klayman v judicial watch miller deposition pt. 1

8/12/2019 Klayman v Judicial Watch Miller Deposition Pt. 1

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EXHIBIT 1 Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page1 of243

In The Matter Of:LARRY E. KLAYMAN

v.

JUDICIAL WATCH INC.

___________________________________________________

GEORGE MILLER Vol 1 May 23 2014

___________________________________________________Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page2 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 1UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF FLORIDALARRY E. KLAYMAN, ))Plaintiff, ))-vs- ) CASE NO.) 13-20610-CIVJUDICIALWATCH, INC., ) ALTONAGA/Simonton)Defendant. )

_________________________________)DEPOSITION OF GEORGE MILLERFRIDAY, MAY 23, 20147:40 a.m.REPORTED BY: ERIKA SJOQUIST, C.S.R., R.P.R., C.R.R.C.S.R. No. 12350Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page3 of


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243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 2

1 DEPOSITION OF GEORGE MILLER, VOLUME 1, TAKEN AT 7:402 A.M., FRIDAY, MAY 23, 2014, AT 5700 RALSTON, SUITE 100,3 VENTURA, CALIFORNIA, BEFORE ERIKA A. SJOQUIST, C.S.R.,4 R.P.R., C.R.R., C.S.R. NO. 12350, CERTIFIED SHORTHAND5 REPORTER, IN AND FOR THE STATE OF CALIFORNIA.678 APPEARANCES OF COUNSEL:9FOR THE PLAINTIFF:10LARRY KLAYMAN, ESQ.11 ATTORNEY AT LAWIN PRO PER12 2520 CORAL WAY, SUITE 2027MIAMI, FLORIDA 3314513 [email protected] (VIA VIDEO CONFERENCING)15ALSO PRESENT: DINA JAMES, PARALEGAL TO MR. KLAYMAN16 (VIA VIDEO CONFERENCING)17FOR THE DEFENDANT:18SCHWED KAHLE & KRESS, P.A.19 DOUGLAS J. KRESSATTORNEY AT LAW20 11410 NORTH JOG ROAD, SUITE 100PALM BEACH GARDENS, FLORIDA 3341821 [email protected] (VIA VIDEO CONFERENCING)23

2425Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page4 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New York


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Page 31 I N D E X2 DEPONENT EXAMINATION PAGE3 GEORGE MILLER (MR. KRESS) 5, 135(MR. KLAYMAN) 128

4567 E X H I B I T S8 NO. PAGE DESCRIPTION9 Exhibit 1 95 Cuyahoga County Court of CommonPleas Criminal Court Division,10 True Bill Indictment for CriminalNonsupport - F511 State of Ohio vs. Larry Klayman12 Exhibit 2 82 Cuyahoga County Prosecutor webpage - Press Release -- 2/3/1213Exhibit 3 95 Court of Common Pleas Division of14 Domestic Relations CuyahogaCounty, Ohio, Case No. DR0715 316840, Judgment EntryRe: 7/28/200916Exhibit 4 96 Court of Common Pleas Division of17 Domestic Relations CuyahogaCounty, Ohio, Case No. DR0718 316840, Judgment EntryRe: 7/2/201019Exhibit 5 102 Case No. DR07 316840, 2/22/201020 Capias Ordered for PlaintiffLarry Elliot Klayman21Exhibit 6 24 2/8/2012 e-mail from Larry22 Klayman to George J. Miller, re:Retention Agreement with Klayman23 Law Firm24 Exhibit 7 40 5/7/2012 e-mail string between

George Miller and Larry Klayman25 Re: Voeltz vs. Obama, et al -Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page5 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New York


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Page 41 Exhibit 8 37 7/23/12 Klayman Law Firm BillingStatement2Exhibit 9 43 9/12/12 e-mail from Larry Klayman

3 to George Miller, re: RetentionAgreement with Klayman Law Firm4Exhibit 10 5 Conwebwatch web page - "Larry5 Klayman, Failed Lawyer" - 8/10/126 Exhibit 11 5 The Nation web page - "KlaymanWatch" - 7/10/077Exhibit 12 5 Miami New Times web page - "Larry8 Klayman, Conservative WingnutLawyer, Gets Reprimanded By9 Florida Bar, Is Broke" - 11/1/1110 Exhibit 13 5 Renew America web page - "Thegood virgin's birther case" -11 12/8/1212 Exhibit 14 47 Orly Taitz, Esquire web page -"My yesterday's presentation to13 CCIR and update onarticle2SuperPAC-Larry Klayman14 $25,000 fundraising fornon-existent law suit affair" -15 2/23/201216 Exhibit 15 104 Orly Taitz, Esquire web page -"Clarification regarding17 article2legal fund and LarryKlayman" - 2/26/2012181920 INSTRUCTION NOT TO ANSWER: 15:20, 16:17, 19:20, 20:2,20:9, 83:17, 87:17, 87:2421222324

25Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page6 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 5


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1 VENTURA, CALIFORNIA2 FRIDAY, MAY 23, 20143 7:40 a.m.45

6 (Exhibits 1 - 15 premarked before deposition.)78 GEORGE MILLER,9 HAVING BEEN FIRST DULY SWORN BY THE REPORTER, WAS10 EXAMINED AND TESTIFIED AS FOLLOWS:1112 DIRECT EXAMINATION1314 BY MR. KRESS:15 Q Good morning, Mr. Miller.16 A Good morning.17 Q My name is Doug Kress, and we met via video18 conference just a few minutes ago. I represent Judicial19 Watch in a lawsuit filed by Larry Klayman. And this20 morning, I'm going to take your deposition.21 And since we are doing this by video22 conference, it's important that we take our time and try23 not to speak at the same time because that would become24 confusing for both of us and difficult for the court25 reporter. And I'll ask you to follow that rule as wellCase 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page7 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 61 as a few additional ground rules.2 If I ask you a question, please answer it out3 loud and clearly so we can all hear you and so the court4 reporter can take it down for the record. If the5 question calls for a "yes" or "no," please try to say6 "yes" or "no" as opposed to "huh-uh" or "uh-huh" because7 those get confusing.

8 If you do not understand me, do not answer the9 question. Tell me you don't understand, and I will10 rephrase it so you do understand. Uhm, if you should11 need a break for any reason, let us know, and we will12 let you take a break.13 A Yes.14 Q Do all the rules sound fair and reasonable to15 you?


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16 A They do.17 Q Okay.18 MR. KLAYMAN: And I might add, Mr. Miller, I'm19 counsel for myself, pro se, Larry Klayman, as you know.20 Before you ask a question, pause to give me an

21 opportunity to object if I need to make an objection.22 THE WITNESS: Yes.23 MR. KLAYMAN: And try to look into the camera24 as much as you can.25 BY MR. KRESS:Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page8 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 71 Q What is your address, Mr. Miller?2 A 2041 Jamestown Way, Oxnard, California.3 Q And how old are you?4 A Sixty-six.5 Q Can you tell me about your professional6 background or work experience? I'll let you just tell7 me instead of trying to ask you a bunch of questions8 about it.9 A I'm retired now, but originally, I was a10 mechanical engineer and transitioned into manufacturing11 operations in the 1960s; worked in the consulting field12 for firms like Booz Allen Hamilton in New York.13 I came out to California in 1980 to run an14 operation locally, and started my own business in 198615 and ran that until I retired around 2010.16 Q What was the name of your business?17 A I had two businesses; one was Proaction18 Management Consultants, and one was The Facilitative19 Group, both involved in similar businesses of operations20 management consulting.21 Q Proaction Management & Consultants, and what22 was the other one?

23 A Proaction, not "proactive."24 Q Okay. Proaction Management Consultants?25 A Proaction, T-I-O-N.Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page9 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/law


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Merrill Corporation - New YorkPage 81 Q Okay. I think that's what I'm saying.2 A Okay. It's not coming across.3 Q Management Consultants?

