alleged that he actually warned the Turkish Embassy about a CIA front company that had been set up to stop proliferation of nuclear weapons.

A: That would be summer 2001. Whatever title he held at that point, he, Mr. Grossman, informed a certain Turkish diplomatic entity who was also an independent operative of a company called Brewster Jennings because Brewster Jennings was frequenting the American Turkish Council as a

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So there were talks between those Turkish operatives and Brewster Jennings, and Mr. Grossman wanted those people to be warned that Brewster Jennings was a government front, front for government, and it was a front. It was not a company for the front for government, U.S. government, and for those Turkish individuals to be told to stay away from Brewster Jennings.

But the person who received that information, the Turkish diplomatic but also operative, actually contacted the Pakistani military attache and discussed with the person who was there about this fact and also told them, warned them to stay away from Brewster Jennings.

Q: And now was this one of the allegations or one of the concerns that you

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A: You mean when I was working for the FBI --

Q: Yes.

A: -- and I blew the whistle inside the FBI?

Q: Right.

A: No, I didn’t do it inside the FBI because at that point I didn’t know they were covering up this information. Only after I was fired and the State Secrets Privilege was invoked, and knowing what I knew, I went to Congress and discussed it with certain people in Congress. I brought it up with the Inspector General’s Office inside during a meeting, and at that point will provide them the details in terms of dates and who were those targets, which I can’t provide right now, the direct targets.

Q: And when you say “the Inspector General’s Office,” do you mean a DOJ Inspector

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A: Correct. I’m sorry. Glenn Fine’s, under Glenn Fine’s office.

Q: And why would Mr. Grossman, if you know, warn the Turkish government and other people not to deal with this CIA front?

A: There were various relationships and various activities Mr. Grossman was engaged with these individuals, and I don’t know which reasons was the top reason for him to do it. Some of them were the monetary relationship, but others dated back to operations that he was leading while he was an ambassador in -- U.S. ambassador in Ankara, in Turkey, until 1997, and some of these operatives dealt with him, and they were doing certain operations in Central Asia for him.

I don’t know who he was working for, Mr. Grossman, at the time for his operations.

It’s hard for me to tell. He was involved in so many different things, and I

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Q: Just going back to the Israeli, we’ve talked mostly about the Turkish organizations.

A: Yes.

Q: Turkish government. Are you aware of the Israeli government or Israeli organizations influencing members of Congress as well?

A: Not directly, not directly.

Q: Indirectly?

A: Indirectly, based on how they work, some of the largest Israeli lobby groups with the entities such as ATC and also the Turkish diplomatic community and how they actually trained and make it possible for the Turkish lobby and these entities to do it. They had training period in ’96 and ’98 from individuals that were sent to them from both APAC and JINSA, both the lobbying, but also on covering the money track, covering up the

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Q: One of the other entries on your Wikipedia entry indicates that you had accused Mr. Hastert and other, quote, high ranking members of U.S. government of -- let me make sure I’m reading this correctly.

The entry says, “Edmonds also accuses Dennis Hastert of taking bribes.” I think we’ve talked about that; is that correct?

A: Yes.

Q: And then it says, “And high ranking members of the U.S. government of selling nuclear secrets to Turkey and Pakistan.”

Did you allege that high ranking members in the U.S. government had sold nuclear secrets to Turkey and Pakistan?

A: They were involved in operations that were obtaining illegally U.S. weapons and nuclear related technology and sell it to foreign governments and also foreign

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Q: Now, one of the other entries indicates, it says 911 For Knowledge, and I’ll just read it. It says, “She claims that the FBI received information in April 2001 from a reliable Iranian intelligence asset that Osama bin Ladin was planning attacks on four to five cities with planes. Some of the people were already in the country, and the attacks would happen in a few months.”

Did you -- did you make that claim?

A: I took the language specialist, Farsi speaking language specialist, senior language specialist from the Iranian Division, Farsi Division, FBI, Washington field office, who worked right next to me, to the 9/11 Commission and Inspector General’s Office, and he testified on this.

He informed me and he showed me this translator Bekru (phonetic) Sharsahr, and there are documents out there that he went to

page 67

I was not part of that translation. I was not involved. After I left the FBI because I was witness to that department, what they had obtained, I just facilitated Mr. Sharshar’s meeting with 9/11 Commission and also with the Glenn Fine, Department of Justice Inspector General’s Office, and I put him in touch with the members of media. But that’s my only involvement with that Iranian case.

Q: Do you believe that that’s why the 9/11 -- the families of the 9/11 victims wanted to get your testimony in connection with their case?

A: I am not sure because as far as I knew, it had to do with the government of Saudi Arabia and the Saudi Arabian financial institutions. I was not told anything about Iranian case.

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Q: We’ve talked about some members of Congress having connections with the Turkish government or Turkish organizations. Are there others that you’re aware of other than the ones we’ve discussed already?

A: Congressional members?

Q: Congressional members.

A: Yes.

Q: Can you identify some of them?

A: Their pictures are on the -- I have pictures included in my Website, and they can be identified. There’s several there outside the ones you named.

Q: I just -- I looked at the Website but didn’t recognize --

A: Okay.

Q: -- some of them. So would you be able to tell me who the other pictures are?

A: Others have been -- they’re all identified as public information.

Q: Yes.

A: Tom Lantos is one of them.

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Q: All right.

A: I believe he passed away, and Tom Lantos’ office would be not only with the bribe, but also in disclosing highest level protected U.S. intelligence and weapons technology information both to Israel and to Turkey. His office was also involved with that. It was not only bribery, but it was other very serious criminal conduct.

