Page 1
BEFORE THE OHIO ELECTIONS COMMISSIONDEPOSITION
þ---------------------------»IN THE MATTER OF:
JEAN SCHMIDT,

:
:
:
:
:
:
: Case No.

Plaintiff,v.

: 2009E-003
DAVID KRIKORIAN,::
Defendant.
:::þ---------------------------¼
Saturday,August 8, 2009
National Whisteblowers
Center3238 P Street, N.W.
Washington, D.C. 20007
DEPOSITION OF:
SIBEL DENIZ EDMONDS
called for examination by Counsel for the
Defendant, pursuant to Notice of Deposition,at the National Whistleblowers Center, locatedat 3238 P Street, N.W., Suite 690, Washington,
D.C., when were present on behalf of therespective parties:

Neal R. Gross & Co., Inc.
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Page 2APPEARANCES:
On Behalf of Plaintiff Jean Schmidt:

Of:

BRUCE FEIN, ESQ.
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:Of:

DAN MARINO, ESQ.
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:Of:

MICHAEL D. KOHN, ESQ.
Kohn, Kohn & Colapinto, LLP
3233 P Street, N.W.
Washington, D.C.

20007

Tel: (202) 342-6980

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TABLE OF CONTENTSWITNESSDIRECTCROSSREDIRECTRECROSS

6

105

190

212

Sibel Deniz

Edmonds

Ex.
NO.

DESCRIPTIONIDENTIFIED

Edmonds Deposition:

1

Subpoena. . . . . . . . . . . . . . . .7

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1

P R O C E E D I N G S

2(10:32 a.m.)

3

VIDEO OPERATOR:

Will counsel and4others present, please introduce themselves

5and state whom they represent?

6

MR. MARINO:

7

behalf of Mr. Krikorian.

8
9

MR. FEIN:

Dan Marino here on

Could I interject anobjection here?

10

Is Mr. Marino admitted in this11

case to practice before the Ohio Elections

12

Commission?

13

MR. MARINO:

14

MR. FEIN:

15

What is the answer tothat question, sir?

16
17

Why don't you --MR. MARINO:

Why don't you goahead and identify yourself?

18

MR. KRIKORIAN:

19

MR. MARINO:

20

Do you want to?

Who's the next gentleman?

21
22David Krikorian.

MR. ELWOOD:

Phil Elwood.

I workat KL.

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1
2

MR. MARINO:

I'd like to haveeveryone identify themselves.

3

MR. FEIN:

4

MR. MARINO:

5

MR. FEIN:Sure.
And you're Mr.?
I'm Mr. Bruce Fein.

6

I'm counsel for Jean Schmidt in this7

proceeding.

8

MR. MARINO:

9

MR. KOHN:

Okay.
I'm Michael Kohn with

10

Kohn, Kohn & Colapinto, representing the11witness Sibel Edmonds, and with me are three12

law clerks.

That's it.

13

VIDEO OPERATOR:

14

Will the court reporter please15

swear in the witness after which we can begin?

16

THE REPORTER?

17

raise your right hand?

18

Whereupon,

19

Thank you.

Would you please

SIBEL DENIZ EDMONDS

20

was called as a witness by counsel for the

21

Defendant and, having been first duly sworn,22

was examined and testified as follows:

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1

DIRECT EXAMINATION

23BY MR. MARINO:
Q

Okay.

Good morning, Ms. Edmonds.

4

I introduced myself to you off the record.

5

name is Dan Marino.

6with the law firm of Luque, Geragos & Marino

7

here in Washington, D.C.

8My

I represent Mr. Krikorian

MR. FEIN:

I'm going to interpose

9

an objection to Mr. Marino asking the question

10

because there's no showing that he has been

11

authorized to participate in the proceeding at

12

issue in this particular matter.

13

MR. MARINO:

14

for coming this morning.

15

MR. FEIN:

I want to thank you

Does Mr. Marino have --16

Mr. Marino, do you have any proof that you've

17been admitted to practice in the proceeding

18

before the Ohio Elections Commission in the19case of Jean Schmidt v. David Krikorian?

20

BY MR. MARINO:

21
22

Q

I'd like to show you what's beenmarked --Neal R. Gross & Co., Inc.
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1

MR. FEIN:I interpose a standing

2

objection, and I will to every single question

3

Mr. Marino asks until he establishes and4

testifies or otherwise documents that he is5

authorized to participate in this proceeding,6

and that if he continues to do this, we will

7

consider seeking sanctions, including the8unauthorized practice of law in Ohio.

9

BY MR. MARINO:

10

Q-- to show you what's been marked

11

as Exhibit 1 to your deposition.

12

one copy of it.

13

from the Ohio Elections Commission for your14

testimony today.

15
16

I only have

It purports to be a subpoena

Have you seen that before?
A

My attorney's office received it.

17

I believe I have seen the PDF version of that.

18(Whereupon, the document referred19

to was marked as Edmonds

20

Deposition Exhibit No. 1 for

21

identification.)22

BY MR. MARINO:

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Q

Okay, and I take it that you're2

here in response to that subpoena today,

3

correct?

4

A

5

Correct.
MR. FEIN:

Now, I interpose an

6

objection again because the documentary7

evidence shows the Ohio Election Commission

8communicated to Mr. Marino that they had no9

intent of enforcing their subpoena beyond the10territorial jurisdiction of Ohio, and that Ms.

11

Edmonds was under no compulsion to attend

12today, and that was made abundantly clear, and13

that's a misstatement of the record made by

14

Mr. Marino, and I highly object to that15

mischaracterization of why Ms. Edmonds is here16

today.

17

MR. KOHN:

Let me clarify.

Ms.

18

Edmonds is here today with respect to that19

subpoena as a courtesy rather than traveling20

to Ohio.

21
22

MR. FEIN:

That is simply a simply

a misstatement of the record in this case,

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Page 91which made quite clear that the Ohio Elections

2

Commission was not ordering Ms. Edmonds to3

appear, that the Justice Department also

4

considered the subpoena that was issued to her

5here, and that if she wanted to come to Ohio

6

and they wanted to issue a subpoena in Ohio,

7

that's up to them.

8

That is not what happened in this9

particular case.

10

the record.

11

That is a misstatement of

MR. KOHN:

Well, I guess you don't

12

understand "courtesy" within the legal

13

community --14

MR. FEIN:

You don't understand15

there are documents that have been issued in

16

this particular case.

17

document issued by Mr. Phil Richter, the18counsel for the Ohio Election Commission, said

19

there was no jurisdiction, and they did not20

intend to enforce this subpoena in the21District of Columbia, and that there was no22

compulsion on Ms. Edmonds to attend thisIn particular, theNeal R. Gross & Co., Inc.
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deposition today.

2

MR. MARINO:

Okay.

Kind of makes

3

you wish you went to law school, right?

4

BY MR. MARINO:

5

Q

All right.

I do want to thank you

6

for coming today, Ms. Edmonds, and I did talk7

to your counsel before the deposition and

8

asked him to communicate and I'll tell you the9same thing.

10in this case, and I'm going to be asking you

11

a series of questions about -- some about your12

background and some about some of the things

13

that we've seen in the press in connection

14

with some of the issues you've had with the

15

U.S. government, et cetera.

16

I just became involved recently

And I do want to sort of advise17

you that until the last couple of days, I

18really had heard nothing about this case, and19

so some of my questions are going to seem

20

somewhat elementary, and it's not because I'm

21

playing Colombo or anything like that.

22

just because I really don't know the

It's

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information.

2

And in a sense, I think that will3

be good because what we're hoping to do with4

your testimony is provide some education to5

the folks involved in this thing.

6

process of educating me, maybe we'll be

7

educating some of the listeners, people who

8will see your deposition testimony.

9

So in theHave you had your deposition taken

10

before?

11A

In business maybe.

12

Q

Okay.

13

process.

14

series of questions and I'm just going to ask

15

you to answer them to the best of your16

ability.

17

people from time to time, and unless someone

18

tells you not to answer the question, it's

19

okay to go ahead and answer it.

Then you understand the

As I said, I'm going to be asking a

You'll maybe see objections from

Okay?

20

And of course, you can take your21

guidance from your counsel on when to answer

22

a question and when not to.

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If at any time you want to stop2

and take a break, talk to your lawyer, get a3

drink of water, whatever, just let us know,

4

and we'd be happy to accommodate that.

5

I'd like to start if we could with6

just a little bit of your background, just for7

the record.

8

reading I did that you, I think, were born in

9Iran; is that correct?

10

A

11

I understand from some of theCorrect.
MR. FEIN:I object.

This is the12standard that Chris Finney asserted in Mr.

13

Krikorian's deposition when the question was

14

raised this fall to Mr. Krikorian, and I'm

15

reading from the transcript of his deposition,

16

page 9.

17"Are you a lifetime Cincinnati

18

area resident or did you move here at some19

point?"

20

Mr. Krikorian's attorney, Mr.

21

Finney, "Objection.

22

with the case?"

What does this have to do

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And the statement that we agreed

2

to with Mr. Finney, that unless there's a3

particular question that goes to the4allegations of falsehood and intentional

5

falsehoods

6

That's the standard that Chris Finney, counsel

7

for Mr. Krikorian, established in his

8deposition, and it applies here in the same

9

way.

in this case, it is off limits.

10

Whether she was born in Iran has

11nothing to do with the allegations that I can12

see that Jean Schmidt has lodged against Mr.

13

Krikorian.

14

of some relevance, then I object to answering

15

that question the same way that Mr. Finney

16

objected to Mr. Krikorian answering whether he17

was a lifetime Cincinnati resident.

18
19
20

Unless there's some demonstration

BY MR. MARINO:Q

I think you answered that, yes,

you were born in Iran.

21

A

Yes.

22

Q

And you ultimately moved to Turkey

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2

at some point; is that correct?
A

3

Correct, because I -MR. FEIN:

And I also have a4

standing objection on relevance for the same5

reasons.

6

BY MR. MARINO:

7

Q

8

answer.

9A

I'm sorry.

I didn't get theYes, because I was always a

10Turkish citizen because my parents were11

Turkish.

12

father's job, and then we moved back to

13Turkey.

14

Q

So we were there because of myAll right, and I understand you

15

speak a number of languages in addition to

16

English, correct?

17

A

Correct.

18

Q

What are --19

MR. FEIN:

Objection.

20

BY MR. MARINO:

21

Q-- those languages?

22

A

Turkish is my primary, my mother

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language.

2

Q

Okay.

3

A

After that, Farsi.

4That's thelanguage spoken in Iran.

5

Q

Okay.

6

A

And I also have conversational

7

abilities in Azerbaijani.

8

MR. FEIN:

I just interpose a9standing objection so we can move along on

10

relevance grounds that I don't believe that11

there's been any establishment that the12witness knows anything about the allegations

13

in the complaint.

14

along, I'll have a standing objection on

15

relevance to every single question asked until

16

there's some connection between her knowledge

17of the complaint and the question that relates

18

to the facts in the complaint.

19
20
21
22

So just to speed things

BY MR. MARINO:
Q

And at some point you moved to theUnited States, correct?
A

Correct.

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1

Q

And when was that?

2

A

1988, July 1988.

3

Q

All right, and can you just tell

4
5

us about your educational background, please?
A

Sure.

I have a Master's degree in6public policy from George Mason University.

7

I have Bachelor's degrees in psychology and in8

criminal justice from George Washington

9

University.

10

from Northern Virginia Community College in11

biology, and I finished high school in Turkey.

12

I graduated in 1988 in Istanbul.

13

Q

I have a AS (phonetic) degree

And I understand, again, just to

14

move things along a little quickly, that at

15

some point you became a contract employee with16

the Federal Bureau of Investigations; is that17

correct?

18

A

Correct.

19

Q

And when was that?

20

A

I started working for the FBI on

21
22around September 15, 2001.
Q

And when you became employed at

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the FBI, did you receive a top secret security

2

clearance?

3

A

Yes, I did.

4

Q

And how did it come to be that you

5

were working for the FBI?

6

A

7

story so it's

8

When I was studying for my Bachelor's degree,9

criminal justice/psychology, I had applied for10internship position with the FBI, and this11

would be around '97, 1997, 1998, and they12

never responded to me and except that they13

were interested in my linguistic abilities

14

because I spoke Turkish and Farsi.

15

Okay.

I will try to summarize thenot -- it won't take too long.

And then I didn't hear back from16

them, and I was contacted around September 11,

17

2001, and they said they had obtained top

18

secret clearance for me, and they needed my19

services for translation in Turkish and Farsi,

20

and they wanted me to start immediately, and21

because I couldn't work full time, I took the22

contractor's position with the FBI for

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Page 181translation of those languages, and to a2certain degree Azerbaijani.

3Q

All right, and so can you describe

4what your job was with the FBI aside from

5translating those languages?

6

A

I assisted Special Agents, both my7-- the primary supervisory Special Agents in

8

Washington, D.C. field office, but also

9Special Agents in charge of various

10

counterintelligence and counterterrorism

11

investigations around the country, and those12

were different FBI field offices.

13

Q

Now, when you refer to14

counterintelligence operations, can you just15

tell us what that means?

16

A

Counterintelligence operations in

17

the FBI had to do with collecting information,

18

monitoring -- and monitoring particular target

19

foreign entities in the United States.

20

Q

And just to -- I'm probably over21

simplifying it, but it's a matter of public

22

record that the FBI may have people who listen

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to telephone conversations, other types of2intercepted conversations that are in foreign3

languages --4

MR. FEIN:

5BY MR. MARINO:

6
7

Q

Leading question.

-- and they have translators whotranslate those, correct?

8

MR. FEIN:

Objection.

9

THE WITNESS:

Leading.

Information could

10

have been both conversational audio, but also

11

documents, written documents, or in certain

12

cases direct surveillance.

13

MR. MARINO:

14

MR. KOHN:

And -For the record, I'd

15

just like to note that I've asked the witness

16

to limit her responses only to the information

17

that she believes to be publicly available or18

she has learned from sources outside of her

19

employment.

20

record.

21
22

So I just wanted that on the

MR. MARINO:

Okay, and I

appreciate that, and you know, I have had in

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the past the chance to work with intelligence2

officers in these kinds of cases, and I

3

realize that you can't get into sources and4methods and so forth.

5that area in any way, just let me know and6

I'll back off.

7
8

If I'm straying into

BY MR. MARINO:Q

It is a matter of public record,

9

however, that our government through the FBI

10primarily does do counterintelligence work

11with respect to foreign nationals and foreign

12organizations, correct?

13

A

Correct.

14

Q

And that would include Turkish

15organizations?

16

A

Correct.

17

Q

And my understanding is that you

18

were terminated by the FBI or at least your19

contract was terminated in was it March or

20

April of 2002?

21

A

April 2002.

22

Q

All right.

And so from September

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1of 2001 until April 2002, you were engaged in2

this activity of listening to and translating

3

documents and conversation audio, correct?

4

A

Correct.

5

Q

And, again, these were materials

6

that were related to counterintelligence

7

operations, correct?

8A

Not limited to9counterintelligence.

Some of them crossed

10

over criminal related investigations, and also

11

counter -- I also translated for

12

Counterterrorism Division.

13

Q

So all three of those.

14

A

Correct.

15

Q

Now, -- and I take it that you

16

were translating obviously the languages that17

you were fluent in, correct?

18

A

Turkish, Farsi.

Although initially I performed

19translation for all three languages, but

20

within a few weeks because of the need in the

21

FBI, urgent need, I was placed primarily on

22Turkish, and that became my main language that

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1
2

I used to work for the FBI.
Q

So, again, I know it sounds

3

elementary, but just by way of background, you

4were translating documents and conversations

5

that were created by and spoken by people who

6

spoke Turkish, correct?

7

A

Correct, but because the targets

8

could also speak English, and this couldn't

9

have been known to the FBI agents until I

10first went through the information, I also had

11

to transcribe and make notes of pertinent

12

conversation, pieces of conversation in

13

English also.

14

English conversation and notify my bosses in

15

the FBI of the ones that were very important.

16

Q

So I had to listen to a lot of

Okay.

Now, let me jump ahead to17

April 2002, and you said your contract was

18

terminated by the FBI.

19

that happened?

20

A

Can you tell us why

After I was hired by the FBI in

21

September 2001, about a month or so later, FBI

22

hired another language specialist for Turkish

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1

Division in the FBI's Washington field office,2

and a few weeks after this person, Melek Can

3

Dickerson -- M-e-l-e-k, middle name C-a-n,

4last name Dickerson, D-i-c-k-e-r-s-o-n -- and5

she also had top security clearance.

6

My main primary agent for Turkish

7

counterintelligence and I, we through various

8

evidence and incidence became aware that she

9

had worked for certain Turkish organizations

10and entities that were directly the targets of11

FBI counterintelligence investigations, and12that she had lied in her application, and that13

for unknown reasons to us -- I don't know why

14-- the FBI security background check had not15caught that important information despite even16

her tax filing records.

17

And not only that; Melek Can

18

Dickerson and her husband, at the time he was19

a major with the Defense Intelligence Agency,

20

Major Douglas Dickerson, and he was working

21

for Douglas Feith's office and was a22

coordinator with the State Department on the

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1

Turkey Republics in Central Asia; both husband

2

and wife, Melek Can Dickerson and her husband,3

they were still associating and had working

4

relationships with these Turkish entities,

5

individuals and organizations that were the6targets of FBI investigations.

7

As we started reporting this to8

our superiors, initially there was a panic in9

the department, but as it went up further to10

the headquarters -- this is the FBI

11

Headquarter -- they started -- the FBI

12

Headquarter started retaliating against me and13

eventually they terminated my contractor.

14

And there is an Inspector

15

General's report available publicly that came16

out, I believe, in 2005 that confirmed all my

17allegations and the fact that FBI fired me

18

simply due to my activities in whistleblowing

19

in making this known to the FBI and later to20

the Congress, and that the evidence on the21translator in question was supported by other22

witnesses from the FBI and documents.

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1

So that's a public document2

report.

3

Q

All right.

There's an4unclassified version of that report which has

5been made public, correct?

6

A

Correct.

7Q

And that report basically

8

substantiated the allegations that you were9

making regarding Ms. Dickerson, correct?

10

A

Correct.

11

Q

And the concerns that you had

12

regarding Ms. Dickerson pertained to espionage

13

really, no?

14

ACorrect.

15

Q

And in part -- and that was in

16

part because of the fact that she was17

associated with these -- she and her husband

18

were associated with these targets of

19

counterintelligence operations.

20

A

Correct.

21

Q

Who were Turkish entities,

22

organizations; is that correct?

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1

A

Yes, and certain U.S. entities who2were also part of these espionage related

3

operations.

4Q

Was one of the organizations that5

you were concerned about the American Turkish

6

Council?

7

A

Yes.

8

Q

Were there others?

9

A

Yes.

10

Q

Can you identify them, please?

11

A

Certain Turkish diplomatic

12

community in Washington, D.C. and other13

locations and other Turkish cultural and14business related associations and lobbying

15

groups in various -- with various chapters in

16

various cities and states in the United

17

States.

18

Q

All right.

Without asking you

19

specifically who the targets were20

point, when you hear the term -- well have you

21

ever heard the term "Turkish lobby"?

22

A

at this

Yes.

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1

Q

What does that mean to you?

2A

Can you be more specific?

3

Itmeans many things to me.

4Q

I mean just what comes to mind

5

when you -- again, I came into this a couple

6of days ago.

7

lobby."

8

someone uses that term, can you tell us either

9generally or specifically what it means to

10

you?

I've seen the term "Turkish

I've seen people referring to it.

11

A

12

things.

13that is classic lobbying for its interests,

14

governmental relationship interests, commerce,

15

et cetera, and the other category is the16

covert activities and operations by the lobby

17

that many of which may not be legal.

18

Q

Correct.

If

It means two sets of

One set is the overt Turkish lobby

And when we talk about the overt

19

Turkish lobby, can you identify the

20organizations you're thinking about here?

21
22

A

There are so many.

AmericanTurkish Council is the primary organization,

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Page 281which is -- directly works with the diplomatic

2community in the United States, Turkish

3

diplomatic community, that is.

4

another umbrella under which there are various

5

locations and chapters, such as ATA Chicago,

6

ATA Patterson, New Jersey, ATA D.C., and also

7

some that are identified as cultural, such as

8

TACA, Turkish American Cultural Association.

9

There are hundreds of small chapters, and I

10

don't know some of these, but the main ones

11

would be American Turkish Council, ATAA, ATA

12

and its various chapters throughout the13

country in the United States, TACA.

14

American Business Association is another15

primary one.

16

Q

17

ATAA wasTurkishATAA, is that the Assembly of

Turkish America Associations?