4 A Correct.5 Q And the other one was the --6 A Facilitator.7 Q -- Facilitator Group?8 A Facilitator Group, correct.9 Q What was the nature of the business of10 Proaction Management Consultants?11 A Operations management consulting and related12 business systems.13 Q What's that mean in lay terms?14 A Operations management consulting is the science15 of managing a manufacturing business and all the related16 systems required to provide the information to support17 that.18 Q Okay. And what -- what was the nature of the19 business of The Facilitator Group?20 A It was almost identical.21 Q So, also operations management?22 A Consulting, right.23 Q Were both businesses located in California?24 A Yes.25 Q Did they operate outside of California?Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page10 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 91 A Mostly outside of California and outside of the2 USA.3 Q Okay. Did they operate in Florida?4 A We have done work in Florida.5 Q What kind of work have you done in Florida?

6 A Mostly --7 MR. KLAYMAN: Objection. Relevancy.8 THE WITNESS: -- onsite analyses of9 manufacturing firms, providing information on operations10 management, and consulting in compliance with government11 contracting regulations related to finance and12 operations.13 BY MR. KRESS:


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14 Q Okay. So your education I believe is as a15 mechanical engineer?16 A That's right, originally. And then I took some17 business courses subsequently since I drifted into18 business in the late 1960s.

19 Q And you retired in 2010, you said, correct?20 A Yes. I actually kind of phased my work out21 because I was spending more and more time on political22 activism and less and less time on work, and I just23 thought it was more important. So I stopped working and24 focused on this just about exclusively.25 Q Okay. So now, do you consider yourself to be aCase 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page11 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 101 political activist?2 A Yes.3 Q Tell me the nature of your activities as a4 political activist?5 MR. KLAYMAN: And George, I instruct you just6 to answer the questions that he's asking you, okay?7 THE WITNESS: Yes, okay.8 MR. KLAYMAN: Okay.9 THE WITNESS: I originally started off in about10 -- in 2008 or 2009, I was very upset because of the11 economic crash and the huge detrimental effect it had on12 my investments. So I started studying why that occurred13 and how the markets were made to crash, how real estate14 crashed, how the stock market crashed, how currencies15 were manipulated, and how that related to election16 politics. And I concluded that some of that really17 didn't have to occur at all.18 And then after that, the national election came19 up, and Obama was elected. And during my studies, I20 found out this was really not a good guy to be running

21 the country at all. So I began to actively oppose that22 at the national level, and that's really what led me,23 ultimately, to meet -- to meet Larry Klayman.24 I also, when this tea party movement started in25 2009, I joined a tea party initially to take action. AtCase 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page12 of243


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GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 111 that time, people weren't very politically

2 sophisticated. We were mostly new to this. We knew3 nothing about what was going on at all. That was quite4 an eye opener. I subsequently started the Ventura5 County Tea Party later in 2010. And part of our6 activity is that the membership voted that we should7 investigate Obama more thoroughly, which we did. And in8 carrying out the wishes of the membership, we,9 ultimately, worked on engaging Larry to support some of10 the cases at the national level as well.11 And then I was also involved in local politics,12 being involved -- working with one of the major13 political parties, the Republicans. You know, they were14 both pretty bad, but Republicans looked a little -- a15 little less worse. And I was a state delegate. I was a16 member of different political organizations. I17 campaigned for various candidates. I wrote publicity18 for various candidates.19 And then last year, we -- we ended up starting20 a newspaper because we felt there really wasn't good21 news in Ventura County at all. And I spend a lot of my22 time on that now as well.23 BY MR. KRESS:24 Q What's the name of the newspaper?25 A CitizensJournal.US.Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page13 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 121 Q Is it an online paper then --2 A Yes.3 Q -- or is it a -- okay.

4 A It is online.5 Q And what is your role in the Citizens Journal?6 Are you publisher or?7 A I am the publisher.8 Q Have you been elected to any political offices?9 A I don't really have the -- the demeanor or the10 desire to be in elective office. I work behind the11 scenes.


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12 MR. KLAYMAN: George, when I question asks for13 a "yes" or "no," just give a "yes" or "no."14 THE WITNESS: Yes.15 MR. KLAYMAN: That's what I'm directing you.16 BY MR. KRESS:

17 Q Mr. Miller, are you represented by counsel for18 the purposes of this deposition?19 A I'm sorry. For what? For this deposition?20 Q For this deposition, are you represented -- are21 you represented by counsel?22 MR. KLAYMAN: I'll stipulate to that. He's23 represented by me.24 BY MR. KRESS:25 Q So, it's your belief you are represented byCase 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page14 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 131 Mr. Klayman in this matter?2 MR. KLAYMAN: For purposes of the deposition.3 THE WITNESS: For this deposition. I don't4 feel he, you know, he's representing me as a client or5 anything like that. But I've been in contact with him6 about it, and we have similar interests in this matter.7 BY MR. KRESS:8 Q Are you -- are you compensating Mr. Klayman for9 his assistance to you in this deposition?10 A No.11 Q Paying him?12 A No.13 Q Is he paying you in any fashion for testimony?14 A No.15 MR. KLAYMAN: I'll let you answer that.16 That's a totally objectionable question,17 Mr. Kress. It invades the attorney-client privilege and18 invades work product.

19 MR. KRESS: Well, are you his -- are you20 stating --21 MR. KLAYMAN: He just answered the question.22 You can go on, Mr. Kress.23 MR. KRESS: Are you stating you are his24 attorney?25 MR. KLAYMAN: For purpose of this deposition,


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Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page15 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/law

Merrill Corporation - New YorkPage 141 yeah, I just stipulated to that.2 MR. KRESS: Okay. Are you his attorney for3 purposes of trial?4 MR. KLAYMAN: I will be representing him for5 purposes of trial in terms of objecting to your6 questions, yes, because I'm a plaintiff pro se. And I7 have a right to object to the questions.8 MR. KRESS: I understand you have a right to9 object, but --10 MR. KLAYMAN: I am not being deposed,11 Mr. Kress. Move on.12 MR. KRESS: I'm just -- I'm trying to determine13 whether I should ask questions. Like, for instance --14 MR. KLAYMAN: That's as far as you are going to15 get because you are getting into attorney-client16 privilege.17 MR. KRESS: All right. Well, I'm going to ask18 this question. I'm sure you are going to object and19 instruct him not to answer, but...20 BY MR. KRESS:21 Q Before the deposition began, you stepped out22 and spoke privately to Mr. Klayman, correct?23 MR. KLAYMAN: You can answer that, George, but24 not the substance of the conversation.25 THE WITNESS: Well, he approached me about theCase 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page16 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 15

1 trial and asked me if I would --2 MR. KLAYMAN: No, no. That calls for a "yes"3 or "no," George.4 MR. KRESS: Well, and I'll get into that later.5 MR. KLAYMAN: When a question asks "yes" or6 "no," you respond either "yes" or "no."7 THE WITNESS: Would you ask the question again,8 Mr. Kress?


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9 BY MR. KRESS:10 Q I will, yes.11 Before we began here, we were sitting in the12 room, and then Mr. Klayman called you privately, and you13 went and stepped into another room and spoke to

14 Mr. Klayman, correct?15 A I did, yes.16 Q What did you talk about?17 MR. KLAYMAN: You are not -- instruct you not18 to answer.1920 (Witness instructed not to answer.)2122 MR. KRESS: All right. We may address that23 later.24 THE WITNESS: May I say something? May I say25 something?Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page17 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 161 MR. KLAYMAN: No, you may not.2 THE WITNESS: Okay. It's really quite simple.3 MR. KLAYMAN: I instruct you not to answer.4 Okay. That's work product, attorney client.5 MR. KRESS: Uhm...6 MR. KLAYMAN: Just answer questions.7 THE WITNESS: Which question?8 MR. KLAYMAN: There's no question pending.9 MR. KRESS: There's no question pending, but10 one will be coming.11 BY MR. KRESS:12 Q When did Mr. Klayman first approach you about13 testifying in this case?14 MR. KLAYMAN: You are not to respond to that.15 George, you are not to respond to that. Okay?