Roy Blunt is there. There have been individuals with a question mark there. The reason there’s a question mark is I lacked -- I was terminated by April 2002, but this particular Congresswoman -- the Turkish -- these Turkish organizations and operatives, if they can’t do it by money, they do by blackmail. So they collect information on sexual lives and other information like that, and with this particular Congresswoman, it being 2000 until I left, they -- this individual, this Congresswoman’s married with children, grown children, but she is bisexual.

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But she was -- there are things; information was being collected for blackmail purposes, and her lesbian relationship, and they, the Turkish entities, wanted both congressional related favoritism from her, but also her husband was in a high position in the area in the state she was elected from, and

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Q: And can you tell me how you know all that, everything you just told me?

A: I can’t discuss the intelligence gathering method by the FBI, but in general terms, when foreign targets among themselves discuss how they were going to achieve certain goals, objectives, and if those communications are collected and recorded, not only do you have that communications, but in some cases they involved field office surveillance team to see that actually they completed.

For example, if they say -- somebody says at five o’clock they’re going to bug his house, the surveillance team would go out and see that he had (unintelligible). So there were various ways that things were collected.

Q: All right. So just to make sure I

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A: Correct.

Q: And is this Congresswoman still a sitting member of Congress?

A: Yes.

Q: And why, if you know, would they want to blackmail this Congresswoman?

A: I don’t know what reasons they had, why they just didn’t do money. They needed -- I was trained as a language specialist by my agent for -- to find personal information, and one of the things that we was taught in the FBI -- everyone was taught in the counterintelligence -- that the target U.S. persons, whether they are in Congress or executive branch or whatever, first go by foreign entities to what they refer to as hooking period, and it was very common; it’s a very common way of trying to find vulnerability, and that is sexual, financial,

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And then the hooking period would take some times. Sometimes it takes months, sometimes one year. They would ask for small favor, but eventually after they reviewed the targets that the U.S. person -- some small favor, then they would go blackmail and that person would give them everything, nuclear related information, weapons related

page 74

Q: If you know, what was it that these Turkish entities wanted from this Congresswoman?

A: I know for sure that Armenian genocide was one, but also where she came from, that city or the district where she came from is where certain Turkish operatives, lobby groups run illegal businesses for fund raising for themselves to generate money, and for laundering that money they needed her influence in that district where she is from and also her husband because he husband was also involved, had some high level position, not an elected person, with where she came from, and they had another Representative who was making it possible, but supposedly she at that point was kind of -- was an obstacle. That’s all I know.

Q: In your experience, I mean, was this hooking technique used with other members

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A: Well, when I worked for the FBI, I work on operations that were not only current, but specific period of 1996 till 2000, 2001, December, 2003 January. So there were a lot of things that certain field office had provided me to go over, and some of that I didn’t complete, but one example would be with regard to Mr. Hastert. For example, he used the townhouse that was not his residence for certain not very morally accepted activities.

Now, whether that was being used as blackmail I don’t know, but the fact that foreign entities knew about this, in fact, they sometimes participated in some of those not maybe morally well activities in that particular townhouse that was supposed to be an office, not a house, residence at certain hours, certain days, evenings of the week.

So I can’t say if that was used as blackmail or not, but certain activities they would share. They were known.

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Q: With respect to the Congresswoman who they were -- you don’t know what happened ultimately because you left, right?

A: Correct.

Q: Or you were terminated.

A: Correct.

Q: But with respect to that Congresswoman you said one of the things that they wanted was you said Armenian genocide. I assume you were referring to the fact they wanted her support --

A: Yes.

Q: -- to oppose the Armenian genocide resolution.

A: Yes, and she was not leaning that way during that stage, until this hooking start.

Q: And does it surprise you that they would go to those lengths to gain her opposition to such a resolution?

A: Not at all.

Q: Why not?

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A: I don’t know what their reason is, but they are going to this extent. I mean, they may have -- I can only guess what their reasons are, but I think they would do anything. It’s a very important issue, and whether it’s money, whether sexual blackmail, anything they would do to not let this happen or get the support so it wouldn’t happen.

Q: Are you aware of -- other than the people that we’ve talked about, and I want to come back to Roy Blunt in a minute, but aside from the people we’ve talked about, are you aware of other current sitting members of Congress who you believe have been given money by the Turkish lobby, Turkish government to oppose the Armenian genocide resolution?

MR. FEIN: Objection. Speculation.

MR. MARINO: You can answer.

THE WITNESS: The pictures are there, and I just talked about that Congressional woman with the question mark

page 78

BY MR. MARINO:

Q: Just before I leave this subject, in your -- when we talk about the Armenian genocide, can you describe what your understanding of that is?

A: In terms of historically?

Q: Historically what it is.

A: It’s the genocide that the -- that was committed in Turkey against Armenians, and there -- I have read certain documents, historical documents in the past because this issue I have been aware of for a long time. Everybody in Turkey, they kind of know but they can’t admit they know, and it’s basically what was available in Turkey was very limited. So my knowledge would be just very, very limited knowledge of what occurred.

Q: All right. So just based upon,

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A: In Turkey?

Q: Yeah.

A: In Turkey, no. I mean, in Turkey nobody can even say they think about it.

Q: What about elsewhere?

A: In other countries like --

Q: Outside of Turkey.

A: -- outside Turkey?

Q: Yeah.

A: Yes. AT least in the circles that I’ve been it is seen as something that is -- that is accepted and that is known as one of those historical events that have taken place.

Q: Like the Holocaust in World War II, something that people generally regard --

A: Correct.

Q: -- as something that happened.

Are you aware of anyone and

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A: Throughout the years, because I used to be on the E-mail list of certain student associations that have international students, so I would get from the Turkish parts of those communities E-mails from this professor or that from Turkey visiting to give that lecture, but I don’t even remember their names of those people.

Is that the question? Did that answer the question?