18

A

I believe that's what it is.

19

Q

How about have you heard of the

20
21
22

Turkish Coalition of America?
A

Just through some cursory reading

recently.

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1

Q

Okay, and are you familiar with an

2organization called the Turkish American Legal

3

Defense Fund?

4

A

I don't recall.

5

Q

Have you ever met Mr. Fein before

6

who is present here today?

7A

I haven't met him personally.

8Q

Are you aware of the fact that9

he's associated with the Turkish American

10

Legal Defense Fund?

11

A

I just -- I didn't know that.

12Q

The organizations you identified

13

just now were I think you identified as -- or14

the ones you identified, not the ones I asked

15

you about -- the ones you identified, I think16

you were listing as part of the overt Turkish

17

lobby, correct?

18

A

19
20

Okay.

Can you repeat thatYes.

I'm sorry.

question?
Q

I was asking

21

about what was meant by the Turkish lobby, and22

you said that there were overt forms of the

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1

Turkish lobby and there were covert forms.

2

The organizations we were talking about, are3they part of the overt Turkish lobby, if you

4

will?

5

A

6

covert.

7

Q

They are part of both overt andOkay.

So when you talk about the8covert Turkish lobby, what are you referring

9

to there?

10

A

Activities that would involve

11

trying to obtain very sensitive, classified,

12highly classified U.S. intelligence

13

information, weapons technology information,

14classified congressional records, recruiting

15-- recruiting key U.S. individuals with access16

to highly sensitive information, blackmailing,17

bribery.

18

perhaps -- and there are many others that I'm

19

unable to think of.

20

Q

These are some of the ones that justWell, by way of example, I think21

you indicated that Ms. Dickerson -- by the22way, is she ever referred to as Jan Dickerson?

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1

A

Correct.

That's how she went at

2

the FBI, and as far as I know, elsewhere she

3

used her middle name in the United States, Jan

4

Dickerson.

5Q

Now, I read in some of the reports

6

about an incident where Ms. Dickerson arrived

7-- showed up at your home unexpectedly on

8Sunday.

9A

Correct.

10Q

And can you tell us what happened

11
12

when that -- when she arrived there?
A

Sure.

She came to my house with13

her husband, who at the time was Major Douglas

14

Dickerson, and he identified himself first as

15

the officer for Air Force, but later said that16

his real task was operations involving records

17

procurements by countries in Central Asia and18

Turkey, and that he directly worked with

19

Douglas Feith and Paul Wolfowitz.

20

Q

Okay.

21

A

At the time this would be 2001,

22

December.

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1
2

Q

All right, and they came to yourhome on Sunday morning.

3A

Yeah, social visit they said.

4Q

And during that discussion, during

5

that visit, did you come to believe that Ms.

6

Dickerson was recruiting you?

7

A

Yes, I did.

8

Q

For what?

9

A

They wanted me to joint the10

American Turkish Council, and they told me

11that I would be provided with many benefits,

12

both monetary but also prestigious benefits,

13

if I were to enroll with them.

14

Q

Okay, and did you know at the time

15

that the American Turkish Council was one of16

the counterintelligence targets?

17

A

Absolutely, yes.

18

Q

And did you believe Ms. Dickerson

1920

knew that as well?
A

She -- yes, and the fact because

21

her husband associated with American Turkish

22

Council and she worked for them.

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1
2
3Q

And did you report this effort torecruit you to your superiors?
A

Immediately.

The next day I

4reported it in writing to my direct

5

administrative supervisor, and a few days

6

later to my agent, who was my supervisory7

agent, but also again in writing to the FBI's

8

Personnel Security Office, because I was

9obligated for my top secret clearance to10report recruitment attempts.

11

Q

Now, why if you can tell me, why

12would the American Turkish Council be a

13

counterintelligence target?

14

A

Certain individuals form that15

organization, American Turkish Council,

16

certain individuals were involved with other17

individuals outside American Turkish Council,

18

which includes diplomatic community and19

Turkish diplomatic community -- sorry -- and20other subchapter organizations.

21

I say "subchapter" because even22though it's not known, ATA is not formally

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1

known as American Turkish Council's

2subchapter, but they do a lot of activities

3

through ATA in various cities and states in4

the United States, and those individuals were5

involved in operations that were

6

counterintelligence related, and not -- if7

they were against the United States interest

8

on security,

9

Q

Okay.

Was there -- let me be sure10

I have this correct -- was there a particular

11

individual at the American Turkish Council who

12

had connections to the Turkish Embassy in

13

Washington at that time?

14

A

There were several people.

15

Q

And again, just because I don't

16know, to your knowledge, was the American

17

Turkish Council an organization that was

18

supported by the Turkish government?

19

A

I don't know directly, but

20

indirectly --21

MR. FEIN:

That's conjecture.

22

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1

MR. FEIN:

Object, object.

Only

2

speak based upon your personal knowledge.

3

Conjecture and speculation otherwise, I move4

to strike your answer unless it's based upon5

personal knowledge.

6

THE WITNESS:

Based on --7

MR. MARINO:

You can answer the

THE WITNESS:

Based on my

MR. MARINO:-- just as I asked

THE WITNESS:-- knowledge, they8question --910

personal --

11
12

it.

13
14

were indirectly supporting it, supporting.

15

Turkish government was indirectly supporting16

the American Turkish Council, certain

17

individuals and operations and projects

18

against.

19

BY MR. MARINO:

20

Q

Okay, and how were they supplying

21

that support?

22

A

Without getting into specifics,

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it's hard to explain.

2

intermediary business individuals to make3

payments for certain activities, lobbying

4

activities or intelligence gathering

5

activities or activities involved in weapon

6

procurement deals between Turkey and the7

United States.

8

Q

9

They could arrange for

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

10

A

Money when they could, yes.

11

Q

So if I said that the American

12

Turkish Council, for example, was an

13organization supported by the Turkish

14

government, that wouldn't be an unreasonable

15

assumption?

16

A

Correct.

17

Q

What about some of these other18

members of the Turkish lobby that we've talked

19

about?

20

that those organizations might be receiving

21

support from the Turkish government?

22

Would I be unreasonable in assuming

A

They were all receiving -- the

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1

ones that I knew of, yes, theoretically.

2

MR. FEIN:I think the question3

was -- can I just clarify for my own mind? --4

the question was based upon the witness'5

personal knowledge, she knows that all the6other organizations that were targets, they7

were receiving money from the government of

8

Turkish.

9

MR. MARINO:

10

MR. FEIN:

11

Okay.

Is that the question

and answer?

12

MR. MARINO:

Mr. Fein is going to13

have an opportunity, I think, to ask some14questions when I'm finished.

15

and I will just have questions and answers.

16
17

Maybe now you

BY MR. MARINO:
Q

So what happened when you reported

18

to your superiors at the FBI that Ms.

19

Dickerson were trying to recruit you for this20organization, American Turkish Council?

21
22

A

At the initial stage -- this is

for Washington field office before it went all

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1

the way up to the FBI Headquarters -- there2

was environmental (phonetic) panic.

3

I worked with, Special Agent Dennis Sharshar,

4

informed the counterespionage section,

5

department of the FBI; write a letter to the6

FBI Headquarters, and he also asked for7

immediate damage assessment because some of8the -- our FBI's counterintelligence primary

9targets -- the targets were graded in10

different -- they have different rates -- some11

primary targets were the ones that Ms.

12

Dickerson was working with closely, and she

13

and her husband associating, but that was the14

initial response.

15

Q

The agentOkay, and ultimately did they take16

any action against Ms. Dickerson or her

17husband?

18

A

Again, initially during this19

initial stage, they, I believe, they asked her

20

to take polygraph, and they also -- the FBI's

21

counterespionage unit, they set up the date22

and time to have some kind of an

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1

interrogation.

2

interrogation session with her that they set

3up, but they were prevented from pursuing it

4later.

5

Q

6

They called it the surprise

And they also had you take apolygraph test, correct?

7

A

Correct.

8Q

And the polygraph examiners found

9that you were not deceptive?

10

A

Yes, I was absolutely truthful.

11

Q

Okay.

Now, in your experience

12

both at the FBI and since then, what is it

13

that the Turkish lobby -- what kinds of issues

14

are they traditionally concerned about in our

15

country?

16

A

Various issues that I'm aware of.

17

Some, the more overt ones, the foreign policy

18of the United States.

19

procurement from the United States and the20

military aid, and political front is being

21

able to secure grants from United States

22

Congress for their operations or some of them,

Another, the weapon

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1

joint operations in Central Asia and Middle

2

East, the front companies for construction or

3road building, et cetera, and to be able to4

secure these grants from Congress for those5

front organizations.

6

Armenian genocide and preventing

7

that from ever being brought up or passing

8

Congress or even discussed in the mainstream

9

media is another political objectives that10

they pursue very strongly.

11

overt ones.

12

overt ones.

13

Q

These are the

So those are -- these are the

All right.

In your experience

14

then, these are issues that the Turkish

15

government is concerned about?

16

A

Not only, yes, Turkish government

17

is concerned, but also other entities with18

their own special interest who are very

19

concerned about these issues.

20

Q

Can you identify those?

21

A

Some of them are business

22

entities.

The others are more like clusters

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Page 411of criminal gangs would be the best way to2

describe them that may or may not be3

independent from the central government.

4

Q

You mentioned the Armenian

5

genocide issues.

My understanding is that6

there have been resolutions proposed,

7

introduced, discussed in Congress to recognize

8

the Armenian genocide, correct?

9

A

Correct.

10Q

And those have been controversial

11

resolutions over the years?

12

A

Correct.

13

Q

And so when you refer to this14

Turkish lobby regarding that as an issue, it

15would be their intent to prevent such a16

resolution from being passed by the U.S.

17

Congress, correct?

18

A

Correct.

19

Q

Now, am I correct that -- I know

20

you don't work for the FBI now, but would you

21

consider yourself sort of still involved in22some of the issues that we've been discussing?

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1

A

Somewhat, yes.

2

Q

Am I correct that you have a blog

3on the Internet?

4

A

Yes.

5

Q

You post material on that?

6

A

Yes.

7

Q

One of the things that I saw on

8

your blog is something called the State

9

Secrets Privilege gallery.

10

I'm referring to?

11
12
13

A

Do you know what

That is on my personal Websitethat is public, JustACitizen.com, correct.
Q

Okay.

And when you talk about the14

State Secrets Privilege, I think I know what15

you mean by that.

16

referring to?

17

A

Can you tell us what you'reState Secrets Privilege is this18

arcane executive privilege that the19

government, United States government, invoked20

in my case twice in order to quash my court

21

case, but also prevent the public knowledge of

22

information I reported to Congress, to the

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Inspector General's Office, and to the FBI and2

the Justice Department itself, and basically3

it acts as a gag order, and the only4

justification the U.S. government provided for5

it was "she may be right with whatever she

6knows and she believes is important and7

crucial, but because the information she has

8

may threaten and affect certain U.S.

9

diplomatic relations and national security, we10

are asking the courts and the Congress as

11

executive privilege called State Secrets

12

Privilege.

13

Q

Okay, and just to bring me up to

14

date, you filed a lawsuit against the15

government at some point, correct?

16

A

Correct.

17

Q

And that was because of your18

termination by the FBI, right?

19

A

20

correct.

21

Q

22

And my First Amendment rights,

And if I understand it correctly,

the government used the State Secrets

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1

Privilege to get that lawsuit thrown out.

2

A

The first invocation, yes.

3

Q

Was there a second invocation?

4

A

Yes.

I was -- my deposition was

5

subpoenaed by a law firm called Motley Rice.

6

I think it's M-o-t-l-e-y, second word R-i-c-e,

7

who represented thousands of 9/11 victims'

8family members, and they subpoenaed my

9deposition, and I believe this was in 2004.

10

That was when the government, FBI and the11

Justice Department, went to the judge who was

12sitting on my case, and asked him to quash it

13

based on State Secrets Privilege, and they

14

cited the State Secrets Privilege together

15

with affidavits from the various individuals

16

in the Justice Department, including the17

Attorney General, and asked the judge to quash

18

that deposition for the second time.

19

Q

So these are lawyers who are20

representing families of the 9/11 victims,

21

correct, who wanted to get information from

22

you?

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1
2
3
4
5

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

6what they were planning to ask specifically,7

but it has to do with certain Turkish lobby

8

and organizations in the United States who

9also had certain dealings with Saudi Arabian10

related financial and lobby organizations in

11

the United States and cases that would have12

been -- that would have involved both Saudi

13

Arabia and Turkey jointly were doing certain

14

things here in the United States, but also

15

outside the United States.

16

Q

Okay, and I think you said earlier

17

basically the government prevented you from18

getting that information to the families of19

the 9/11 victims, correct?

20

A

Correct.

It's been five years,

21

but to my best of knowledge, they forced the22party who was subpoenaing me to submit

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1questions, and they said all those questions

2

are classified and covered by the State

3

Secrets Privilege and they invoked4(inaudible.)

5Q

All right.

Now, on that Website

6and this States Secrets Privilege gallery, it

7seems like you have photographs of various

8

individuals, correct?

9

A

Yes.

10

Q

Is Dan Burton one of the people

11

who's in the gallery?

12

A

His picture is there, yes.

13

Q

Okay.

14

A

I can't discuss the details of

Why is his picture there?

15

those individuals not legal activities in the16

United States, but those pictures, his and17others, are there because State Secrets

18

Privilege was mainly involved to cover up

19those individuals illegal, extremely illegal

20

activities against the United States citizens

21

who were involved in operations that were,22

again, against order foreign government and

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foreign entities against the United States'

2

interests.

3

Q

And Dan Burton is a4

representative, member of Congress from5

Indiana; is that correct?

6

place?

7

A

I believe he is.

8

Q

Okay.

Is that the right

What about -- it also

9appears that you have a photograph of Dennis

10

Hastert in the gallery.

11

A

Yes.

12

Q

Okay, and why is his photograph13

there?

14

A

Again, just information that's

15

public, has been public, is he would be one of16

the primary U.S. persons involved in

17

operations and activities that are not legal,

18

and they're not for the interest of the United

19

States but for the interest of foreign

20

governments and foreign entities.

21
22

Q

Now, again, Mr. Hastert was the

Speaker of the House and Representative from

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1

Illinois?

2

A

At the time he was.

3

Q

Can you tell me anything about

4
5

what your concerns are about Mr. Hastert?
A

This information has been public.

6

The concerns, again would be several

7

categories.

8

bribery in forms of cash or laundered cash and9laundering is to make it look legal for his

10

campaigns, and also for his personal use, in

11order to do certain favors and call certain --12

call for certain actions, make certain things

13

happen for foreign entities and foreign

14

governments' interests, Turkish government's

15

interest and Turkish business entities'

16

interests.

17

Q

The acceptance of large sums of

Did you have reason to believe

18

that Mr. Hastert, for example, killed one of19

the Armenian genocide resolutions in exchange

20

for money --21

MR. FEIN:

Leading question.

22

BY MR. MARINO:

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1

Q-- money from these Turkish

2organizations?

3A

Yes, I do.

4

Q

So if I were to say that a member

5of Congress -- if I were to just walk out on

6

the street and say, "Gee, I think members of7

Congress have taken money from these Turkish

8organizations in exchange for denying the9

Armenian genocide," would that be an

10

unreasonable assumption on my part?

11

MR. FEIN:

12

That's pure conjecture.

The individual --13

THE WITNESS:

14

MR. FEIN:

15-- is totallyirrelevant.

16
17

No.

BY MR. MARINO:Q

Are you aware of other members of18

Congress, other than Mr. Hastert, taking money

19

from Turkish organizations in exchange for20

denying the Armenian genocide?

21
22

A

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

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1blackmailed for various reasons.

2

Q

Stephen Solarz is on your gallery

3

as well.

I believe he's a Representative from4

New York.

Is that correct?

5

guessing.

6

A

He used to be.

7Q

Was, right?

8

A

Correct.

I'm really

He is a registered9lobbyist for the -- or was registered lobbyist

10

for the government of

11

Q

Turkey.

And Mr. Hastert is also a

12registered lobbyist for the government of13

Turkey now?

14

A

15
16
17
18

That's what I have read and it wasannounced, yes, he is.
Q

And why is Mr. Solarz in yourgallery, if you can tell me?
A

Mr. Solarz and certain others in

19

the gallery, as lobbyists they also acted as20

conduits to deliver or launder contribution

21

and other briberies to certain members of

22

Congress, but also in pressuring outside

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Congress, and including blackmail, in certain2

members of Congress.

3

Q

And Mr. Solarz and others would be4

doing this on behalf of these Turkish

5organizations?

6

A

7

correct, both.

8Q

And the Turkish government,

Would you say that -- would it be9

your opinion that the Turkish government

10

through these Turkish organizations in the11

United States and otherwise has corrupted

12

members of Congress?

13

MR. FEIN:

14

asking for an opinion.

15

a witness who testifies to facts.

Objection.

This is supposed to be

16

THE WITNESS:

17

BY MR. MARINO:

18
19
20

Q

She's justAbsolutely, yes.

And is that based on you justspeculating or is it based on something else?
A

Based on documented and provable,

21

tracked files and based on facts 100 percent,22

documented facts.

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1

Q

Now, are some of those documented

2

facts that you're referring to, are they3

public knowledge?

4

domain, in other words?

5

A

Are they in the public

Some of them through various, I

6guess, reporting and other sources who have7

been disturb (phonetic) and talk, yes.

8Q

And is your opinion based in part9

upon your experience working on

10

counterintelligence matters for the United

11

States?

12

MR. KOHN:

To the extent she can13answer that question without -- why don't we

14

just withdraw that question?

15
16

MR. MARINO:

19

That's fairenough.

17
18

Okay.

BY MR. MARINO:Q

It looks like you have a photo of

Bob Livingston on your gallery as well.

20

A

Yes.

21

Q

And I believe he's a Congressman

22

from I want to say Louisiana at some point.

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1

A

Correct.

2

Q

He was the one that was going to3

be the speaker, but then left.

4

A

Yes.

5

Q

Why is he in your gallery?

6

A

Until 1999, until he left for

7

activities that he was engaged, not very legal

8

activities on behalf of foreign interests and9entities, and after 1999 acting as a conduit

10

to, again, further foreign interests, both11

overtly and covertly as a lobbyist, but also12

as an operative.

13
14
15
16

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?

17

Q

Sure.

18

A

Just a hypothetical example or --19

Q

It's okay with me.

20

A

Okay.

If an individual has

21

companies set up and clients in offshore22

islands like Cayman Islands, for example, andNeal R. Gross & Co., Inc.
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is able to as an operative to launder money by2foreign entities that were obtained illegally,3

and some of them had to do with narcotics, and4

used these Cayman Islands offshore accounts to5

do that, and then some of that money goes to6

the congressional people, I would call that7

not overt.

8

operations, covert operative, operations for

9that person rather than the classic lobbying

10

operation.

11

I would call that covert

MR. MARINO:

All right.

12

been going for about 55 minutes.

13

take a break, ten-minute break?

We've

Why don't we

14(Whereupon, the foregoing matter15

went off the record at 11:22 a.m.

16

and went back on the record at

17

11:41 a.m.)18

BY MR. MARINO:

19
20
21
22

Q

Okay.

Ms. Edmonds, have you everreviewed your Wikipedia entry?
A

Once in a while I do.

I don'tknow when was the last time, but maybe a year

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1
2

ago.
Q

Okay.

I mean, do you know have3

you contributed to it or do you know people4

who do contribute to it?

5

A

No.

I know many people, they give6

me mainstream media articles or any reports.

7

They put it in there, but, no, I haven't

8contributed.

9

Q

When you've looked at it, have you

10thought that it's generally accurate about11

most of the statements?

12A

Yes, generally, yes.

13

Q

One of the things that it

14

indicates in your biographical information is15

that you've made certain allegations.

16them we've talked about a little bit, and I

17

wanted to ask you about some of the others.

18

Some of

One of the entries indicates

19

nuclear secrets black market, and it says,

20"Edmonds alleges that in the course of her

21

work for the government she found evidence

22

that the FBI, State Department and Pentagon

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1

had been infiltrated by a Turkish and Israeli

2

run intelligence network that paid high3

ranking American officials to steal nuclear

4

weapons secrets," and they have some footnotes5

for that, some cites.

6
7

Is that correct that you've madethose allegations?

8A

That information is correct, and9

if ever -- you can get, I would say, those10

government organizations and others.

11

another place missing there.

12

State Department itself, but there is one

13other place that's missing.

There's

They list the

14

Q

And what is that place?

15

A

That would be RAND Corporation.