1617 (Witness instructed not to answer.)1819 THE WITNESS: Yes.20 MR. KLAYMAN: That's attorney-client privilege.21 MR. KRESS: I think we might to have the court22 intervene. This is a witness.23 MR. KLAYMAN: That -- I'm representing him for


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24 purposes of this deposition.25 MR. KRESS: All right. We -- I'm going getCase 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page18 of243

GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 171 through the substance of it, and then we may have to2 call --3 MR. KLAYMAN: We can talk about it, but get4 your questions out there.5 MR. KRESS: Because he's a -- he's a -- he's a6 witness. I mean, you can't prevent me from finding out7 what was discussed with the witness by saying there's an8 attorney -- you are his attorney.9 MR. KLAYMAN: Yes, I can because that's10 attorney-client privilege, Mr. Kress.11 BY MR. KRESS:12 Q Do you have any type of fee agreement or13 retainer agreement with respect to -- with Mr. Klayman14 with respect to this deposition or the testimony at15 trial?16 MR. KLAYMAN: You can answer that.17 THE WITNESS: We have no financial agreement.18 BY MR. KRESS:19 Q Any written agreement whatsoever?20 A We have no --21 MR. KLAYMAN: You can answer that.22 THE WITNESS: We have no written agreement.23 BY MR. KRESS:24 Q What verbal agreement do you have, if any?25 A Well, I was asked if I would testify on thisCase 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page19 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/law

Merrill Corporation - New YorkPage 181 matter, and I said that I would.2 Q Okay.3 A And he said --4 Q When was that?5 A This goes way back. This is two years ago when6 these events happened. At the time, we both were


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7 extremely upset at the lies told by your company. And8 at that time, Larry said that he was going to sue. I9 didn't believe him. So, I really had no idea this would10 ever happen, I'd be sitting here today, but at the time,11 I said, "If you need help, I will testify as to what

12 happened and what was done to -- to our fundraising13 effort for Article II PAC, for Constitution Action Fund,14 for our case, for Michael Voeltz, for our boarded case15 in California, and that you people really screwed up big16 time. So, yes, I was very motivated to testify. Any17 other questions?18 Q I have a lot of questions.19 A Go ahead.20 Q We are going to be -- we're going to be here21 for a while.22 A Okay.23 MR. KLAYMAN: Please avoid the sarcasm,24 Mr. Kress.25 MR. KRESS: He asked me if I had moreCase 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page20 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 191 questions.2 MR. KLAYMAN: That's fine, but no more sarcasm.3 Just be -- just be a gentleman to my client.4 MR. KRESS: I am being a gentleman with your5 client.6 MR. KLAYMAN: Thank you.7 BY MR. KRESS:8 Q And -- okay. Do you intend to travel to9 Florida for the trial?10 A Excuse me?11 Q Do you intend to travel to Florida for the12 trial?13 A It was my intention I had to go to Miami for a

14 trial, which has been postponed once already.15 Q Who is paying for your airfare?16 A It's my impression --17 MR. KLAYMAN: You are not to answer that. You18 are not to answer that.1920 (Witness instructed not to answer.)21


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22 BY MR. KRESS:23 Q Are you paying for your own airfare?24 MR. KLAYMAN: You are not to answer that.25 Attorney-client privilege.Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page

21 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 2012 (Witness instructed not to answer.)34 BY MR. KRESS:5 Q Who is paying for your hotel when you are here?6 MR. KLAYMAN: You are not to answer that.7 Attorney-client privilege.89 (Witness instructed not to answer.)1011 BY MR. KRESS:12 Q Okay. When did you first meet Larry Klayman?13 A I first met Larry Klayman in December of 2011,14 but I had -- face to face.15 Q Okay. Did you speak to him or communicate with16 him before December 2011?17 A Yes.18 Q And in what circumstances did you speak to him19 prior to December of 2011?20 A Well, you know, Larry's a very famous person,21 having been the founder of the organization, which now22 pays you. And he's been involved extensively in various23 causes for liberty and justice. And I've always been a24 great admirer of Larry, and I contacted him a couple of25 times, once when he was running a rally in Washington,Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page22 of243

GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 211 DC. And numerous times, I tried to get him to work for2 us to take on cases, but it wasn't until December3 of 2011 where I actually met him and was able to talk in4 detail about it.


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5 Q Okay. So, you -- but you contacted him before6 that and tried to get him to help you?7 A Excuse me?8 Q You had contacted him before December of 20119 and sought his assistance, correct?

10 A Correct.11 Q In other matters?12 A Yes.13 Q Tell me what occurred in December of 2011 with14 respect to Mr. Klayman?15 A Well, I met him, and I immediately brought up16 the topic, which is of mutual interest. I told him what17 we were trying to accomplish. He indicated that he18 agreed with it. And I asked him if he would consider19 representing us, and he was amenable to that. And we20 met the following week and worked out a tentative21 agreement, which I then had to get ratification for from22 my group of people.23 So, we had a major teleconference after that,24 and we agreed -- we hammered out the details of how it25 would work, and then we moved forward from there.Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page23 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 221 Q Who is your group?2 A Well, uhm, at that time, I was involved in the3 Obama Ballot Challenge effort, which was a national4 group, a very loose affiliation of people, who5 communicated by telephone and e-mail. And we started6 off with the New Hampshire Ballot Challenge, since7 that's the first one in the country, and developed some8 relationships during that time.9 I was also the lead person that ran a website10 called "Obama Ballot Challenge" that attempted to report11 on what was happening in that movement and also reported

12 -- attempted to motivate people to get involved in the13 movement, to contribute money, to contribute legal14 services, to file cases all over the nation.15 And then subsequently, I was involved with some16 different organizations that were being used as vehicles17 to raise funds.18 Q So, you've extensively worked on the Obama19 challenges even before communicating with Mr. Klayman,


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20 correct?21 A Yes, yes.22 Q For instance, Mr. Klayman was not involved in23 the New Hampshire matter?24 A I don't know if he was or not.

25 Q Well, you didn't involve him in the NewCase 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page24 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 231 Hampshire matter, did you?2 A No. No, I didn't.3 Q You're an admirer of Larry Klayman?4 A Yes.5 Q Are you a friend of Larry Klayman?6 A I would consider myself a friend now just7 because we've worked together and been through a lot of8 battles together.9 Q Okay.10 A I mean, he hasn't been to my house. I haven't11 been to his house or anything like that, but, you know,12 we are on very -- we are on good terms.13 Q Okay. What was the -- you talked -- you talked14 about a couple of these groups.15 What was the name of the group that was looking16 to hire Larry Klayman?17 A The name of the group. It was just some18 individuals, you know. We are just people. We didn't19 have a corporation. We didn't have an organization.20 Q Who are the names -- who are the names of the21 people?22 A Well, there are really dozens of people. But23 the ones that were most centrally involved in the24 organization were myself, Captain Pamela Barnett, Sam25 Sewell. We are the ones that actually formed theCase 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page

25 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 241 fundraising organization. There were many others2 involved, too.