Q: Well, I gather from what you are saying, that you would get E-mails possibly from Turkish organizations --

A: I did.

Q: -- people where they would dispute that the Armenian genocide took place.

A: Absolutely.

Q: Okay. Outside of that group, that cultural group, if you will, are you aware of other objective scholars who dispute that the

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A: I’m not.

Q: Why is Roy Blunt in your gallery?

A: One of the individuals who was the recipient of both legally and illegally raised donations, campaign donations from foreign entities.

Q: And what foreign entities?

A: The ones that I’m aware of, Turkish entities. It’s just like a network because those people, they worked together, and I don’t have expertise in PAC, but a lot of -- there are so many ways that these PAC things can be not very legally distributed from one person’s, let’s say, Mr. Hastert’s campaign to that individual or let’s say it’s a foreign registered lobbyist, like Livingston can get foreign money, but then clean it and then give it to him. It’s just so many ways. It’s a very complicated maze-like network on how they get this money cleared and into people, into people’s pocket and also their

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Q: Are you familiar with some of those PACs?

A: No, not really.

Q: Have you ever heard of the Turkish Coalition, USA PAC?

A: Yeah.

Q: So, I mean, you’re aware that the PACs exist, but you wouldn’t be able to identify any of them?

A: Correct, not by names, correct.

Q: Now, are you -- has it come to your attention that some members of Congress once they’ve left Congress like Dennis Hastert engaged in lobbying for the Turkish government?

A: Dennis Hastert is known publicly. Stephen Solarz is known publicly. He used to be a Congressman, and then he became lobbyist as soon as he left both for Israel and Turkey. Bob Livingston, he within a year after he left Congress, he became lobbyist for the

page 83

But then there are people who work for these lobbying firms who are not the top, but they have received their share while they were working, whether they are in Pentagon. One person was Defense Intelligence Agency person, Dana Bauer, and now she works for Bob Livingston, but this individual, Ms. Bauer, did a lot of favors and illegal favors to -- for government of Turkey and others, and then was hired by Livingston and put on a big salary to represent Turkish government.

So it’s not only top tier of the lobbying firm, but then the people who work for them later and the various layers of those people.

Q: How about Richard Gephardt? You know, who he is, right?

A: Yes, I do.

Q: And do you have any information about whether or not he took money from

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A: No, I just have (unintelligible) information based on what I read that he joined the lobby firm for -- that represents Turkey, the lobby that Mr. Hastert got hired, but I don’t have any information.

Q: For the firm called DLA Piper?

A: Yes.

Q: Law firm. Are you aware of them lobbying for the Turkish government?

A: Yes.

Q: Let me give you a hypothetical and just get your understanding of what might be going on because it’s particularly relevant to our case.

You have a hypothetical Congresswoman from State X. Her district has no Turkish population to speak of or Armenian population to speak of. She’s the largest recipient of Turkish PAC money in the 2008 election cycle. All right?

She meets with Livingston and

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What’s your sense? What does it tell you is going on there in --

MR. FEIN: Object. There’s no showing at all that she’s got any expertise. It’s speculation here. He’s asking purely for an opinion. It’s totally irrelevant and objectionable.

THE WITNESS: Based on several that I personally know about in terms of how they conduct and how they behave, those elected officials who are serving the foreign government’s interest, I would say that’s modus operandi that you describe. It’s a

page 86

BY MR. MARINO:

Q: And your view, based on what you know, would it be a reasonable statement to say that that Congresswoman is taking money from Turkish interest in part for denying the existence of the Armenian genocide?

MR. FEIN: Objection. Pure speculation?

THE WITNESS: Say based on my knowledge, my experience, and what I know, that money -- those Turkish entities’ lobby organization will not give a penny to anyone unless they have a prior pact with that person. This is what you’re going to do for

page 87

BY MR. MARINO:

Q: On your blog, one of the things that you say, you’re referring to your lawsuit, I think, but you say, “My case also involves espionage activities by several high level U.S. officials both elected and appointed.”

Have we already talked about for the most part what you were referring to there?

A: Some of it.

Q: What have we not talked about that you’re referring to in that portion of your blog?

MR. KOHN: Do you want to discuss it off the record?

THE WITNESS: Sure.

MR. MARINO: Do you want to take a break off the record?

(Whereupon, the foregoing matter

page 88

MR. MARINO: We had a pending question and during the break discussed it with counsel, and we agreed to withdraw that question basically because it was too broad and so forth, and it’s probably not necessary.

BY MR. MARINO:

Q: Let me ask you a different question, Ms. Edmonds. I understand that you executed an affidavit or a declaration actually in this case on August 5, 2009. I’m happy to show it to you. I’ve only got one copy, but I’m happy to show it to you if you’d like to see, but I just have some questions about some of the things you said in the declaration.

In Paragraph 3 of your declaration, you say, “I also obtained evidence that the government of Turkey had engaged in practices and policies that were

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Do you recall saying that in your declaration?

A: Yes.

Q: Can you tell me what practices and policies that you were referring to that were inimical to American interests?

A: There’s several. One is practices and operations implemented from mid-1990s at least until towards end of 2001 in Central Asia and Caucasus, and these operations and practices included Islamization of certain segments of those Turkic nations, Uzbekistan, Turkmenistan, Tajikistan. There are so many of them in that -- in that area, and setting up madrasahs and bringing in, helping bringing -- at the time they were not referred to as al-Qaeda until 2001, September 11th. They were referred to as mujahideens from Afghanistan and Pakistan into Central Asia,

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And also -- and it’s very broad I can go on for a long time about what practices and why they were -- they were against the security and the interests of the Americans and the lives.

Q: Okay. Well, I don’t want to burden you too much, but I would like as complete an answer as you can give us in terms of what you were referring to.