16

Q

And can you tell me about the --17

give me some more information about the18

Turkish and Israeli run intelligence network

19

that is referred to there?

20

A

This information has been public,

21

documenting methods of intelligence gathering.

22

Yes.

Through certain U.S. officials,

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1

executively appointed officials, foreign2

entities, not necessarily or not only3

government related; so if you say Israel and4

Turkey, not only government but other entities

5

because it has multi-layers.

6Q

All right.

7

A

Their operations, and some of8

these layers sometimes they conduct their9

operations independently and with the sole

10

purpose of obtaining a profit, and therefore,

11

the information they obtain, let's say, the12nuclear or weapons technology, weapons

13

technology related information doesn't

14

necessarily only go to Turkey or Israel, but

15they sell it to the highest bidder.

16

how they operate.

17

whether it's in ISI, in Washington, D.C. part18of the military attache for Pakistani

19

intelligence, or the certain Saudi business20

people in Detroit may be contacted, and they21

say, okay, and talk about these Turkish

22

entities.

That's

They contact their people

This is we have obtained this

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1

particular DVD containing this, and this2

person is willing to pay 500,000.

3offer more because if you don't, we will give4

it to this person.

5

Will you

So what I'm trying to say is they6

do it both for governments, foreign

7

governments, but some of those operatives,

8

they also -- they offer it in open market, and9they have -- they have individuals on their

10

payroll on almost every major nuclear facility

11in the United States.

12

various -- in Midwest, various Air Force labs

13

that develop certain weapons technology, which

14

I am not very familiar with the technology

15

itself.

16

Q

RAND Corporation andWhen you refer to the or when the17

article refers to the paid, high ranking

18

American officials, can you identify who they

19

are?

20

A

21

others.

22

Q

That person has been identified by

Okay.

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1A

And he has been identified as Mr.

2

Marc Grossman, who used to work for the State

3

Department.

4

Q

5

Right, and Mr. Grossman, I think,

was also in your gallery, correct?

6

A

Yes.

7

Q

And I read somewhere that Mr.

8

Grossman had some relationships with a Turkish

9organization, Turkish diplomats here in the10

United States.

11

A

Yes.

He had very, very close

12

relationship with not only Turkish diplomatic

13

communities and entities, but business and14

also some of these criminal layer operatives

15

that I told you about.

16

nor working; he actually is working for a

17

Turkish company called Ihals Holding.

18
19

Q

Okay.

Currently, that he'sNow, was Mr. Grossman theambassador to Turkey at some point?

20

A

Yes.

21

Q

Okay, and then what was his

22position at the State Department, if you

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1recall?

2

A

He had several different

3

positions.

I believe in 1999 or 2000, was4European Affairs.

5and afterwards during early bush6administration's stage, he was the second or7

the third highest person in the State

8

Department.

I'm not sure about the title.

9

Q

Okay, and during that time -- I'm

That dealt a lot with NATO,10

sorry -- during that time when he was the11second or third highest ranking person in

12

State, I've read somewhere that you've alleged

13

that he actually warned the Turkish Embassy

14

about a CIA front company that had been set up

15

to stop proliferation of nuclear weapons.

16

A

That would be summer 2001.

17

Whatever title he held at that point, he, Mr.

18

Grossman, informed a certain Turkish

19

diplomatic entity who was also an independent

20

operative of a company called Brewster

21

Jennings because Brewster Jennings was

22

frequenting the American Turkish Council as a

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consulting or analyst firm, and there were2certain nuclear related operatives who wanted3

to hire Brewster Jennings and have it pose as

4

a front company.

5

So there were talks between those

6

Turkish operatives and Brewster Jennings, and

7

Mr. Grossman wanted those people to be warned

8that Brewster Jennings was a government front,

9front for government, and it was a front.

10

was not a company for the front for

11

government, U.S. government, and for those

12

Turkish individuals to be told to stay away

13

from Brewster Jennings.

It

14

But the person who received that15

information, the Turkish diplomatic but also

16

operative, actually contacted the Pakistani

17

military attache and discussed with the person

18

who was there about this fact and also told

19

them, warned them to stay away from Brewster

20

Jennings.

21
22

Q

And now was this one of theallegations or one of the concerns that you

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1brought to the attention of anybody at any

2point?

3

A

4

You mean when I was working for

the FBI --

5

Q

Yes.

6

A

-- and I blew the whistle inside7

the FBI?

8

Q

Right.

9A

No, I didn't do it inside the FBI

10

because at that point I didn't know they were11

covering up this information.

12

was fired and the State Secrets Privilege was13

invoked, and knowing what I knew, I went to14

Congress and discussed it with certain people

15

in Congress.

16

Inspector General's Office inside during a17meeting, and at that point will provide them18

the details in terms of dates and who were19

those targets, which I can't provide right20

now, the direct targets.

21
22

Q

Only after I

I brought it up with the

And when you say "the Inspector

General's Office," do you mean a DOJ Inspector

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1

General?

2

A

3
4

Correct.

I'm sorry.

Glenn

Fine's, under Glenn Fine's office.
Q

And why would Mr. Grossman, if you

5know, warn the Turkish government and other6

people not to deal with this CIA front?

7

A

There were various relationships

8and various activities Mr. Grossman was

9engaged with these individuals, and I don't

10know which reasons was the top reason for him

11

to do it.

12

relationship, but others dated back to

13

operations that he was leading while he was an

14

ambassador in -- U.S. ambassador in Ankara, in

15

Turkey, until 1997, and some of these16

operatives dealt with him, and they were doing

17

certain operations in Central Asia for him.

18

I don't know who he was working

Some of them were the monetary

19

for, Mr. Grossman, at the time for his

20

operations.

21
22

It's hard for me to tell.

He wasinvolved in so many different things, and I

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don't know which one constitutes the biggest

2

reason he was providing this.

3

Q

Just going back to the Israeli,

4

we've talked mostly about the Turkish

5organizations.

6

A

Yes.

7

Q

Turkish government.

Are you aware

8of the Israeli government or Israeli

9organizations influencing members of Congress

10

as well?

11

A

Not directly, not directly.

12

Q

Indirectly?

13

A

Indirectly, based on how they14

work, some of the largest Israeli lobby groups

15

with the entities such as ATC and also the16

Turkish diplomatic community and how they17

actually trained and make it possible for the18

Turkish lobby and these entities to do it.

19they had training period in '96 and '98 from20

individuals that were sent to them from both

21

APAC and JINSA, both the lobbying, but also on

22covering the money track, covering up the

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1

money track.

2

Q

One of the other entries on your3

Wikipedia entry indicates that you had accused

4

Mr. Hastert and other, quote, high ranking

5

members of U.S. government of -- let me make6

sure I'm reading this correctly.

7

The entry says, "Edmonds also8

accuses Dennis Hastert of taking bribes."

9

think we've talked about that; is that10

correct?

11

A

Yes.

12

Q

And then it says, "And high13

ranking members of the U.S. government of

14

selling nuclear secrets to Turkey and15

Pakistan."

16

Did you allege that high ranking

17

members in the U.S. government had sold18

nuclear secrets to Turkey and Pakistan?

19

I

A

They were involved in operations

20

that were obtaining illegally U.S. weapons and21

nuclear related technology and sell it to22

foreign governments and also foreign

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1

independent operatives.

2

Q

Now, one of the other entries

3

indicates, it says 911 For Knowledge, and I'll

4

just read it.

5

FBI received information in April 2001 from a6

reliable Iranian intelligence asset that Osama

7

bin Ladin was planning attacks on four to five8

cities with planes.

9already in the country, and the attacks would

10

happen in a few months."

11

It says, "She claims that theSome of the people were

Did you -- did you make that

12

claim?

13

A

I took the language specialist,

14

Farsi speaking language specialist, senior

15

language specialist from the Iranian Division,

16

Farsi Division, FBI, Washington field office,17

who worked right next to me, to the 9/11

18

Commission and Inspector General's Office, and19

he testified on this.

20

He informed me and he showed me

21

this translator Bekru (phonetic) Sharsahr, and22

there are documents out there that he went to

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1

the Inspector General's Office.

2

the documents, the translated documents on the

3

Iranians.

4

He gave them

I was not part of that

5translation.

6left the FBI because I was witness to that7

department, what they had obtained, I just8

facilitated Mr. Sharshar's meeting with 9/11

9Commission and also with the Glenn Fine,

10

Department of Justice Inspector General's

11

Office, and I put him in touch with the12members of media.

13

involvement with that Iranian case.

14

Q

I was not involved.

After I

But that's my only

Do you believe that that's why the15

9/11 -- the families of the 9/11 victims

16

wanted to get your testimony in connection

17

with their case?

18

A

I am not sure because as far as I

19knew, it had to do with the government of

20

Saudi Arabia and the Saudi Arabian financial

21

institutions.

22

Iranian case.

I was not told anything about

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1

Q

We've talked about some members of2

Congress having connections with the Turkish

3government or Turkish organizations.

4

there others that you're aware of other than5

the ones we've discussed already?

Are

6

A

Congressional members?

7

Q

Congressional members.

8

A

Yes.

9

Q

Can you identify some of them?

10

A

Their pictures are on the -- I11have pictures included in my Website, and they12

can be identified.

13

outside the ones you named.

14
15

Q

There's several there

I just -- I looked at the Website

but didn't recognize --

16

A

Okay.

17

Q

-- some of them.

18
19
20

So would you beable to tell me who the other pictures are?
A

Others have been -- they're allidentified as public information.

21

Q

Yes.

22

A

Tom Lantos is one of them.

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1

Q

All right.

2A

I believe he passed away, and Tom

3

Lantos' office would be not only with the4bribe, but also in disclosing highest level5

protected U.S. intelligence and weapons

6technology information both to Israel and to

7

Turkey.

8

that.

9

other very serious criminal conduct.

His office was also involved with
It was not only bribery, but it was

10

Roy Blunt is there.

There have11

been individuals with a question mark there.

12

The reason there's a question mark is I lacked

13-- I was terminated by April 2002, but this14

particular Congresswoman -- the Turkish --15

these Turkish organizations and operatives, if

16

they can't do it by money, they do by

17

blackmail.

18

sexual lives and other information like that,19

and with this particular Congresswoman, it

20

being 2000 until I left, they -- this21

individual, this Congresswoman's married with22

children, grown children, but she is bisexual.

So they collect information on

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1

So they have sent Turkish female agents, and2that Turkish female agents work for Turkish

3government, and have sexual relationship with4

this Congresswoman in her townhouse actually5in this area, and the entire episodes of their6sexual conduct was being filmed because the7entire house, this Congressional woman's house8

was bugged.

9

to be used for certain things that they wanted10

to request when I left.

11

whether she -- that Congresswoman complied and

12

gave.

13

because I don't -- I meant her face because I

14

don't know if she did anything illegal

15

afterwards.

So they have all that documented

So I don't know

That's why I couldn't use her name16

But she was -- there are things;

17

information was being collected for blackmail18

purposes, and her lesbian relationship, and19

they, the Turkish entities, wanted both20

congressional related favoritism from her, but

21also her husband was in a high position in the22

area in the state she was elected from, andNeal R. Gross & Co., Inc.
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these Turkish entities ran certain illegal

2

operations, and they wanted her husband's

3

help.

4

with those.

5

Q

6
7

But I don't know if she provided them
I left.

I was terminated.

And can you tell me how you know

all that, everything you just told me?
A

I can't discuss the intelligence

8

gathering method by the FBI, but in general9terms, when foreign targets among themselves

10

discuss how they were going to achieve certain

11

goals, objectives, and if those communications

12

are collected and recorded, not only do you

13

have that communications, but in some cases

14

they involved field office surveillance team15

to see that actually they completed.

16

For example, if they say --17

somebody says at five o'clock they're going to18

bug his house, the surveillance team would go

19

out and see that he had (unintelligible).

20

there were various ways that things were21

collected.

22

Q

All right.

So

So just to make sure I

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understand this, the Turkish entities were at2

least preparing to blackmail this3

Congresswoman.

4

A

Correct.

5Q

And is this Congresswoman still a6sitting member of Congress?

7

A

Yes.

8

Q

And why, if you know, would they

910

want to blackmail this Congresswoman?
A

I don't know what reasons they11

had, why they just didn't do money.

They

12

needed -- I was trained as a language

13

specialist by my agent for -- to find personal

14

information, and one of the things that we was15taught in the FBI -- everyone was taught in16

the counterintelligence -- that the target

17

U.S. persons, whether they are in Congress or

18

executive branch or whatever, first go by

19

foreign entities to what they refer to as

20

hooking period, and it was very common; it's

21

a very common way of trying to find22

vulnerability, and that is sexual, financial,

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any other kinds of greeds, and it was -- it2

was done a lot, was being done a lot, and in3

some cases certain people from Pentagon would

4

send a list of individuals with access to5sensitive data, whether weapons technology or

6

nuclear technology, and this information would

7

include all their sexual preference, how much8

they owed on their homes, if they have9gambling issues, and the State Department,

10high level State Department person would

11

provide it to these foreign operatives, and12those foreign operatives then would go and13

hook those Pentagon people, whether they were14

at RAND or some other Air

15

Force base.

And then the hooking period would

16

take some times.

Sometimes it takes months,

17

sometimes one year.

18

favor, but eventually after they reviewed the19targets that the U.S. person -- some small

20

favor, then they would go blackmail and that

21

person would give them everything, nuclear

22

related information, weapons related

They would ask for small

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information.

2

it was not always money.

3

Q

It always worked for them.

So

If you know, what was it that

4

these Turkish entities wanted from this5

Congresswoman?

6A

I know for sure that Armenian

7

genocide was one, but also where she came8

from, that city or the district where she came9

from is where certain Turkish operatives,

10

lobby groups run illegal businesses for fund11

raising for themselves to generate money, and12

for laundering that money they needed her

13

influence in that district where she is from14

and also her husband because he husband was

15

also involved, had some high level position,16

not an elected person, with where she came17

from, and they had another Representative who

18

was making it possible, but supposedly she at

19

that point was kind of -- was an obstacle.

20

That's all I know.

21
22

Q

In your experience, I mean, wasthis hooking technique used with other members

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1
2

of Congress by Turkish entities?
A

Well, when I worked for the FBI, I

3work on operations that were not only current,4

but specific period of 1996 till 2000, 2001,

5

December, 2003 January.

6of things that certain field office had

7provided me to go over, and some of that I

8didn't complete, but one example would be with9

regard to Mr. Hastert.

10

the townhouse that was not his residence for

11certain not very morally accepted activities.

12

Now, whether that was being used13

as blackmail I don't know, but the fact that14

foreign entities knew about this, in fact,

15

they sometimes participated in some of those16

not maybe morally well activities in that17particular townhouse that was supposed to be18

an office, not a house, residence at certain

19

hours, certain days, evenings of the week.

So there were a lot

For example, he used20

So I can't say if that was used as21

blackmail or not, but certain activities they22

would share.

They were known.

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1

Q

With respect to the Congresswoman2

who they were -- you don't know what happened

3

ultimately because you left, right?

4

A

Correct.

5Q

Or you were terminated.

6

A

Correct.

7

Q

But with respect to that

8

Congresswoman you said one of the things that9

they wanted was you said Armenian genocide.

10

I assume you were referring to the fact they11

wanted her support --

12

A

Yes.

13

Q

-- to oppose the Armenian genocide

14

resolution.

15

A

Yes, and she was not leaning that16

way during that stage, until this hooking

17

start.

18

Q

And does it surprise you that they

19

would go to those lengths to gain her

20

opposition to such a resolution?

21

A

Not at all.

22

Q

Why not?

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1

A

I don't know what their reason is,2

but they are going to this extent.

3

they may have -- I can only guess what their4

reasons are, but I think they would do

5anything.

6

whether it's money, whether sexual blackmail,7

anything they would do to not let this happen

8

or get the support so it wouldn't happen.

9

I mean,It's a very important issue, andQ

Are you aware of -- other than the10people that we've talked about, and I want to11

come back to Roy Blunt in a minute, but aside

12

from the people we've talked about, are you

13

aware of other current sitting members of

14

Congress who you believe have been given money15

by the Turkish lobby, Turkish government to16

oppose the Armenian genocide resolution?

17
18

MR. FEIN:

Objection.

Speculation.

19

MR. MARINO:

You can answer.

20

THE WITNESS:

The pictures are21

there, and I just talked about that

22

Congressional woman with the question mark

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because I don't know whether she complied with2

their -- but those are everything that --3

those people are all there, that Website

4

pictures.

56

BY MR. MARINO:
Q

Just before I leave this subject,

7

in your -- when we talk about the Armenian

8

genocide, can you describe what your9

understanding of that is?

10

A

In terms of historically?

11

Q

Historically what it is.

12

A

It's the genocide that the -- that13

was committed in Turkey against Armenians, and14

there -- I have read certain documents,

15

historical documents in the past because this16

issue I have been aware of for a long time.

17

Everybody in Turkey, they kind of know but

18

they can't admit they know, and it's basically19

what was available in Turkey was very limited.

20

So my knowledge would be just very, very

21

limited knowledge of what occurred.

22

Q

All right.

So just based upon,

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1

you know, your background, your experience, in2

your opinion is the Armenian genocide3

something that's generally accepted as an

4historical fact?

5

A

In Turkey?

6

Q

Yeah.

7

A

In

8

Turkey, no.

I mean, in Turkey

nobody can even say they think about it.

9Q

What about elsewhere?

10

A

In other

11

Q

Outside of Turkey.

12A-- outside Turkey?

13

Q

Yeah.

14

A

Yes.

countries like --AT least in the circles that15

I've been it is seen as something that is --16that is accepted and that is known as one of

17

those historical events that have taken place.

18
19

Q

Like the Holocaust in World War

II, something that people generally regard --20

A

Correct.

21

Q-- as something that happened.

22

Are you aware of anyone and

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Page 801serious scholars, serious people who dispute2

that those genocides took place?

3

A

Throughout the years, because I

4used to be on the E-mail list of certain

5

student associations that have international

6

students, so I would get from the Turkish

7parts of those communities E-mails from this8

professor or that from Turkey visiting to give

9

that lecture, but I don't even remember their10

names of those people.

11
12
13

Is that the question?

Did that

answer the question?
Q

Well, I gather from what you are14

saying, that you would get E-mails possibly

15

from Turkish organizations --16

A

I did.

17Q-- people where they would dispute

18

that the Armenian genocide took place.

19

A

Absolutely.

20

Q

Okay.

Outside of that group, that21

cultural group, if you will, are you aware of22

other objective scholars who dispute that the

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genocide took place?

2

A

I'm not.

3

Q

Why is Roy Blunt in your gallery?

4A

One of the individuals who was the5

recipient of both legally and illegally raised

6

donations, campaign donations from foreign

7

entities.

8Q

And what foreign entities?

9A

The ones that I'm aware of,10

Turkish entities.

It's just like a network

11

because those people, they worked together,12

and I don't have expertise in PAC, but a lot

13of -- there are so many ways that these PAC

14things can be not very legally distributed

15

from one person's, let's say, Mr. Hastert's

16

campaign to that individual or let's say it's

17

a foreign registered lobbyist, like Livingston

18

can get foreign money, but then clean it and19then give it to him.

20

it's a very complicated maze-like network on

21

how they get this money cleared and into

22

people, into people's pocket and also theirIt's just so many ways.

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1

campaigns.

2

Q

3

those PACs?

4

ANo, not really.

5

Q

Have you ever heard of the Turkish

6

Are you familiar with some of

Coalition, USA PAC?

7

A

Yeah.

8

Q

So, I mean, you're aware that the9

PACs exist, but you wouldn't be able to10

identify any of them?

11

A

Correct, not by names, correct.

12

Q

Now, are you-- has it come to13

your attention that some members of Congress

14

once they've left Congress like Dennis Hastert

15

engaged in lobbying for the Turkish

16

government?

17

A

Dennis Hastert is known publicly.

18

Stephen Solarz is known publicly.

He used to19

be a Congressman, and then he became lobbyist20

as soon as he left both for Israel and Turkey.

21

Bob Livingston, he within a year after he left

22

Congress, he became lobbyist for the

Neal R. Gross & Co., Inc.
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Page 831

government of Turkey, and he is registered2

under Foreign Agent's Registration Act.

3

But then there are people who work4

for these lobbying firms who are not the top,5

but they have received their share while they6

were working, whether they are in Pentagon.

7

One person was Defense Intelligence Agency

8

person, Dana Bauer, and now she works for Bob

9

Livingston, but this individual, Ms. Bauer,

10

did a lot of favors and illegal favors to --11

for government of Turkey and others, and then12

was hired by Livingston and put on a big

13

salary to represent Turkish government.

