Ruffley Deposition, Klayman v Judicial Watch

EXHIBIT “1”

Case 1:13-cv-20610-CMA Document 80-1 Entered on FLSD Docket 02/28/2014 Page 1 of 130

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1 UNITED STATES DISTRICT COURT

2 SOUTHERN DISTRICT OF FLORIDA

3

4 LARRY E. KLAYMAN, Plaintiff,

5 Case No. 13-20610-CIV-ALTONAGA/SIMONTON

6 v.

7 JUDICIAL WATCH, INC., et al.,

8 Defendants.

9

10

11

12 DEPOSITION OF CONSTANCE S. RUFFLEY

13 FRIDAY, JANUARY 31, 2014

14 9:01 a.m.

15

16 205 South Broadway, Suite 200

17 Los Angeles, California 90012

18

19

20

21

22

23 REPORTED BY:

24 TRACY WILLIAMS, CSR #10139, RPR, CRR

25 JOB NO. 109385

Coalition of Court Reporters of Los Angeles 205 South Broadway, Suite 200, Los Angeles, CA 900121213.471.29661 www.ccrola.com

1


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1 APPEARANCES:

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FOR PLAINTIFF:

KLAYMAN LAW FIRM BY: LARRY KLAYMAN, ESQ., PRO SE

(VIA TELEPHONIC CONFERENCE) NAVEED MAHBOOBIAN, ESQ. MONA FALAH, ESQ.

2520 Coral Way Suite 2027 Miami, Florida 33145 (310) 595-0800 Leklayman®gmail.com

10 FOR DEFENDANT:

11

12

13

14

15

LAW OFFICES OF SCHWED, KAHLE, KRESS BY: DOUGLAS J. KRESS, ESQ. 11410 North Jog Road Suite 100 Palm Beach Gardens, FL 33418 (561) 694-0070 [email protected]

16 Also Present:

17 JUDICIAL WATCH

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PAUL J. ORFANEDES, Director of Litigation 425 Third Street, SW Suite 800 Washington, DC 20024 (202) 646-5172 [email protected]

VIDEOGRAPHER: Elizabeth Collins


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1 I N D E X

2 WITNESS: CONSTANCE S. RUFFLEY

3 EXAMINATION BY PAGE

4 Mr. Klayman .................................. 8

5 Mr. Kress ................................... 74

6 Mr. Klayman ................................. 76

7

8

9 EXHIBITS

10 EXHIBIT DESCRIPTION PAGE

11 29 Declaration under penalty of perjury of Constance S. Ruffley 24

12 2 World's Leading Obama Eligibility

13 Challenge Web Site reprint 27

14 9 Driscoll Seltzer document dated March 5th of 2012, 10 pages 62

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1 LOS ANGELES, CALI FORNIA i

2 FRIDAY, JANUARY 31, 2014 9:01 A.M.

3 -000-

4

5 THE VIDEOGRAPHER: Today is the videotaped

6 deposition of Constance Ruffley taken on January 31st,

7 2014, at the Coalition of Court Reporters of

8 Los Angeles at 205 South Broadway Street, Suite 200,

9 in Los Angeles, California. In the matter of Larry

10 Klayman v. Judicial Watch, et al., Case No.

11 13-20610-CIV-ALTONAGA in the U.S. District Court for

12 the Southern District of Florida.

13 My name is Elizabeth Collins with Coalition

14 of Court Reporters of Los Angeles, located at 205

15 South Broadway, Suite 200, in Los Angeles, California.

16 We are now commencing at 9:01 a.m.

17 Will all present please identify themselves, beginning

18 with the witness.

19 THE WITNESS: Constance Ruffley.

20 MR. KRESS: Douglas Kress, attorney for Judicial

21 Watch and for the witness, as well.

22 MR. ORFANEDES: Paul Orfanedes with Judicial

23 Watch.

24 MS. FALAH: Mona Falah with Larry Klayman.

25 MR. MAHBOOIAN: Naveed Mahboobian for Larry

4

Coalition of Court Reporters of Los Angeles 205 South Broadway, Suite 200, Los Angeles, CA 90012 I 213.471.2966 I www.ccrola.com


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1 Klayman.

2 THE VIDEOGRAPHER: And, Mr. Klayman, if you will

3 identify yourself.

4 MR. Ia...AYMAN: Yes.

5 Larry Klayman, Counsel Pro Se for Larry

6 Klayman.

7 Can you all hear me? Because it's breaking up

8 coming through on our end.

9 MR. KRESS: We can hear you fine.

10 MR. Ia...AYMAN: Okay. Well, let's see how we do

11 with the witness. I may have to call back on a

12 different phone.

13 THE VIDEOGRAPHER: Okay.

14 will the court reporter please swear in the

15 witness?

16 THE REPORTER: will you raise your right hand,

17 please?

18 THE WITNESS: (Complies.)

19

20 CONSTANCE S. RUFFLEY,

21 having been first duly sworn was examined and

22 testified as follows:

23


25 You can proceed.

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1 (No audible response.)

2

3 MS. FALAH: Larry .

4 MR. KLAYMAN: Yes.

5 Who was who said "Larry"?

6 MS. FALAH: You can proceed.

7 Did you get --

8 MR. KLAYMAN: Hello.

9 I think we are going to have to call back.

10 MR. KRESS: If that's what you need to do, that's

11 fine.

12 I mean, can you hear me now?

13 MR. KLAYMAN: I can hear you fine. I can't hear

14 the court reporter at all.

15 MR. KRESS: Let's -- let's try and see if it works.

16 MR. KLAYMAN: All right.

17 Let me -- let's -- starting with Ms. Ruffley.

18 We are not communicating really well over the phone.

19 It won't take long.

20 Can you hear me?

21 THE WITNESS: Yes.


23 THE WITNESS: Yes, I can hear you.

24 MR. KLAYMAN: We are going to have to go to

25 another -- we will call in in just a second.

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1 MR. KRESS: Okay.


3 Do you want to go off the record, then?

4 MR. KRESS: We will go off the record.

5 THE VIDEOGRAPHER: The time is 9: 03 a. m. We are

6 going off the record.

7

8 (At 9:03 a.m., a recess was taken

9 until 9:06 a.m. of the same day.)

10

11 MR. KLAYMAN: Larry Klayman joining the conference

12 again.

13 MR. KRESS: Hi, Larry.


15 MR. KRESS: We are back.

16 Can you hear us now?

17 MR. KLAYMAN: Yeah, hold on.

18 We are seeing if our speaker works. If not,

19 I'm going to call back on the other phone again.

20 Because I think the problem is at your end, frankly.

21

22 (A brief pause in the proceedings.)

23

24 MR. KLAYMAN: Can you hear me?

25 MR. KRESS: Yes.

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1 THE WITNESS: Yes.

2 MR. KLAYMAN: You can?

3 MR. KRESS: Yes, we can hear you.

4 MR. KLAYMAN: Okay. All right.

5 Let's start.

6 MR. KRESS: Wait. The videographer is going to

7 turn the video back on.

8 MR. KLAYMAN: Ms. Ruffley, have you been sworn

9 in?

10 THE VIDEOGRAPHER: Okay. The time is 9:06 a.m.

11 We are now back on the record.

12 MR. KRESS: Larry, the videographer was just

13 speaking. If you could ask your question again.

14 MR. KLAYMAN: Yes.

15

16 EXAMINATION

17 BY MR. KLAYMAN :

18 Q. Ms. Ruffley, have you been sworn in?

19 A. Yes.

20 Q. Okay. Would you please state your name?

21 A. Constance Ruffley.

22 Q. When were you born?

23 A. January 14th, 1944.

24 Q. Where were you born?

25 A. Pasadena, California.

8

Coalition of Court Reporters of Los Angeles 205 South Broadway, Suite 200, Los Angeles, CA 90012 1 213.471.29661 www.ccrola.com


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1 Q. Can you run us briefly through your

2 educational background?

3 A. I graduated from high school in 1961, and I

4 received my B.S./B.M. in 1994.

5 Q. What is an ESBM [sic]?

6 A. It's a Bachelor of Science in Business

7 Management.

8 Q. And where did you receive that degree?

9 A. University of Redlands, California.

10 Q. What did you do after you got that degree?

11 A. The bank I was working for paid for my degree

12 and I continued to work in the bank.

13 Q. Which bank was that?

14 A. Communi ty Bank.

15 Q. Which bank was that?

16 A. Community Bank headquartered in Pasadena,

17 California.

18 MR. KLAYMAN: Can we turn the sound up a bit?

19 You are very faint.

20 MR. KRESS: I don't know if there is

21 One second, please. Let me see.

22


24

25 MR. KRESS: How does that sound to you now,

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1 Larry?

2 Larry.

3 MR. KLAYMAN: Yes.

4 MR. KRESS: We tried. Let's see how that works.

5 THE VIDEOGRAPHER: Move it closer.

6 THE WITNESS: (Complies.)

7 MR. KLAYMAN: All right.

8 Hold on one second.

9


11


13 MR. KRESS: Hello.

14 MR. KLAYMAN: Yes. Okay. All right.

15 Q. What bank was that, Ms. Ruffley?

16 A. I beg your pardon?

17 Q. What bank did you work for that paid for your

18 education?

19 A. Community Bank headquartered in Pasadena,

20 California.

21 Q. And how long did you stay with the bank?

22 A. Nine years.

23 Q. Who was your immediate supervisor at that

24 bank?

25 A. Richard M. Acu. A-c-u-n-a, with a tilde

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lover the "n."

2 Q. Is he still there?

3 A. No.

4 Q. And what, if anything, did you do after you

5 left the bank professionally?

6 A. I went to work for Judicial Watch.

7 Q. What was your position at the bank?

8 A. First it was executive secretary, and then

9 legal secretary.

10 Q. What was your duties and responsibilities as

11 legal secretary?

12 A. I helped to write business contracts between

13 the bank and the customers; I did filing for my boss;

14 maintained relationships between

15 Q. Who was your boss?

16 A. Richard M. Acu.

17 Q. Is he still with the bank?

18 A. No.

19 Q. Where is he located now?

20 A. I'm -- I'm not sure.

21 Q. Have you had any contact with him since he

22 left the bank?

23 A. Yes.

24 Q. When was that?

25 A. The last time was about two years ago.

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1 Q. And what were the circumstances of that

2 contact?

3 A. He was going to be homeless and wanted to know

4 if he could come and live with me and my husband.

5 Q. Do you know someone by the name of Marian

6 Hurley?

7 A. Yes. She's dead.

8 Q. When did she die?

9 A. September 19th of 2009.

10 Q. Was Marian Hurley the person who introduced

11 you to me?

12 A. She introduced -- yes.


14 introduction?

15 A. Mike Pendleton, the director of the San Marino

16 branch of Judicial Watch, was looking for a secretary,

17 and Marian called Mike after he had been there for a

18 month and said, "I know just the person who will be

19 perfect for you. She can write, she can -- has

20 stamina, and she can work all night, if need be."