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3 One of the things we had to do is figure out4 which cases we were going to work on. So, some people5 submitted different cases; among them, Mike Voeltz from6 Florida, and Pamela Barnett for the California case.7 Those are the two cases that we initially wanted to have

8 Larry represent us on. And then we had delusions of9 grandeur, it turned out because we wanted to have him go10 through several states and work with lawyers in11 different states and have more of a coordinated effort.12 And you, folks, did a really good job of sabotaging that13 for us. Thank you.14 MR. KRESS: Move to strike as nonresponsive.15 MR. KLAYMAN: It was responsive.16 BY MR. KRESS:17 Q So, let's go to the exhibits, Mr. Miller. Do18 you have those in front of you?19 A I do, yes.20 Q Can you, please, go to Exhibit 6?2122 (Exhibit 6 identified.)2324 A Yes. The retention agreement?25 Q Yes. Okay. You are familiar with thisCase 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page26 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 251 document, correct?2 A Yes.3 Q It's an e-mail from Larry Klayman to you, dated4 February 8, 2012, correct?5 A That's correct.6 Q And is this -- is this the only retention7 agreement that you have with Mr. Klayman related to the8 Obama cases?9 MR. KLAYMAN: Objection. Assumes facts not in

10 evidence. Leading.11 BY MR. KRESS:12 Q You can answer.13 MR. KLAYMAN: You can answer. That's a legal14 objection.15 THE WITNESS: Yes, as far as I know.16 BY MR. KRESS:17 Q Okay. Let me ask it a different way. I just


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18 want to try to avoid any objections.19 Did -- did you, personally, enter into any20 other agreements with Larry Klayman with respect to21 Obama litigation?22 MR. KLAYMAN: Objection. Assumes facts not in

23 evidence. Leading.24 You can respond.25 THE WITNESS: No.Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page27 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 261 BY MR. KRESS:2 Q Okay. Did you hire Larry Klayman to file an3 Obama challenge?4 A Well, it depends on what you mean by "you." I5 did not personally take on any obligation, but I did6 commit our fundraising efforts to do that. And many7 people attempted to help me with that, and we intended8 to raise enough money to not only do the Voeltz case,9 but the California case and cases in other states as10 well; and, if necessary, take this to the Supreme Court,11 which we knew would be quite expensive, you know, beyond12 our personal means to finance. So we needed to raise13 funds from people who were motivated to act on this.14 Q Okay. Well, the letter that's before us, as15 Exhibit 6, is only -- you are the only recipient of the16 letter, correct?17 MR. KLAYMAN: Objection. Leading. Assumes18 facts not in evidence. And document speaks for itself.19 BY MR. KRESS:20 Q You can answer.21 MR. KLAYMAN: You can answer.22 THE WITNESS: I was the point person.23 MR. KLAYMAN: It was an improper question, but24 you can answer that. Okay.

25 THE WITNESS: Okay. Answer an improperCase 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page28 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 27


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1 question. I was the point person on this thing. I was2 the one that was the entrepreneur that found Larry3 Klayman, met Larry Klayman, made the proposal,4 marshalled the resources, wrote the agreements, but5 other people were involved in this as well.

6 BY MR. KRESS:7 Q Okay. And the other people, you mentioned8 Pamela Barnett and Sam Sewell.9 Anyone else that you can identify?10 A I'm not sure I want to identify them and drag11 them into this thing unless that's necessary for the12 case.13 MR. KLAYMAN: You can identify them, George.14 THE WITNESS: I can answer it?15 MR. KLAYMAN: You can identify them, George.16 Yeah, you can answer.17 THE WITNESS: Okay. Well, for example, the18 following week after I met Larry Klayman, Tony Dolz19 (phonetic) accompanied me for the negotiations to hammer20 out the scope of the case and the financial arrangements21 in Beverly Hills, meeting Larry Klayman.22 BY MR. KRESS:23 Q Let's go through the process of hiring Larry in24 a little more detail. You communicated with him in25 December of 2011. And then was that by phone or -- thatCase 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page29 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 281 was in person, correct?2 A I met him in person at the time.3 Q Okay. What happened next with respect to4 hiring Larry Klayman, either through you or through a5 group you are affiliated with?6 A Well, I followed up with a call, which he did7 not respond to. And I had a mutual friend call him and

8 persuade him to talk to me. And then we talked, and9 then we established a meeting, a face-to-face meeting in10 Beverly Hills, which we did that -- the very next week,11 I think, or maybe the week after. I can't remember the12 exact chronology.13 And then I had to go out to our followers and14 -- and I communicated to them the essence of what Larry15 wanted to do and what we had tentatively agreed on with


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16 Tony, and we got agreement from a lot of people to do17 that because they said they would help spread the word18 and raise the money, and they were in accord with what19 Larry and I wanted to do.20 Q Okay. So, there's this collective effort to

21 hire Larry.22 MR. KLAYMAN: Please don't characterize his23 testimony.24 MR. KRESS: Larry --25 MR. KLAYMAN: That's improper.Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page30 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 291 MR. KRESS: Let me just as the questions.2 BY MR. KRESS:3 Q Who hired Larry to represent -- who hired Larry4 for the purposes of the Florida Obama litigation?5 A Well, this group of people, basically.6 Q Okay. Is there a written agreement with --7 between Larry and a group of people?8 A The only thing we have is this document --9 MR. KLAYMAN: Asked and answered. George --10 MR. KRESS: Please let him answer.11 MR. KLAYMAN: I'm allowed to make an objection.12 MR. KRESS: You can object to the form.13 MR. KLAYMAN: I am. Asked and answered.14 THE WITNESS: Excuse me? Answer it?15 MR. KLAYMAN: Objection is asked and answered,16 George.17 BY MR. KRESS:18 Q And you can answer the question, which is --19 MR. KLAYMAN: Yeah, after I make the objection,20 you can answer the question.21 MR. KRESS: Of course.22 THE WITNESS: Yeah, it was understood with the

23 group I was speaking for them. So we perceived the24 agreement was the group, and that our commitment was to25 raise funds through our fundraising vehicles, whichCase 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page31 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/law


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Merrill Corporation - New YorkPage 301 would fuel this effort.2 BY MR. KRESS:3 Q Who is the client?

4 A Who was the client?5 MR. KLAYMAN: That's both a legal conclusion6 and calls for legal conclusion.7 MR. KRESS: Larry, you are being very invasive8 and --9 MR. KLAYMAN: You are asking improper10 questions, Mr. Kress.11 MR. KRESS: No, I am not.12 BY MR. KRESS:13 Q Who was the client?14 MR. KLAYMAN: I'm allowed to object.15 MR. KRESS: You are allowed to object to some16 extent.17 MR. KLAYMAN: I will object, and please be18 respectful to me as well as my client, and let me make19 my objection. Do not talk over me. That's20 attorney-client privilege.21 MR. KRESS: Not who the client was.22 MR. KLAYMAN: He already testified. Asked and23 answered. He already testified to it.24 MR. KRESS: I don't think we do --25 BY MR. KRESS:Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page32 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 311 Q What -- what's the name of the client?2 MR. KLAYMAN: You can answer the question,3 George, that's fine, but I have to make a question, so4 please -- objection. Don't talk over me when I have an5 opportunity to make an objection. You can answer the

6 question.7 BY MR. KRESS:8 Q And the question is: What was the name of the9 client subject to Mr. Klayman's --10 MR. KLAYMAN: (Inaudible.)11 (Mr. Klayman talking at the same time.12 Mr. Kress and witness are talking.)13 THE WITNESS: There are some legalities


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14 involved in there, which I may not understand. Let me15 give you an analogy of something I do understand. When16 I was in the consulting business --17 BY MR. KRESS:18 Q I just want you to --

19 MR. KLAYMAN: Wait, let him answer.20 THE WITNESS: Would you just listen, please?21 MR. KLAYMAN: Be respectful of my client,22 please.23 THE WITNESS: When I was in the consulting24 business, we had both a client and a customer. The25 client was the ultimate beneficiary of the work. TheCase 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page33 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 321 customer might be the one that engaged me. So, I would2 characterize myself as Larry's customer, but the client3 was Michael Voeltz, in this particular case.4 BY MR. KRESS:5 Q Okay. That's fine. Thank you.6 Are you aware of a written agreement between7 Larry Klayman and Michael Voeltz for the purpose of the8 Obama litigation?9 A I don't know. That's really not my bailiwick.10 Q Okay. Don't know one way or the other?11 A I don't know, no. I don't know.12 Q Okay. And just so it's clear on the record,13 because all the objections and the talking --14 MR. KLAYMAN: Wait a second. Wait a second.15 MR. KRESS: I haven't even asked a question16 yet.17 MR. KLAYMAN: Yeah, but you are making18 sarcastic --19 MR. KRESS: I'm not making sarcastic remarks.20 I'm trying to clarify the record. I'm going to do it.