14

So it's not only top tier of the15

lobbying firm, but then the people who work

16

for them later and the various layers of those17

people.

18

Q

19

How about Richard Gephardt?

Youknow, who he is, right?

20

A

Yes, I do.

21

Q

And do you have any information

22

about whether or not he took money from

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Page 84
1
2

Turkish organizations?
A

No, I just have (unintelligible)

3

information based on what I read that he4joined the lobby firm for -- that represents

5

Turkey, the lobby that Mr. Hastert got hired,6

but I don't have any information.

7Q

For the firm called DLA Piper?

8

A

Yes.

9

Q

Law firm.

10

Are you aware of themlobbying for the Turkish government?

11

A

Yes.

12

Q

Let me give you a hypothetical and13just get your understanding of what might be14

going on because it's particularly relevant to15

our case.

16

You have a hypothetical

17

Congresswoman from State X.

18

no Turkish population to speak of or Armenian19

population to speak of.

20

recipient of Turkish PAC money in the 2008

21

election cycle.

22

Her district has

She's the largest

All right?

She meets with Livingston and

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1

Rogers or Livingston Group when they're2

escorting members of the Turkish parliament to3

a reception.

4

the Livingston Group talking about Turkish

5

relations; goes to luncheons in honor of the6

Turkish Foreign Minister, and she opposes

7

Armenian genocide resolution and, in fact,

8

refuses to even recognize the genocide as a9historical fact.

10

She receives fact sheets from

What's your sense?

11

tell you is going on there in --12

MR. FEIN:

What does it

Object.

There's no13

showing at all that she's got any expertise.

14

It's speculation here.

15

an opinion.

16

objectionable.

17

He's asking purely for

It's totally irrelevant and

THE WITNESS:

Based on several

18

that I personally know about in terms of how

19

they conduct and how they behave, those

20

elected officials who are serving the foreign

21

government's interest, I would say that's

22

modus operandi that you describe.

It's aNeal R. Gross & Co., Inc.
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Page 86
1classic fit of how individuals who happen to2

owe their position and favors to a foreign

3

government, in this particular case Turkey,

4

behave at and the kinds of people they5

associate with.

6classically matches of the individuals I know

7

who were serving Turkish government's and8other Turkish entities' interest.

9
10

That modus operandi

BY MR. MARINO:Q

And your view, based on what you

11know, would it be a reasonable statement to

12

say that that Congresswoman is taking money

13

from Turkish interest in part for denying the14

existence of the Armenian genocide?

15

MR. FEIN:

16

Objection.

Pure

speculation?

17

THE WITNESS:

Say based on my18

knowledge, my experience, and what I know,

19that money -- those Turkish entities' lobby

20organization will not give a penny to anyone

21

unless they have a prior pact with that22

person.

This is what you're going to do for

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Page 871

us, and that has been the case at least up

2till 2002.

3

BY MR. MARINO:

4Q

On your blog, one of the things

5

that you say, you're referring to your6

lawsuit, I think, but you say, "My case also

7

involves espionage activities by several high8level U.S. officials both elected and9appointed."

10

Have we already talked about for11

the most part what you were referring to12

there?

13

A

Some of it.

14

Q

What have we not talked about that15

you're referring to in that portion of your

16

blog?

17
18

MR. KOHN:

Do you want to discuss

it off the record?

19

THE WITNESS:

Sure.

20

MR. MARINO:

Do you want to take a

21
22

break off the record?
(Whereupon, the foregoing matter

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Page 88
1

went off the record at 12:16 p.m.

2

and went back on the record at

3

12:27 p.m.)4

MR. MARINO:

We had a pending

5question and during the break discussed it

6with counsel, and we agreed to withdraw that

7question basically because it was too broad

8

and so forth, and it's probably not necessary.

910

BY MR. MARINO:
Q

Let me ask you a different

11question, Ms. Edmonds.

12

executed an affidavit or a declaration

13

actually in this case on August 5, 2009.

14

happy to show it to you.

15

copy, but I'm happy to show it to you if you'd

16

like to see, but I just have some questions

17

about some of the things you said in the18

declaration.

19

I understand that you

I'm

I've only got one

In Paragraph 3 of your20

declaration, you say, "I also obtained

21

evidence that the government of Turkey had

22

engaged in practices and policies that were

Neal R. Gross & Co., Inc.
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Page 891

inimical to American interests and had, in2fact, resulted in both the direct and indirect3

loss of American lives."

4

Do you recall saying that in your5

declaration?

6

A

Yes.

7

Q

Can you tell me what practices and8

policies that you were referring to that were9

inimical to American interests?

10

A

There's several.

One is practices

11

and operations implemented from mid-1990s at

12least until towards end of 2001 in Central

13

Asia and Caucasus, and these operations and14

practices included Islamization of certain

15

segments of those Turkic nations, Uzbekistan,

16

Turkmenistan, Tajikistan.

17of them in that -- in that area, and setting18

up madrasahs and bringing in, helping bringing

19-- at the time they were not referred to as

20

al-Qaeda until 2001, September 11th.

21

were referred to as mujahideens from22

Afghanistan and Pakistan into Central Asia,

There are so many

They

Neal R. Gross & Co., Inc.
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Page 901then to Turkey to give them passports, and2then funnel them in 1997, 1998 to certain

3

Eastern European countries and the Balkans.

4

And also -- and it's very broadI

5

can go on for a long time about what practices

6

and why they were -- they were against the7security and the interests of the Americans

8

and the lives.

9

Q

Okay.

Well, I don't want to10burden you too much, but I would like as

11complete an answer as you can give us in terms

12of what you were referring to.

13

A

Those operations when until -- at14

least until September 2001, and again, for

15

those operations, they corroborated and worked

16

with certain U.S. persons who were involved in17

these operations.

18

The other, the obtaining,

19

illegally obtaining and selling U.S. military

20

and military technology and that includes

21

weapons and nuclears, and even from foreign

22

policy related secret or high -- top secret

Neal R. Gross & Co., Inc.
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Page 911

information, and not only for Turkey, but

2

passing this information to what they refer to3

as highest bidders and whoever bid highest,

4

whether these people were nation-states or5they were just individuals that they were

6

pursuing under counterterrorism after

7

September 11.

8

of activities that they were involved that

9

were against the security and the interest of

10

the Americans with cost in terms of lives.

11

Q

That would be another example

Well, that was going to be my next

12question, is how do you connect what the13

Turkish government was doing to the direct and14

indirect loss of American lives.

15

A

One example of this would be with

16

Brewster Jennings, for example, just selling

17

that information and giving that information

18

out in the hands of those foreign entities,

19

including Pakistan.

20

the CIA was asked for right away, to do damage

21

assessment, and one of the things that came22

out of it was the damage assessment included

One of the things that

Neal R. Gross & Co., Inc.
(202) 234-4433

Page 921

damage to asset both in terms of2

effectiveness, which was neutralized and that3

Brewster Jennings' front company for CIA have4

to be immediately absolved that summer after

5

this information was obtained, but also they6

were accessing U.S. people who were7

compromised because of that by -- within these8

foreign governments.

That's another.

9

And the third one that I started

10talking about were helping these individuals

11

from Azerbaijan, the Turkey entities that

12

served the mujahideen groups starting from13

1995, 1996.

They were given Turkish

14

passports.

In some cases they were given

15

Azerbaijani passports, and they -- Turkey

16

played a very active and important role in17

taking these people and moving them into

18

Europe and some of those people actually ended

19

up in the United States.

20

Q

And I think you indicated earlier

21

that the Turkish government to your knowledge

22

was provided support to what was once called

Neal R. Gross & Co., Inc.
(202) 234-4433

Page 931

the mujahideen.

2

A

Correct.

3

Q

It's now called al-Qaeda.

4

A

Right.

5Q

And has it generally been publicly

6

reported that al-Qaeda was behind the 9/11

7

attacks?

8

A

Correct.

9Q

And that cost American lives?

10

A

Correct.

11

Q

How else has, to your knowledge,12

the mujahideen or al-Qaeda that Turkey was

13

supporting cost American lives?

14A

September 11 and the other15

category I talked about was the intelligence16

and identifying assets or the front companies.

17

The third category that involved narcotics

18

activities and that was, at least until I

19

left, these Turkish people, and some of them20

are directly connected to Turkish intelligence

21

and Turkish military in the United States,

22

they played a very significant role in

Neal R. Gross & Co., Inc.
(202) 234-4433

Page 941

bringing in heroin from source from2

Afghanistan to Turkey, but from Turkey into3

both United States, but also directly to

4Belgium, large quantity, very, very large

5

quantity of heroin.

6

Q

All right.

So if I were to say

7that -- if I were a Congress person and I'm

8taking money from the Turkish government

9either directly or indirectly, would it be a10

fair statement that I'm taking money from a11

government that has engaged in policies and12practices that cost American lives?

13

A

Correct.

14

Q

Are you familiar with a person

15

named Fetullah Gulan, G-u-l-a-n?

16

A

Yes.

17

Q

Can you tell us who that is?

18

A

My information is mainly about his

19

activities and issues that were, again, done

20

from late 1990s until I left, and then after

21

that it will be known activities here in the22

United States.

He shortly -- he was the

Neal R. Gross & Co., Inc.
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Page 95
1

religious activist figure in Turkey, and he2

landed on Turkish government's wanted list and3

was going to be persecuted for wanting to4throw Turkish secular government -- replace it

5with Islamic shariah kind of type of6government.

7

And when he was wanted in Turkey

8

for that and he was going to go to jail, he

9actually got on the plane and came to the10

United States, and he was given immediately

11

visa to stay in the United States, and he has

12been in the United States until now as far as

13

I know.

14

He has since established more than15

300 madrasahs in Central Asia and what he16

calls universities that have a front that is17

called Moderate Islam, but he is closely

18

involved in training mujahideen-like militia

19

Islam who are brought from Pakistan and20

Afghanistan into Central Asia where his

21madrasahs operate, and his organization's

22

network is estimated to be around$25

Neal R. Gross & Co., Inc.
(202) 234-4433

Page 96
1
2

billion.
He has opened several Islamic

3

universities in the United States.

4

it's being promoted under Moderate Islam.

5

is supported by certain U.S. authorities here

6

because of the operations in Central Asia, but

7what they have been doing since late 1990s is

8actually radical Islam and militizing

9(phonetic) these very, very young, from the10

age 14, 15, by commandoes they use, and this11

is both commandoes from Turkish military,

12

commandoes from Pakistani ISI in Central Asia

13

and Azerbaijan, and after that they bring them14

to Turkey, and from Turkey they send them15

through Europe, to European and elsewhere.

16

As I saidIt

Up until 1999, the Turkish

17

government, also paramilitary units in Central

18

Asia, they operated under the groups that call19

themselves Gray Wolves, ultra-nationalists,

20

and their method was, you know, assassination

21of certain leaders in the Central Asian

22

countries, and militizing, but not throughNeal R. Gross & Co., Inc.
(202) 234-4433

Page 97
1Islam.

2

But after this scandal that took

3

place in Turkey, Susurluk scandal, they were4

no longer supported by certain segments in the5United States, and instead some of our people

6

involved in foreign policy, they supported the7Islamic movements of Gulan in the Central

8Asian countries in order to counter Russia as

9far as the energy sources are concerned in10those countries.

11

Q

How is it, if you know, or how is

12

it that Gulan is allowed to be in the United

13

States?

14

Let me ask a different question.

15

A

Okay.

16

Q

I'm sorry.

Is that an individual

17

based on what you've told me that you would be

18-- that you would consider a threat to U.S.

19

interests?

20

A

One hundred percent, absolutely.

21

Q

And if you know, how is it that22

he's allowed to be in the United States?

Neal R. Gross & Co., Inc.
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Page 98
1A

Because part of what he has in2

terms of the deal with certain segments in the3

United States is furthering the interests of4

the people who are interested in the energy

5sources in Central Asia, and that is the --6

whether it's oil or whether it's natural gas,7and basically it's a fight.

8

The best way to describe it is9

Cold War is not over.

10

Cold War over those nations, and what we did

11

in Afghanistan in early 1980s with mujahideen,

12

we have been joined now in Central Asia by

13

using Islam and extremism and these madrasahs,

14and Pakistani and Afghani elements to build

15(unintelligible) and staff in terms of those16

resources towards certain business interests.

17
18

Q

It's a continuation of

Did you say that Gulan had set up

schools in the United States as well?

19

A

Yes.

20

Q

Are some of those in Cincinnati,21

if you know?

22

A

I'm not sure.

I know of some in

Neal R. Gross & Co., Inc.
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Page 991

Texas.

I know one in Virginia, but I don't

2

know.

They are multiplying, and they're3spreading rapidly.

4or universities everywhere.

5

track of the locations.

6

Q

There's Islamic madrasahs
So I haven't kept

I don't know.

I assume that - -well, let me just7

ask you, and I'm not trying to put you on the

8

spot.

If you can't answer, just tell me.

9

Would you be prepared to tell me

10

who the Congresswoman is that we've been

11

talking about?

12

A

I would have, and it wouldn't be

13because of classification I don't believe.

14-- if in case this congressional person did

15

not bend under the pressure in case.

16

don't want somebody, innocent person's

17

reputation destroyed because I don't know if

18

this person complied with whatever she

19

happened to be blackmailed later.

20

I --

21
22

Q

All right.

I

I justI thinkThat's fair enough.

I

take it then from what you've told me that the

Neal R. Gross & Co., Inc.
(202) 234-4433

Page 1001people you've identified, the people that2

you've talked about today you're certain

3

about.

4

A

Yes.

5

Q

And what you've told me today

6

about those people is not based on

7

speculation.

8

A

9
10

No.
MR. MARINO:

Can you just give me

one moment please?

11(Pause in proceedings.)

12

BY MR. MARINO:

13

Q

Are you familiar with reports that14

the Turkish nationals were being supported or

15

acting as suicide bombers against U.S. troops

16

overseas?

17

A

Not directly.

18

Q

Any doubt in your mind that the19

Turkish government has caused American lives?

20

A

No.

21

Q

Caused a loss of American lives?

22

A

No.

And not only American lives.

Neal R. Gross & Co., Inc.
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Page 101
1

Even in other countries and some innocent

2

Turkish lives, too, but American lives, too,

3

yes.

4

Q

Any question in your mind based on

5

everything that you've experienced that the6

Turkish government has infiltrated members of7

Congress to get their support against or their8

opposition to the Armenian genocide

9

resolution?

10

A

None whatsoever.

11

Q

I've asked you about members of

12

Congress, but I haven't asked you about staff.

13

Are you aware of senior staff for members of

14

Congress who have also been corrupted by the15

Turkish government?

16

A

Absolutely.

17

Q

Can you identify them?

18

A

The pictures are there.

19

Q

Who is Larry Franklin?

20

A

He was an analyst working for21

Pentagon who was indicted on charges of22

espionage and passing information to, I

Neal R. Gross & Co., Inc.
(202) 234-4433

Page 1021

believe, Israeli lobby ATAC.

2

participants in ATC, American Turkish Council

3

around these Turkish operatives.

4

MR. MARINO:

ActiveOkay.

Well, I think

5

that's all I have.

6

some questions for you, but I do want to thank7

you again for your patience and for coming

8

today..

9

I think others may have

MR. FEIN:

I have many questions,10

but I don't know whether you want to take a11

break yet.

12

least an hour or two hours.

13

estimate whether you want to break now or

14

whatever you want to do or whatever counsel

15

wants to do as well.

16

I suspect the questions may be at

17

MR. MARINO:

Yeah, we'll take alunch break.

18
19

MR. FEIN:

Do you want to take abreak?

20

THE WITNESS:

21

MR. FEIN:

22

So you need to

How long for?

You decide.

I'llaccommodate whatever you want, and I can talk

Neal R. Gross & Co., Inc.
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Page 1031

to counsel here.

2

Whatever you want is fine.

MR. MARINO:

Well, I think3

personally I always ask the witness how much4time she wants, and then I ask the court

5

reporters because they're captives here.

6

I always try to -- yeah, why don't we go off

7

the record?

8(Whereupon, at 12:45 p.m., theSo

9deposition was recessed for lunch, to10reconvene at 1:30 p.m., the same day.)

11
12
13
14
15
16
17
18
19
20
21
22

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1

AFTERNOON SESSION

2
3(1:31 p.m.)
Whereupon,

4

SIBEL DENIZ EDMONDS

5

resumed as a witness called by counsel for the

6

Defendant and, having been previously duly

7

sworn, was examined and testified further as

8follows:

9

THE WITNESS:

Before we start, I

10need to go on the record with one question

11

about whether I had provided a deposition.

12

the past I answered that question saying in a13

business matter, but I forgot I provided -- I14

was deposed by the Justice Department on a15

federal tort claim which had to do with my16

family's pictures, that the FBI had

17

confiscated and lost, and for that particular

18

case they deposed me for like two or three

19

hours.

20
21
22

In

So I just want to go on the recordand correct that.
MR. MARINO:

Thank you.

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Page 105
1

MR. FEIN:

2

the afternoon session.

3

I guess we're beginning

CROSS EXAMINATION

4BY MR. FEIN:

5Q

Ms. Edmonds, my name is Mr. Fein,

6

and I'm an attorney who represents Jean

7

Schmidt in her complaint against Mr. Krikorian

8

here

before the Ohio Elections Commission.

9

When did you first learn of the10complaint that Ms. Schmidt had filed against

11

Mr. Krikorian?

12

A

13

ago, ten days.

14

Q

And how did you learn of that?

15

A

I either received an E-mail or

About maybe ten days, two weeks

16

call from Mr. Krikorian's office, and I was

17

told that there was this lawsuit, that I may

18

be called as a witness.

19

Q

And who spoke to you?

20A

I spoke with Mr. Krikorian.

21

Q

And what did he ask you to do?

22

A

He asked whether I would be

Neal R. Gross & Co., Inc.
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Page 1061

available to be deposed if he and his

2

attorneys before the trial they were going to3have would want to seek my deposition.

4

Q

And what did you respond?

5

A

I don't recall exactly, but I said

6-- I said, well, if I get a subpoena or just7

let me know what it is, then I will speak with8

my attorneys.

9

Q

10
11

Did Mr. Krikorian explain to youwhat the complaint was about?
A

No.

He told me there was public

12

information available and just in general he13

said that there was a complaint brought

14

against him in the -- with the Ohio State

15

Election16

briefly read a couple of articles that were17

out there on the case, that the fact that this18

case existed

19

Q

Commission, and I just went andto verify it.
Did you actually read the20complaint that had been filed before the Ohio

21

Elections Commission?

22

A

Do you mean the actual legal

Neal R. Gross & Co., Inc.
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Page 1071

complaint?

2

Q

Yes.

3

A

No.

4

Q

Have you read it at present?

When

5

you came here today had you read the actual

6

legal complaint?

7

A

No.

8

Q

So you don't know what's actually

9
10
11
12

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

13

called you about ten days ago and your14

response was that you would be willing to be

15

deposed or what exactly did you tell him?

16

MR. KOHN:

Objection.

17

MR. FEIN:

I apologize.

18

MR. KOHN:

Asked and answered.

19

MR. FEIN:

Well, I apologize.

20

BY MR. FEIN:

21

Q

What is it -- I want a

22clarification.

When he asked you would you be

Neal R. Gross & Co., Inc.
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Page 1081

deposed, did you say yes?

2

MR. KOHN:

3BY MR. FEIN:

4Q

Asked and answered.

Did anyone inform you before you

5

appeared today that the Ohio Elections

6

Commission had stated it would not enforce the7

subpoena that had been issued for you to be8

deposed here?

9A

I read the letter.

10

Q

So that you knew that you didn't

11

have to appear here.

12

MR. KOHN:

13

Objection.

It calls

for a legal conclusion.

14

MR. FEIN:

15

like her opinion here.

16

States Secrets Privilege.

She's testified

17

about what genocide means.

Those are all18

legal questions.

19

subpoena.

20
21
22

No, I'm sorry.

I would

She's testified about

She can testify about her

MR. MARINO:

Excuse me.

I join in

the objection.
MR. FEIN:

Okay.

Go ahead and

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1

answer.

2

MR. KOHN:

What is the question?

3

MR. FEIN:

The question is:did

4

you read and understand that the Ohio

5

Elections Commission had stated that they did

6

not intend to --7

MR. KOHN:

Do you have a copy?

8

MR. FEIN:-- enforce the9subpoena?

10

What?

11

I said did you have -- were you

12

under that understanding that the Ohio

13

Elections Commission in the letter had stated14

to all the attorneys involved in the15

Department of Justice they did not intend to16

enforce the subpoena that had been issued for17

you to be deposed here today.