21 Q. Michael Pendleton was looking for a legal

22 secretary. Correct?

23 A. He was looking for someone to run his office.

24 Q. The office administrator?

25 A. Basically, office administrator.

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Coalition of Court Reporters of Los Angeles 205 South Broadway, Suite 200, Los Angeles, CA 90012 1213.471.2966 1 www.ccrola.com


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1 Q. I didn't hear you. I'm sorry.

2 A. Basically office administrator.

3 Q. Okay. But he also was looking for someone who

4 had legal background. Correct?

5 A. I don't remember that.

6 Q. You do have legal background, as you were a

7 legal secretary for Mr. Acu. Correct?

8 A. Yes.

9 The only reason I was a legal secretary is

10 they had enough executive secretaries, and they were

11 looking to get rid of one of the executive secretaries

12 so they changed my title.

13 Q. Michael Pendleton subsequently left Judicial

14 Watch. Correct?

15 A. Correct.

16 Q. Did you hear my question?

17 A. Yes.

18 Q. Michael Pendleton subsequently left Judicial

19 Watch. Correct?

20 A. Yes.

21 Q. When did he leave Judicial Watch?

22 A. I don't remember exactly.

23 Q. Roughly speaking.

24 A. 2004.

25 Q. About the same time that I left Judicial

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1 Watch. Correct?

2 A. No, you left before.

3 Q. Well, I left in 2003, at the end of 2003.

4 You recollect that, don't you?

5 A. Yes. September 22nd of 2003.

6 Q. Right.

7 In fact, Mr. Pendleton was fired by Judicial

8 Watch because I had hired him. Correct?

9 A. No.

10 Q. When Mr. Pendleton left, you were the one who

11 was in the office most of the time. Correct?

12 A. Yes.

13 Q. I had hired someone by the name of Ernie

14 Norris.

15 You remember that --

16 A. Yes.

17 Q. -- correct?

18 Ms. Ruffley, do you hear my question?

19 A. Yes.

20 MR. KRESS: Her answer was: "Yes."

21 BY MR. KLAYMAN:

22 Q. I had hired someone by the name of Ernie

23 Norris. Correct?

24 A. Yes. And I responded "Yes."

25 Q. Okay. Well, the phone broke up, apparently.

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1 Ernie Norris at some point retired. Correct?

2 A. Not from Judicial Watch.

3 Q. Well, he started to spend most of his time in

4 Wyoming. Correct?

5 A. No.

6 Q. Where is he now?

7 A. In San Marino.

8 Q. How many times -- let's go back a little bit.

9 From -- during 2013, how frequently was

10 Mr. Norris in the office?

11 A. About six months.

12 Q. How many days per week, if any?

13 A. Three.

14 Q. I didn't hear your response.

15 A. Three.

16 Q. Three days?

17 A. Yes.

18 Q. But he wasn't there every week, was he?

19 A. He wasn't there when he was in Wyoming.

20 Q. And he was in Wyoming quite a bit, was he

21 not?

22 A. Half the year.

23 Q. Mr. Norris is not an office administrator, is

24 he?

25 A. No.

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1 Q. Doesn't manage the office, does he?

2 A. No.

3 Q. When did you first -- do you know someone by

4 the name of Orly Taitz?

5 A. Yes.

6 Q. When did you first come to know of her?

7 A. When she was running for Secretary of State of

8 California.

9 Q. And when was that?

10 A. 2008, 2010. I don't recollect exactly.

11 Q. What were the circumstances of your coming to

12 know her?

13 A. I went to a meeting where she was talking

14 about her qualifications for being Secretary of State,

15 and that's when I met her.

16 Q. And at that time did you have discussion with

17 her?

18 A. Just briefly. Just introducing ourselves.

19 That's it.

20 Q. And what was that date again, Ms. Ruffley?

21 A. It was either 2008 or 2010. It was at the

22 Green Hotel in Pasadena, California.

23 Q. Did you offer to assist her in her campaign to

24 become secretary?

25 A. No.

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1 Q. Did there come a point in time when you had

2 further contact with Ms. Taitz?

3 A. Maybe -- I think the only time -- other time

4 I had contact with her was in -- when I had gone to a

5 meeting of the California Coalition for Immigration

6 Reform where she was running as a potential candidate

7 to run against Barbara Boxer's seat as the senator

8 from California.


10 A. February 22nd of 2012. And there was another

11 candidate--

12 Q. Did you

13 A. Excuse me?

14 Q. Did you speak with Ms. Taitz at that event?

15 MR. KRESS: I think she was -- she didn't quite

16 finish her last answer.

17 THE WITNESS: I was going to say that the other

18 candidate who was speaking that night was Robert

19 Lauten, L-a-u-t-e-n. And the person who

20 videographed -- took the videotape of that gave me a

21 DVD of the presentation.

22 BY MR. KLAYMAN :

23 Q. Did you have a conversation with Ms. Taitz

24 that day?

25 A. Yes.

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1 Q. And what was discussed?

2 A. I don't exactly remember what we were talking

3 about, but

4 Q. But generally.

5 A. "How are you doing?" "How is things?"

6 Q. At the point that you first met Ms. Taitz at

7 that meeting, you had followed her activities, had you

8 not?

9 A. No.

10 Q. You tracked her -- you followed her on the

11 website, on the Internet?

12 A. Never.

l3 Q. You are aware that she has a Internet site

14 called "The World's Leading Obama Eligibility Challenge

15 Web Site"?

16 A. If that's what its name is. I don't remember.

17 Q. And you, from time to time, look at that

18 website, do you not?

19 A. No.

20 Q. You do not believe that President Obama is

21 eligible to be president, do you?

22 A. I don't believe he's eligible.

23 Q. After that second encounter with Ms. Taitz

24 you've had further encounters with you, have you not?

25 A. Once.

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2 A. I think it was the -- in November of 2012.

3 Q. And what happened then?

4 A. I had invited her to speak at UROC, United

5 Republicans of California, and she came.

6 Q. And why did you invite her to speak there?

7 A. Because of her -- I thought it was the

8 authority on Obama's eligibility.

9 Q. Did she ultimately come and speak?

10 A. Yes.

11 Q. Did she speak?

12 A. Yes.

13 Q. And how long was her speech, approximately?

14 A. Oh, half an hour, 45 minutes.

15 Q. You invited Ms. Taitz because you have a high

16 regard for her. Correct?

17 A. Yes.

18 Q. You have never known her to lie, have you?

19 A. No.

20 Q. At that event, did you offer to help her in

21 any way or at any time after that event in her

22 endeavors with regard to eligibility?

23 A. We passed the hat for her, and that was it.

24 Q. Did you offer to help her in any of her

25 activities?

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1 A. No.

2 Q. You have helped her, though, in her

3 activities, have you not?

4 A. I beg your -- would you please repeat the

5 question?

6 Q. You have helped her in her activities, have

7 you not?

8 A. No, I have not helped her in her activities.

9 Q. Did there come a time after November 2012 when

10 you encountered Ms. Taitz?

11 A. I'm sorry. Would you repeat that again?

12 Q. Did there come a time after November 2012 when

13 you had contact with Ms. Taitz?

14 A. No.

15 Q. But you did have contact with her in February

16 2013, did you not?

17 A. Yes.


19 contact?

20 A. I was there with some Judicial Watch

21 materials, which I've often taken down to the CCIR

22 meetings, the regularly-scheduled ones, which this one

23 was, and -- excuse me -- I was down there

24 Q. What materials did you take?

25 MR. KRESS: 1--

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1 THE WITNESS: I can't hear you.

2 MR. KRESS: If I could just --

3 BY MR. KLAYMAN:

4 Q. What materials of Judicial Watch did you take

5 to that meeting?

6 A. Oh, probably copies of the verdict, several

7 issues of them. And I think we had some Judicial Watch

8 note bags, or something like that. But I -- or

9 calendars. We had some leftover calendars, and so I

10 took them down there to share with the -- the people

11 at CCIR.

12 MR. KRESS: Larry, if I could interject.

13 I believe the date that's been stated was

14 actually incorrect, and I don't want there to be a

15 confusion in the record.

16 There was a mention of February of 2013. I

17 believe from all the records the meeting was February

18 of 2012.

19 MR. KLAYMAN: Oh, thank you. Then I misspoke.

20 MR. KRESS: I think it was actually Ms. Ruff-

21 well, I'm not sure who misspoke. But I believe --

22 just so the record's clear, I think everyone's talking

23 about February of 2012.

24 BY MR. KLAYMAN:

25 Q. So the meeting that dealt with eligibility --

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1 you had a meeting in November of 2012 and then before

2 that February of 2012 where Ms. Taitz was in

3 attendance, Ms. Ruffley?

4 MR. KRESS: I object to the form.

5 But you can answer if you --

6 THE WITNESS: I've -- she appeared at -- in

7 November at the UROC Convention in 2012. And prior

8 to that, the last time that I had seen her before then

9 was when she was at the CCIR meeting in February 22nd

10 of 2012. And I have not --

11 BY MR. KLAYMAN :

12 Q. At that meeting Ms. Taitz was advocating for

13 her candidacy for the U.S. Senate, was she not?

14 A. Yes.

15 Q. And did she also discuss eligibility issues

16 at that time?

17 A. I don't remember.

18 Q. You offered to help her in her senate bid,

19 did you not?

20 A. I did not.

21 Q. Did you help her in her run for the U.S.

22 Senate in any way as a volunteer

23 A. No.

24 Q. -- personally?

25 A. No.

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1 Q. You were at that -- the CCIR meeting where

2 she advocated her senate candidacy as a representative

3 of Judicial Watch, were you not?

4 A. Who are you talking about, Orly Taitz being a

5 representative of Judicial Watch or me?

6 Q. I'm saying when you went to that meeting at

7 the CCIR with the women's club --

8 A. Yes.

9 Q. -- you were there as a representative of

10 Judicial Watch. I'm not asking you about Orly Taitz.

11 A. Okay. Yes.

12 Q. I'm going to show you what has been -- what

13 I'll ask the court reporter to mark as Plaintiff's

14 Exhibit 10.

15 A. The court reporter is not producing anything.

16 MR. KRESS: Your assistant is.

17 MR. KLAYMAN: Okay. Well - -

18 MR. KRESS: And if -- Larry, if you remember, we

19 did the exhibits consecutively, so there's already an

20 Exhibit 10. I think we are on --

21 MR. KLAYMAN: Okay.

22 MR. KRESS: -- we are on 29, if you don't mind

23 marking it 29.

24 MR. KLAYMAN: Fine. Then we will make it

25 Plaintiff's Exhibit 29.

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1 Naveed, would you please hand that to the

2 court reporter so Ms. Ruffley can have a copy.

3 MR. MAHBOOBIAN: (Complies.)

4

5 (Exhibit 29 was marked

6 for identification.)

7

8 MR. KRESS: She has the exhibit.

9 BY MR. KLAYMAN:

10 Q. Exhibit 29 is a Declaration Under Penalty of

11 Perjury of Constance S. Ruffley, is it not?

12 A. Yes.

13 Q. This is your affidavit that was submitted in

14 the lawsuit that you are here on today; correct?