A: Those operations when until -- at least until September 2001, and again, for those operations, they corroborated and worked with certain U.S. persons who were involved in these operations.

The other, the obtaining, illegally obtaining and selling U.S. military and military technology and that includes weapons and nuclears, and even from foreign policy related secret or high -- top secret

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Q: Well, that was going to be my next question, is how do you connect what the Turkish government was doing to the direct and indirect loss of American lives.

A: One example of this would be with Brewster Jennings, for example, just selling that information and giving that information out in the hands of those foreign entities, including Pakistan. One of the things that the CIA was asked for right away, to do damage assessment, and one of the things that came out of it was the damage assessment included

page 92

And the third one that I started talking about were helping these individuals from Azerbaijan, the Turkey entities that served the mujahideen groups starting from 1995, 1996. They were given Turkish passports. In some cases they were given Azerbaijani passports, and they -- Turkey played a very active and important role in taking these people and moving them into Europe and some of those people actually ended up in the United States.

Q: And I think you indicated earlier that the Turkish government to your knowledge was provided support to what was once called

page 93

A: Correct.

Q: It’s now called al-Qaeda.

A: Right.

Q: And has it generally been publicly reported that al-Qaeda was behind the 9/11 attacks?

A: Correct.

Q: And that cost American lives?

A: Correct.

Q: How else has, to your knowledge, the mujahideen or al-Qaeda that Turkey was supporting cost American lives?

A: September 11 and the other category I talked about was the intelligence and identifying assets or the front companies. The third category that involved narcotics activities and that was, at least until I left, these Turkish people, and some of them are directly connected to Turkish intelligence and Turkish military in the United States, they played a very significant role in

page 94

Q: All right. So if I were to say that -- if I were a Congress person and I’m taking money from the Turkish government either directly or indirectly, would it be a fair statement that I’m taking money from a government that has engaged in policies and practices that cost American lives?

A: Correct.

Q: Are you familiar with a personnamed Fetullah Gulan, G-u-l-a-n?

A: Yes.

Q: Can you tell us who that is?

A: My information is mainly about his activities and issues that were, again, done from late 1990s until I left, and then after that it will be known activities here in the United States. He shortly -- he was the

page 95

And when he was wanted in Turkey for that and he was going to go to jail, he actually got on the plane and came to the United States, and he was given immediately visa to stay in the United States, and he has been in the United States until now as far as I know.

He has since established more than 300 madrasahs in Central Asia and what he calls universities that have a front that is called Moderate Islam, but he is closely involved in training mujahideen-like militia Islam who are brought from Pakistan and Afghanistan into Central Asia where his madrasahs operate, and his organization’s network is estimated to be around $25

page 96

He has opened several Islamic universities in the United States. As I said it’s being promoted under Moderate Islam. It is supported by certain U.S. authorities here because of the operations in Central Asia, but what they have been doing since late 1990s is actually radical Islam and militizing (phonetic) these very, very young, from the age 14, 15, by commandoes they use, and this is both commandoes from Turkish military, commandoes from Pakistani ISI in Central Asia and Azerbaijan, and after that they bring them to Turkey, and from Turkey they send them through Europe, to European and elsewhere.

Up until 1999, the Turkish government, also paramilitary units in Central Asia, they operated under the groups that call themselves Gray Wolves, ultra-nationalists, and their method was, you know, assassination of certain leaders in the Central Asian countries, and militizing, but not through

page 97

But after this scandal that took place in Turkey, Susurluk scandal, they were no longer supported by certain segments in the United States, and instead some of our people involved in foreign policy, they supported the Islamic movements of Gulan in the Central Asian countries in order to counter Russia as far as the energy sources are concerned in those countries.

Q: How is it, if you know, or how is it that Gulan is allowed to be in the United States?

Let me ask a different question.

A: Okay.

Q: I’m sorry. Is that an individual based on what you’ve told me that you would be -- that you would consider a threat to U.S. interests?

A: One hundred percent, absolutely.

Q: And if you know, how is it that he’s allowed to be in the United States?

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A: Because part of what he has in terms of the deal with certain segments in the United States is furthering the interests of the people who are interested in the energy sources in Central Asia, and that is the -- whether it’s oil or whether it’s natural gas, and basically it’s a fight.

The best way to describe it is Cold War is not over. It’s a continuation of Cold War over those nations, and what we did in Afghanistan in early 1980s with mujahideen, we have been joined now in Central Asia by using Islam and extremism and these madrasahs, and Pakistani and Afghani elements to build (unintelligible) and staff in terms of those resources towards certain business interests.

Q: Did you say that Gulan had set up schools in the United States as well?

A: Yes.

Q: Are some of those in Cincinnati, if you know?

A: I’m not sure. I know of some in

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Q: I assume that - -well, let me just ask you, and I’m not trying to put you on the spot. If you can’t answer, just tell me.

Would you be prepared to tell me who the Congresswoman is that we’ve been talking about?

A: I would have, and it wouldn’t be because of classification I don’t believe. I -- if in case this congressional person did not bend under the pressure in case. I just don’t want somebody, innocent person’s reputation destroyed because I don’t know if this person complied with whatever she happened to be blackmailed later. I think I --

Q: All right. That’s fair enough. I take it then from what you’ve told me that the

page 100

A: Yes.

Q: And what you’ve told me today about those people is not based on speculation.

A: No.

MR. MARINO: Can you just give me one moment please?

(Pause in proceedings.)

BY MR. MARINO:

Q: Are you familiar with reports that the Turkish nationals were being supported or acting as suicide bombers against U.S. troops overseas?

A: Not directly.

Q: Any doubt in your mind that the Turkish government has caused American lives?

A: No.

Q: Caused a loss of American lives?

A: No. And not only American lives.