21 MR. KLAYMAN: I'm allowed to make objections.22 MR. KRESS: I haven't asked a question yet.23 MR. KLAYMAN: But let me make objections, and24 you won't have a problem. If you give me an opportunity25 to object, like I did when your clients were beingCase 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page34 of243


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GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 331 represented and made their own objections without even

2 you. So give me an opportunity and don't be sarcastic3 with George.4 MR. KRESS: Okay.5 BY MR. KRESS:6 Q Just to make sure we are clear on the record,7 I'm trying to speak as evenly as possible, the only8 agreement for the retention -- only written agreement9 for the retention of Larry Klayman's services with10 respect to the Florida Obama litigation is what's11 reflected in Exhibit 6, correct?12 MR. KLAYMAN: Asked and answered.13 MR. KRESS: And he can answer it again.14 MR. KLAYMAN: Ask and answered.15 MR. KRESS: He can answer the question.16 THE WITNESS: Yes.17 MR. KLAYMAN: He testified to quite long18 answer.19 MR. KRESS: Thank you.20 THE WITNESS: Yes, again.21 COURT REPORTER: Counsel...22 MR. KRESS: Yes.23 COURT REPORTER: Please, do not talk over one24 another. You're starting to make me angry, and I can't25 throw my shoe through the phone. (Laughter.)Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page35 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 341 MR. KRESS: All right. You could, but it2 wouldn't do much good for you or anyone else. I3 apologize, and we'll try.

4 BY MR. KRESS:5 Q Okay. So let's -- let's talk about this6 agreement here in -- in Exhibit 6, but first of all, did7 you, either independently or on behalf of the group,8 agree to the terms reflected in Exhibit 6?9 A Well, what we agreed to is that we would make a10 maximal effort to raise money from our donors.11 Q Okay. The agreement refers to an upfront


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12 retainer of $18,000.13 Was that paid?14 MR. KLAYMAN: Objection. Mischaracterizes the15 document. The document for itself.16 George, take a look at the document.

17 THE WITNESS: Okay. I'm looking at it.18 MR. KLAYMAN: I ask, Mr. Kress, that you don't19 mischaracterize documents please. That's not --20 MR. KRESS: I'll read it word for word.21 MR. KLAYMAN: It's not correct or ethical.22 BY MR. KRESS:23 Q I'll read it word for word then.24 In paragraph 2, it says:25 "To file suit in Florida, we will needCase 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page36 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 351 an upfront retainer of 18K, which will need to2 be kept at this level throughout the course of3 the case replenishing it monthly."4 And it goes on to say:5 "I will bill for out-of-pocket6 disbursements and expenses and my hourly rate7 of $395 per hour, which is reduced from my8 usual minimum rate of $600 per hour. The9 statements will issue on the 1st of each month10 and be payable upon -- or payable on receipt."11 Did I read that correctly?12 A Yes.13 MR. KLAYMAN: It's not accurate.14 MR. KRESS: I'm asking --15 MR. KLAYMAN: No, no, it's not accurate because16 you are mischaracterizing the document. What you are17 doing is unethical.18 MR. KRESS: It's not unethical.

19 MR. KLAYMAN: It's unethical. Read the next20 line.21 MR. KRESS: Okay. We can -- I want to ask him22 questions about that.23 MR. KLAYMAN: The objection, because you are24 distorting the document, the document speaks for itself,25 and you are not reading the whole document.


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Merrill Corporation - New YorkPage 361 BY MR. KRESS:2 Q Was an upfront retainer of $18,000 paid by3 Larry Klayman -- paid to Larry Klayman?4 A Not -- not on the terms that were done here.5 We were not able to all the money before he started, but6 to his eternal credit, he agreed to start anyway in the7 interests of our country.8 Q Okay. Was the $18,000 retainer paid at some9 point?10 A Yes.11 Q At what point was it paid?12 A It was actually after the hearing. So, he13 actually went and did the hearing without having the14 full amount, but we finally did raise that and part of15 the expense money.16 Q How much was -- how much was Larry paying --17 Larry Klayman paid in total from the group related to18 the Florida Obama litigation?19 A It was about 21,000 something. I don't20 remember the exact amount anymore.21 Q Did that -- was that based on fees, expenses or22 both?23 A Well, the retainer was 18,000. There was some24 feels over and above that, which we were able to25 partially reimburse him for.Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page38 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 37

1 Q Okay. Did you pay for any of his -- his2 expenses?3 A Again, 18,000 was retainer and the rest was --4 went towards his expenses. So, I think that would be a5 yes.6 Q Okay. Did Larry Klayman issue any billing7 statements to you or to the group?8 A Yes. I believe there's one in the exhibits, is


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9 there not?10 Q Yes. Is that -- we will refer to that one. If11 you could look at George Miller Deposition Exhibit 8,12 please.13

14 (Exhibit 8 identified.)1516 A Exhibit 8. Yes, I see it.17 Q Okay. And you are familiar with this document,18 correct?19 A I am, yes.20 Q Other than this billing statement -- well, let21 me ask it -- let me ask it a little bit more clearly.22 Did Larry Klayman issue any bills to you or to23 your group related to the Florida Obama litigation?24 MR. KLAYMAN: Hold on, George.25 Asked and answered. You already referred to aCase 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page39 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 381 prior document, which set forth amounts of retainers,2 and you misstated what was in there as well. There was3 18,000 that was Florida and 25 of it was California as4 well.5 Go ahead. You can answer, George. I just want6 to make sure you focus on the question.7 THE WITNESS: Yeah. There was the initial --8 there was the initial retainer agreement and some9 dunning on that, and there was this particular bill in10 Exhibit 8, plus he referred to much larger amount of11 time he had put in that he did bill us for. And at that12 time, he felt he was not going to be compensated for it.13 BY MR. KRESS:14 Q Okay. So, let's just break that down a little15 bit.

16 Mr. Klayman sent you Exhibit 6, correct?17 A Let me go back to Exhibit 6 again. I don't18 remember which one it is. Yes. Yes, he did.19 Q Okay. And that refers -- I will try to20 characterize it because -- there's some reference in21 there to retainers and so forth. And then he sent you22 Exhibit 8, which is a billing statement.23 Did Larry Klayman send you any other written


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24 bills or billing statements or invoices for his services25 in the Obama -- Florida Obama litigation?Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page40 of243

GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 391 A I didn't see any hard copy or digital image,2 but we discussed the scope of what he had done for us3 that exceeded both of these substantially.4 Q Okay. I just want to -- but I just want to5 make sure it's clear on the record.6 Did he send you any written documents -- I'm7 looking for written documents right now -- that were8 bills or invoices for his services in the Florida Obama9 litigation other than Exhibit 6 and Exhibit 8?10 A Not that I'm aware of, no.11 Q Okay. And I just to make sure that I'm clear12 on this. Uhm... regardless of the amounts stated in13 Exhibit 6 and Exhibit 8, it's your recollection that14 Larry Klayman was paid approximately $21,000 by the15 group for the Florida Obama litigation?16 MR. KLAYMAN: Objection. Improper question.17 Compound. You are mixing apples and oranges. You can18 ask him for each particular document, but not on a19 compound question like that.20 BY MR. KRESS:21 Q You can answer, if you understand.22 A Why don't you ask them separately so even I can23 understand.24 Q When you -- you testified earlier, I believe,25 that the group paid Larry Klayman approximately $21,000Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page41 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/law

Merrill Corporation - New YorkPage 401 for his services in the Florida Obama litigation,2 correct?3 A Correct, yes.4 Q Was that based on -- well, at what time was he5 paid? Do you remember what month?6 A He was paid in dribs and drabs, as we could


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7 collect the money. And we would save enough to send it,8 and he would call us up begging for it sooner. So we9 would send it pretty much whenever he asked when we had10 some.11 Q Uhm-hum. And if you could refer to Exhibit 7,

12 please.1314 (Exhibit 7 identified.)1516 A Yes.17 Q Okay. There's actually two e-mails referenced18 on this one page. The first one is at the bottom of the19 page, and it's from Larry Klayman to George Miller,20 May 7, 2012, at 8:43 p.m. And it states:21 "George, Sam and Pamela."22 So that's you, Sam Sewell, and Pamela Barnett,23 correct?24 A Yes.25 Q And it states:Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page42 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 411 "This confirms that I will take this2 through the hearing on defendant's motion to3 dismiss if you pay the agreed retainer in full4 of 18,000 before the hearing. You agreed to5 pay about 3,000 this week with more coming next6 week. The remainder of the retainer at this7 point in time is 11K. Thank you for your8 cooperation and best, Larry Klayman."9 If you know, is the 18K that's referenced in10 this May 7, 2012, e-mail from Larry Klayman the $18,00011 retainer referenced in the February 8, 2012, e-mail?12 A It's all the original retainer, yes.13 Q Okay. Thank you.