15 A. Yes.


17 BY MR. KLAYMAN :

18 Q. Klayman v. Judicial Watch.

19 A. (No audible response. )

20 Q. Correct?

21 A. I'm sorry. Would you repeat the question?

22 Q. This is an affidavit which was submitted on

23 your behalf in the lawsuit that you are appearing on

24 today, Klayman vs. Judicial Watch. Correct?


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1 But you can answer.

2 THE WITNESS: It says -- not an affidavit, it says

3 "Declaration of -- under Penalty of Perjury."

4 MR. KLAYMAN: Okay. Let's call it a declaration.

5 Q. Correct?

6 A. Yes.

7 Q. You signed this declaration under oath.

8 Correct?

9 A. Yes.

10 Q. Do you know what it means, "under oath"?


12 Q. Do you know what being under oath means?

13 A. Right. To tell the truth, the whole truth,

14 and nothing but the truth, so help me God.

15 Q. Thank you.

16 All right. Turn your attention to Paragraph

17 3.

18 Well, take a look at Exhibit 29. That is the

19 declaration which was submitted. Right? That's--

20 A. Yes.

21 Q. -- that's accurate?

22 Okay. Turn to Paragraph 5.

23 A. (Witness complies.) All right.

24 Q. Where it states, "It is my understanding that

25 Larry Klayman has sued me, Judicial Watch, Inc., and

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1 other Judicial Watch, Inc. employees alleging that we,

2 on or about February 22nd, 2012, negligently,

3 maliciously and/or willfully published and furthered

4 the publication of a false statement that Plaintiff

5 Klayman had been 'convicted' of a crime for not paying

6 a large amount of child support with regard to his

7 children, on the Internet and elsewhere within this

8 judicial district, Florida, and elsewhere throughout

9 the United States and the world," unquote.

10 Is that a true statement?

11 A. I object to the word "convicted" because I

12 can't remember whether I said "convicted" or, urn,

13 "indicted."

14 Q. In fact, you also told Orly Taitz, did you

15 not, whether or not you can remember using the word

16 "convicted" or "indicted," that this information that

17 you were providing to her should be given to Klayman's

18 donors. Correct?

19 A. What about Klayman's donors?

20 Q. You told Ms. Taitz, did you not, whether or

21 not you used the word "convicted" or "indicted," which

22 you say you can't remember --

23 A. Correct.

24 Q. -- the information about Klayman not paying

25 child support in Ohio should be given to donors.

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1 Correct?

2 A. No.

3 Q. All right. I'll turn your attention to what's

4 been marked as Exhibit 2.

5



8

9 BY MR. :Ea.AYMAN:

10 Q. This is the eligibility website of Orly Taitz,

11 a reprint, is it not?

12 A. I'm being handed this by your assistant,

13 Naveed.

14 Q. All right. Take a look at it. Take your

15 time.

16 The question is: This is a reprint of what

17 appeared on Orly Taitz's website on February 23rd,

18 that website called "World's Leading Obama Eligibility

19 Challenge Web Site." Correct?

20 A. That's what it says.

21 MR. KRESS: Okay. Just - - the court reporter is

22 looking confused.

23 We actually have -- we have exhibits - -

24 MR. :Ea.AYMAN: I don't care whether the court

25 reporter is confused or not.

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1 MR. KRESS: Well, I --

2 MR. KLAYMAN: Please don't put colloquy in the

3 record now.

4 MR. KRESS: No, no. No . She's --

5 MR. KLAYMAN: Just let me get an answer, and let

6 me move on.

7 MR. KRESS: No, Larry, I'm just trying to clarify

8 something. Your -- because your office is marking this

9 as Exhibit 30. I just want to make sure everyone --

10 MR. KLAYMAN: Oh, no. It's--

11 MR. KRESS: It's already marked as Exhibit 2.

12 MR. KLAYMAN: It's Exhibit 2. Please don't do

13 that.

14 MR. KRESS: Okay. That's -- that's all right.

15 That's it.

16 MR. KLAYMAN: That's all right.

17 MR. KRESS: We don't know what the question is.

18 MR. KLAYMAN: Third paragraph.

19 Q. "Ms. Ruffley actually advised me that Larry

20 Klayman is not licensed in California. She told me

21 that he no longer works with the Judicial Watch and

22 that donors should know about litigation in Ohio, where

23 he was convicted just recently of not paying large

24 amount in child support. She provided a lot of other

25 information. I will publish only what is in the public

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1 record. I'm not publishing anything that is not in the

2 public record."

3 That's an accurate statement of what you told

4 Ms. Taitz. Correct?

5 A. I never said any -- no, it's not correct.

6 Because where it says that "donors should know about

7 litigation in Ohio."

8 Q. It says, "She provided a lot of other

9 information. II

10 What other information did you provide to

11 Ms. Taitz?

12 A. The only other information that I provided is

13 that you are not licensed in the State of California.

14 I told her about the issue of the -- the child support.

15 And also there was the issue -- excuse me -- of a

16 lawsuit that was down in Florida.

17 Q. Was that an eligibility lawsuit for Michael

18 Dolz?


20 Q. But it was an eligibility lawsuit. Correct?


22 Q. Well, what was the subject matter of the

23 lawsuit?

24 A. Basically, that you had taken money for a

25 lawsuit and not performed.

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1 Q. You offered information to Ms. Taitz about

2 this, did you not?

3 MR. KRESS: I'm going to object to the form.

4 You can answer.

5 THE WITNESS: I told Ms. Taitz only what could be

6 found on the Internet. I told her nothing else.

7 BY MR. KLAYMAN:

8 Q. You told her what could be found in the public

9 record. Correct?

10 A. Correct.

11 Q. Did you say "Yes"?

12 A. Yes.

13 Q. And the public record would include court

14 files. Correct?

15 A. Well, as I found it on the Internet, it was

16 not in the court files. It was public information.

17 And she had the ability to look up those -- those

18 things on the Internet herself.

19 Q. And you gave her that information you

20 volunteered that information. She didn't ask you for

21 it. Correct?

22 A. Yes.

23 Q. And you did that because you were trying to

24 help Ms. Taitz?

25 A. No.

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1 Q. You did that because you were trying to hurt

2 me, Larry Klayman. Correct?

3 A. No.

4 Q. So you just gave the information because it

5 came to your head in some kind of epiphany?

6 MR. KRESS: Objection to the form.

7 You can answer.

8 BY MR. KLAYMAN:

9 Q. Is that the reason?

10 A. No.

11 Q. You did it because you thought it would curry

12 favor with the directors of Judicial Watch, Mr. Fitton

13 and Mr. Orfanedes --

14 A. Absolutely.

15 Q. -- to follow which had been adverse to me.

16 Correct?

17 A. No.

18 Q. Then why did you do it?

19 A. Because she asked me.

20 Q. You just told me you volunteered the

21 information. Which is right, she asked you or you

22 volunteered it?


24 You can answer.

25 THE WITNESS: Would you mind repeating the

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1 question again? Whether I volunteered it, or --

2 BY f'.1R. KLAYMAN:

3 Q. You previously testified in this deposition

4 under oath that you volunteered the information in

5 this case.

6 A. Yes.

7 Q. That's correct, is it not?

8 A. That's because she asked me.

9 Q. What did she ask you?

10 A. She asked me if you were still with Judicial

11 Watch. And I told her no.

12 Q. But she didn't ask you about my children, and

13 she didn't ask you about whether I was licensed in

14 California, did she?

15 A. I did not provide her any information that

16 was not available on the Internet.

17 Q. But the question --

18 A. This was a completely private conversation

19 between the two of us, and it was not to be -- I did

20 not have any expectation of her putting it out there

21 on the web.

22 f'.1R. KLAYMAN: Non responsive. Move to strike.

23 Q. In fact, she didn't ask you about my children,

24 and she didn't ask you about my being licensed in

25 California, did she?

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1 A. No.

2 Q. And, in fact, I had already left Judicial

3 in 2012, in February 2012, I had been gone from

4 Judicial Watch eight to nine years. Correct?

5 A. Could have been.

6 Q. So you didn't have any -- and you didn't have

7 any contact with me in those years, did you?

8 A. No.

9 Q. So you would have no way of knowing whether I

10 had become licensed in California or not when you said

11 that to Ms. Taitz. Correct?

12 A. I would know whether you were not licensed

13 because I -- anyone can go to the State Bar and look up

14 and plug in a name and see if that person is licensed

15 In California or not.

16 Q. But you hadn't done that before telling

17 Ms. Taitz that I was not licensed in California.

18 Correct?

19 A. Wrong. Because I did look it up, and you were

20 not licensed.

21 Q. When did you look it up? Afterwards? After

22 you had the conversation with Taitz?

23 A. Prior to that.

24 Q. Why did you bother to look it up?

25 A. Because I wanted to see if you had become

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1 licensed at some point.

2 Q. And why was that?

3 A. Just because I wanted to know.

4 Q. Because you didn't want me representing anyone

5 with regard to eligibility, did you?

6 A. No.

7 Q. Because you wanted to try to hurt me.

8 Correct?

9 A. No.

10 Q. Then what business was it of yours?


12 You can answer.

l3 THE WITNESS: Would you mind restating the

14 question properly?

15 BY MR. KLAYMAN:

16 Q. What business was it of yours whether I was

17 licensed in California or not?


19 You can answer.

20 THE WITNESS: I f I want to look up anyone, I

21 can -- there's nothing that prohibits me from looking

22 up someone's name in the State Bar.

23 BY MR. KLAYMAN :

24 Q. Then I'm asking you why you did it, then.

25 What caused you to do it?

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1 MR. KRESS: Objection to the form. Asked and

2 answered.

3 You can answer it one more time.

4 THE WITNESS: Because I had looked it up several

5 years before, maybe once a year, something like that,

6 and this was just something that happened.

7 BY MR. KLAYMAN:

8 Q. Why bother looking it up if I'm not with

9 Judicial Watch anymore?

10 A. Why not?

11 Q. What caused you to look up any situation with

12 regard to my kids?

l3 MR. KRESS: I object to the form.

14 You can answer.

15 THE WITNESS: It was just one of the things that

16 happened to pop up.

17 BY MR. KLAYMAN :

18 Q. In fact, Ms. Taitz [sic], you were aware that

19 I had been in litigation with Judicial Watch and its

20 directors before you met with Ms. Taitz on

21 February 22nd, 2012. Correct?

22 A. You addressed me as Ms. Taitz.

23 Q. Ms. Ruffley.

24 A. Restate the question, please.

25 Q. In fact, you knew at the time that you met

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1 with Ms. Taitz on February 22nd, 2012 that I, Larry

2 Klayman, had been in various litigations with Judicial

3 Watch and its directors. Correct?

4 A. Yes.

5 Q. And you knew that we were adverse to each

6 other. Correct?