18
19

MR. KOHN:

understanding of the letter.

20
21
22

Not quite my

MR. FEIN:I think it speaks foritself.
THE WITNESS:

I read the letter.

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BY MR. FEIN:

2

Q

3

voluntarily?

4

So in your view are you here

5

MR. KOHN:

Objection.

legal conclusion.

6

MR. FEIN:

7BY MR. FEIN:

8

Q

9

the question.

10

voluntarily?

I know.

Are you here voluntarily?

MR. KOHN:

12BY MR. FEIN:Q

AnswerIn your view, are you here

11

13

Calls for a-- is under --Did anyone advise you that you

14

were compelled to be here and you would be in

15

contempt of an outstanding decree issued by a16

government agency if you were not here?

17

MR. MARINO:

18

just make an objection?

19

MR. FEIN:

20

MR. MARINO:

Excuse me.

May I

Sure.
Object based on it

21

calls for a legal conclusion, and now you're

22

asking for attorney-client communications.

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1

MR. FEIN:

No.

2

MR. KOHN:

I agree.

3

MR. FEIN:

It's not -- go ahead.

4

MR. KOHN:

The witness is not5going to answer that question because it's

6

outside the scope of her appearance.

7

BY MR. FEIN:

8Q

Did you discuss what you would be

9saying here today to anyone before you arrived

10

here at 10:30 or so?

11

A

Can you be more specific?

12

Q

Yes.

Did you talk to somebody

13

about what you would testify to in today's

14

deposition to anybody else?

15

about the substance; just that you did, and16

identify the people who you spoke about.

17

A

I'm not talking

I have responded to requests about

18

comments about today as I don't know.

There

19

are going to be questions, and I don't know

20

what questions I'm going to be asked, and21

after it is over and before, my attorneys will22

be present to make comments.

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1
2

Q

Did you talk to Mr. Krikorian

about what you would be saying today?

3

A

To -- you mean this --4

Q

Mr. Krikorian.

5

A

You mean what I'm going to say

6during deposition today?

7

Q

Yes.

8

A

No, no.

9Q

Did you talk to anybody else about

10

what you would be saying here today?

11

I'm not talking about the12

substance.

13

identify you spoke to about what you would be

14

saying and what questions you might be15

confronting?

16

A

17

Just a person that you can

I have -MR. KOHN:

Let me just make --18

excuse me.

19

assume you're not referring to her own counsel

20

and asking whether she talked to --21

MR. FEIN:

22

attorney.

Let me just make an objection.

No, I don't want an

I don't want client -- attorney-

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IPage 1131

client privilege.

2

THE WITNESS:

3

questions I was going to be asked.

4

couldn't talk about my answers.

5

I did not know what
So I

BY MR. FEIN:

6

Q

Let's go back to your hiring by

7

the FBI.

I think your testimony is it was

8

September 15th, 2001.

9A

Around that time.

10

Q

Okay.

11

Now, were you employedprior to your hiring by the FBI?

12

A

Yes.

13

Q

And where were you employed?

14

A

Had my own company with my15

husband.

16

Q

17

involved in?

18

A

Technology for retail industry.

19

Q

And when was that company formed?

20

A

About 1996.

21

Q

1996.

22

company.

Un-huh, and what was that company
What business?

Been about five years old

Where was it -- do you know where it

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was registered?

2A

I believe Alexandria, Virginia.

3

Q

And so what were the -- what were4

your tasks at that company?

5A

Marketing.

6

Q

Marketing.

7

A

And day-to-day management of

8people.

9Q

I'm -- could you be a little more

10

specific?

11

a retail marketing company.

12

services to retailers?

13

retail items?

14
15

You're saying it's a market -- it's
Do you offer yourDo you actually sell

MR. KOHN:

Do you have a relevant

MR. FEIN:

Yes, I do have aquestion?

16
17

relevant.

18

going to the FBI exactly what her background19

in intelligence was.

20
21
22

It's her background, knowing before

MR. MARINO:

I object.

It'soutside the scope of the direct examination.
THE WITNESS:

The position I had

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Page 1151

involved providing inventory, supply chain

2

management related software and services, IT

3services for retail45chains.

BY MR. FEIN:Q

All right, and were there any

6

employees of the company or just you and your7

husband?

8

A

9
10

No, at that time, I believe he had

eight, seven or eight employees.
Q

So is it fair to say the company

11

was involved in writing some kind of software

12that would enable retailers to do inventory

13

control?

14

A

IT services.

15

Q

IT services.

16

Did it have anythingat all to do with intelligence collection?

17

A

No.

18

Q

Did it have anything at all to do

19

with lobbying Congress or campaign finance?

20

A

No.

21

Q

How old were you when you were22

hired by the FBI?

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1A

Thirty-one.

2

Q

Thirty-one years old, and prior to3

that time, did you consider yourself an

4intelligence expert?

5

Did you do just as an avocation a6

lot of reading in intelligence collection and7

counterintelligence and espionage and how

8covert operations were run?

9

MR. MARINO:

Objection.

Compound.

10

THE WITNESS:

Both in terms of my11

education and background and also certain

12

activities that I was involved still while I

13

was in the United States, in Turkey, and14basically the kind of thing that you would

15

consider -- today's being considered citizen

16

journalism.

17
18

BY MR. FEIN:
Q

Could you be more explicit?

19

What's citizen journalism?

20

with that concept.

21

concept to me.

22A

I'm not familiar

If you could, explain that

Conducting research and write

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1

editorial pieces, whether the political2

situation in Iran or whether the articles I

3

had written or meetings I have discussed, the4journalists -- protection of journalists in

5Turkey, other human rights, because of the --6

my involvement with Committee to Protect

7

Journalists, political and civil liberties

8

related issues.

9

Q

10

So how many articles or books had

you published when you were hired by the FBI?

11

A

I had not published any books.

12Q

Any articles, any newspaper

13
14

articles, op-eds, magazine articles.
A

It's hard for me to tell how many15of the stuff I had written have been picked up

16

by international press, whether in Turkey or17

elsewhere.

18

Q

I have to check.

I don't know.

Let me just give you an example.

19

If I write an article, I will submit it and it

20

may be published by the New York Times or the21

L.A. Times or something like that, and I know

22

because I have an arrangement where you submit

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articles and they tell you it's going to be2

published or not.

3
4

Did you have any such arrangementwith any publication?

5

A

6

public.

7

the Committee to Protect Journalists or also

8

working on behalf of sexually abused children

9in Alexandria with Alexandria courts.

10

going -- providing all those services and11expertise for free because that was my public

12

work as a volunteer.

13

Q

No, I was doing it just mainly for
The same thing for my activism with

And how many hours of volunteer

14

time would you do for a week would you

15

suggest?

16
17
18

I was

MR. KOHN:

Can we have a time

MR. FEIN:

The time period when

period?

19

you were working on your -- with your company.

20

I guess it began in '96.

21

THE WITNESS:

22

My company wasestablished in 1992, and I had other real

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Page 1191

estate related businesses.

2

It depends.

During, between '96

3and '99 for Alexandria Court and sexually4abused children I would spend about 15 hours

5

a week working on that case.

6

and writing and reading about political

7

related issues, including journalism, civil

8

liberties, during that period of time it's

9

hard to estimate.

10

maybe ten hours a week.

11

BY MR. FEIN:

12Q

On researching

I would say in the range ofWhat was the title of the position

13

that you applied for for employment in the

14

FBI?

15

A

Language specialist, contract

16

language specialist for Turkey and another17

agreement that said contract language

18

specialist for Farsi.

19

Q

Were the criteria for that job at

20

all involved any knowledge, expertise in21

intelligence?

22

A

When they advertised and told me

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1about it, no, but upon my hiring --

2

Q

3

answer.

4
5

That's -- that's a good enough
And was that -MR. KOHN:

Had you completed youranswer?

6

THE WITNESS:

7

MR. FEIN:

No.

Oh, did you want to --8

if you -- if you think I've interrupted you,9

if you want to explain further, you just tell

10

me.

11

THE WITNESS:Sure.

The Special

12

Agent, Dennis Sharshar, for Turkish

13

Counterintelligence and Counterterrorism

14

Division, he also had a say in the matter, and15

he wanted to evaluate my political

16

understanding and understanding of Turkish

17

criminal operations in general, including the18

ultra nationalist Gray Wolves, before he gave

19

his okay, and we had a session that was during

20

the time when my contract was being approved,

21

and he made recommendations saying, yes, he22needed my expertise in the area of Gray

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Page 1211

Wolves, Turkey, Turkish ultra nationalists.

2

So I don't know how much role it

3

played, his opinion, but that was one of the4criteria that he wanted to have for his

5translator.

6
7
8
9

BY MR. FEIN:Q

Was he the one who made thedecision to hire you?
A

I am not sure about how the10hierarchy works within the FBI.

11

into consideration?

12of the Headquarters and the Headquarter people

13

that I'm not sure who they were; they --14

Q

Was it taken

I don't know because some

So you -- and he -- did you have a15

separate interview with him in conjunction

16

with your application?

17

A

After my application, yes.

18

Q

And this is before you were hired,19
20

as part of the application process?
ANo, this was during the time that21

they were drawing my contract.

Because of

22

September 11th terrorist attack, they wanted

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1

me to start immediately.

2

they were actually completing my contract.

3

contract was not completed because they wanted

4

me to start immediately.

5

Q

So as I was working,My

So that when you -- at the time6

you were hired, you were not -- had not been

7

interviewed by anybody at the FBI.

8just based upon your written application; is9that correct?

10

urgency?

11

A

This was

Because there was such an

Correct.

Three years before that12

it was polygraph test for background check and13

the filling out application, but I was never14

interviewed by anyone in the FBI ever.

15
16
17

Q

And how long did it take after you

applied before you were hired?
A

I don't recall.

In the range of18

not weeks, maybe a week or ten days, but I'm

19-- I don't recall exactly how long it took.

20
21
22

Q

And does the FBI have the GS level

pay compensation schedule?
A

As far as I know, they don't have

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Page 1231

it for contractors.

2time employees.

3

Q

4

They have it for full-

Were you a contract or a full-time

employee?

5A

I was a contractor.

6

Q

So what were you -- what were the7terms of the contract?

8

paid?

9

What were your obligations?

What was the length of the contract?

1011

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

12

A

13

and --

14

Q

15
16

How much were you

No, I showed up the premises

Was it at the J. Edgar Hoover

Building?
A

It was Washington field office,17

which is only a few blocks from the FBI

18

Headquarters.

19

Q

Okay.

Let's go -- I'll -- I'll --20

let's go thought item by item.

21

compensation rate?

22

A

What was yourI don't recall exactly.

It was in

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1

the range of 35 to $40 per hour.

2

Q

So they paid you on an hourly

3basis.

4

A

Correct.

5Q

Did they have a minimum or a6

maximum number of hours you're supposed to

7

work per week?

8

A

They asked me to work 40 hours or

9

more because they needed both my expertise in

10

language and also in the active, urgent cases

11

the FBI had, but I could not because I have

12

another job, and I was also preparing for my

13

Master's degree.

14

than 25, 30 hours a week, and they wanted much15

more, and they kept asking me, and they also

16

gave me the application and asked me to apply

17

for agent position at Quantico because they18

needed my expertise and language skills, and19

I got official letters, recommendations,20

recommending me to Quantico because of my21

knowledge, expertise, and the language skills.

22

Q

So I couldn't give them more

Did you actually apply for a full-

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time position?

2

A

No.

3

Q

No.

4

A

They couldn't pay me enough.

5
6

I

couldn't do that.
Q

So they offered you 35 to $40 an

7hour, and was it up to you or did you have to

8work a minimum number of hours in order to9stay as a contractor?

10

A

They told me everything was up to11

me because they couldn't find someone with my12expertise13

background checks.

14

even if it was ten hours I could spare, would

15

be great because they wanted me to work for16them full time or overtime.

17
18
19

Q

in language skills and the
So anything I could do,

And was there a time -- was therea term for the contract?
A

I believe so.

I am not sure about

20

the date, whether by the end of that year,

21

because I started in 2001, whether it had to22

be renewed by January 2002, but there was a

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1

time period, correct.

2

it was.

3

Q

I don't remember what

Had the time period expired and4

you were renewed in April of 2002 when you

5were let go?

6

A

7
8

That may have been the case.

was eight years ago.
Q

It

I don't recall.

And during the period when you

9were with the FBI, about how many hours per

10week did you, in fact, work?

11A

It was not exactly the same way

12

every week because based on my school

13

schedule, based on my family life and work,

14

some weeks I was able to work maybe 30 hours.

15

Some weeks I was able to work about 15 hours.

16

If you were to average it, it would be in the17range of 20, 25 hours a week.

18

Q

So that would be about half time,19

and let's assume 40 hour week would be a20

standard work week for someone who's employed

21

full time.

22

employee in terms of hours.

You were somewhat like a half-time

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1
2

MR. KOHN:

She was a contract

MR. FEIN:I know.

employee.

3Well, I'm a4little bit confused when you -- independent5

contractor may have different rights and legal

6

obligations as an employee who may get pension

7

benefits and all sorts of health insurance.

8

I worked in the Department of Justice for 15

9years, and contractors would not be entitled10

to those benefits like an employee was.

1112

BY MR. FEIN:
Q

Were you identified in your13

contract as an independent contractor or an

14

employee for purposes of these benefits and15

other what you would call subsidiary16

remuneration for working?

17

A

Independent contractor.

18

Q

Do you know how many other19

independent contractors were working with the20

FBI about the time you were?

21
22

A

No.
MR. KOHN:

I presume you're

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talking in her area.

2

MR. MARINO:

Yeah, in -- in --3

THE WITNESS:

Language.

4

MR. MARINO:

In the language, the5translation area.

6

THE WITNESS:No.

I know several.

7

There were more than 200, 300 people in that8

department, combination of full time and9contractors, and my knowledge is limited to10

the Farsi Department and maybe Turkish

11

Department because things were changing.

12

people would start as contractors and wanted

13

to work full time.

14

exact number.

15
16

Some

So I can't give you an

BY MR. FEIN:Q

Do you know whether it was17customary that other independent contractors

18

work on an average 20, 25 hours a week where

19

you were in the mid-range or did you not know

20

about other independent contract arrangements?

21

A

I don't.

22

Q

You didn't know?

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1

A

I didn't know.

2Q

You didn't know about any other3kind of arrangement.

4

were the work place arrangements for you to5

perform your work?

Did you go to a fixed

6

office at the FBI?

Were you given opportunity

7

to choose where you wanted to listen to tapes?

8

How did that work?

9A

And tell me exactly what

I can't give you details because

10of the area, but it was combination.

11

as my main work that I was asked to do because

12

it was top priority outside counterterrorism,13

it was only Washington field office, and that14

was where from other field offices they would

15

send information related to Turkish related

16

area and I would translate.

17

As farBut for certain counterterrorism

18

tasks I had to go to Philadelphia or New

19

Jersey to the Special Agents.

20

I had to interrogate 9/11 detainees that were

21

shackled in rooms who didn't speak English and22

they spoke either Turkish or Farsi.

In some cases

It was a

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1
2

combination of different tasks.
Q

So your tasks included not only3

listening to tapes, but doing interrogation of

4detainees?

5A

I can't say tapes or not tapes,

6

but in addition to audio, it was written.

7

Also it included live interviews, going to8various field offices, and translate

9interrogation results.

10

Q

So let me be clear in my own mind.

11

You would translate an answer, but you

12

wouldn't be the one making up the questions

13

for the detainees or is that inaccurate?

14

A

It depended because after

15

September 11th, some of the FBI agents, they16

didn't know anything, and they were very nice17

and good to know that they didn't know

18

anything.

19

to ask the right questions from detainees and20

some of the immigrants they had rounded up.

21

In some cases there were certain Kurdish

22

individuals, and even the Special Agent in

So they would defer to my expertise

Neal R. Gross & Co., Inc.
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Page 1311

Charge would take me out and say, "What kind2of questions do you think needs to be asked?"3and I would tell them this and this, and4because of the region this person from Turkey

5

had come, it's not a very religious city.

6-- or this person seems to be from the area7

and a family background that is ultra

8nationalist.

9

draft the questions to trick the detainees and10

get the right answers.

So they would ask me to actually

11

So, yes, in fact the Special

12

Agents in Charge deferred to me to draft

13

questions because they didn't know where

14

Turkey even was.

15

Q

So

Can you give me -- and I don't

16

want to intrude on intelligence sources and17

methods --18

A

Right.

19

Q-- can you give me an example of a20

particular question you drafted for a21

detainee?

22

MR. KOHN:

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1-

2

THE WITNESS:

3

MR. FEIN:

4BY MR. FEIN:

5Q

I can't make it up.

Withdraw the question.

Mow, I think that in your6

testimony this morning you stated that the7allegations that you had made internally to

8

the FBI about various amounts of wrongdoing

9

had all been substantiated by the Inspector

10

General's report.

11

and statement, that your allegations were all

12

substantiated by the Inspector General?

13

A

Is that your recollection

No, I said the Inspector General's

14

report is public and you can defer to it, and15

I believe I was asked about Dickerson

16

espionage case, and on that particular case I

17

said the report substantiates and states that18

those allegations were supported by other19

witnesses and documents, or some language to20

that effect.

21

Q

22

Now, were there other allegations

that you made that the OIG said were not

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substantiated?

2

MR. MARINO:

Objection.

3

Foundation.

4

OIG looked with the other allegations.

5

BY MR. FEIN:

6Q

You haven't established that the

To your knowledge, did the OIG

7look at allegations, for example, relating to8misuse of travel?

9

A

Yes.

10

Q

It did look at those, and do you

11

recall whether the OIG substantiated your12

allegations on that score?

13

A

I don't recall.

It may have been

14

one of those that it was not conclusive or15

they didn't have other witnesses.

16

sure.

17

report, but we can bring the report and I can

18

go over that.

19

Q

I'm not

It's been a while since I read theWould it surprise you if I gave

20

you the report and it said that it was unable21

to substantiate your travel allegations?

22A

Not at all.

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1

MR. KOHN:

2

you well enough to be surprised.

3
4

I don't think she knows

BY MR. FEIN:
Q

After April when you were

5discharged or you weren't renewed by the FBI,

6

what then did you turn to for employment or

7work or what then occupied your time?

8

A

What period of time you're

9referring to?

10

Q

Well, why don't we -- let's take11

it year by year and maybe we can abbreviate it12

if there's some years that are the same.

13

from April in 2002 to the end of 2002, what

14

were you doing after you left the FBI?

15

A

So

Oh, I had just begun my case with16-- my court case with my attorneys.

17of my time was concentrated on my case, legal

18

case, in court and the necessary research

19

related to my case.

20

Q

Okay.

So most

So you were working on

21

challenging the legality of your discharge; is22that correct?

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1

A

Yes.

2

Q

And what about 2002 to 2003?

3

A

More research and contacting other4

FBI and CIA and Department of Defense

5witnesses who could have known about these6

cases or worked in the relevant areas, and my

7legal case, and starting my organization

8

around that time, which is a nonprofit

9organization.

10

Q

11

organization?

12

A

13

Okay.

What's the name of the

National Security Whistleblowers

Coalition.

14

Q

And is that incorporated as a15

501(c)(3) organization or what's the16

corporate --17

A

It's 501(c)(4).

18

Q(c)(4) organization, and that was

19

incorporated in 2003?

20
21
22

A

I believe it was 2000 -- end ofQ

End of 2004?

2004.

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1

A

Correct.

2

Q

And what is the mission of that3
4

particular organization?
A

It works with intelligence and law

5

enforcement related individuals who have been

6

wrongly treated or retaliated against for7

whistleblowing, in general, and helping them8

with their cases, legal cases, referring them9

to attorneys, analyzing their cases, their

10

court cases, their filings, and also

11

coordinating with the media about any release12

or statements on their cases' development, and13

also legislation activities with Congress.

14

Q

Who are the officers of that15

organization?

16

A

It's myself.

17

Q

What's your title?

18

A

I'm the founder and director, and19

we have -- I have two senior advisors.

One of20

them is Professor William Weaver, who used to21

work for NSA, National Security Agency, and22

now he's a senior professor at the University

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1of Texas.

2

Q3

advisor?

4

A

And who is the other senior

Steve Elson.

He was the top

5

ranking Federal Aviation, FAA Red Team member

6

on terrorism related operations.

7Q

So you are the director and then8

you have two senior advisors.

9

board of directors?

10
11

A

Is there aYes, and the board of directors ismyself and Steven Elson and William Weaver.

12Q

Any others?

13

ANo, not that --14

Q

Are there any other officers, a15

treasurer, secretary, anything like that?