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Q: Any question in your mind based on everything that you’ve experienced that the Turkish government has infiltrated members of Congress to get their support against or their opposition to the Armenian genocide resolution?

A: None whatsoever.

Q: I’ve asked you about members of Congress, but I haven’t asked you about staff. Are you aware of senior staff for members of Congress who have also been corrupted by the Turkish government?

A: Absolutely.

Q: Can you identify them?

A: The pictures are there.

Q: Who is Larry Franklin?

A: He was an analyst working for Pentagon who was indicted on charges of espionage and passing information to, I

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MR. MARINO: Okay. Well, I think that’s all I have. I think others may have some questions for you, but I do want to thank you again for your patience and for coming today..

MR. FEIN: I have many questions, but I don’t know whether you want to take a break yet. I suspect the questions may be at least an hour or two hours. So you need to estimate whether you want to break now or whatever you want to do or whatever counsel wants to do as well.

MR. MARINO: Yeah, we’ll take a lunch break.

MR. FEIN: Do you want to take a break?

THE WITNESS: How long for?

MR. FEIN: You decide. I’ll accommodate whatever you want, and I can talk

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MR. MARINO: Well, I think personally I always ask the witness how much time she wants, and then I ask the court reporters because they’re captives here. So I always try to -- yeah, why don’t we go off the record?

(Whereupon, at 12:45 p.m., the deposition was recessed for lunch, to reconvene at 1:30 p.m., the same day.)

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AFTERNOON SESSION



(1:31 p.m.)

SIBEL DENIZ EDMONDS

THE WITNESS: Before we start, I need to go on the record with one question about whether I had provided a deposition. In the past I answered that question saying in a business matter, but I forgot I provided -- I was deposed by the Justice Department on a federal tort claim which had to do with my family’s pictures, that the FBI had confiscated and lost, and for that particular case they deposed me for like two or three hours.

So I just want to go on the record and correct that.

MR. MARINO: Thank you.

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MR. FEIN: I guess we’re beginning the afternoon session.





CROSS EXAMINATION

BY MR. FEIN:

Q: Ms. Edmonds, my name is Mr. Fein, and I’m an attorney who represents Jean Schmidt in her complaint against Mr. Krikorian here before the Ohio Elections Commission.

When did you first learn of the complaint that Ms. Schmidt had filed against Mr. Krikorian?

A: About maybe ten days, two weeks ago, ten days.

Q: And how did you learn of that?

A: I either received an E-mail or call from Mr. Krikorian’s office, and I was told that there was this lawsuit, that I may be called as a witness.

Q: And who spoke to you?

A: I spoke with Mr. Krikorian.

Q: And what did he ask you to do?

A: He asked whether I would be

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Q: And what did you respond?

A: I don’t recall exactly, but I said -- I said, well, if I get a subpoena or just let me know what it is, then I will speak with my attorneys.

Q: Did Mr. Krikorian explain to you what the complaint was about?

A: No. He told me there was public information available and just in general he said that there was a complaint brought against him in the -- with the Ohio State Election Commission, and I just went and briefly read a couple of articles that were out there on the case, that the fact that this case existed to verify it.

Q: Did you actually read the complaint that had been filed before the Ohio Elections Commission?

A: Do you mean the actual legal

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Q: Yes.

A: No.

Q: Have you read it at present? When you came here today had you read the actual legal complaint?

A: No.

Q: So you don’t know what’s actually in the complaint; is that correct?

A: Just some major points that had been public on Websites and also on post.

Q: So you received -- Mr. Krikorian called you about ten days ago and your response was that you would be willing to be deposed or what exactly did you tell him?

MR. KOHN: Objection.

MR. FEIN: I apologize.

MR. KOHN: Asked and answered.

MR. FEIN: Well, I apologize.

BY MR. FEIN:

Q: What is it -- I want a clarification. When he asked you would you be

page 108

MR. KOHN: Asked and answered.

BY MR. FEIN:

Q: Did anyone inform you before you appeared today that the Ohio Elections Commission had stated it would not enforce the subpoena that had been issued for you to be deposed here?

A: I read the letter.

Q: So that you knew that you didn’t have to appear here.

MR. KOHN: Objection. It calls for a legal conclusion.

MR. FEIN: No, I’m sorry. I would like her opinion here. She’s testified about States Secrets Privilege. She’s testified about what genocide means. Those are all legal questions. She can testify about her subpoena.

MR. MARINO: Excuse me. I join in the objection.

MR. FEIN: Okay. Go ahead and

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MR. KOHN: What is the question?

MR. FEIN: The question is: did you read and understand that the Ohio Elections Commission had stated that they did not intend to --

MR. KOHN: Do you have a copy?

MR. FEIN: -- enforce the subpoena?

What?

I said did you have -- were you under that understanding that the Ohio Elections Commission in the letter had stated to all the attorneys involved in the Department of Justice they did not intend to enforce the subpoena that had been issued for you to be deposed here today.

MR. KOHN: Not quite my understanding of the letter.

MR. FEIN: I think it speaks for itself.

THE WITNESS: I read the letter.

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BY MR. FEIN:

Q: So in your view are you here voluntarily?

MR. KOHN: Objection. Calls for a legal conclusion.

MR. FEIN: I know.

BY MR. FEIN:

Q: Are you here voluntarily? Answer the question. In your view, are you here voluntarily?

MR. KOHN: -- is under --

BY MR. FEIN:

Q: Did anyone advise you that you were compelled to be here and you would be in contempt of an outstanding decree issued by a government agency if you were not here?

MR. MARINO: Excuse me. May I just make an objection?

MR. FEIN: Sure.

MR. MARINO: Object based on it calls for a legal conclusion, and now you’re asking for attorney-client communications.