8 You can answer.

9 THE WITNESS: Yes.

10 BY MR. KLAYMAN:

11 Q. And that was the basis for your looking up

12 whether I was licensed in California and in order to

13 be able to get information about my children. Correct?


15 You can answer.

16 THE WITNESS: No.

17 BY MR. KLAYMAN:

18 Q. The Judicial Watch directors asked you to

19 track me, did they not?

20 A. No.

21 Q. You conveyed the information about my not

22 being licensed in California and the information that

23 you claimed pertains to my children to the directors

24 of Judicial Watch, though, didn't you?

25 A. No.

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1 Q. You never talked to them about my being

2 licensed in California?

3 A. No.

4 Q. Or my children?

5 A. No.

6 Q. Why is it, then, that you gave this

7 information to Ms. Taitz?

8 MR. KRESS: I obj ect to the form. Asked and

9 answered.

10 You can answer it one more time.

11 THE WITNESS: Well, I had an expectation of

12 privacy with Ms. Taitz. And, in fact, she said that

13 she was going to call me the next morning, and I've

14 never heard from her since. Well, except for when I

15 invited her to speak at UROe.

16 BY JVIR. KLAYMAN:

17 Q. And why did you have an expectation of

18 privacy?

19 A. Because the conversation was between she and

20 myself, and there weren't any other people around.

21 Q. But that doesn't answer the question.

22 Why did you give her the information, apart

23 from expectations of privacy?

24 MR. KRESS: I object to the form. Asked and

25 answered.

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1 You can answer.

2 THE WITNESS: I still just had the expectation of

3 privacy that it would be just information between

4 herself and myself. I had no idea that she would have

5 ever put that up there on her website.

6 BY MR. KLAYMAN:

7 Q. Why did you -- why did you give her the

8 information?

9 A. I --

10 Q. I'm not talking about expectations of privacy.

11 Why

12 A. So that she could --

13 Q. did you give her the information?

14 A. So that she could look it up for herself.

15 Q. And why did you want her to look it up for

16 herself?

17 A. To make sure that what I said was correct.

18 Q. Ms. Ruffley, we will stay here for hours.

19 I will get an answer to this question. So you can

20 answer it now. Do you want to go two hours more on it?

21 I will ask it for two hours.

22 MR. KRESS: What question is before her?

23 BY MR. KLAYMAN:

24 Q. Why did you give her the information?

25 MR. KRESS: She just answered that question.

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1 THE WITNESS: So that she -- I gave her the

2 information and told her where she could find it on --

3 excuse me. I didn't tell her where she could find it

4 on the web. But if she did a Google search, she would

5 have been able to find it.

6 BY MR. KLAYMAN:


8 MR. KRESS: Maybe you can ask your question

9 differently. Because--

10 MR. KLAYMAN: No, she understands what I said.

11 She's highly educated. She has a college degree. She

12 was a legal secretary. She understands what I said.

13 I'm asking it the way I want to answer it -- ask it.


15 MR. KRESS: Objection.

16 You can answer.

17 THE WITNESS: So that she could look it up for

18 herself and make sure that the information was correct.

19 I believe in giving correct information, not lies or

20 innuendos or anything else.

21 BY MR. KLAYMAN:


23 A. I just told you --

24 MR. KRESS: We are going to have to

25 She has answered the question.

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1 IVlR. KLAYMAN: Oh, you didn't give me the

2 information.

3 Q. So she could look it up. What was the

4 underlying purpose of giving her the information so she

5 could look it up on the Internet?

6 A. So that she would have the correct

7 information.

8 Q. For what reason?

9 IVlR. KRESS: I don't know how many times she can

10 tell you.

11 BY IVlR. KLAYMAN:

12 Q. For what reason?

13 IVlR. KRESS: If you have any different answer, you

14 can give it to him. But--

15 THE WITNESS: I don't have a different answer.

16 You can say that all day long if you want to

17 say "And for what reason," and it's not going to help.

18 BY IVlR. KLAYMAN :

19 Q. You do not want to answer the question; do

20 you, Ms. Ruffley?


22 Q. You do not want to answer this question, do

23 you?

24 A. I believe I've answered the question three or

25 four times already.

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1 Q. I'm asking you -- the underlying question

2 is

3 A. You don't -- you are not asking me an

4 underlying question, you are asking me about the same

5 thing--

6 Q. I'm asking information about anything that she

7 could look up on the Internet, why did you do it?

8 I'm not asking about her looking it up on the

9 Internet

10 MR. KRESS: This is getting --

11 BY MR. KLAYMAN:

12 Q. -- I'm asking about what was the reason that

13 you gave her that information; what was in your mind

14 why you gave it to her.

15 MR. KRESS: Is that a different question, or do

16 you have

17 THE WITNESS: Is that a different question?

18 MR. KLAYMAN: No, it's the same question. But

19 you can answer it.

20 MR. KRESS: This is getting close to the point of

21 just being harassing. She's been answering the

22 question. You don't like the answer, but that's not

23 her problem.

24 MR. KLAYMAN: That's your problem, not mine.

25 MR. KRESS: Well, we will see about that.

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1 BY MR. KLAYMAN:

2 Q. Answer the question, Ms. Ruffley.

3 MR. KRESS: Are you asking her - - you have asked

4 her if she was intending to harm you. She said no.

5 MR. KLAYMAN: I don't want the testimony. That's

6 inappropriate.

7 MR. KRESS: Well, you --

8 MR. KLAYMAN: I'll phrase it --

9 Will you, Madam Court Reporter, please read my

10 last question back.

11 Thank you.

12

13 (Whereupon, the record was read

14 by the reporter.)

15

16 MR. KLAYMAN: Please answer that.

17 THE WITNESS: Because she asked me about you.

18 BY MR. KLAYMAN :

19 Q. What did she ask you?

20 A. She asked me what I knew about you.

21 Q. Did she say why she asked me [sic] what you

22 knew about me?

23 A. No.

24 Q. The time that you gave Ms. Ruffley that

25 information, you knew that Orly Taitz had an

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1 eligibility website. Correct?

2 A. No.

3 Q. You were very knowledgeable about eligibility

4 issues, though, were you not?

5 A. Probably more than the average person.

6 Q. You are telling me that you would look up

7 whether I was a California lawyer and about my children

8 on your own, but you never looked at Orly Taitz's

9 eligibility website

10 A. No.

11 Q. -- up to the point --

12 MR. KRESS: Objection to form.

13 BY MR. KLAYMAN:

14 Q. of November 22nd, 2012? Is that what you

15 are saying?


17 You can answer it.

18 THE WITNESS: Would you restate the question,

19 please?

20 MR. KLAYMAN: Please read it back.

21

22 (Whereupon, the record was read

23 by the reporter.)

24


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2 THE WITNESS: No, I never looked up her website.

3 BY MR. KLAYMAN:

4 Q. But you knew she had a website?

5 A. I don't believe I did.

6 Q. Based on your experience in public interest

7 activities and politics, you are aware that nearly all

8 people have websites these days. Correct?

9 A. Yes. A lot of people do. I don't.

10 Q. People that are running for the U.S. Senate

11 have websites. Correct?

12 A. I'm not sure whether all people do or not.

13 I don't know.

14 Q. Well, any credible candidate would have one.

15 Correct?


17 You can answer, if you know.

18 THE WITNESS: I don't know.

19 BY MR. KLAYMAN:

20 Q. You are aware that Ms. Taitz is an activist,

21 a conservative activist, in addition to having run for

22 the U.S. Senate. Correct?

23 A. Yes.

24 Q. Conservative activists generally have websites

25 so they can communicate with the public. Correct?

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1 A. I don't know.

2 Q. You didn't tell Ms. Taitz not to publish the

3 information that you gave her on the Internet, did you?

4 A. She said she would call me the next day.

5 Q. You did not tell Ms. Taitz not to publish

6 the information you gave her about me on the Internet,

7 did you?

8 A. No, I did not. Because I had -- I had

9 anticipated that the conversation was just between

10 the two of us, and that was it. And that if she wanted

11 to do any further research, she could do that on her

12 own.

13 And I object to your inserting your children

14 into this. I -- the only reason I mentioned that was

15 because it happened to pop up on one of the searches

16 that I did. And that was about Cuyahoga County,

17 et cetera. And that's where your children came in.

18 But I did not deliver --

19 Q. Before your deposition today, this morning,

20 you met with the lawyer for Judicial Watch in this

21 lawsuit and Mr. Orfanedes its director, one of its

22 directors. Correct?

23 A. Yes.

24 Q. And you discussed your testimony today, did

25 you not?

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2 THE WITNESS: No.

3 BY MR. KLAYMAN:

4 Q. I didn't hear your response.

5 A. No.

6 Q. You didn't discuss anything about your

7 testimony today?

8 MR. KRESS: I'm going to object to the extent you

9 are getting into or very close to the attorney-client

10 privilege.

11 MR. KLAYMAN: No, I'm - you know, Doug, I'm not

12 getting into that. I'm just identifying whether there

13 was a discussion. I'm not asking for the content.

14 MR. KRESS: Okay. If you want to know whether

15 there'S a discussion, you can -- you can inquire.

16 MR. KLAYMAN: Okay.

17 Q. You had a discussion about your testimony

18 today, did you not, earlier before this deposition

19 began with Mr. Kress and Mr. Orfanedes?

20 A. Maybe two minutes.

21 Q. Was your response "two minutes"?

22 A. Yes.

23 Q. Okay. But you had discussions before today

24 with one or both of them. Correct?

25 A. Yes.

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1 Q. And when did you have discussions with him

2 about your testimony?

3 A. Again --

4 MR. KRESS: You can answer, but don't give him

5 any of the substance.

6 THE WITNESS: Yesterday.

7 BY MR. KLAYMAN:

8 Q. How long was your discussion?

9 MR. KRESS: You can answer that.

10 THE WITNESS: Approximately two hours.

11 BY MR. KLAYMAN :

12 Q. The affidavit which has been marked as

13 Exhibit 29, you didn't actually draft it, did you?

14 A. Parts of it, yes.

15 Q. Who presented to you the first draft of it?

16 MR. KRESS: I object

17 THE WITNESS: I don't remember.

18 MR. KRESS: And I will just object along this line

19 to be careful not to reveal confidential communications

20 with any lawyers.

21 BY MR. KLAYMAN:

22 Q. Was it Mr. Orfanedes who sent it to you?


24 Q. But you do have a computer at Judicial Watch?

25 A. Yes.

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1 Q. And have you deleted any communications

2 concerning this lawsuit from that computer?

3 A. No.

4 Q. Did you check your computer today about

5 A. NO I because I didn't go in the office.

6 Q. the various documents that were relevant to

7 this case?

8 A. No.

9 Q. Have you ever checked your computer In that

10 regard?

11 A. No.

12 Q. Have you ever checked your computer in that

13 regard?

14 A. No.

15 Q. I'm going to ask you to check your computer in

16 that regard I Ms. Ruffley. Because there were documents

17 that were requested by me from Judicial Watch I and

18 obviously you are at the eye of the hurricane here.