16

A

That would be me.

17

Q

That's all you?

18

A

Yes.

19

Q

And is this a stock or non-stock

20

corporation?

21

A

No.

22

Q

It's a non-stock corporation.

Neal R. Gross & Co., Inc.
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HowPage 1381

do you receive your revenues, your receipts?

2

How is it funded?

3

A

It's based on volunteer work, and4

all my members, they all work as volunteers

5

for the organization.

6

workers who work without getting paid.

So I have a hundred

7

Q

Do you solicit any contributions?

8ANo, not right now.

9Q

Are the revenues zero?

10

A

Correct, because I am

11

independently wealthy at this point, and I

12

don't need to owe anything to anyone.

13

don't have to raise funds.

So I

14

Q

15

organization?

16

A

It has a P.O. box.

17

Q

It has a P.O. box.

18

A

Correct.

19

Q

Is it fair to say it operates out

20
21
22

What is the street address of thisof your house, your residence?
A

And other members' residence, too,and also the coalition organization.

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Page 1391

several members' partner organizations will2

have me doing this.

3

partners.

4
5
6

So they are also my

Q

And how many volunteers have youA

It depends with the time period.

had?

7

During congressional legislation activities,

8

sometimes I have 60 who are working with9

writing articles and working with the media,

10

going to Congress, meeting with various

11

congressional offices.

12

periods, I may have only one.

13

depends.

14

Q

In certain quieter
So it justDo you keep track of how often

15

your organization is quoted in the media

16

through Google or otherwise?

17

A

We have a press section which18

keeps track of it.

Again, certain periods

19

when we have high level congressional

20

activities, which we had a lot in 2000 -- end

21

of 2005, it was almost daily, which would be

22

Congressional Quarterly, Federalist, and all

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1of these documents.

2

period that will be quite, like any other NGO.

3

Q

Then there will be a

What about getting articles that4

the organization has written published in the5

media?

6

A

Does that happen?
Yes.

I was published by the7

Journal of Atomic Scientists on nuclear black8

market and nuclear whistleblowers, and that9

was published, I believe, in 2006, and I was

10

published, together with my partner, Professor

11

William Weaver, I believe it's Federal Times

12

publication on intelligence related

13

whistleblowers.

14

Q

15

think, in 2004.

16

do you devote to this organization?

So you began the organization, you
About how many hours per weak17

A

It depends.

Certain period --18

QDo you have a range?

19

A

Totally depends.

During20

congressional activities, I may spend 70 hours

21

a week, and during some quiet time, it may end

22

up being ten hours.

It just depends.

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1

Q

Now, other than this organization

2

that you are the director of, any other3

employment, work-related activities that4

you've undertaken since your discharge?

5

A

Continuing my company together

6with my husband as a consulting company for7

retail.

8

Q

So those --9

A

Until now.

10Q

So does that exhaust the universe

11of your work activities?

12

consultant on the retail and inventory.

13

are running -- you're the director of the14

whistleblowers 501(c)(4), and does that15

exhaust your work-related activities?

16

A

You worked as aYouNo, it doesn't because I spend a17

lot of time both researching and writing not18

only for my Website, but for my blog and also

19

working with individuals from the intelligence

20

community on issues of interest.

21
22

Q

And could you identify thoseparticular issues that have been of interest

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Page 1421

to you?

2

year.

Let's not take -- how about the year

3

2009?

What have been the intelligence

4

activities, national security activities that5

have been of interest to you that you pursued?

6

A

Let's start out with the most recent

Civil liberties related issues,

7

including the misuse and abuses of State

8

Secrets Privilege; the recent congressional

9

activities on legislation for whistleblowers,

10

for the inclusion of national security

11

whistleblowers who are currently not included

12

in the legislation or the mark-up.

13

Also, it has been on the -- on the

14

general, mainstream media, a trend of not

15

reporting on certain areas and issues, whether

16

it's related to national security

17

whistleblowers or certain geographic regions

18

or certain cases, this, for example.

19

this will be something I will be working on in20

the next few months.

21
22

Q

Like

Since you left the FBI, has any --has your area of interest continued with

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Page 1431

regard to foreign governments corrupting the2State Department, Defense Department, and3members of Congress to get weapons material,

4

nuclear material, bribery and that kind of

5thing; has that been an area that you've

6

pursued since you left the FBI?

7

A

It's not only that I have pursued.

8

It's been because of my background, a lot of

9sources and people have started contacting me,

10

and I have gotten to see more documents in the11

newspaper articles, et cetera, on these areas

12

than I even had before the time or interest

13

me.

14

Q

Now, you testified that the15

government of Turkey has corrupted the U.S.

16

Congress and the State Department, et cetera.

17

What other countries do you know have also

18

corrupted the United States Congress, State

19

Department, Defense Department, National

20

Security Council through bribes, blackmail or21

otherwise?

22

MR. KOHN:

I think she identified

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Page 1441

specific individuals, not entire institutions.

2MR. FEIN:

3government of Turkey.

4

raised, the government of Turkey, and she said5

the government of Turkey had corrupted the6United States Congress, amongst others.

7
8

That question was

THE WITNESS:

So the question iswhat other --910No, she identified theBY MR. FEIN:
Q

What other countries other than

11

Turkey have corrupted the U.S. government and12various of its organs based upon your under --13

you have testified most of it is money, but

14

sometimes it's blackmail -- but what other15

governments have also accomplished that feat?

16

MR. KOHN:

Objection.

I object to17

the breadth of the question.

18

questions were based on specific individuals.

19
20

MR. FEIN:

The other

Answer the question,please.

21

THE WITNESS:

Based on my22

information, I had knowledge and have

Neal R. Gross & Co., Inc.
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Page 1451knowledge to particular activities that was2done in conjunction, together jointly with3

those entities, the Turkish entities,4

including the ones connected to the Turkish

5

government, that were working and they were6with Israeli lobby groups and certain people

7

from the diplomatic community of Pakistani

8

Embassy that were operating out of Washington,

9D.C., together with those Turkish entities.

10
11

BY MR. FEIN:Q

So your testimony is under oath12

here that the government of Pakistan and the13

government of Israel worked in conjunction

14

with the government of Turkey to give money

15

and to blackmail Congress people and people in16

the government in order to get things

17

favorable from the U.S. in their foreign18

policy?

19A20

those offices.

21

Q

22

I said individual connected toNow, let's go back.

When youtestified earlier, I think to one of Mr.

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1

Manion's (phonetic) questions, you did use the2word "government of Turkey" had corrupted the3

Congress and the establishment and the4

executive branch through money and blackmail5

and otherwise.

6of Turkey."

7

only the Prime Minister or people in the8embassy's office.

9"government of Turkey."

You used the word "government

You didn't identify, oh, it was

You used the word

10

Now I'm asking you are you also

11

saying that the government of Pakistan, the12government of Israel also worked in

13collaboration with the government of Turkey to14

corrupt members of Congress and the executive

15

branch establishment through money or

16

blackmail in order to get foreign policy

17

favors.

18

MR. KOHN:

I object.

19

you have taken her testimony

20

context.

21
22

MR. FEIN:

I believe

somewhat out of

I'm repeating.

I know

the word "government of Turkey" was used.

Neal R. Gross & Co., Inc.
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I'm

Page 1471

not taking it out of context.

2

MR. KOHN:

Well, the word

3

"government of Turkey" may have been used, but

4

I don't recollect it being used in the exact

5

context you're using it.

6

MR. FEIN:

Please answer.

7

THE WITNESS:

Individuals

8connected, working with these governments,

9with these governments, in their official

10capacity.

11
12

MR. FEIN:
my question.

13
14

Well, you're not asking

BY MR. FEIN:Q

I'm asking you to use, as you used

15

the word "government of Turkey," in the same16

sense that you understood "government of17

Turkey" when you used it in answering Mr.

18

Manion's (phonetic) question to apply that19

same understanding in Pakistan and Israel as

20

to whether or not the government of Pakistan

21

and the government of Israel collaborated with22

the government of Turkey in corrupting U.S.

Neal R. Gross & Co., Inc.
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Page 1481

Congress people and members in the executive

2

branch of the United States government to win

3

favors in the foreign policy and national

4

security.

5

MR. KOHN:

6

the question and unintelligible.

7

a simple question, please?

89MR. MARINO:
objection.

10
11

Object to the form of
Can you give

I join in the

I can't understand the question.
BY MR. FEIN:Q

When you testified earlier that12

the government of Turkey was corrupting the13

U.S. Congress and the executive branch

14

officials by money, bribes, and blackmail,15

what did you mean by "the government of

16

Turkey"?

17

A

Individuals and certain

18

individuals and operatives with official

19

capacity, and that official capacity being the20

employees and members of Turkish government.

21
22

Q

So you did not mean the governmentof Turkey in the sense that there was an

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1

official government of Turkey policy that2

involved bribery.

3

have been rogue elements that weren't

4

operating under the aegis of the Prime

5

Minister's office and doing this on their own

6

for their own personal greed or pecuniary

7

benefit.

You meant that these could

8

MR. KOHN:

Are you identifying a

9specific person or the totality?

10

MR. FEIN:

11

to get a clarification between her

12understanding of individual members who belong

13

to a government.

14

United States, you can have one individual who

15

is subject -- who's found guilty of bribery in16

the executive branch.

17

mean that that individual was operating under18

the aegis and the sponsorship of the President

19of the United States and the government.

20

It might be or it might not.

Well, I'm just trying

Take, for example, in the

It doesn't necessarily

It

21

could be rogue or it could be in collaboration

22

with the government itself, the policy of the

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1government.

2

BY MR. FEIN:

3
4Q

Do you understand that

distinction, Ms. Edmonds?

5

A(Nodding.)

6

Q

All right.

Now I'm trying to take

7

that distinction and applying it to your use

8of the word "the government of Turkey" is9bribing and blackmailing members of Congress

10

and the executive branch to doing favors in

11

its foreign policy and national security

12

arena.

13

Were you think government of

14

Turkey in the sense that these individuals

15

that you're referring to were acting at the16

behest and the aegis and the sponsorship of17

the Prime Minister and his government, or were18

they acting as rogue elements?

19

you referring to?

20

MR. KOHN:

Which one were

Object to the question.

21

It is -- for example, I don't think the United

22

States government itself can engage in

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1

unlawful conduct.

Individuals of government2

may be, and the government in itself may be

3viewed as being engaged in illegal conduct,

4

but the government, but a country cannot

5

engage -- this country cannot engage in6

illegal conduct.

So --

7

MR. FEIN:

8

MR. MARINO:

9

Well, there -Wait, wait, wait,

wait, wait.

10

MR. KOHN:

Excuse me.

The

11

problem, the perception is when the President

12of the United States does something illegal,

13

the government has done something illegal, and14

so I think it is difficult to try to pull them

15

apart.

16

You're asking this individual to17

speak on behalf of actions taken on behalf of18

the government or taken on behalf of the19

representatives of the government, and I

20

believe it's beyond her capacity to give you

21

the specific answer you're looking for.

22

MR. MARINO:

Can I make an

Neal R. Gross & Co., Inc.
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Page 1521

objection?

2

MR. FEIN:

3

MR. MARINO:

4questions are very argumentative.

5very convoluted.

6

just making an argument and then asking the7witness a question which is unintelligible,

8and it seems like you're defending the9government of Turkey and not cross-examining.

10

Of course.
I think these
They'reI mean, I feel like you're

MR. FEIN:

No, I'm responding to11

actually something that's in the complaint

12

rather than something that's totally13

irrelevant because one of the charges that Mr.

14

Krikorian makes against Jean Schmidt in his

15various campaign literature that's subject to16

the complaint is that the government of17

Turkey, the government of Turkey gave money to18Jean Schmidt, and the government of Turkey,

19

government sponsored PACs gave money, and20

that's the phraseology he uses, "government of21

Turkey," "government," not individuals, and22

that's why I'm trying to get your assessment

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Page 1531

when you testified the Turkish government what2

you meant by that.

3

MR. MARINO:

Okay.

I'm going to

4

object.

I think you're mischaracterizing.

5

Why don't you show the witness the complaint

6

instead of you trying to characterize it?

7

Because I think you're mischaracterizing it.

8

MR. FEIN:

9

MR. MARINO:

10
11
12

complaint.

I will -Show her the

There's a copy right here.
MR. FEIN:

Yeah, I'll show her theexhibits, which is perhaps more relevant.

13

MR. MARINO:

14

client's complaint which you just15

characterized.

16

MR. FEIN:

Show her yourThis is the -- why

17

don't we do this?

18

your time -- the complaint and exhibits to the19

complaint that form the gist of the20

outstanding petition, and then we can ask you

21questions about it.

22

You read through -- take

MR. MARINO:

All right.

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1
2

MR. KOHN:

question or is she supposed --3
4

Is there a specificMR. MARINO:

May I see what you're

showing the witness, please?

5

MR. FEIN:

Sure.

6

MR. MARINO:

7

MR. FEIN:Is this the whole -There are additional

8

exhibits, but those aren't part of the9question.

If you want to show them, show her

10

your copy.

That's fine.

11

MR. MARINO:

It doesn't matter.

12

just need to give the witness an opportunity

13

to review it.

14
15

I

Do you want to go off the record
while she reviews the exhibit?

16

MR. FEIN:

17

probably make sense.

Yeah, that would

18(Whereupon, the foregoing matter

19

went off the record at 2:14 p.m.

20

and went back on the record at

21

2:25 p.m.)

22

MR. FEIN:

Ms. Edmonds, let me try

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Page 1551

to accelerate this.

2
3

BY MR. FEIN:Q

I believe on one of the exhibits

4

the sentence I underlined there is the5statement to the effect -- and I think Mr.

6

Krikorian clarified this in his own deposition

7-- that Jean Schmidt had received money from8

the government of Turkey.

9

Do you have any personal knowledge

10

that Jean Schmidt received money from the11government of Turkey?

12

A

No.

13

Q

You'll see also, I believe, on

14some of these, I think there are two other15

places in that exhibit I underlined.

16

the statement that Jean Schmidt received money

17

from Turkish government sponsored PACs.

18

you have any personal knowledge as to whether

19

or not Jean Schmidt received any money from20

the Turkish government sponsored PACs?

21

A

22

Jean Schmidt?

There's

Do

You're asking specifically about

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1

Q

Jean Schmidt.

2

A

No.

3

Q

Okay.

4

That's enough.

Now, I want to go back to the time

5

frame in which I think you were identifying

6

for Mr. Manion (phonetic), those members of7

Congress who your judgment was had received

8

bribes, and you had mentioned Mr. Blunt and9Mr. Hastert and Mr. Burton and some others.

10

Now, was your knowledge based upon information

11

you had acquired prior to your leaving the

12

FBI?

13

MR. KOHN:

Her knowledge would

14

have been based on information outside the15

scope of her employment.

16

deposition has been set up.

17

MR. FEIN:18

BY MR. FEIN:

19

Q

That's how thisOkay, but I am --So, number one, your knowledge was20

not related to anything you learned in your21

FBI employment, but I'm also asking whether or

22

not that knowledge outside your government

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1

employment was acquired

2

the FBI.

3

MR. KOHN:

prior to your leaving

Let me rephrase it.

4

There's much of what she learned while she was5

employed with the government that she happened6

to also learn through additional sources after7

she left the government.

8

corroborating source that she learned it from,

9

whether or not she learned it in the10

government, she would have revealed it here.

11

MR. FEIN:So

if there was a

Right, but I guess this12

is what I'm trying to clarify, is the time

13

frame in which the information related.

14

they bribed in 2001, 1998 or whatever.

15

BY MR. FEIN:

16

Q

So what I'm asking is:Wereis the17

information you acquired, whether it was18

corroborating information in the public record

19

or not, relating to the bribery, were the20

bribes, the blackmail in a time frame that was

21

prior to April of 2002 when you left the FBI?

22

MR. MARINO:

I'm going to object

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Page 1581

to the question.

2and I don't know what specific things you're3talking about.

4

that have been --5
6

I think it's really mangled,

You keep compounding things

MR. FEIN:

The question is very

simple.

7

MR. MARINO:

8

MR. FEIN:

9No, it's not.
Okay.

I will goback --

10

MR. MARINO:

11

MR. FEIN:

12

MR. MARINO:

13

been doing this for the entire cross-14

examination -- I would ask that you just ask

15

simple, direct questions and on specific16

things, not combining all the things you've

17talked about.

18

you know, break it down.

19

a clear record.

20
21
22

Let me just finish.
Okay.
I would ask -- you've

Was that based upon informa --MR. FEIN:

I just want to haveLet's take one ofthose.
BY MR. FEIN:

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1Q

Mr. Burton you said received

2

bribes from the government of Turkey.

3

years were those bribes received?

4
5

A

What

My information that is limited forthe time period 1997 until January 2002.

6Q

Is that also true for all the7others that you've identified for Mr. Manion

8(phonetic), that time frame?

910

MR. KOHN:"All the others" is avery broad --11

MR. FEIN:

12

that you had -- were on your blog.

13

think, were the ones that you related to Mr.

14

Manion (phonetic).

15

there that he was recounting:16

Mr. Blunt, and I think there were some others

17

there that I assume that you had identified on

18

your blog.

19
objection.

21

one.

Those, I

They were the pictures

MR. MARINO:

20

22No, I'm saying the ones

Mr. Hastert,

Again, same

I mean, I went through them one by

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1

them one by one.

2
3

MR. MARINO:
you should do.

45

MR. FEIN:

All right.

Let's gothrough.

6
7

I think that's what

BY MR. FEIN:Q

So Mr. Burton, your information

8

related to the time frame 1997 up to January

9of 2001.

10

MR. MARINO:

11

BY MR. FEIN:

12
13
14
15

Q

Two.

Mr. Blunt, what was the time frameof the information relating to bribery?
A

Mr. Blunt, to the best of myrecollection, the same time period.

16

Q

Mr. Hastert?

17

A

To the best of my recollection,18

the same time period.

19

Q

Steven Solarz?

20

A

To the best of my recollection it

21
22

would be 1999 to January 2002.
Q

Mr. Gephardt, Richard Gephardt.

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1A

And I'm sorry.

I have to go back.

2

Mr. Solarz, referring to his capacity as his

3

firm.

4

during those -- so we're not talking about

5

congressional.

6

Q

The people that you had --7

A

Okay, and that would -- their

He was not an elected representative

We're talking about --8

activities of receiving or those kinds of

9

activities in the context that I explained for10

Mr. Solarz's role would be 1999 until January

11

2002.

12

Q

And Mr. Richard Gephardt?

13

A

I don't have any information on

14

Mr. Gephardt.

15

Q

16

Having received any government

bribes --

17

A

No.

18

Q

-- or otherwise?

19

A

No.

20

Q

Do you have any information

21

relating to bribery and blackmail of incumbent

22

members of Congress that were after January of

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1

2002?

2

A

You mean direct information?

3

Q

Yes, based on personal knowledge.

4

A

No.

5

Q

Do you know who Jean Schmidt is?

6

A

Limited to the news articles I

78have come across.
Q

Before Mr. Krikorian spoke to you

9about ten days ago, did you know anything

10

about Jean Schmidt?

11

A

Very small amount that had to do

12with some computers in 2006 that had a glitch

13

during election because this was on the14

headlines, but no, I didn't.

15

Q

Did you know anything about the16

Turkish Coalition of America until it was

17

raised in the question by Mr. Manion

18(phonetic) this morning?

19A

Either that or maybe in the past20

one year I may have received some of these E-

21

mails that this organization sends on

22

supporting Turkish, you know, vote against

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1

Turkish genocide because I get those from2

Steven's association.

3

there.

4

Q

They name may have been

I don't recall.
Do you know anything other than5

what you've just described here about what's

6

known as TCA?

7

A

TCA?

8

Q

You don't know who the officers

10A

You work with them.

11Q

I think I'm Turkish American Legal

12

Defense Fund.

13

A

Okay.

14

Q

But you would know that I work

9

Yes, I don't know.

are.

Then all right, all right.

15

with them just because I told you.

You didn't

16know it independently from the informants; is17that correct?

18

independent?

19

A

Or did you know thatYour name just came up in, you

20

know, associated with that organization.

21

Maybe it was in the article that I read in

22

Politico.

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1

Q

Okay.

2

A

But no.

3

Q

Okay.

I think you testified in4

the direct examination about state secrets and5

how that had been -- the State Secrets

6

Privilege had been employed in some of the7litigation that you had initiated to obtain

8

dismissal, I think, of your case and then9

blocking is it Motley Rice having access to a

10

deposition?

11

Now, the State Secrets Privilege

12

is a legal document.