14 And then if we go to the e-mail above that,15 this appears to be from microma- --16 [email protected] Do you know whose e-mail address that is?18 A Yeah, that's mine.19 Q Is that yours?20 A It's my -- my address.21 Q So, that's from you to Larry Klayman. It says:


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22 "We have already paid at least 9K."23 And then I'm not going to read the whole thing.24 I'm not trying to misrepresent it. I just don't think I25 need to read the whole thing.Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page

43 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 421 MR. KLAYMAN: Well, but -- objection.2 Objection. If you're -- well, take it --3 MR. KRESS: I am not --4 MR. KLAYMAN: Give me an opportunity to object.5 MR. KRESS: Okay.6 MR. KLAYMAN: If you distort this the way you7 distorted the other one.8 MR. KRESS: I object to your characterization.9 BY MR. KRESS:10 Q The first -- just reading the first sentence,11 it says:12 "We've already paid at least 9,000."13 And then the last sentence says:14 "That would leave 9K or less to go15 according to my math. Where did I go wrong?"16 What did you mean by -- by that statement,17 "That would leave 9K or less to, go according to my18 math. Where did I go wrong?"19 A I think the memo speaks for itself. Add up the20 numbers. It comes to eight, nine, $9,300. That would21 mean that I owe -- that we owe less than 9,000 since the22 retainer was 18,000.23 Correct?24 Q That makes sense to me.25 A Okay.Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page44 of243

GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 431 MR. KLAYMAN: Object. Move to strike.2 Mr. Kress, please avoid the colloquy, okay, because3 that's what causes me to have to object. I don't want4 to have to interrupt your questioning, but please don't


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5 put your own thoughts on the record. You are not6 testifying. You're not under oath. I'll put you under7 oath, and I can depose you.8 MR. KRESS: Your client is asking questions.9 MR. KLAYMAN: No, but it's improper.

10 BY MR. KRESS:11 Q Well, let's go to Exhibit 9. Take a moment to12 read this, please.1314 (Exhibit 9 identified.)1516 A Yes.17 Q You are familiar with this e-mail?18 A Yes, I am.19 Q You recall receiving it from Larry Klayman on20 or about August 9th of 2012?21 A At this point, I can't deny it. It's something22 we've discussed before. I remember hearing e-mails.23 Did I receive it on that exact date? I don't know. It24 looks like it from this copy.25 Q Uhm-hum. I want to refer you to paragraph 3.Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page45 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 441 It says:2 "There is no formal contract" -- I'm3 sorry, I misread that. It states:4 "That there is no formal written5 contract is not controlling. There is written6 evidence of our agreement in the form of7 e-mails and you owe the moneys under the legal8 doctrines of promissory estoppel, quantum9 meruit and unjust enrichment as well as breach10 of contract. A contract can be oral as well as11 written."

12 As the recipient of this e-mail, what did that13 mean to you?14 A Well, he's attempting to say that I,15 personally, owe the money. I did subsequently clarify16 that it was -- it was an effort to raise funds, and that17 we had committed to try to raise those funds.18 Otherwise, I agreed pretty much. I'm not a lawyer. I19 couldn't tell you exactly what the word "estoppel"


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20 means, but the bottom line is that we wanted to do this21 project. We agreed to work and raise the funds with our22 best efforts, and we continued to attempt to do that23 during the life of this relationship.24 Q Thank you.

25 But as of August 9, 2012, was Larry KlaymanCase 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page46 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 451 asking that you and Pamela Barnett and Sam Sewell pay2 his bill?3 A Well, depends again what you mean by "you." He4 used "you" in there, but again, as I told you, we were5 attempting to bring the group together to raise the6 funds, yes.7 Q Okay. Did you, personally, refuse to8 contribute to Larry's legal bills or Larry's efforts9 because of any comments that you read on Orly Taitz10 website?11 A Well, I will tell you --12 MR. KLAYMAN: Objection. Assumes facts.13 Objection. George, hold on.14 MR. KRESS: Wait. Don't -- let's not coach15 him.16 MR. KLAYMAN: I'm not coaching him.17 MR. KRESS: If you have an objection, don't18 coach him -- he's your client.19 MR. KLAYMAN: It assumes facts not testified20 to. Not in evidence.21 MR. KRESS: I'll break it down a little bit.22 MR. KLAYMAN: Break it down, please.23 BY MR. KRESS:24 Q I know that you, at some point, read that Orly25 Taitz posted on her website that Connie Ruffley saidCase 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page

47 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 461 that Larry Klayman had been convicted of a crime of not2 paying child support; is that correct?


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3 A Correct.4 MR. KLAYMAN: Object. That mischaracterizes --5 hold it, George. Just a moment.6 That mischaracterizes what was on the website.7 It was that I was convicted of a crime, and the

8 information should be given that I --9 MR. KRESS: I object.10 MR. KLAYMAN: Let me -- let me tell you11 something.12 MR. KRESS: I ask --13 MR. KLAYMAN: The questions that you you are14 asking are misleading, and they mischaracterize what's15 in -- what Connie Ruffley said. So, consequently,16 please read to him that which was published on the17 website because otherwise it's not ethical to do this.18 MR. KRESS: This is plenty ethical.19 MR. KLAYMAN: It's not. It's not.20 BY MR. KRESS:21 Q Mr. -- Mr. Miller, do you recall reading Connie22 Ruffley's -- I'm sorry.23 Do you recall reading Orly Taitz's website24 posting from February 23, 2012?25 A I don't remember the exact date, but it was inCase 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page48 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 471 February, and she -- she used Connie's --2 Q My question is -- okay. We can -- we can go to3 Exhibit Number 14.4 MR. KLAYMAN: Let's do that.5 MR. KRESS: Let's do that.6 THE WITNESS: Okay.78 (Exhibit 14 identified.)9

10 BY MR. KRESS:11 Q So, you are familiar with Exhibit 14, correct?12 A Yes, I am.13 Q Let me ask you this --14 MR. KLAYMAN: Give him an opportunity to review15 it if you are going to ask him questions.16 Go ahead, George, read it.17 MR. KRESS: Well, I don't --


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18 MR. KLAYMAN: He's entitled to do that if you19 are going to ask him questions on the exhibit.20 BY MR. KRESS:21 Q If you need to read the whole thing --22 MR. KLAYMAN: I'm instructing him to do it

23 because that's the way you should ask questions; give24 him the opportunity to look at the document first.25 That's the ethical thing to do.Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page49 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 481 THE WITNESS: Okay. There's a lot in here.2 What are your specific questions?3 BY MR. KRESS:4 Q My question is, did anything in Exhibit 14,5 after you read it, cause you to refrain personally from6 contributing to any of -- contributing money to any --7 MR. KLAYMAN: Hold it, George.8 MR. KRESS: Let me ask the question.9 MR. KLAYMAN: Ask it, but do not answer the10 question because it's an improper question. I need to11 make an objection.12 BY MR. KRESS:13 Q Let me start again, Mr. Miller. Hopefully, I14 won't be interrupted this time.15 Does any --16 MR. KLAYMAN: You are interrupted because the17 questions are -- are inappropriate and unethical.18 MR. KRESS: I will just state this on the19 record. Mr. Miller was not originally identified as a20 witness. He was -- we objected to him being called at21 trial. The judge stated that he can only testify at22 trial if you gave me the opportunity to depose him.23 MR. KLAYMAN: That's fine.24 MR. KRESS: If you are interfering with my

25 ability to depose him, then you are further -- it'sCase 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page50 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 49