19 MR. KRESS: Well I when you say II in that regard l II

20 that's a little broad and open-ended.

21 I will -- SOl as you know I we've objected to

22 numerous document requests.

23 MR. KLAYMAN: No I I understand. But I obvious 1 Y I

24 she should have done a search for the documents I so I'm

25 asking that a search be conducted.

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1 THE WITNESS: Well, the search was not conducted

2 because there weren't any documents related to this.

3 MR. KLAYMAN: Well, you just testified

4 Ms. Ruffley, you are under oath. Okay? So let me ask

5 the questions.

6 THE WITNESS: I remember that I'm under oath.

7 MR. KLAYMAN: I'm not asking for gratuitous PYA

8 responses when I don't have a question pending.

9 MR. KRESS: Please be polite to the witness.

10 MR. KLAYMAN: Excuse me?

11 MR. KRESS: I -- I -- I don't think we need to

12 engage in this.

l3 MR. KLAYMAN: Well, I used an acronym. It's not

14 appropriate for her to inject stuff before questions

15 are made.

16 MR. KRESS: Please move on.

17 BY MR. KLAYMAN :

18 Q. You just testified that you hadn't checked

19 your computer. So I'm asking you politely and

20 courteously to check your computer.

21 MR. KRESS: I will confer with Ms. Ruffley, and

22 we will be sure to do that.

23 BY MR. KLAYMAN:

24 Q. Let's turn to Paragraph 7.

25 A. (Witness complies.)

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1 MR. KRESS: This is of the declaration. Correct?

2 MR. KLAYMAN: The affidavit of the 29th.

3 THE WITNESS: Declaration.

4 MR. KLAYMAN: Declaration.

5 Q. "On or about February 22, 2012, I attended the

6 monthly meeting of the California Coalition for

7 Immigration Reform in Garden Grove, California.

8 Orly Taitz was one of the speakers at the meeting.

9 I am familiar with Orly Taitz. Ms. Taitz is a

10 California resident who was, at the time, running on

11 the primary ballot for one of the California seats on

12 the United States Senate.

13 "After the meeting, I was seated at an

14 information table for Judicial Watch, displaying

15 various forms of Judicial Watch literature. Orly Taitz

16 approached me and we discussed a number of issues.

17 We eventually discussed Larry Klayman. The only

18 information that I conveyed to Ms. Taitz about Larry

19 Klayman was information that I had learned from public

20 records, including information related to court

21 proceedings for failure to pay child support."

22 In reference to public records, you were not

23 talking about the Internet, were you?

24 A. Yes, I was talking about the Internet.

25 Q. You were talking about court records, were you

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1 not?


3 THE WITNESS: No.

4 BY MR. KLAYMAN:

5 Q. In fact, you had gone into court records in

6 Cleveland, Ohio with regard to my custody proceeding

7 with my children. Correct?

8 A. No.

9 Q. In fact, you have a tremendous curiosity about

10 me -- don't you, Ms. Ruffley -- at a minimum?

11 A. Morbidly.

12 Q. What do you mean by "morbidly"?

13 A. You are an interesting person. I just wanted

14 to keep abreast of what your dealings were.

15 Q. And that's morbid. Correct?



18 THE WITNESS: Well, I'm sorry. That was probably

19 an offhand word. But, uh, just a curiosity.

20 BY MR. KLAYMAN :

21 Q. You don't usually use offhand words, do you?

22 A. Yes.

23 Q. Paragraph 8, "My expectation was that Orly

24 Taitz would not restate my comments to any other person

25 or entity. II

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1 In fact, you didn't know one way or the other

2 whether Orly Taitz would restate your comments --

3 A. I had no --

4 Q. -- to anyone else or the public, did you?

5 A. I had no way of knowing whether she would.

6 And I never gave her permission to restate my comments

7 to any other person or entity.

8 Q. But you never told her not to. Correct?

9 A. I thought that that was understood.

10 Q. You are aware that Orly Taitz communicates

11 with the public on the Internet?

12 A. I do now.

13 Q. And you are aware that she communicates in

14 public by either giving speeches like she gave at the

15 Garden Grove Women's Club

16 A. She

17 Q. -- or that she gave earlier at UROC?

18 A. She gave her candidacy for U.S. Senator. And

19 Robert Lauten was there and another candidate who gave

20 his statements for running for Barbara Boxer's seat.

21 Q. So you are aware that Orly Taitz's activities

22 as a U.S. senator candidate requires her to communicate

23 with the public. Correct?

24 A. Well, if that's what you have to do to run,

25 yes.

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1 Q. Let's look at Paragraph 9. "The information

2 that I conveyed to Orly Taitz was gathered through my

3 own independent research. No one from Judicial Watch

4 advised me of this information or instructed me to

5 convey the information to Orly Taitz."

6 A. That's true.

7 Q. And your independent research entailed looking

8 in court records in Cleveland t Ohio about Larry Klayman

9 and his children. Correct?



12 THE WITNESS: No. There's no way that you can get

13 into the -- the court records in any court.

14 BY MR. KLAYMAN :

15 Q. Subsequent to your making these statements

16 that are the subject of this lawsuit to Ms. Taitz t

17 you have researched and learned that I was not

18 convicted of any crime for nonpayment of child support.

19 Correct?

20 A. Convicted t indicted. I don't know.

21 Q. I'm talking about convicted.

22 A. I don't know when I used the word "convicted"

23 or "indicted."

24 Q. I'm not even asking you what word you used at

25 this point. We have already been over that.

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1 You are aware today that I was never convicted

2 of any crime. Correct?

3 A. True. Yes, I am aware that you --

4 Q. How did you learn that?

5 A. Pardon?

6 Q. How did you learn that?

7 A. That you were not convicted of any crime?

8 Q. Correct.

9 A. It's on the Internet.

10 Q. Where on the Internet did you find that?


12 Q. You went into the court records of the

13 Cleveland family court and found out that I was not

14 convicted of any crime. Correct?

15 A. I went onto the Internet and found that.

16 It was not in the court records.

17 Q. You looked in the court records, though,

18 didn't you?

19 A. No.

20 Q. Did you make any effort before you made the

21 statement that I was convicted to determine

22 definitively whether I was convicted or not?


24 But you can answer it.

25 You can answer if you know the -- if you

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1 understand the question and you know the answer.

2 THE WITNESS: I don't know about any convictions.

3 BY MR. KLAYMAN :

4 Q. You have never known about any convictions,

5 have you?

6 A. No.

7 Q. Did you tell anyone at Judicial Watch after

8 you gave this information to Ms. Taitz that you had

9 talked to her about me?

10 A. No.

11 Q. You are aware that I ran for the U.S. Senate

12 in Florida?

13 A. Yes. That's why you left Judicial Watch.

14 Q. You are aware that I've been involved in

15 many lawsuits involving Fidel Castro for the CUban

16 community in Miami?

17 A. Somewhat, yes.

18 Q. You are aware that I traveled while at

19 Judicial Watch to Europe to lobby on behalf of

20 victims of Castro?

21 A. Yes.

22 Q. You are aware that I was involved while at

23 Judicial Watch with trying to help the Elian Gonzalez

24 family?

25 A. Sure. You brought Donato Dalrymple out, who

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1 was holding Elian Gonzalez when he was -- when Elian

2 was stripped from his arms.

3 Q. In fact, shortly after 9/11 occurred in 2001,

4 I took a trip to Belgium -- you remember, do you not

5 to have Fidel Castro and others indicted for crimes

6 against humanity?

7 A. Somewhat.

8 Q. And after that happened, we had a -- a

9 judicial international conference in Miami when I

10 returned from Belgium. Correct?

11 A. Yes. I was there.

12 Q. Right.

13 And you were aware that Miami is my home town.

14 Correct?

15 A. 11m not exactly aware of that.

16 Q. You are aware that I lived in Miami many

17 years?

18 A. Yes.

19 Q. You are aware that I began my legal career

20 there?

21 A. Yes.

22 Q. You are aware that the eligibility lawsuits

23 that I brought were in Florida?

24 A. Not really.

25 Q. You -- you had become aware of that, though,

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1 haven't you?

2 A. Not completely.

3 Q. I couldn't hear your response.

4 A. Not completely.

5 Q. But partially?

6 A. Partially.

7 Q. I was the founder of Judicial Watch, was I

8 not?


10 You can answer.

11 THE WITNESS: Yes.

12 BY MR. KLAYMAN :

13 Q. You have a high regard for me, don't you?

14 A. On a personal level, yes.

15 Q. And you're aware that I was always nice to

16 you, wasn't I?

17 A. Always.

18 Q. And I was nice to other people in the San

19 Marino office --

20 THE REPORTER: Pardon me. Repeat that.

21 BY MR. KLAYMAN:

22 Q. -- correct?

23 MR. KRESS: I think he said, "I was nice to other

24 people in the San Marino office."

25 THE WITNESS: Yes. Yes.

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1 BY MR. KLAYMAN:

2 Q. And that I would come out there frequently to

3 visit to make sure that the office was running in a

4 productive way?

5 A. That you would come out and visit when you had

6 other things to do. But I don't remember, you know,

7 coming out to make sure that it was being run properly.

8 I remember on a personal level when I was

9 going through the cancer it was the chemo and the

10 radiation back in September through May of 2002 that

11 you, as head of Judicial Watch -- that there was a

12 beautiful bouquet from the most expensive florist in

13 town. And it was gorgeous. And it said on the card,

14 "From your friends at Judicial Watch."

15 And two days later, I received a second

16 bouquet from the same expensive florist that said,

17 "From Larry Klayman and your friends at Judicial

18 Watch."

19 Q. I appreciate that, Ms. Ruffley. I wish you

20 well. I want you to know that.

21 A. Thank you. I'm still here.

22 Q. How is your health today? You don't have to

23 tell me, but I hope it's well.

24 A. It's well. Thank you.

25 Q. You don't have to answer that.

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1 A. I thought I did.

2 Q. Okay. All right.

3 Is it good?

4 A. Yes. Thank you.

5 Q. I hope so. Okay.

6 Are you aware that I asked after the

7 statements were published by Ms. Taitz, the ones that

8 we are here on today, that I asked Judicial Watch and

9 its lawyers to correct those statements?

10 A. Did -- are you asking whether Mr. Kress and

11 Mr. Orfanedes asked me to correct any statements?

12 Q. No.

13 Are you aware that shortly after the

14 February 22nd, 2012 meeting

15 A. Right.

16 Q. -- with Ms. Taitz that I asked Judicial Watch

17 to correct those statements?

18 A. I'm not aware of that.

19 Q. Did you have any contact with anyone by the

20 name of Richard Driscoll after February 22nd, 2012?

21 A. That name is completely unfamiliar to me.

22 Q. Did anyone from Judicial Watch after

23 February 22nd, 2012, before this litigation was filed

24 that you are here on today, ask you whether you had

25 made those statements to Ms. Taitz?

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1 A. No.

2 Q. Was the answer "No"?

3 A. Correct.

4 Q. Have you ever had discussions with Mr. Fitton

5 about the statements that you are here on today that

6 were published by Ms. Taitz on her website?