13

Court cases that identify what the elements of14

the state secret is?

15

A

Have you read Supreme

I have read so much on State

16

Secrets Privilege and so many court documents.

17

Are we talking about any recent

18

Court?

19

Q

Well, how about Doe v. Webster?

20

A

No, I haven't.

21

Q

You haven't read that.

22

Supreme

Have youread Reynolds v. United States?

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1

A

Yes.

2

Q

Totten v. the United States?

3

A

Yes.

Again, these were -- I read4

all of those during my court case, and my5

court case was active.

6four years ago, namely, those cases.

7

Q

So it would be three,

Have you testified on the pending

8

legislation on state secrets that I think

9

Jerry Nadler is the chief sponsor?

10

testified for any of the congressional

11

committees considering state secrets

12

legislation?

13

A

No.

Have you

I have to qualify that.

14

Congressional members have a kind of a gag

15order on them because of the retroactive

16

classification and order they got from Justice17

Department during, I believe, Attorney General

18

Ashcroft.

19

have me there.

20

Q

So they don't even know if they canWell, I've testified at the21

hearings, and they don't get into anything

22

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be, but that's aside.

Let's move on.

2

Have you put in a fair amount of -3

- do you study lobbyists and lobby groups and4

how they operate in Washington?

5A

I have been reading.

6

Q

And what have you read about how

7lobby groups operate in Washington?

8A

It depends on what I have read.

9

Q

Give me the books that you've

11AMore than books --12

Q

Let me put a time frame.

10

read.

I don't

13

want it to be endless.

Say since you left the

14

FBI, it has been mainly articles published15

both by mainstream media and also alternative

16

media on at least the cases that have come up,

17

whether it is on, you know, APAC or the18

conflict of interest case, such as the recent

19case that had to do with the defense

20

contractors being related to a particular

21

Congressman Murtha and how that lobbying

22

caused -- so it would be mainly mainstream

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media related article of the consequences of2

the foreign lobbies and the conflict of

3interest between certain business sectors'

4

lobby and congressional relations.

56Q

Have you ever read the Foreign

Agents Registration act?

7

A

Several years ago, yes, and I

8believe it is Department of Justice's Website.

9

This would be around maybe 2006 or 2005.

10
11

Q

And what's your understanding ofwhen you have to register as a foreign agent?

12

A

Again, it's been a while.

It was13

my understanding that if you work and you

14

lobbied on behalf of that foreign government.

15

Q

If you're a lawyer do you have --16

if you represent a foreign government as a17

lawyer, do you have to register?

18

A

I don't know.

19

Q

What about the Lobbying Disclosure

20
21
22

Act?

Are you familiar with that statute?
A

Not as an expert and somewhat very

familiar with the technical language, but very

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broad kind of understanding when I was

2

reading, again, with just the regular3

mainstream media and all kinds of media

4

articles about this topic.

5

Q

Do you have any personal knowledge

6of the campaign that was run by Mr. Krikorian7

in 2007-2008 election cycle in which he ran as

8

an independent against Jean Schmidt in the 2nd

9District of Ohio?

10

A

No.

11

Q

If I used the word "a government

12

sponsored political action committee," what is13

your understand of a government -- a foreign

14

government sponsored political action

15

committee?

16What does that mean to you?
In specifics, does that mean the17

foreign government is giving money to that18

political action committee or other things of

19value?

20

A

I'm not sure.

21

Q

Does it have any meaning to you at

22

all?

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1

A

Government --2

QSponsored.

3A-- sponsored --4Q-- political action --5A-- political action committee?

6Q

Un-huh.

7

A

I guess, again, I don't know.

I8haven't read the description or definition of

9that particular terminology.

10

me would be it would be either by, commerce,

11commerce/business sponsored, and doesn't mean

12

necessarily money or the lobbying and the13

advocacy for by a certain group.

14
15

Q

Okay.

The meaning to

If it's not money, what are

the other things that come to mind?

16

A

I'm not sure.

17

Q

But money would be the most18

prominent thing that would come to mine or

19

not?

20

what it means?

21

A

22

Other things compete with money as to

I guess that depends on whichcountry, foreign country you're dealing with

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1

and what --2

Q

Dealing with Turkey, if it's

3

Turkey, if it's the Turkish government

4

sponsored.

5A

If it's a Turkish sponsored PAC,

6

up until, let's say year 2000 to January, it

7meant certain things.

8

meant since then, but up until 2002, it would

9

have meant something.

I don't know what has

10Q

And what was that?

11

A

When their donations are made to a

12certain PAC or a lobbying, well, during that13

time period it was only done to PACs or PACs

14

that are related to congressional candidates

15

who have made covertly promises and deals

16

because they have overt promises.

17

will be promoting commerce, et cetera, but18

covertly to further certain interests or

19

agendas of certain business and entities and20

sometimes or most of the time those work hand21

in hand with certain government agents,

22

foreign government agency.

Yeah, I

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1

Q

So that was giving money prior to2

2002; government, Turkish sponsored PACs would

3

be giving money to the PACs to give the money4

to the members of Congress?

5
6
7

A

No.

You asked for the reason.

You said why would they give and I -Q

No, no.

If I spoke that, it was

8inartful.

9

just saying a government, a Turkish government

10

sponsored PAC prior to 2002 -- I think that11

was the time frame you were referring to --12

meant in your understanding that the13

government of Turkey gave money to the PAC in

14

order to give to members of Congress.

15
16
17

I'm not asking why they gave.

I'm

I'm not asking what they sought inexchange.
A

Right, and they did so overtly and18

covertly.

For example, sometimes the money in

19

the form of a suitcase of cash would go to a

20

certain person or business entity, and from

21

that business person/entity, would be divided

22

to ten people in order to not trace the origin

Neal R. Gross & Co., Inc.
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Page 1721of that money to that particular Turkish

2government agent or Turkish government group.

3

So they did it in steps.

4Q

So it just depends.

So it would be like you would use

5or they would use the middle men.

6

It has come -- the origin of the money is the7government of Turkey.

8

looks like a private business or entity, and9they tell them you then turn around and maybe

10give it to another middle man so that there is11some kind of chain of custody that separates

12

the government of Turkey directly from the end

13

user, but the origin of the money is from

14

Turkey.

15

A16

with the --

17

Q

18
19

They giveAll right.

till itOr a government entity associatedA government owned corporation orenterprise of some type.
A

Or it can be an entity, let's say.

20

Let's say it can be a military attache person

21

that is doing that, that the Turkish military22

attache and that person is -- you know, that

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military attache person is employed by the2Turkish government, and suddenly he says,

3"Okay.

4

are we going to distribute that?"5

have a candidate in mind, there are ways they6

did it, and that would be -- one way would be7

to give some of that cash.

8

citizens, Turkish people who are citizens

9

here.

10

have each one of those citizens write some11

amount like under $200, let's say, to a

12

particular candidate.

I have a suitcase of $45,000, and how
Unless they

They get the

You know, they give them cash, and they

13

Even though that money didn't come14

from those U.S. citizens, the money came from15

Turkish Embassy, and as long as it was under

16

200, they can get 500 Turkish people.

17

one write $200.

18

they do it.

19

Q

20

Each

So that's one of the ways

Okay.

All right.

That answers myquestion.

21

If a PAC gave campaign

22

contributions to a member of Congress who was

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a sponsor of the Armenian genocide resolution,

2

then you're pretty certain that would not be

3

a PAC that got any money from the Turkish

4government?

5
6

MR. MARINO:

Objection.

Foundation.

7

MR. FEIN:

8

MR. MARINO:

9BY MR. FEIN:

10

Q

Excuse me?
Foundation.

Oh, I think that you testified

11

earlier in response to Mr. Marino's question.

12

I think he was asking you to speculate a13

little bit that one of the ways in which the14

Turkish government was able to obtain promises

15

and influence against an Armenian genocide

16

resolution, which you identified was a17

concern, was that they would audit -- they18

would invariably extract iron-clad promises

19

from members who were going to receive their

20

money that they would vote in particular ways.

21

They would do the bidding.

22that open to chance so that they would not

They didn't leave

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give money to a candidate or to a member of2

Congress who wasn't pledged to oppose the3

genocide resolution.

4

So I'm really asking -- I guess I

5

can ask it in a similar language.

6

a PAC did give money to members of Congress

7

who were sponsors of the genocide resolution,

8

then is it your conclusion or opinion that PAC

9

was not receiving any money from the Turkish

10

government?

11

MR. MARINO:

12

incomplete hypothetical.

13

THE WITNESS:

Objection.

That is, if

It's anThat would be

14

impossible to guess because Armenian genocide15

was one criteria, but there were other16

criterias also, and that included, as I said,17

the criteria that's related to the weapons

18purchase from the United States, and which

19

general in Turkey is going to get a claim of

20

this thing, and who's going to get what money.

21
22

So there were, as I said, theArmenian genocides was one of three or four

Neal R. Gross & Co., Inc.
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Page 1761

criteria that they considered and honored in2order to give money or not only money, but

3also other ways of giving position, a certain

4

company to the son of certain congressional

5

person or keeping certain things secret or et6cetera.

7

genocide bill was one of them.

8

So that was one of -- the Armenian

So maybe I'm saying in a9hypothetical situation that particular

10

candidate may be a sponsor of Armenian

11

genocide, when on the other three criteria

12that are extremely important or two other13

criteria, that person or candidate may be

14

doing important, very important favor or15

giving important favor.

16
17
18

So I can't -- I can't tell you.
It just depends on the situation.
Or that candidate may be in a or

19

incumbent may be in a very sensitive committee

20

in Congress or Senate and in the position of21

obtaining some very important classified

22

information they may want.

So it can be other

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things under that scenario that we just2

discussed.

3

BY MR. FEIN:

4

Q

Right.

So they look at a variety

5of criteria.

6of them, they may be some money because they

7view some of the issues as more important than8

others.

9

A

Even if they don't satisfy all

May be.

10

MR. KOHN:

11

break for one second?

12

MR. FEIN:

13(Whereupon, the foregoing matter14

went off the record at 2:46 p.m.

15

and went back on the record at

16

2:47 p.m.)17

BY MR. FEIN:

18
19

Q

Can we take a short

Sure.

Ms. Edmonds, have you ever beencalled as an expert witness in any litigation?

20

A

No.

21

Q

Have you ever been called to22

testify at a committee hearing before

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1

Congress?

2

A

Yes.

3

Q

And what hearings were those?

4A

I don't recall.

They're all5

available on the House Website, and I have had

6several testimonies during hearings on

7

whistleblower legislation, and also I believe8

it was House Government Reform Committee that9

I was providing testimony for civil liberties

10

related issues, excessive secrecy and11classification.

12

entitle 2005 -- you have to look at the13

Website for House bill.

14

Q

I believe that was was a

I don't remember.

I think you did testify about, you

15

know, your knowledge of the Armenian genocide,16

the resolution.

17

genocide convention of 18 -- I mean of 1948?

Have you ever read the

18

A

No.

19

Q

Have you ever read the U.S.

20

genocide statute?

21

A

No.

22

Q

Do you know what the elements of

Neal R. Gross & Co., Inc.
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genocide are?

2

A

Not technically.

3

Q

If you don't know what the4elements of genocide are, do you know whether

5

or not the United Nations has ever voted a6resolution that endorsed the Armenian genocide

7

claim?

8

A

No.

9

Q

Do you know whether Great Britain

10

parliament has ever endorsed the Armenian

11

genocide claim?

12A

I'm not sure about Great Britain.

13

Q

That's the only question I'm

14

asking right now.

15

A

Yes, I know.

16Q

How about government of Sweden?

17

A

I don't know.

18

Q

Do you know the author Bernard

19

Lewis?

20

A

Yes.

21

Q

He's at the University of

22

Princeton, correct?

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1

A

Yes.

2

Q

He's written voluminously about

3
4
5

the Middle East.
A

Is that your understanding?

I can't make objective -- anycomment, answer about Mr. Bernard --

6

Q

7

asking about --8A

Yeah, it is.

9

Q-- things in the public domain.

10

A

Yes, correct.

11

Q

Has he been a White House

12

consultant?

13

A

Yes.

14

Q

Do you consider him a person of15

I'm just have you read -- only

stature in the community of scholars?

16

A

No.

17

Q

You don't.

18
19
20
21
22

Why do you not place

him into that category?
A

I have my own personal reasons.

They're based on my personal opinions.
Q

And why is that?

What is -- whyis it that you do not view him in the category

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of scholars in the Middle East?

2

A

Because I consider objectivity as

3one of the criterias for being considered4scholarly and reputable, and I don't believe5

his agenda -- he's not agenda driven.

6

believe he's not objective.

7

personal opinion.

8

Q

I

That's my

If you were -- if you were hiring

9

faculty at the University of Princeton, would

10

you not hire Bernard Lewis as a scholar?

11

MR. KOHN:

12

THE WITNESS:

13

Objection.
I don't know becauseof the situation.

14

MR. KOHN:

Speculation.

15

MR. FEIN:

She's speculated on all

16

sorts of things.

17

BY MR. FEIN:

18

Q

Are you aware of outstanding

19

trials in Cambodia for the atrocities of Pol

20

Pot?

21

A

Not the details.

22

Q

Is it your view that what Pol Pot

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did was genocide?

2

A

Was it genocide?

3

Q

Un-huh.

4A

I would consider it a genocide.

5

Q

Do you know that, in fact, there6

have been none of those who are on trial have7

been accused of genocide?

8

A

If they haven't been on trial --9QNo, they're on trial right now.

10

A

Correct.

11

Q

They're not being charged with12

genocide.

13

A

Okay.

(Inaudible.)

14

Q

Now, I want to go through a list,

15

and maybe we can add more, of the persons that16

you identified to Mr. Manion (phonetic) that17

had been -- had committed crimes either

18

related to bribery or stealing classified

19

information or otherwise.

20

Blunt, Mr. Tom Lantos, and Mr. Dennis Hastert,

21

Mr. Dan Burton, Mr. Stephen Solarz, Mr. Robert

22

Livingston.

My list was Mr. Roy

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1

Are there other current or former2

members of Congress to your knowledge who have3

also committed crimes that have not been --4none of these members have been prosecuted,

5

but have also committed crimes that have not

6been prosecuted?

7

A

Based on the definition, possibly

9Q

And who is that?

10A

The lady we just talked about,

11

Congresswoman.

12

Q

8

13

one.

addition you would make?

14
15
16

But that would be the onlyA

Based on my knowledge, research,

Q

Now, what about -- I think it's

yes.

17

fair to say in the executive branch you

18

identified Marc Grossman as always as someone

19

who's guilty of a crime.

20

individuals in the executive branch who you

21

know are also guilty of crimes of bribery,

22

selling or leaking classified information to

Are there any other

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obtain a --2

MR. KOHN:

I think the witness has

3

identified activity she viewed to be criminal,4

not that they were guilty of criminal

5

activities.

6

MR. FEIN:

Well, somebody had --7

if there's criminal activity, somebody has to8commit the crime.

9

abstract.

10

You have to have a defendant -MR. KOHN:

11

determination.

12

act that's wrong.

13

It can't be a crime in the

Guilt is a legal

It's not when you committed an

MR. FEIN:

I understand.

I'm

14

asking -- she's -- bribery, I assume, when you

15

mean bribery, you're not using that in a16

colloquial sense, that it means something that17

you didn't like.

18

elements of a crime, just like if you accuse

19

somebody of murder, you don't get to decide20

what murder is.

21

don't have any foundation for saying that,22even though murder is a criminal concept.

Bribery is the specificThat's defamatory if you

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1
2

BY MR. FEIN:
Q

Now, I'm asking you.

You had3

identified Marc Grossman as someone who was

4

guilty of basically --5

MR. KOHN:

6"guilty" when you referred --7
8

Did not use the word

MR. FEIN:

Engage in criminal

activity.

9

THE WITNESS:

And I didn't

10

identify.

11

identified by other sources who have spoken to12

the media, main media, has it before that

13

date, and yes, it's on the Website.

14

picture is there, but I did not make any

15

specific allegations about or I don't have16

specific information about Mr. Grossman.

17

said he has been identified to me, and when I

18

was asked is it correct, I said yes.

19

BY MR. FEIN:

20

Q

I said that name has been

Okay.

His

I

Do you have any personal

21

information that Mr. Grossman has committed22

criminal activity?

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1

A

Yes.

2

Q

And that's based on your personal

3knowledge?

4

A

Yes.

5

Q

Now, are there any other current

6

or former members of the executive branch --7

and let's take the time frame 2001-2009 --8that you have personal knowledge have engaged

9

in criminal activity?

10

A

I can't cover time frame after

11

January 2002.

12

Q

Okay.

Let's take the time frame

13

1997 up to 2002.

Now, other than Mr.

14

Grossman, do you have any other direct

15

personal knowledge of executive branch

16

officials, meaning executive branch in the17

United States, who were involved in criminal

18

activity?

19

A

Yes.

20

Q

And could you identify those?

21

A

My Website identifies them by

22

pictures.

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1

Q

I'm sorry.

I don't -- I'm not2familiar with your Website.

3

enumerate the names for me?

4A

Sure, www.Just --5

QNo, no.

Could you just6

I just would like thenames of the individuals, not the --

7

A

8

their pictures.

9individuals.

10

you were to ask me and name them yourself and11

ask me questions about them, then I will

12

answer you.

13

Q

14

I haven't named them.

I haveI haven't named those

There are pictures there.

If

No, I'm asking you can you

identify the pictures on your Website?

15

A

Yes, I can.

16

Q

Okay.

What are -- those pictures

17

that you have on your Website, identify those18

pictures on your Website --19A

I don't have any --20Q-- who are -- who are executive

21

branch officials who you say are -- have been

22

involved in criminal activity?

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1

A

I don't have any in front of me.

2

Q

You don't remember what's on your3

Website?

4

the pictures of the people who are on your5

Website?

6

A

Yes, I do, and I --7

Q

Then I'd like you to -- I'm just

8

asking you.

9A

You're under oath.

You don't know

Just tell me who they are.
I have to look at them right now,10

in front of me in order to identify each one

11of those individuals.

12
13

Q

Do you have any name other than

Marc Grossman that comes to mind?

14

A

Yes.

15

Q

Name that person.

16
17

MR. KOHN:

Would you like to talkto counsel?

18

THE WITNESS:

Yes.

19

(Whereupon, the foregoing matter20

went off the record at 2:56 p.m.

21

and went back on the record at

22

2:57 p.m.)

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1

MR. KOHN:

We have objected to the2question as it is formed with reveal of

3classified information.

4

BY MR. FEIN:

5
6

Q

Is the picture you're maintaining

on your Website classified information?

7

MR. KOHN:

The picture is not

8classified, but asking information related to9why the picture is on the Website would be.

1011

MR. FEIN:
end here.

12
13

So I'm getting to the

BY MR. FEIN:Q

If I visit your Website, your14

testimony is that the people whose pictures

15

are there on your Website have been involved

16

to your personal knowledge in criminal

17

activity?

18

MR. KOHN:

She won't answer that

20

MR. FEIN:

The answer is yes.

21

MR. KOHN:

The witness will not

19

22question.

answer that question as it relates to

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1classified information.

2
3

MR. FEIN:

I'll just visit the

Web.

4

I think that's all.

5

MR. MARINO:

6

I have just a coupleof follow-up before you're done.

7

REDIRECT EXAMINATION

8BY MR. MARINO:

9Q

I want to go back to some of the10questions Mr. Fein asked you about

11

contributions, government-sponsored acts.

12

It's back to that category.

13

You had answered the question, I

14

think, in part by saying there's covert

15

support and there's overt support.

16

experience, for example, I think you said you

17

had not really hear of the Turkish American

18

Council or --19

MR. FEIN:

20

MR. MARINO:

21
22

In your

Coalition.
I'm sorry.

Which

one?
MR. FEIN:

Coalition.

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1
2
3
4
5
6

BY MR. MARINO:
Q

Turkish Coalition of America.

That was the one you had not -A

Because there are so many

abbreviations it's so hard, but I don't -Q

Okay, and I think earlier you

7

testified and said you hadn't heard about the8

Turkish American Heritage PAC.

9

A

Again, they have so many names and10

abbreviation that I don't recall now, but I

11

may have known.

12

recall it right now, specific names of various

13

PACs because there are so many different kinds

14that they set up.

15

Q

I just can't -- I don't

And you described -- I think what16

you were describing when you were describing17

the covert kinds of support the situation

18

where an official has a suitcase full of cash,

19

gives it to ten people who are not government

20

officials, and those ten people make a21

contribution separately to --22

A

Correct.

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1

Q-- the PAC that then gives money2

to the left, and that would be something that3

would be considered covert.