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MR. FEIN: No.

MR. KOHN: I agree.

MR. FEIN: It’s not -- go ahead.

MR. KOHN: The witness is not going to answer that question because it’s outside the scope of her appearance.

BY MR. FEIN:

Q: Did you discuss what you would be saying here today to anyone before you arrived here at 10:30 or so?

A: Can you be more specific?

Q: Yes. Did you talk to somebody about what you would testify to in today’s deposition to anybody else? I’m not talking about the substance; just that you did, and identify the people who you spoke about.

A: I have responded to requests about comments about today as I don’t know. There are going to be questions, and I don’t know what questions I’m going to be asked, and after it is over and before, my attorneys will be present to make comments.

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Q: Did you talk to Mr. Krikorian about what you would be saying today?

A: To -- you mean this --

Q: Mr. Krikorian.

A: You mean what I’m going to say during deposition today?

Q: Yes.

A: No, no.

Q: Did you talk to anybody else about what you would be saying here today?

I’m not talking about the substance. Just a person that you can identify you spoke to about what you would be saying and what questions you might be confronting?

A: I have --

MR. KOHN: Let me just make -- excuse me. Let me just make an objection. I assume you’re not referring to her own counsel and asking whether she talked to --

MR. FEIN: No, I don’t want an attorney. I don’t want client -- attorney-

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THE WITNESS: I did not know what questions I was going to be asked. So I couldn’t talk about my answers.

BY MR. FEIN:

Q: Let’s go back to your hiring by the FBI. I think your testimony is it was September 15th, 2001.

A: Around that time.

Q: Okay. Now, were you employed prior to your hiring by the FBI?

A: Yes.

Q: And where were you employed?

A: Had my own company with my husband.

Q: Un-huh, and what was that company involved in? What business?

A: Technology for retail industry.

Q: And when was that company formed?

A: About 1996.

Q: 1996. Been about five years old company. Where was it -- do you know where it

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A: I believe Alexandria, Virginia.

Q: And so what were the -- what were your tasks at that company?

A: Marketing.

Q: Marketing.

A: And day-to-day management of people.

Q: I’m -- could you be a little more specific? You’re saying it’s a market -- it’s a retail marketing company. Do you offer your services to retailers? Do you actually sell retail items?

MR. KOHN: Do you have a relevant question?

MR. FEIN: Yes, I do have a relevant. It’s her background, knowing before going to the FBI exactly what her background in intelligence was.

MR. MARINO: I object. It’s outside the scope of the direct examination.

THE WITNESS: The position I had

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BY MR. FEIN:

Q: All right, and were there any employees of the company or just you and your husband?

A: No, at that time, I believe he had eight, seven or eight employees.

Q: So is it fair to say the company was involved in writing some kind of software that would enable retailers to do inventory control?

A: IT services.

Q: IT services. Did it have anything at all to do with intelligence collection?

A: No.

Q: Did it have anything at all to do with lobbying Congress or campaign finance?

A: No.

Q: How old were you when you were hired by the FBI?

page 116

A: Thirty-one.

Q: Thirty-one years old, and prior to that time, did you consider yourself an intelligence expert?

Did you do just as an avocation a lot of reading in intelligence collection and counterintelligence and espionage and how covert operations were run?

MR. MARINO: Objection. Compound.

THE WITNESS: Both in terms of my education and background and also certain activities that I was involved still while I was in the United States, in Turkey, and basically the kind of thing that you would consider -- today’s being considered citizen journalism.

BY MR. FEIN:

Q: Could you be more explicit? What’s citizen journalism? I’m not familiar with that concept. If you could, explain that concept to me.

A: Conducting research and write

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Q: So how many articles or books had you published when you were hired by the FBI?

A: I had not published any books.

Q: Any articles, any newspaper articles, op-eds, magazine articles.

A: It’s hard for me to tell how many of the stuff I had written have been picked up by international press, whether in Turkey or elsewhere. I have to check. I don’t know.

Q: Let me just give you an example. If I write an article, I will submit it and it may be published by the New York Times or the L.A. Times or something like that, and I know because I have an arrangement where you submit

page 118

Did you have any such arrangement with any publication?

A: No, I was doing it just mainly for public. The same thing for my activism with the Committee to Protect Journalists or also working on behalf of sexually abused children in Alexandria with Alexandria courts. I was going -- providing all those services and expertise for free because that was my public work as a volunteer.

Q: And how many hours of volunteer time would you do for a week would you suggest?

MR. KOHN: Can we have a time period?

MR. FEIN: The time period when you were working on your -- with your company. I guess it began in ’96.

THE WITNESS: My company was established in 1992, and I had other real

page 119

It depends. During, between ’96 and ’99 for Alexandria Court and sexually abused children I would spend about 15 hours a week working on that case. On researching and writing and reading about political related issues, including journalism, civil liberties, during that period of time it’s hard to estimate. I would say in the range of maybe ten hours a week.

BY MR. FEIN:

Q: What was the title of the position that you applied for for employment in the FBI?

A: Language specialist, contract language specialist for Turkey and another agreement that said contract language specialist for Farsi.

Q: Were the criteria for that job at all involved any knowledge, expertise in intelligence?

A: When they advertised and told me

page 120

Q: That’s -- that’s a good enough answer. And was that --

MR. KOHN: Had you completed your answer?

THE WITNESS: No.

MR. FEIN: Oh, did you want to -- if you -- if you think I’ve interrupted you, if you want to explain further, you just tell me.

THE WITNESS: Sure. The Special Agent, Dennis Sharshar, for Turkish Counterintelligence and Counterterrorism Division, he also had a say in the matter, and he wanted to evaluate my political understanding and understanding of Turkish criminal operations in general, including the ultra nationalist Gray Wolves, before he gave his okay, and we had a session that was during the time when my contract was being approved, and he made recommendations saying, yes, he needed my expertise in the area of Gray

page 121

So I don’t know how much role it played, his opinion, but that was one of the criteria that he wanted to have for his translator.