7 A. No. The only communications I had with

8 Mr. Fitton are a beautiful Christmas card every

9 Christmas. And that's it.

10 Q. Otherwise, you don't talk to him at all?

11 A. Nuh-uh. Right. I do not speak with him at

12 all.

13 Q. And you have not spoken with him since I left

14 Judicial Watch?

15 A. That's not entirely correct.

16 I have as a daughter of the American

17 Revolution, I have gone back to Continental Congress in

18 Washington, D.C. where I was a part of the -- where I

19 was Vice Chairman of the National Resolutions

20 Committee. And, as such, I would have a little time

21 off, and so I would go over to Judicial Watch

22 headquarters and visit.

23 So I would spend maybe five minutes with each

24 person such as, you know, Mr. Orfanedes and Mr. Fitton

25 and Mr. Farrell if they were in the offices. And

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1 Mr. -- but it was just chitchat. I don't -- and that's

2 it. Your name never came up.

3 Q. Did you ever talk to Mr. Orfanedes about the

4 statements that Ms. Taitz published on her eligibility

5 website concerning me?

6 A. No.

7 Q. Did you ever talk to Mr. Farrell about them?

8 A. No.

9 Q. Did you ever talk to anyone at Judicial Watch

10 about the statements that Ms. Taitz published on the

11 website about me?

12 A. No.

13 Q. Did you?

14 A. No, I do not -- did not, have not.

15 Q. If I was not convicted of a crime, are you

16 sorry that this wound up on Ms. Taitz's website?


18 MR. KLAYMAN: I'll withdraw the question.

19 THE WITNESS: Did you say you wi thdrew the

20 question?

21 MR. KRESS: Right.

22 MR. KLAYMAN: I'll withdraw this question.

23 THE WITNESS: Thank you.

24 BY MR. KLAYMAN:

25 Q. The -- I'll turn your attention to Exhibit 9.

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1 MR. KLAYMAN: If my colleague would put that in

2 front of you or your attorney.

3 THE WITNESS: It's still here.

4 MR. KRESS: No, that's a different one.

5 THE WITNESS: Oh. I'm sorry.

6 MR. KRESS: This one (indicating).

7



10

11 THE WITNESS: Okay. I'm looking at something that

12 says Driscoll Seltzer dated March 5th of 2012. It's

13 addressed to you --

14 MR. KLAYMAN: Right.

15 Q. I want to turn your attention to a document

16 that is labeled "Judicial Watch, Bates No. 000508."


18 Q. Do you see that?

19 A. Okay.

20 Q. That's an e-mail that you sent to Tom Fitton,

21 Paul Orfanedes, and Chris Farrell --

22 A. Right.

23 Q. -- correct?

24 Okay. It says, "From my sister-in-law."

25 A. Right.

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1 Q. And then the subject is, "Judge orders

2 eligibility attorney to stay away."

3 Who is your sister-in-law?

4 A. Carolyn Kwan Sloan.

5 Q. It says, "Klayman is at it again!"

6 Exclamation point.

7 You meant that in a negative way?

8 A. I don't know. Because I don't know what this

9 thing is where it says, "Judge orders eligibility

10 attorney to stay away."

11 Q. Why did you write to the judicial directors,

12 "Klayman is at it again! II exclamation point?

13 A. I don't know. I don't remember.

14 Q. You were trying to curry favor with them,

15 were you not


17 BY MR. KLAYMAN:

18 Q. -- the Judicial Watch directors?

19 A. No.

20 Q. It says, "Read if you are interested. The

21 truly disturbing thing, however, is that the judge

22 DID," capital DID, "refer to a fictitious movie to make

23 his ruling!!" double exclamation point.

24 A. Right.


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1 A. Yes, I see it.

2 Q. You were disturbed that the judge had made

3 a -- a stupid ruling about something that was a

4 fictitious movie. Right?


6 You can answer.

7 THE WITNESS: Yeah. I mean, when a judge makes a

8 ridiculous ruling, then it affects everyone.

9 BY MR. KLAYMAN:

10 Q. But you would you would like Barack Obama

11 to be ruled ineligible by a court of law. Correct?

12 A. I'm sorry. What was that?

13 Q. You would like a court of law to make a ruling

14 that President Barack Hussein Obama isn't eligible to

15 be president.

16 MR. KRESS: I object to the form. And relevancy.

17 You can answer.

18 THE WITNESS: I'm sorry. 1--

19 BY MR. KLAYMAN:

20 Q. Correct?

21 A. I'm sorry, Larry.

22 Q. You would like -- you would like the Court to

23 make a ruling that Barack Obama is ineligible to be

24 president. Correct?


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1 You can answer.

2 THE WITNESS: It would be great.

3 BY MR. KLAYMAN :

4 Q. And you were aware at the time that you met

5 Ms. Taitz that she had several lawsuits trying to

6 declare Obama ineligible. Correct?

7 A. Correct.

8 Q. And you were very supportive of her efforts

9 to do that. Correct?

10 A. On a personal level.

11 Q. And you were supportive of her attempts to

12 raise money for those efforts. Correct?

13 A. I was aware of it.

14 Q. You weren't against her raising money for

15 those efforts, were you?

16 A. No.

17 Q. Were you?

18 A. No.

19 Q. So when you gave her the information about my

20 children and me and had given it to the donors, you

21 were trying to help Ms. Taitz. Correct?


23 THE WITNESS: This memo -- this e-mail was dated

24 January 7th of 2013, not 2012.

25 MR. KLAYMAN: I'm not talking about the date.

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1 Q. I'm saying at the time that you gave Ms. Taitz

2 the information

3 A. Right.

4 Q. about me and my children and suggested that

5 it would be given to donors, you were trying to help

6 Ms. Taitz. Correct?


8 THE WITNESS: Objection because I did not tell her

9 to give it to donors.

10 BY MR. KLAYMAN:

11 Q. But you don't remember what you said, do you?



14 THE WITNESS: I do remember what I said on a

15 limited basis.

16 BY MR. KLAYMAN :

17 Q. But you read Ms. Taitz's posting, did you not?

18 A. I didn't read her posting until months later.

19 Q. Having read it months later, did you ever tell

20 her to correct it?

21 A. No.

22 Q. You were aware that giving that information to

23 donors could hurt Larry Klayman. Correct?


25 THE WITNESS: I did not give it to her to hurt --

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1 to have her put it on a website or hurt you.

2 MR. KLAYMAN: Let's back up on this.

3 Q. Turn your attention to -- who is Price Sloan?

4 A. My brother who died last June.

5 Q. Who is it?

6 A. Price--

7 Q. Who is Price Sloan?

8 A. Price Newton -- well, there are two Price

9 Sloans. There's Price William Elmer Sloan, who lS my

10 father. And there's Price N. Newton Sloan, who is my

11 brother.

12 My brother died on

13 Q. On the e-mail that I just -- on the e-mail

14 that I just read to you, which is Judicial Watch

15 Document 508, it says Sloan Price Sloan. Which

16 Price Sloan is that?

17 A. My brother, as my father died on December 14th

18 of 2001.

19 Q. Turn your attention to a document Judicial

20 Watch Bates Number 505. It's part of that same

21 Exhibit 9.



24 A. Okay.

25 Q. Ms. Ruffley, do you see that?

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1 A. Yes, dated August 28th.

2 Q. Yes.

3 There's an e-mail there from Steve Andersen

4 of Judicial Watch to Tom Fitton, Paul Orfanedes, and

5 Chris Farrell. Copy to Susan prytherch. Subject:

6 "Orly Taitz posting a Judicial Watch invite to speak on

7 her website??"

8 And it states, "I am extremely proud, I just

9 got a call from the 'Judicial Watch,' and was asked to

10 be a speaker at their event, 'Republicans United,' on

11 October 13th in California."

12 That's a posting on Orly Taitz's website, is

13 it not?

14 A. Right.

15 Q. You said "Right"?

16 A. Yes.

17 Q. Now, that's in -- when Andersen sent that to

18 Fitton, Orfanedes, and Farrell, that then generated an

19 e-mail from Paul Orfanedes to you Tuesday, August 28th,

20 2012 at 4:03 p.m., which is above what I just read to

21 you on that page

22 A. Right.

23 Q. -- Bates Number 505. Correct?

24 A. Correct.

25 Q. And that e-mail says, "Connie: We've had a

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1 couple of inquiries about this posting. Can you make

2 clear to Ms. Taitz or whomever is responsible for the

3 posting that she was invited by UROC and not 'The

4 Judicial Watch.' The posting also needs to be

5 corrected to avoid any further confusion. Thanks.

6 PJO."

7 A. Right.


9 A. Yes.

10 Q. PJO is Paul J. Orfanedes. Correct?

11 A. Correct.

12 Q. The person who is in the room with you today?

13 A. Yes.

14 Q. One of them. Correct?

15 A. (Nods head in the affirmative.)

16 Q. What was this about?

17 Well, strike that.

18 In fact, Mr. Orfanedes was concerned that

19 Ms. Taitz had posted something incorrectly on her

20 website

21 A. Right.

22 Q. -- as she was being invited by Judicial

23 Watch --

24 A. Well --

25 Q. -- to a Judicial Watch event rather than UROC.

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1 Correct?


3 THE WITNESS: Correct.

4 MR. KRESS: But you can answer it. That's fine.

5 THE WITNESS: She had only known me as Judicial

6 Watch. And the fact that -- you know, because that's

7 the way I had introduced myself. And so when I called

8 her on the phone, which was around 8:42 p.m., she was

9 still at her office doing work. And I called her on

10 her cell phone and asked her if she would speak at

11 UROC.

12 And because of Ms. Taitz's heavy accent --

13 well, it's not a heavy accent, but it's an accent.

14 She was just confused about the -- the UROC. I mean,

15 I don't know when this woman ever sleeps. So that's

16 why she said that.

17 But she -- and I said -- and I told her

18 United Republicans of California. She got confused and

19 put in there Republicans United. So I called her and

20 asked her to correct it. And I think she did.

21 BY MR. KLAYMAN :

22 Q. But you never called her, as you testified,

23 to ask her to correct anything she wrote about me,

24 did you?

25 A. No.

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1 Q. Ms. --

2 A. Actually

3 Q. Someone

4 A. Let --

5 Q. at Judicial

6 A. let me --

7 Q. Watch --

8 A. Wait a

9 Q. had called

10 A. minute.

11 Q. after --

12 A. Let me -- wait a minute. The court reporter

13 is having a little trouble keeping up.

14 Let me restate that last comment. I never

15 never corrected her on that. I was just, you know,

16 stunned and didn't know that she would actually print a

17 retraction or a correction.

18 Q. Well, regardless of whether you were stunned

19 or not, you didn't feel like you had an obligation to

20 correct her claimed misquotes with you?

21 A. I'm not sure whether

22 MR. KRESS: I'm going to object to the form.

23 But you can answer it. You can answer it,

24 if you know.