4

A

That was one of the covert ways.

5

Q

Ways to do it.

6A

Right.

7Q

And so you wouldn't expect -- if8that happened, for example with the Turkish

9American Heritage PAC with some Turkish

10

official who with a suitcase full of cash to11

ten different then made contributions to the12

PAC, you wouldn't expect the PAC

13

their Website that they got money from the14

Turkish government.

15

A

They never do.

to put it on

I mean up until,

16

based on my knowledge, experience to 2000,

17

they don't.

18

Q

If they were doing that, you

19

wouldn't have to listen to their phone

20

conversations and figure out.

21

really need counterintelligence operations,22

right?

We wouldn't

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1

MR. KOHN:

2

listening to phone conversations.

3
4

Objection as to

BY MR. MARINO:
Q

And in fact, if the treasurer of5

the PAC submitted an affidavit and said, "Our6

PAC is not, never has been sponsored by the7Turkish government and has never received any

8money or non-monetary support from the Turkish

9government," as far as we know, that treasurer

10

may not even know that the contributions came11

in from --12ARight.

13

Q-- those ten people, right?

14

A

Correct, or in some cases the15

treasurer may be the key person involved,

16

carrying out these illegalities, as it was in

17

Chicago.

18

Q

Would you expect them to give us

19

an affidavit saying, "Yes, we got money from20

the Turkish government through covert

21

sources"?

22

A

I wouldn't think so, no.

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1
2

Q

If they would do that, you

wouldn't have to --3

A

Right.

4Q-- review telephone conversations.

5

You said that -- I want to ask you

6

a kind of personal question.

7

to answer if you don't want.

8

You don't have

You indicated that you were9

independently wealthy, and I assume that what10

you mean by that is you don't really have to11

work in a day-to-day job if you don't want to.

12

You have sufficient means that you don't

13

necessarily have to do that.

14A

Currently.

15

Q

Okay.

16

A

Currently.

My husband and I, yes,17

we worked very, very hard for 18 years, and18

before that he did.

19

right now work like that.

20

Q

So, yes, we don't have to

I got the impression from your21

testimony that when you went to work for the22

FBI back in 2001, that money was not the

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1

motivating factor for you.

2

A

Absolutely not.

3

Q

They offered you a chance to be a

4
5

FBI Special Agent.
A

With the highest level GS the

6

moment I graduated from Quantico because of7

the language abilities and the Master's

8degree.

9

have qualified me to start at GS-12 or GS-13

10versus the GS-8 that regular agents start.

11

That was part of the offerings they were12

giving as part of this package, yes.

13

Q

It was just all the stuff which would

Would it be fair to say the FBI

14

found you to be a fairly valuable resource, by

15

the way?

16

A

Absolutely, and I had and they17

have several commendation letters from all the18

agents.

19

with, and they all submitted commendation

20

letters, and most of them request specifically21

me for their own projects, yes.

22

Q

These are field agents that I worked

All right, and then when the

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1

issues that got you, let's say, cross-wise2

with the FBI when they terminated your3

contract, the FBI, the Office of OIG actually4

investigated and determined that you're --5

they really didn't pay enough attention to6

your allegations, and that they were7

substantiated, correct?

8

A

Right.

9Q

And Mr. Fein asked you about the10

travel allegations, but the four allegations

11

about Ms. Dickerson, they were substantiated,12

correct?

13

A

14

substantiated.

15

Q

Correct.

They were all

And so if it wasn't money, then16

why did you go to work for the FBI in the17

capacity that you did?

18

motivated you to do that?

19

A

What was it thatOne reason only.

Immediately

20

after September 11th, the FBI, the Justice21

Department, they kept coming on TV, radio, and22

they said they were desperately in need of

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1

language specialists in these areas simply

2

because we didn't know if we were going to3have other attacks, et cetera.

4

like a going and enlisting with the Army or5

whatever.

6

attacked, then somebody taps you.

7

It just was

If there is a war and you're

So I -- I just joined in order to8

do something as a citizen to contribute9

because I did have those languages and the10

education, the background.

11

the FBI during the crises and the need, so-

12called desperate need that they had.

13
14

Q

So I was serving

So you had skills and experiencethat would be helpful to your country, right?

15

A

Correct.

16

Q

And out of love for this country

17

you offered those skills and experience,18

correct?

19

A

Correct.

20

Q

When you reported to your21

superiors at the FBI that you detected a case22of attempted espionage, why did you do that?

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Why did you tell them about that?

2

A

Because I was, first of all,3

obligated for that security clearance and that

4

informant.

5

basic question was if somebody tries to6

recruit me, if I come across suspicious

7

activities or recruitment, that kind of an

8

incident, the first thing I have to do was to9

go and report it to my superiors and the10

Security Office.

11

One of the things I signed, my

So I -- I -- not only did I

12believe that I have to go and do it.

13

obligated to do it.

14

Q

I was

And did you feel morally that out

15of loyalty to your country that you should

16

report it?

17A

Absolutely.

18

Q

And when you -- after you left the19

FBI and you testified before congressional

20

committees, testified before the 9/11

21

Commission, et cetera, why were you doing

22

that?

Why were you telling them all of the

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1
2

things you were telling them?
A

Because all along -- and that even3

includes my court cases -- I -- the government

4

gives the State Secrets Privilege and5classification to cover up operations and6

activities by Turkish entities, something

7

within government, some rogue elements, and8certain criminal U.S. persons that have9

nothing to do with national security of the10people in the United States, that had nothing

11

to do with the national interest.

12

to do with covering up these criminal

13

activities because of those high level people

14

and officials and other people who benefitted

15

from it.

16

It only had

And in fact, it jeopardized and17

still does American security not having those18

people accountable and not pursuing those19

people criminally, and that was not only my

20

belief.

21

I work with who work on Turkish

22

counterintelligence.

It was the belief of all the agents

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1

Even the Department of Justice was2

told by State Department to shut down their3

investigations of particular operations.

4

These agents covertly continued it.

5

And I have been through these commissions and6going and testifying before Congress, inside

7

secure compartmentalized facilities, and even8

my court case was to put this information

9

forth and force the issue so that it would be10

publicly addressed first.

11

would know what's been happening and what this12

information involved, not national security,

13

not their security first, just the opposite.

14

Okay?

American people

And second, it would be truly

15

pursued and investigate and prosecuted.

16

you would see accountability, not only ending

17

it, but also you will see accountability.

18

Because treason, these kinds of criminal

19

activities, they're serious.

20

serious crimes, and these were the beliefs of21

the agents I worked with.

22

So

These areAnd some of these agents have

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1

talked with the members of the media.

2

why you have seen some of these articles.

3

They haven't gone by one or two sources.

4

have gone to multiple sources, and it hasn't

5happened to date.

6

But that was the reason.

That's

They

That has7

been the reason why I have pursued it by all

8

the expenses and expulsion, through courts,

9Congress, Inspector General's Office,10

basically every legal available channel that11

was out there.

12Q

Now, have you written any books?

13

A

I'm in the process of writing a

14

book, and I am also writing a book, academic

15

book, which would be studied at Johns Hopkins

16

and Georgetown University with Professor

17

Weaver called Shoot the Messenger.

18

to do with whistleblower legislation,

19

specifically national security whistleblowers

20

and intelligence whistleblowers, which will be

21

published at the end of 2010 by Kansas

22

University Press.

That has

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1

Q

Now, Professor Weaver, I think you

2

said, I think you said he previously worked

3

for NSA; is that correct?

4
5
6
7
8

A

Correct.

A long time ago, 30

years ago.
Q

And can you tell us what his

position with NSA was?
A

He was a member of Air Force, and9it had something to do with -- I don't know.

10

It was highly classified that had to do with

11

communications, which is obvious for NSA, but

12

I'm not sure.

13

Q

Okay.

Mr. Fein asked you about

14certain counties and whether they had passed

15

resolutions recognizing the Armenian genocide.

16

Do you recall that?

17

A

Correct.

18

Q

Have some countries actually

19
20

passed resolutions recognizing -A

Yes.

For example, France did

21

that, and it was important because France was22

also frightened in their relationship with

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1

Turkey would end and they were going to be2

rewriting it and they were going to become

3

destitute, et cetera, and they didn't.

4

did what they felt was right, and the5

relationship has been good as far as I know.

6

Q

They

And the United States has not

7

passed a resolution recognizing the Armenian

8

genocide so far?

9ANo, as far as I know, it hasn't.

10Q

And that's in part because

11

Congress will not vote for it because they're

12

lobbied by the Turkish lobby.

13
14

MR. FEIN:
question.

15
16
17

That's a leading

MR. MARINO:

That's okay.

You can

THE WITNESS:

Also the executive

answer.

18

branch pressuring the Congress because there's

19

always some reason.

20

before that it was Cold War, and now it's

21

going to be Afghanistan.

22

be Central Asia, which is going to be

It's today Iraq, andThen it's going to

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1

(unintelligible) maybe.

2

reason underway.

3
4

So there's always a

BY MR. MARINO:Q

Are you pretty sure that the5

Turkish lobby is lobbying legislators and6

government officials in other countries as

7well to stop them from passing such

8

resolutions?

9A

I don't know.

10Q

Why do you feel that Bernard Lewis

11
12

is not objective?
A

I have read some of his scholarly

13

articles, and especially those that have to do

14

with the strategy for the United States on

15

foreign policy, that includes Afghanistan and

16

Central Asia as very agenda driven, that17

fulfills the agenda of certain entities that18

I happen to know about.

19

Q

And by agenda driven, you mean it

20

starts with a point he's trying to make as

21

opposed to doing real analysis?

22

A

Correct.

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1
2
3

Q

And what entities are you talking

about when you say it's agenda driven?
A

Certain business entities, the4military-industrial complex in oil, and also

5certain business entities, foreign business

6

entities, and that even includes certain

7

business entities in Turkey.

8Q

I think you said that since you've

9been working with the organization you're

10

working with now, the whistleblowers

11organization, you said that you continue to12

get information --13

A

Absolutely.

14

Q-- from people.

15

A

Including from Turkey, yes.

16

Q

From Turkey, you're getting

17

information from current government people,

18

from --

19

A

CIA, Defense Intelligence Agency,

20

FBI, National Security Agency, every single

21

intelligence agency we have.

22

contacts in all of them, and these are even

I have lots of

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1

people who haven't blown the whistle publicly

2

yet.

3

(Counsel conferred.)4

BY MR. MARINO:

5Q

To your knowledge, do you have any

6information about the Turkish government

7

sponsoring chairs at universities, like8

Princeton, University of Utah, and other9

places?

10

A

Georgetown University, and not

11

only that.

Some of these academic experts

12

also are recruited agents who actually steal

13

U.S. military and intelligence related

14

information because they have security

15

clearances and they have obtained position in

16

high level institutions, and one good example

17

would be RAND Corporation, and Professor Sabri

18

Sayari in Georgetown University who has stole

19

tens of millions of dollars worth of secrets

20

by actually recruiting people there that has

21

been identified to him by his superiors,

22

handlers, and he does it currently in -- was

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doing it in 2002 with RAND Corporation, one of2

the individuals.

3

academic expert that they recruit.

4
5

Q

That's an example ofAnd how do they recruit them?

With money and other things?

6

A

Money and in some cases

7

combination of money and sexual related favors

8and information.

9
10

Q

Now that you have had a chance toread the complaint that --11

A

No, I really -- I read the12

article, but I didn't have time to read the13complaint.

14

Q

15

complaint then.

16

A

Okay.

17

Q

I won't ask you to read it.

18
19

Okay.

I won't ask you about the

MR. MARINO:

Do you have anything

else?

20

(Counsel conferred.)21

BY MR. MARINO:

22

Q

If you don't mind, do you still

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Page 2081

have the complaint in front of you?

2

A

Yes.

3

Q

If you would look at Paragraph 14

4

of Ms. Schmidt's complaint, please, and I'm

5referring specifically to her reference to a6letter from Mr. Krikorian.

7

saying that Ms. Schmidt insanely, quote,8"denies the Christian Armenian genocide at the9hands of the Muslim Ottoman Empire."10

it goes on to say a couple of lines down,

11"Jean Schmidt has taken $30,000 in blood money

12

from Turkish sponsored political action

13

committees to deny the slaughter of 1.5

14

million Armenian men, women and children by

15

the Ottoman Turkish government during World

16

War I."

17

She quotes it as

And then

Do you see that?

18

A

right.

19

Q

Now, do you think that based on

20

everything that you know that Mr. Krikorian is21

coming out of left field by saying something

22

like that?

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1

A

As I said, based on my first hand2

information, my own knowledge, anybody who

3strongly comes and denies this and also has

4that kind of relationship with the Turkish

5sponsored PACs and organizations, et cetera,6

at least in the past, has been exactly for7this particular reason.

8

representing the other foreign interest and9

not being objective represent the United

10

States interest.

11

It's been

So this, again, as I said, it

12

fits.

13

but it fits the modus operandi of all the14

others who were on the payroll one way or

15

another.

16

payroll of the Turkish government entities,

17

certain Turkish government --18

I don't know anything about this lady,Q

To just do this, they were on the

So it wouldn't surprise you at all

19

for Mr. Krikorian to say something like that20

under the circumstances, right?

21

MR. FEIN:

22

hypothetical and pure speculation.

That's purelyThis goes

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Page 2101over the top.

She said she hadn't even met

2

Mr. Krikorian until nine days ago, Mr. Manion

3(phonetic), and you're asking her to get

4

inside his head?

5

MR. MARINO:

You can answer.

6

THE WITNESS:

I mean, there's no7-- that doesn't surprise me.

89

BY MR. MARINO:Q

If you look at Paragraph 20 of her

10complaint, she says it would be a crime under

11

federal law for the Turkish government or any

12foreign national to fund a political action

13

committee that made donations to a federal

14candidate seeking election to Congress, among

15

other federal offices, and she cites a federal

16

statute.

17

A

Yes.

18

Q

Now, many of the things that you

Do you see that?

19

describe which you have personal knowledge of20

would be crimes under U.S. statutes, correct?

21
22

A

Absolutely, and they would havethese people in jail, those people.

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1
2

MR. MARINO:
with me.

One moment.

Bear

I'm sorry.

3(Counsel conferred.)4

MR. MARINO:

Let me just ask.

The

5

passage I'm looking for, which is part of her

6complaint, is the statement that Mr. Krikorian7

made requesting that it be put to the voters.

89
10

BY MR. MARINO:
Q

By the way, you're not a voter,are you, from Ohio?

11

A

No.

12

Q

And you're not making

13

contributions to Mr. Krikorian's campaign?

14

A

I haven't contributed to anyway.

15

Q

If Mr. Krikorian asked the16question -- this gentleman asked the question

17of those voters, why would you want to vote18

for someone who has taken money from the19

government, whose policies and practices cost

20

American lives?

21

question for him to ask under your -- based on

22

your experience?

Would that be a crazy

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1

A

Absolutely not, and that's where I

2would even go further.

For any candidate who

3starts really getting that kind of a close

4

relationship with any foreign government to

5that degree and to get that kind of support

6

because of that, I -- that would be a very

7

valid -- that would be a valid question, and8

I would not want to vote for someone.

9

MR. MARINO:

Thank you, ma'am.

10

That's all I have, and I want to thank you

11again for coming.

12
13

MR. FEIN:
questions.

14

RECROSS EXAMINATION

15
16

I just have two

BY MR. FEIN:
Q

One, Ms. Edmonds, have you

17

requested that the incumbent Attorney General,

18

Eric Holder, investigate the crimes that19

you've identified at this deposition today?

20
21
22

A

I have asked his predecessor,

Attorney General Ash -Q

I'm just asking Mr. Holder.

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1

A

Asked him to review -- revoke my2State Secrets Privilege basically.

3

what I --4

Q

Excuse me.

That's

I did not ask about

5

the State Secrets Privilege.

6

Mr. Holder, the current Attorney General, to7

investigate the crimes that you've identified

8

at this deposition today?

9A

Not, not directly.

10

Q

Okay.

Have you asked

The second thing is I

11

believe in response to the last question Mr.

12

Manion (phonetic) said if you were a voter you

13

certainly would not be inclined to vote for a

14

candidate who had received and was receiving

15

money from a foreign government.

16

MR. MARINO:

17

MR. FEIN:

18

That's not what -That's not what?

What was it?

19

MR. MARINO:

The record said what20

it says, but you're mischaracterizing it

21

again.

22

Okay.

MR. FEIN:

The record says what it

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1

says, and if I can go back, I can show you

2

this here.

3
4

BY MR. FEIN:Q

I believe the sentence that he was5

referring to, Mr. Manion (phonetic) was, and6

now I'm quoting, "I asked the people of Ohio's

7

Second Congressional District to ask

8themselves if our representative in Congress

9

should be taking money from a foreign

10

government that is killing our soldiers, and11

if that assertion is true, would you be

12inclined to vote against that candidate?"

13

MR. MARINO:

That wasn't what I

14

asked, but I don't have a problem with you

15

asking that question.

16
17

THE WITNESS:

would I vote for that person?

18

MR. FEIN:

19

THE WITNESS:

20

MR. FEIN:21

BY MR. FEIN:

22

The question isQYes.
If somebody who --Yeah.

If a candidate was taking money

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1

from a foreign government.

2

A

Candidate was taking --3

Q

Taking money from a foreign

4

government, and that government was the5government of Turkey or it could be any other.

6A

Any other government.

7

have serious questions about that.

8

MR. FEIN:

9

That's all I

have.

10
11

Okay.

No, I would

MR. MARINO:

That's all I have.

I

thank you very much.

12

Do you have any other questions?

13

MR. KOHN:

No, just to note for14

the record that the Justice Department

15

apparently declined to attend the deposition

16

and that we've had no communications with them17

other than the written communications of18

yesterday.

19

MR. MARINO:

That concludes it.

20

You have a right to read the transcript and21

make corrections.

22

THE WITNESS:

Right now, you mean?

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1

MR. MARINO:

2

MR. KOHN:

No, no.
We would like a copy

3

provided to the witness.

4

MR. MARINO:

5

So should we give it

to Mr. Kohn?

6

THE WITNESS:

7

MR. KOHN:

8

MR. MARINO:

9That would be great.

That will do it.
Thanks again.

Appreciate it.

10

Off the record.

11(Whereupon, at 3:21 p.m., the12deposition of Sibel Deniz Edmonds was

13

concluded.)

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compartmentaliz...
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Neal R. Gross & Co., Inc.
(202) 234-4433

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Neal R. Gross & Co., Inc.
(202) 234-4433

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Neal R. Gross & Co., Inc.
(202) 234-4433

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Neal R. Gross & Co., Inc.
(202) 234-4433

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Neal R. Gross & Co., Inc.
(202) 234-4433

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(202) 234-4433

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Neal R. Gross & Co., Inc.
(202) 234-4433

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Neal R. Gross & Co., Inc.
(202) 234-4433

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Neal R. Gross & Co., Inc.
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narcotics 54:3
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Neal R. Gross & Co., Inc.
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Philadelphia
129:18Neal R. Gross & Co., Inc.
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phone 192:19
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Quantico 124:17
124:20 195:6
quantity 94:4,5

Neal R. Gross & Co., Inc.
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Quarterly 139:22
quash 42:20 44:12
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question 4:15 6:9
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relevance 13:14
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relevant 45:4 84:14
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reliable 66:6
religious 95:1

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131:5
remember 80:9
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renewed 125:22
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repeat 29:18
repeating 146:21
rephrase 157:3
replace 95:4
report 24:15 25:2,4
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126:12schools 98:18
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scholars 80:1,22
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seeking 7:7 210:14
school 10:3 16:11
seen 7:15,17 10:13

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27:6,7 79:15
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send 73:4 96:14
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senior 66:14
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sent 64:20 70:1
sentence 155:4
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separately 191:21
separates 172:11
September 16:21
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serious 69:9 80:1,1
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served 92:12
services 17:19
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set 27:12 38:21
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share 75:22 83:5
shariah 95:5
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sponsors 175:7
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136:12states 15:21 18:19
26:16,17 28:2,13
31:3 34:3,4,7 36:7
39:18,19,21 42:19

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45:8,11,14,15
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stature 180:15
statute 167:20
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statutes 210:20
stay 61:12,19 95:11
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steal 56:3 206:12
stealing 182:18
Stephen 50:2 82:18
182:21steps 172:3
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Steven 137:11
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stole 206:18
stop 12:1 60:15
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strategy 204:14
straying 20:4
street 1:15,21 2:12
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strike 35:4
strongly 40:10
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terminology 169:9
terms 62:18 71:9
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territorial 8:10

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terrorism 137:6
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