BY MR. FEIN:

Q: Was he the one who made the decision to hire you?

A: I am not sure about how the hierarchy works within the FBI. Was it taken into consideration? I don’t know because some of the Headquarters and the Headquarter people that I’m not sure who they were; they --

Q: So you -- and he -- did you have a separate interview with him in conjunction with your application?

A: After my application, yes.

Q: And this is before you were hired, as part of the application process?

A: No, this was during the time that they were drawing my contract. Because of September 11th terrorist attack, they wanted

page 122

Q: So that when you -- at the time you were hired, you were not -- had not been interviewed by anybody at the FBI. This was just based upon your written application; is that correct? Because there was such an urgency?

A: Correct. Three years before that it was polygraph test for background check and the filling out application, but I was never interviewed by anyone in the FBI ever.

Q: And how long did it take after you applied before you were hired?

A: I don’t recall. In the range of not weeks, maybe a week or ten days, but I’m -- I don’t recall exactly how long it took.

Q: And does the FBI have the GS level pay compensation schedule?

A: As far as I know, they don’t have

page 123

Q: Were you a contract or a full-time employee?

A: I was a contractor.

Q: So what were you -- what were the terms of the contract? How much were you paid? What was the length of the contract? What were your obligations?

Did you actually show up at the premises or did you work off premises?

A: No, I showed up the premises and --

Q: Was it at the J. Edgar Hoover Building?

A: It was Washington field office, which is only a few blocks from the FBI Headquarters.

Q: Okay. Let’s go -- I’ll -- I’ll -- let’s go thought item by item. What was your compensation rate?

A: I don’t recall exactly. It was in

page 124

Q: So they paid you on an hourly basis.

A: Correct.

Q: Did they have a minimum or a maximum number of hours you’re supposed to work per week?

A: They asked me to work 40 hours or more because they needed both my expertise in language and also in the active, urgent cases the FBI had, but I could not because I have another job, and I was also preparing for my Master’s degree. So I couldn’t give them more than 25, 30 hours a week, and they wanted much more, and they kept asking me, and they also gave me the application and asked me to apply for agent position at Quantico because they needed my expertise and language skills, and I got official letters, recommendations, recommending me to Quantico because of my knowledge, expertise, and the language skills.

Q: Did you actually apply for a full-

page 125

A: No.

Q: No.

A: They couldn’t pay me enough. I couldn’t do that.

Q: So they offered you 35 to $40 an hour, and was it up to you or did you have to work a minimum number of hours in order to stay as a contractor?

A: They told me everything was up to me because they couldn’t find someone with my expertise in language skills and the background checks. So anything I could do, even if it was ten hours I could spare, would be great because they wanted me to work for them full time or overtime.

Q: And was there a time -- was there a term for the contract?

A: I believe so. I am not sure about the date, whether by the end of that year, because I started in 2001, whether it had to be renewed by January 2002, but there was a

page 126

Q: Had the time period expired and you were renewed in April of 2002 when you were let go?

A: That may have been the case. It was eight years ago. I don’t recall.

Q: And during the period when you were with the FBI, about how many hours per week did you, in fact, work?

A: It was not exactly the same way every week because based on my school schedule, based on my family life and work, some weeks I was able to work maybe 30 hours. Some weeks I was able to work about 15 hours. If you were to average it, it would be in the range of 20, 25 hours a week.

Q: So that would be about half time, and let’s assume 40 hour week would be a standard work week for someone who’s employed full time. You were somewhat like a half-time employee in terms of hours.

page 127

MR. KOHN: She was a contract employee.

MR. FEIN: I know. Well, I’m a little bit confused when you -- independent contractor may have different rights and legal obligations as an employee who may get pension benefits and all sorts of health insurance. I worked in the Department of Justice for 15 years, and contractors would not be entitled to those benefits like an employee was.

BY MR. FEIN:

Q: Were you identified in your contract as an independent contractor or an employee for purposes of these benefits and other what you would call subsidiary remuneration for working?

A: Independent contractor.

Q: Do you know how many other independent contractors were working with the FBI about the time you were?

A: No.

MR. KOHN: I presume you’re

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MR. MARINO: Yeah, in -- in --

THE WITNESS: Language.

MR. MARINO: In the language, the translation area.

THE WITNESS: No. I know several. There were more than 200, 300 people in that department, combination of full time and contractors, and my knowledge is limited to the Farsi Department and maybe Turkish Department because things were changing. Some people would start as contractors and wanted to work full time. So I can’t give you an exact number.

BY MR. FEIN:

Q: Do you know whether it was customary that other independent contractors work on an average 20, 25 hours a week where you were in the mid-range or did you not know about other independent contract arrangements?

A: I don’t.

Q: You didn’t know?

page 129

A: I didn’t know.

Q: You didn’t know about any other kind of arrangement. And tell me exactly what were the work place arrangements for you to perform your work? Did you go to a fixed office at the FBI? Were you given opportunity to choose where you wanted to listen to tapes? How did that work?

A: I can’t give you details because of the area, but it was combination. As far as my main work that I was asked to do because it was top priority outside counterterrorism, it was only Washington field office, and that was where from other field offices they would send information related to Turkish related area and I would translate.

But for certain counterterrorism tasks I had to go to Philadelphia or New Jersey to the Special Agents. In some cases I had to interrogate 9/11 detainees that were shackled in rooms who didn’t speak English and they spoke either Turkish or Farsi. It was a

page 130

Q: So your tasks included not only listening to tapes, but doing interrogation of detainees?