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1 further prejudicing us.2 MR. KLAYMAN: No. What's -- what's -- what's3 improper, Mr. Kress, is that you've asked him a4 question, and you never asked him a foundation question5 about whether he made contributions, okay. You are

6 assuming in your question.7 MR. KRESS: Okay.8 MR. KLAYMAN: And you are doing that9 intentionally.10 MR. KRESS: No, I am not.11 MR. KLAYMAN: And that's what's unethical. You12 are doing it intentionally, okay, and it's an improper13 question.14 MR. KRESS: It's improper of accusing me15 unethical conduct.16 MR. KLAYMAN: Well, then I'm asking that you to17 stick to what -- what is, you know, what question was is18 that you are assuming facts that he never testified to,19 okay. You are putting him in his mouth. Just break the20 questions down, and you can ask them.21 BY MR. KRESS:22 Q Mr. Miller, did you ever refuse to contribute23 money to Larry Klayman's Florida Obama efforts, legal24 services, because of anything that you read in25 Exhibit 14?Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page51 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 501 MR. KLAYMAN: Objection. It assumes facts not2 testified to. He never said he contributed anything.3 BY MR. KRESS:4 Q You can answer the question.5 A It definitely inhibited me from giving more. I6 gave him some money prior to that. And, you know,7 frankly, we had a really heavy heart-to-heart talk after

8 this came out because it really shook my confidence9 quite a bit. I mean, look at this thing. This is10 Ruffley --11 Q There's no question --12 MR. KLAYMAN: Let him answer the question.13 MR. KRESS: There's no question before --14 THE WITNESS: I'd like to read you --15


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16 (Mr. Klayman, Mr. Kress, and the17 witness all speaking at the same time.)1819 COURT REPORTER: Stop, stop, stop, stop. Stop,20 stop, stop. Stop. I don't know how many fingers you

21 think I have, but I can't do it. One person at a time.22 Sorry. Excuse me. I'm talking. If you want this done,23 if you want me to certify it, you will speak one at a24 time. Got it? Does everybody understand one at a time?25 MR. KRESS: We understand.Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page52 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 511 COURT REPORTER: Thank you.2 MR. KLAYMAN: You asked for it, and he's going3 to answer.4 THE WITNESS: This is the most --567 (Mr. Klayman, Mr. Kress, and the8 witness all speaking at the same time.)910 COURT REPORTER: Stop. You're doing it again.1112 (Mr. Klayman, Mr. Kress, and the13 witness all speaking at the same time.)1415 COURT REPORTER: You're doing it again. Stop.16 Please, stop. There has to be control. There has to be17 order in this deposition. You have to speak one at a18 time. That includes the witness. That includes both19 the attorneys. One at a time. I will not certify this20 record if you keep talking over each other because I21 will not be able to get everything.22 MR. KRESS: Thank you.

23 MR. KLAYMAN: George, just answer the question.24 THE WITNESS: Okay. May I read you the words25 that caused me the most angst and did the most damage toCase 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page53 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/law


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Merrill Corporation - New YorkPage 521 our program that you people have just about destroyed.2 May I do that?3 BY MR. KRESS:

4 Q Yes.5 A Thank you. Okay.6 "Mrs. Ruffley" -- these are Orly7 Taitz's words in her blog.8 "Mrs. Ruffley actually advised me that9 Larry Klayman is not licensed in California" --10 which, by the way, is misleading, which I'll explain11 later.12 "She told me that he no longer works13 for Judicial Watch" -- not that he said that he14 did.15 -- "and that donors should know about16 litigation in Ohio" -- which is where the17 litigation took place on the child support --18 -- "where he was convicted" --19 Really? Convicted? This was news to me. This20 was quite a shock.21 -- "recently of not paying large22 amount in child support. She provided a lot of23 information."24 Really? I wonder what that was.25 "I will publish only what is a publicCase 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page54 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 531 record. I am not publishing anything that is2 not in public record."3 Show me, please, where this is in the public4 record that your employee, Judicial Watch, the manager5 of the California thing, who has high visibility, who

6 shows up at public events, who crashes Orly Taitz's7 session, volunteers this information. Are you kidding?8 Yes. I'm very concerned, and I'm very angry. You've9 destroyed our program, and you hurt our nation as well.10 Any other questions?11 BY MR. KRESS:12 Q Are you finished with your answer, Mr. Miller?13 I have a lot more questions.


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14 A Good. Fire away.15 Q Okay. So you read the paragraph that caused16 you the most concern, correct?17 A Correct.18 Q All right. Do you know whether it was true or

19 false that Larry Klayman was not licensed in California?20 A I've known that all along. He was supposed to21 go pro hac vice. We knew that he is licensed to22 practice in Washington, DC. and Florida. He sent me a23 copy of his law license before we started this24 assignment.25 Q Okay. But just make sure we have it clear onCase 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page55 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 541 the record, you understood that he was not licensed in2 California, correct?3 A I understood that. But the way Orly writes4 this, it's like he can't even work on the case. She5 only mentions the facts that were most pertinent, and6 Mrs. Ruffley as well.7 Now, why is Mrs. Ruffley making a big deal8 about the fact that he's not licensed to work in9 California when he can easily work in California, as10 attorneys do all over the country, using pro hac vice?11 It's very, very deceptive on her part, very misleading,12 especially for someone, who is supposedly a legal expert13 that works for the world's leading public interest firm,14 Judicial Watch, which Mr. Klayman founded, by the way.15 MR. KRESS: Objection. Move to strike as16 nonresponsive.17 BY MR. KRESS:18 Q It was correct that he no longer worked at19 Judicial Watch, correct?20 A Correct.

21 Q There was litigation in Ohio, correct?22 A Correct.23 Q Prior --24 MR. KLAYMAN: Wait a minute.25 BY MR. KRESS:Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page56 of243


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GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 551 Q Prior --

2 MR. KLAYMAN: Objection. It's indefinite as to3 time as to when he had knowledge. Objection. Move to4 strike.5 MR. KRESS: I'm going to follow up on that.6 MR. KLAYMAN: Go ahead.7 BY MR. KRESS:8 Q As of February 23, 2012, did -- were you aware9 -- well, let me strike that and start over again.10 Prior to reading this website article, did --11 did you know that Larry Klayman was involved in some12 type of litigation in Ohio related to child support?13 A I did not know there was litigation. I had14 heard he was behind on his child support payments. At15 that time, we asked him. He explained the situation to16 our satisfaction. I knew nothing about a conviction. I17 didn't even know that this was a criminal matter. I18 thought it was a civil matter, actually.19 Q Okay. So, before the group hired Larry, you20 knew there was some type of child support issue in Ohio,21 correct?22 A I can't remember the exact timing. You know,23 we did some basic due diligence, and we knew of all24 kinds of things on the blogs. You know, people attack25 Larry Klayman all the time. We try to sort out what wasCase 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page57 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 561 true from what was not true. Basically, we concluded2 that he was behind on his child support payments, and3 that's due in part that he works for low rent clients

4 like us, and he puts in a lot of time on his own,5 dedication time. So, to me, that was really, to some6 extent, uhm, a pro; that this guy is struggling, trying7 to make ends meet, working on cases like us, trying to8 help the country. He's not one of these shyster lawyers9 that charges high prices and profits vastly. This is a10 cause for him.11 Q Okay. All right. So, a few things to ask you


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12 about what you just said.13 You, as part of your due diligence, reviewed14 Larry Klayman's background, correct?15 A To some extent, yes.16 Q And you found a lot of things on the web that

17 were, uhm, critical --18 MR. KLAYMAN: Objection.19 BY MR. KRESS:20 Q -- of Larry Klayman, correct?21 MR. KLAYMAN: Objection. He never testified to22 that. Assumes facts not in evidence.23 MR. KRESS: Let me ask it this way.24 MR. KLAYMAN: Yes, please, ask it in a25 different way.Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page58 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 571 BY MR. KRESS:2 Q Did you find any information during your due3 diligence regarding Larry Klayman that reflected4 negatively on Larry Klayman?5 MR. KLAYMAN: Objection. Relevancy.6 You can answer.7 BY MR. KRESS:8 Q You can answer.9 A Well, sure. Lots of stuff. He's not exactly10 popular with the left. He's not exactly popular with11 government or organizations that are being investigated.12 He is certainly not popular with Bill Clinton or Barack13 Obama or any of their minions.14 Q So, did you read any, for instance, articles15 that were critical of Larry Klayman?16 MR. KLAYMAN: Objection. Relevancy. Judge has17 already ruled the articles are inadmissible.18 BY MR. KRESS:

19 Q You can answer.20 A We read various things on blogs. I can't say21 that we read those particular exhibits that you have in22 there. They didn't look familiar to me.23 Q Okay. But you were aware that there was24 negative press related to Larry Klayman before you --25 before you hired him, correct?