25 THE WITNESS: I really don't know. I didn't feel

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1 like I, uh -- I just kind of object to the word

2 "obligation," or whatever it was that you used.

3 BY MR. KLAYMAN:

4 Q. You don't know of anyone at Judicial Watch

5 calling her to ask her to correct the statements with

6 regards to Larry Klayman that are at issue here, do

7 you?

8 A. No.

9 Q. If you were so stunned about what Ms. Taitz

10 had published about your conversation with her

11 A. Right.

12 Q. -- why you did you invite her to the November

13 conference to speak?


15 THE WITNESS: Well, she really does know from

16 the -- the times that I have seen her speak and

17 everything and from all of the -- I -- this goes back

18 to when I first met her when she was running for

19 Secretary of State, how she had been to visit all of

20 the Secretaries of State and all -- in the union, and

21 I didn't know anyone else who did that.

22 So that's one of the reasons why she was

23 invited to speak

24 BY MR. KLAYMAN:

25 Q. That impressed you. Right?

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1 A. -- to UROC.

2 I beg your pardon?

3 Q. That I'm pressed you?

4 A. Well, it should impress anyone. She was

5 taking the time to get out there to gather the correct

6 information.

7 Q. So you didn't think it was that important that

8 she allegedly misquoted you, you just wanted her to

9 speak?


11 THE WITNESS: It had nothing to do with what she

12 had put on the website. I just wanted her to speak to

13 the attendees at the UROC Convention and discuss --

14 BY MR. KLAYMAN:

15 Q. You saw her at the UROC Convention, did you

16 not?


18 Q. You saw her at the URoe Convention, did you

19 not?

20 A. Yes.

21 Q. You didn't ask her to correct what she had

22 published on her website about Larry Klayman, did you?

23 A. No.

24 MR. KLAYMAN: I have no further questions.

25 We will leave this deposition open because you

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1 need to look for the documents on your computer,

2 Ms. Taitz -- Ms. Ruffley.

3 I just want you to know that I wish you no

4 harm. And I trust that we can get the documents that

5 you haven't looked for yet, and that we can resolve

6 this case appropriately.

7 But thank you for your time.

8 MR. KRESS: I

9 MR. KLAYMAN: And

10 MR. KRESS: I do have

11 MR. KLAYMAN: and that concludes the question

12 session.

13 MR. KRESS: I do have a couple questions for her,

14 Mr. Klayman.

15

16 EXAMINATION

17 BY MR. KRESS:

18 Q. First of all, do you know for certain when it

19 was that you first read Orly Taitz's website posting

20 about Mr. Klayman?

21 A. It was probably several months after the --

22 several months after the incident.

23 Q. Was it -- do you know whether

24 MR. KLAYMAN: Objection. Move to strike.

25 Speculative.

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1 BY MR. KRESS:

2 Q. Do you know whether it was before or after the

3 UROC Convention?

4 A. It would have been before the UROC Convention.

5 Q. Okay. At the -- back in February of 2012,

6 did you understand the difference between the words

7 "convicted" and "indicted"?

8 A. No.

9 Q. When you did the work as a legal secretary,

10 did you do any criminal work?

11 A. Never.

12 Q. Okay. Did you -- at the time that you first

13 read Orly Taitz's website, did you also see that she

14 had made a correction of the statement?

15 A. No, I didn't.

16 MR. KLAYMAN: I didn't hear that.

17 MR. KRESS: I asked if -- if she -- I asked if

18 she recalls -- well, I asked if she saw Orly Taitz's

19 correction, and she said no.

20 MR. KLAYMAN: I didn't hear the question.

21 MR. KRESS: The question was --

22 MR. KLAYMAN: Can you repeat?

23 MR. KRESS: Sure. I'll paraphrase, if that's all

24 right.

25 I asked her if she had seen Orly Taitz's

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1 correction on the website. And she answered no.

2 And those are all of the questions that I

3 have.

4 J.VIR. KLAYMAN: I obj ect to that. That presumes

5 facts not in evidence that there was a correction.

6 J.VIR. KRESS: I have no further questions.

7 J.VIR. KLAYMAN: I have a few more.

8 J.VIR. KRESS: All right.

9

10 Examination

11 BY J.VIR. KLAYMAN :

12 Q. You have spent a good deal of time working

13 with Ernie Norris, who is former Deputy District

14 Attorney of Los Angeles County --

15 A. Yes.

16 Q. -- at Judicial Watch. Correct?

17 A. Yes.

18 Q. Correct?

19 A. Yes.

20 Q. Ernie is a -- Ernie was a criminal prosecutor

21 for a number of years with the District Attorney's

22 Office of Los Angeles. Correct?

23 A. 32 years. Yes.

24 Q. In fact, he played a role in the prosecution

25 of O.J. Simpson underneath Deputy D.A. Gil Garcetti.

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1 Correct?

2 A. I'm sorry. I didn't hear the first part of

3 the question correctly.

4 Would you mind repeating it, please, Larry?

5 Q. Ernie Norris, as Deputy Assistant District

6 Attorney underneath the District Attorney Gil Garcetti,

7 played a substantial role in the prosecution of O.J.

8 Simpson.

9 You are aware of that?

10 A. No, he did not have anything to do with the

11 O.J. Simpson trial. The O.J. Simpson trial was given

12 to his underling, Marcia Clark, and to Chris Darden.

13 But Ernie did not have

14 Q. You are aware that you have talked about

15 the O.J. Simpson case with Mr. Norris. Correct?

16 A. Oh, off and on.

17 Q. And Mr. Norris was quite -- was quite

18 despondent or upset that O.J. Simpson was not convicted

19 of the crime of murder. Correct?

20 A. I can't speak to his feelings on that or

21 emotions.

22 Q. You are aware that O.J. Simpson was indicted

23 but never convicted for murder. Correct?

24 A. Did you say "Ernie Simpson" or "O.J. Simpson"?

25 I'm sorry.

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1 Q. O.J.

2 A. Yes.

3 Q. Okay.

4 A. I'm aware that he was not convicted.

5 Q. Therefore, you do know the meaning of the word

6 "convicted" as opposed to "indicted." Correct?

7 A. More now. But at the time -- but at the time,

8 I was not aware of a difference between indicted and

9 convicted.

10 Q. So during the time of the O.J. Simpson trial,

11 you thought that O.J. Simpson was convicted because he

12 was indicted?

13 A. No.

14 Q. You are a highly intelligent person; are you

15 not, Ms. Ruffley?

16 A. Thank you. Yes.

17 Q. Newspaper regularly?


19 Q. You do read the newspaper, do you not --

20 A. No.

21 Q. -- regularly?

22 A. No.

23 Q. You watch Fox News, don't you?

24 A. I'm forced to watch it, yes. I hate it.

25 Q. You prefer MSNBC?

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1 A. No, I don't watch anything else except Fox.

2 It's my husband who watches Fox from in the morning

3 until late at night. And I just -- I'm stuck with it.

4 MR. KLAYMAN: I have no further questions at this

5 time.

6 Thank you for your time.

7 MR. KRESS: No further questions.

8 Thank you.

9 THE WITNESS: Thank you.

10 THE VIDEOGRAPHER: Any stipulation?

11 MR. KRESS: We will read -- he will read the

12 transcript.

13 What other stipulations are you looking for?

14 THE REPORTER: Who receives it.

15 MR. KRESS: Who receives it? I would prefer if

16 the transcript would be sent to me for review, if that

17 is acceptable.

18 Mr. Klayman.

19 MR. KLAYMAN: Excuse me.

20 MR. KRESS: In terms of reading the transcript, do

21 you mind if the court reporter just sends the

22 transcript to me for review so that I can send it to

23 Ms. Ruffley for review?

24 MR. KLAYMAN: No, I don I t mind. But we want a

25 copy, too --

79



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1 MR. KRESS: Sure.

2 MR. IaAYMAN: - - contemporaneous.

3 MR. KRESS: All right.

4 THE VIDEOGRAPHER: This concludes today' s

5 videotaped deposition of Constance Ruffley in the

6 matter of Larry Klayman vs. Judicial Watch.

7 We are off the record. The time is

8 10:33 a.m.

9 THE WITNESS: P.M.

10 Oh, it is A.M.

11 MR. IaAYMAN: Thank you.

12 You have also a very courteous counsel. So

13 I'll say that, as well.

14

15 (At 10:33 a.m., the proceedings

16 were concluded.)

17

18

19

20

21

22

23

24

25

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1 STATE OF CALIFORNIA

2 COUNTY OF LOS ANGELES

3

4 I, Tracy Williams, CSR #10139, Certified

5 Shorthand Reporter, do hereby certify:

6 That prior to being examined, the witness

7 named in the foregoing deposition was by me duly

8 sworn;

9 That said deposition was taken down by me in

10 shorthand at the time and place therein named and

11 thereafter transcribed under my direction;

12 I further certify that I am neither counsel

13 for, nor related to, any party to said proceedings, not

14 in any way interested in the outcome thereof.

15 I declare under penalty of perjury under the

16 law of the State of California that the foregoing is

17 true and correct.

18

19 Dated: February 14, 2014

20

21 Tracy Williams

22 CSR No. 10139, RPR CRR

23

24

25

81

Coalition of Court Reporters of Los Angeles 205 South Broadway, Suite 200, Los Angeles, CA 900121213.471.2966 1 www.ccrola.com


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1 DECLARATION UNDER PENALTY OF PERJURY

2 I, Constance S. Ruffley, do hereby certify under

3 penalty of perjury that I have read the foregoing

4 transcript of my deposition taken January 31, 2014; that I

5 have made such corrections as appear noted on the

6 Deposition Errata Page, attached hereto, signed by

7 me; that my testimony as contained herein, as

8 corrected, is true and correct.

9

10 Dated this day of ____________________ _

11 2014, at ------------------------------------------12 California.

13

14

15

16 CONSTANCE S. RUFFLEY

17

18

19

20

21

22

23

24

25

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1 DEPOSITION ERRATA SHEET

2

3 Page No. Line No.

4 Change:

5 Reason for Change:

6 Page No. Line No.

7 Change:


9 Page No. Line No.

10 Change:


12 Page No. Line No.

13 Change:



16 Change:



19 Change:



22 Change:


24

25 CONSTANCE S. RUFFLEY Dated

83



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room 69:12 66:1 send 79:22 responded 14:24

roughly 13 :23 says 25:2,227:20 sends 79:21 response 6:115:14 29:6,862: 12,24 24:1946:4,21 57:3 (6) rpr 1: 1013981 :22 63:5,9,2067:1568:25 sent 47:2262:20

(12) 68:1779:16 (4) responses 49:8 ruff 21:20

school 9:3 september 12:9 14:5

Coalition of Court Reporters of Los Angeles 205 South Broadway, Suite 200, Los Angeles, CA 90012 I 213.471.29661 www.ccrola.com


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speakers 50:8 street 2:184:8 since 11:21 37:14 swear 5:14



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2003 14:3,3,5

2004 13:24

2008 16:10,21

2009 12:9

2010 16:10,21

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2013 15:920:1621:16 65:24 (4)

2014 1:13 4:2,7 81:19 82:4,11 (6)

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2520 2:6

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20024 2:19

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18



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EXHIBIT "13"


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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 13-20610-CIV-ALTONAGAlSimonton

LARRY E. KLAYMAN,

Plaintiff,

v.