A: I can’t say tapes or not tapes, but in addition to audio, it was written. Also it included live interviews, going to various field offices, and translate interrogation results.

Q: So let me be clear in my own mind. You would translate an answer, but you wouldn’t be the one making up the questions for the detainees or is that inaccurate?

A: It depended because after September 11th, some of the FBI agents, they didn’t know anything, and they were very nice and good to know that they didn’t know anything. So they would defer to my expertise to ask the right questions from detainees and some of the immigrants they had rounded up. In some cases there were certain Kurdish individuals, and even the Special Agent in

page 131

So, yes, in fact the Special Agents in Charge deferred to me to draft questions because they didn’t know where Turkey even was.

Q: Can you give me -- and I don’t want to intrude on intelligence sources and methods --

A: Right.

Q: -- can you give me an example of a particular question you drafted for a detainee?

MR. KOHN: I think that would be --

page 132

THE WITNESS: I can’t make it up.

MR. FEIN: Withdraw the question.

BY MR. FEIN:

Q: Mow, I think that in your testimony this morning you stated that the allegations that you had made internally to the FBI about various amounts of wrongdoing had all been substantiated by the Inspector General’s report. Is that your recollection and statement, that your allegations were all substantiated by the Inspector General?

A: No, I said the Inspector General’s report is public and you can defer to it, and I believe I was asked about Dickerson espionage case, and on that particular case I said the report substantiates and states that those allegations were supported by other witnesses and documents, or some language to that effect.

Q: Now, were there other allegations that you made that the OIG said were not

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MR. MARINO: Objection. Foundation. You haven’t established that the OIG looked with the other allegations.

BY MR. FEIN:

Q: To your knowledge, did the OIG look at allegations, for example, relating to misuse of travel?

A: Yes.

Q: It did look at those, and do you recall whether the OIG substantiated your allegations on that score?

A: I don’t recall. It may have been one of those that it was not conclusive or they didn’t have other witnesses. I’m not sure. It’s been a while since I read the report, but we can bring the report and I can go over that.

Q: Would it surprise you if I gave you the report and it said that it was unable to substantiate your travel allegations?

A: Not at all.

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MR. KOHN: I don’t think she knows you well enough to be surprised.

BY MR. FEIN:

Q: After April when you were discharged or you weren’t renewed by the FBI, what then did you turn to for employment or work or what then occupied your time?

A: What period of time you’re referring to?

Q: Well, why don’t we -- let’s take it year by year and maybe we can abbreviate it if there’s some years that are the same. So from April in 2002 to the end of 2002, what were you doing after you left the FBI?

A: Oh, I had just begun my case with -- my court case with my attorneys. So most of my time was concentrated on my case, legal case, in court and the necessary research related to my case.

Q: Okay. So you were working on challenging the legality of your discharge; is that correct?

page 135

A: Yes.

Q: And what about 2002 to 2003?

A: More research and contacting other FBI and CIA and Department of Defense witnesses who could have known about these cases or worked in the relevant areas, and my legal case, and starting my organization around that time, which is a nonprofit organization.

Q: Okay. What’s the name of the organization?

A: National Security Whistleblowers Coalition.

Q: And is that incorporated as a 501(c)(3) organization or what’s the corporate --

A: It’s 501(c)(4).

Q: (c)(4) organization, and that was incorporated in 2003?

A: I believe it was 2000 -- end of 2004.

Q: End of 2004?

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A: Correct.

Q: And what is the mission of that particular organization?

A: It works with intelligence and law enforcement related individuals who have been wrongly treated or retaliated against for whistleblowing, in general, and helping them with their cases, legal cases, referring them to attorneys, analyzing their cases, their court cases, their filings, and also coordinating with the media about any release or statements on their cases’ development, and also legislation activities with Congress.

Q: Who are the officers of that organization?

A: It’s myself.

Q: What’s your title?

A: I’m the founder and director, and we have -- I have two senior advisors. One of them is Professor William Weaver, who used to work for NSA, National Security Agency, and now he’s a senior professor at the University

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Q: And who is the other senior advisor?

A: Steve Elson. He was the top ranking Federal Aviation, FAA Red Team member on terrorism related operations.

Q: So you are the director and then you have two senior advisors. Is there a board of directors?

A: Yes, and the board of directors is myself and Steven Elson and William Weaver.

Q: Any others?

A: No, not that --

Q: Are there any other officers, a treasurer, secretary, anything like that?

A: That would be me.

Q: That’s all you?

A: Yes.

Q: And is this a stock or non-stock corporation?

A: No.

Q: It’s a non-stock corporation. How

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A: It’s based on volunteer work, and all my members, they all work as volunteers for the organization. So I have a hundred workers who work without getting paid.

Q: Do you solicit any contributions?

A: No, not right now.

Q: Are the revenues zero?

A: Correct, because I am independently wealthy at this point, and I don’t need to owe anything to anyone. So I don’t have to raise funds.

Q: What is the street address of this organization?

A: It has a P.O. box.

Q: It has a P.O. box.

A: Correct.

Q: Is it fair to say it operates out of your house, your residence?

A: And other members’ residence, too, and also the coalition organization. I have

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Q: And how many volunteers have you had?

A: It depends with the time period. During congressional legislation activities, sometimes I have 60 who are working with writing articles and working with the media, going to Congress, meeting with various congressional offices. In certain quieter periods, I may have only one. So it just depends.

Q: Do you keep track of how often your organization is quoted in the media through Google or otherwise?

A: We have a press section which keeps track of it. Again, certain periods when we have high level congressional activities, which we had a lot in 2000 -- end of 2005, it was almost daily, which would be Congressional Quarterly, Federalist, and all

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Q: What about getting articles that the organization has written published in the me