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Merrill Corporation - New YorkPage 581 A Well, yes. Any great man leaves a wake.2 Q Okay. So, there's some good stuff out there,3 there's some bad stuff out there, correct?4 A Correct, yes.5 Q But you --6 MR. KLAYMAN: Objection to using the word good7 and bad. Vague and ambiguous. And move to strike.8 BY MR. KRESS:9 Q Do you understand the words "good" and "bad"?10 A I have my own understanding.11 Q I'll withdraw the question. I'll withdraw the12 question.13 But you -- you -- you gathered that14 information, and you sorted through it to determine what15 was, in your view, true or false, correct?16 A To some extent, yes.17 Q Okay. As of -- well, prior to reading Orly18 Taitz's publication, which was Exhibit 14, did you know19 that Larry Klayman had been criminally indicted for20 failure to pay child support?21 A No.22 Q Okay. So, prior to this time, prior to reading23 this, on February 23, 2012, internet blog or article,24 you thought it was merely a civil matter, correct?25 A Yes.Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page60 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 59

1 Q The fact that he was indicted speaks negatively2 of Mr. Klayman, doesn't it?3 MR. KLAYMAN: Objection. Facts speak for4 itself.5 THE WITNESS: Is a person not innocent until6 proved guilty anymore?78 (Mr. Klayman speaking at the same


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9 time as witness.)1011 BY MR. KRESS:12 Q You mentioned that you thought it was only a13 civil matter. You didn't know it was a criminal matter.

14 MR. KLAYMAN: Objection. Compound question.15 You can answer, George.16 BY MR. KRESS:17 Q I'll withdraw the question because you've18 already said it.19 A I've already said it.20 Q Okay. And in fact, if we go down back to21 Exhibit 14 and read further on, couple paragraphs down,22 it states:23 "Larry" --24 MR. KLAYMAN: Paragraph 14 of what?25 MR. KRESS: Exhibit 14.Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page61 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 601 MR. KLAYMAN: Okay.2 MR. KRESS: The last full paragraph on the3 third -- well, what I'm showing as the second page of4 the article.5 MR. KLAYMAN: All right.6 BY MR. KRESS:7 Q And it states --8 MR. KLAYMAN: Let me make an objection. The9 document speaks for itself.10 MR. KRESS: Okay. I haven't asked a question11 yet.12 MR. KLAYMAN: I know the way you ask questions,13 Mr. Kress. I'm just trying to get an objection, so you14 can ask the question in a correct way.15 BY MR. KRESS:

16 Q The last paragraph states:17 "Larry Klayman, 60, of Los Angeles,18 California was indicted on two counts of19 criminal nonsupport. He owes $78,861.76 for20 his two children, ages of 11 and 14. Two21 hearings were held in domestic relations court22 between 2009 and 2010. The last voluntary23 payment was made on August 30, 2011, in the


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24 amount of $1,014.26. Arraignment is scheduled25 for February 7, 2012."Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page62 of243

GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 611 Prior to reading Orly Taitz's posting, were you2 aware of the information that I just read to you?3 A I don't remember the exact amount. All I4 remember is he was substantially behind in child5 support, and I did not know it was a criminal thing. I6 did not know he was indicted. I certainly didn't know7 he had been convicted because he wasn't. A little bit8 of misinformation there, yes?9 Q So, Mr. Miller, going back to where I was --10 how much money did you contribute to Larry Klayman's11 efforts in the Florida Obama litigation?12 MR. KLAYMAN: Objection. That's leading, and13 it doesn't ask the foundation question, Mr. Kress. I14 can only assume, because you keep doing this, that you15 are doing it intensionally. And that's why -- that's16 why I consider this to be unethical because I don't mean17 to be abrasive, but you know what to do. You are an18 experienced lawyer. You've been a lawyer for a long19 time. Ask the foundation question. Don't ask questions20 that assume facts that are not in evidence.21 BY MR. KRESS:22 Q Mr. Miller, didn't you already tell us that you23 contributed money to Larry Klayman's Florida Obama24 Challenge efforts?25 A Yes.Case 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page63 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/law

Merrill Corporation - New YorkPage 621 Q How much?2 A I did a contribution of a thousand, and I think3 I did more, too. I can't remember the exact amount4 anymore. It was over a thousand dollars from my5 personal funds.6 Q Okay. Thank you.


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7 Do you believe that you, personally -- well,8 let me ask it this way. Let me back up.9 Did you ever, personally, make a decision to10 refuse to contribute any funds to Larry Klayman's11 Florida Obama Challenge as a result of reading that

12 paragraph that concerned you?13 A I was certainly more inhibited. I mean,14 there's a number of factors that go into making a15 donation, like how much money you have, how strongly you16 feel about the cause, how likely this is to succeed, and17 all those other things. But that did make me less18 likely to contribute more money, yes.19 Q Okay. Did you ever make a conscious decision20 to say, "I'm not going to contribute money because I21 read on this internet blog that Mr. Klayman had been22 convicted"?23 MR. KLAYMAN: Objection. Relevancy.24 You can answer.25 THE WITNESS: I -- I don't -- I don't know. ICase 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page64 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 631 know it was definitely a factor, but I can't tell you2 exactly how that weighed with everything else, but it3 was a negative factor for sure as it was for hundreds,4 if not thousands, of other people probably.5 BY MR. KRESS:6 Q Okay. What other factors led to your decisions7 regarding whether or not to -- well, let me ask it this8 way. You said you contributed a thousand, maybe a9 little bit more.10 A Yes.11 Q What other factors led to your decision not to12 contribute more?13 A I already told you that.

14 MR. KLAYMAN: Objection. Assumes facts not in15 evidence. He didn't -- he hasn't testify to that.16 BY MR. KRESS:17 Q Well, you mentioned that you considered a lot18 of factors, and this -- this internet article was19 something that inhibited you.20 A Yes.21 Q What other factors did you consider?


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22 A I thought I told you that already. Should I do23 it again?24 Q I didn't hear that. So, if you could, please.25 A Okay. I mentioned when you -- when youCase 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page

65 of243GEORGE MILLER - 5/23/20141-800-325-3376 www.merrillcorp.com/lawMerrill Corporation - New YorkPage 641 contribute to a cause, you ask a lot of questions, like2 how strongly you feel about the cause, how righteous is3 it, how likely is it to succeed, how competent are the4 people doing it, what are the opposition. Those are all5 factors.6 This is obviously a very big one and, you know,7 based on the reaction we had from potential donors and8 the public, in general, this was a disaster. It dried9 up our funds. It hurt our credibility very badly, and10 it was worse by the fact that it came from the very11 organization that he founded. Kind of like, "Et tu,12 Brutus."13 This was just terrible when it happened. You14 just -- it was -- everyone was kind of moping around,15 and we tried to figure out how to react to it. I16 finally wrote that open letter to Taitz to try to get17 out to the public what the situation was; that these18 weren't accurate charges, really, and also, they were19 very colored.20 It's interesting that she mentioned about --21 she mentioned about the child support, but she never22 said a thing about the Hartman decision and the fact23 that the divorce was actually done in Virginia,24 originally, not in Ohio at all. And that the judge25 probably did something illegal in that ruling. So, sheCase 1:13-cv-20610-CMA Document 127-1 Entered on FLSD Docket 05/27/2014 Page

klayman v judicial watch miller deposition pt. 1

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