JUDICIAL WATCH, INC., eta/.,

Defendants. ______________________ ~I

DECLARATION UNDER PENALTY OF PERJURY OF CONSTANCE S. RUFFLEY

STATE OF CALIFORNIA ) )

COUNTY OF LOS ANGELES )

CONSTANCE S. RUFFLEY, pursuant to 28 U.S.C. §1746, makes the following declaration

under the penalty of perjury:

1. I am over the age of eighteen (18) and I am capable of making this affidavit.

2. I have personal knowledge of the following facts and, if called upon as a witness,

could testify competently thereto.

3. I am a resident of the State of California.

4. I am employed as the Office Administrator for Judicial Watch, Inc. 's Western

Regional Headquarters in San Marino California.

5. It is my understanding that Larry Klayman has sued me, Judicial Watch, Inc., and

other Judicial Watch, Inc. employees alleging that we, on or about Febnuu:y 22, 2012, "negligently,

maliciously and/or willfully published and furthered the publication of a false statement that Plaintiff


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Klayman had been 'convicted' of a crime for not paying a large amount of child support with regard

to his children, on the internet and elsewhere within this judicial district, Florida, and elsewhere

throughout the United States and the world."

6. I deny Klayman's claims and I deny that I am liable on Klayman's claims for

defamation, defamation by implication, tortious interference with a contract, and intentional

infliction of emotional distress.

7. On or about February 22,2012, I attended the monthly meeting of the California

Coalition for Immigration Reform in Garden Grove, California. Orly Taitz was one of the speakers

at the meeting. I am familiar with Orly Taitz. Ms. Taitz is a California resident who was, at the

time, running on the primary ballot for one of the California seats on the United States Senate. After

the meeting, I was seated at an information table for Judicial Watch, displaying various forms of

Judicial Watch literature. Orly Taitz approached me and we discussed a number of issues. We

eventually discussed Larry Klayman. The only information that I conveyed to Ms. Taitz about Larry

Klayman was information that I had learned from public records, including information related to

court proceedings for failure to pay child support. I do not recall stating that Mr. Klayman had been

convicted for the crime offailure to pay child support. This was the only discussion that I had with

Ms. Taitz regarding Larry Klayman.

8. My expectation was that Orly Taitz would not restate my comments to any other

person or entity. I never gave Orly Taitz permission to restate my comments to any other person or

entity. I did not expect or anticipate that OrIy Taitz would restate my comments on her website or in

any other format. I expected that Orly Taitz would keep my comments to herself and only use the

comments to conduct her own research into the publicly-available information related to Larry

2


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Klayman.

9. The information that I conveyed to orty Taitz was gathered through my own

independent research. No one from Judicial Watch advised me of this information or instructed me

to convey the information to Ody Taitz.

10. I did not make any statements about Larry Klayman in the State of Florida. I did not

intend for any of my statements about Mr. Klayman to be published or restated in the State of

Florida. I did not intend to cause any injw'Y. harm, or damage to Larry Klayman.

11. I do not: (I) own or lease any real property in Florida; (2) have a telephone listing or

mailing address in Florida; (3) have any Florida bank accounts; (4) have any Florida property tax

liability; (5) have any Florida registered vehicles or a Florida driver's license; (6) hold allY Florida

professional licenses; (7) vote in Florida; (8) operate, conduct, engage in, or carryon any personal

business in Florida; (9) travel to Florida except as referenced below; (10) contract to insure any

person or thing in Florida: (11) commit tortious acts in Florida; (12) cause injury to people or

property in Florida; or (13) enter into or breach contracts that are to be performed in Florida.

12. I have travelled to Florida only twice in my life, both times on Judicial Watch

business. The last time I travelled to Florida on Judicial Watch business was in 2001.

FURTHER DECLARANT SA YETB NAUGHT.

I declare under penalty ofperjury that the foregoing is true and correct.

Executed on June 28, 2013. in San Marino, California.

7""") /'"'l' -:-T' . ,/ / / " /I ." /' (F lL-r;;J-£d··pL t!: e" \ I- tt<.. /'':: i.. /Jl

, ~ / _ ~P r I

CONSTANCE S. RUFFLEY / .". .

3


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It

7129113 My~terday's presentation to CCIR and t¢ate on article2SuperPAC-Larry K1~ $25,000 fuldraising for rlOIr-eJdstent ICfNsLit affair I Dr. OrlvTaitz, Es ..

Dr. Orly Taia, Esquire Defend Our Freedoms Foundation 29839 Santa Margarita Pkwy. Ste 100 Rancho Santa Margarita CA 92688 Copyright 2013

World's Leading Obama Eligibility Challenge Web Site

If you love your country, please help me fight this creeping tyranny and corruption.

'Ill;: articles posted represent 01£ opinion of the writerS anO do not neces~ represent the ogoon of~Jaltz, . q. , who haS rp .means of chec,kIllg.UIt: vera9Itv of all the CIaIlUS and allegamns m the artices.

Donations no matter how small will help pay for airline and travel expenses.

~~~~~"::~ ==""'=~El

Mail donations to: Defend Our Freedoms Foundation, c/o Dr. Orly Taitz

29839 Santa Margarita Plwy , Ste 100

Rancho Santa Margarita, CA 92688.

Contact Dr. Taitz at orly [email protected]

l.n case of emer!!"DCY, call 949-683-5411.

When Ihe people fear Iheir govertlmen~ Ihere is tyranny.

When the government fears Ihe people. there is liberty.

- Thomas Jefferson

Durmg times of universal deceit. telling the truth

becomes a revolutionary aCL - George Orwell

Firs l/hey ignore you. theil/hey ridicule you. then Ihey

fight you. then you win. - Mahatma Gandhi

Apr(aline DCllli,try (If F Jr'!'" ~"~ tJt,rr,,,', C<C'''"''~, .. f~\!.."'rPftttU·~~'"

('J"', 71 ... ?f~

My yesterday'S presentation to CCIR and update on article2SuperPAC-Larry Klayman $25,000 fundraising for nonexistent law suit affair Posted on 1 Februal)' 23,201214 Comments

Anicle2supcrpac $25000 solicitation RJr Lan'" KlamJiln

Screen shot $25 000 sQljcitatKm lor Lany Klavman lawsuits FebruaJ:Y 10 2012

Plantiff'sl Defend .. ", Exhibil ---i...".,... Witness : <:" Dale I I ., • r,cy Williams, CSR, RPR, eRR·~ J139

'U) ('1<")

Yesterday I gave a 2hour presentation of my platfonn as a candidate for the US Senate. 'Ill;: presentationwas given to some 100 CA voters in the Women's club of Garden Grove. I was tokl, that a representative of the Judicial Watch drove fur over an hour from San Marmo to hear me speak and talk to me. I got a very wann reception, after my presentation peopk: stood up and applauded. 1bi5 member of the judicial watch approached me and gave me her card. Her

WNN.orl}tljtzesq .com'?p= 320n 1/10


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7/29/13 My)€Sterday's presentation to CCIR and update on article2SuperPAC-LarryKla~n $25,000 fundraising for non-eJ<istent lawsuit affair I Dr. OrlyTaitz, Es ...

name is Constance RuftJey and she is an office administrator fur the Judicial Watch in their Western Regional Headquarters at 2540 Huntington Dr., San Marino. She told me, that she used to work fur the FBI and that she worked fur the Judicial Watch for many years. She actually initiated the discussion about Larry Klayman and told me that she heard that he is involved in birther cases. I told her that this group, article2superpac was soliciting money, that they sent an e-mail and posted on their site an advertisement on February 10, asking for $25,000, claiming that they need to raise $25,000 in 96 hours, as the cases in Florida and Califumia need to be filed within a week. I told her, that it was a hard sell, they wrote it is now or never, saying finally Obarna's team met their match, dis sing 4 years ofmy tireless work in the process, and in the end nothing was filed by Larry Klayman. It is not clear what happened to all of the money that was raised, who got it.

Ms. Ruffiey actually advised me that Larry Klayman is not licensed in California, she told me that he no longer works with the Judicial Watch and that donors should know about litigation in Ohio, where he was convicted just recentlty of not paying large amount in child support. She provided a lot of other infonnation I will publish only, what is a public record. I am not publishing anything, that is not in public record.

A number of individuals sent me this information:

Larry Klayman, 60, of Los Angeles, Califurnia, was indicted on two (2) counts of criminal non-support. He owes $78,861.76 for his two children ages 11 and 14. Two hearings were held in Domestic Relations Court between 2009 and 2010. The last voluntary payment was made on August 30, 2011, in the amount of$I,014.26. Arraignment is scheduled for February 7, 2012.

FWIW, you might want to read this suit (below) filed against Kayman ... from the time this suit was filed against Klayman (2007), he has not honored his promise to pay back what the court ordered, even though it was nowhere near the $25,000 he was trusted with. I would be worried too, if I had donated money to this man.

IN THE SUPREME COURT OF FLORIDA THE FLORIDA BAR, Supreme Court Case No. Complainant,vs. No. 2011-70,621(IIA)

LARRY ELLIOT KLAYMAN, Respondent. COMPLAINT

3. On or about November 11,2007, Natalia Humm ("Humm') filed a grievance against Respondent (Larry Klayman) alleging that he had had fuiled to provide services in her criminal case after she paid him a $25,000 retainer.

Yesterday I got an e-mail from Pamela Barnett titled: "Larry Klayman did not get nearly his retainer". When Barnett wrote that Klayman did not get nearly his retainer, it means, that he got something. Barnett did not disclose, what did he get. What does it mean? According to the solicitation by a pack ofbloggers in this article2Superpac, all of these bloggers were heavily soliciting a total of$25,000. Nobody knows, how much did they actually raise. Additiona1ly, Barnett claims, that she and George Miller are no longer connected with the article2superpac, however the Article2superpac and solicitation fur donations fur article2superpac is located at the top of the blog, ObamaBallotChallenge which is administered by Barnett and Miller. The link

http://www.art2superpac.com/floridaballot.html shows the actual article. The PDF and screenshot are at the top of the page.

"Not nearly his retainer" can be $15,000 out of$25,000, it can be$1 0,000. Bottom line, nobody knows, how much Klayman actually got. The question is, why was he paid anything, ifhe did not file the law suits, as he was supposed to?

Later I got an e-mail from Tony Dolz, who is not on the board of the Article2Superpac, but who is in contact with a mnnber of the board members of this PAC, who stated, that he had a discussion with George Miller, who is on the board of the Article2superpac, who runs a blog ObamaBallotChaIlenge together with Barnett. According to Dolz, Miller stated, that Klayman was not paid anything.

The question is: who is lying? Was Klayman paid or not? Ifhe was paid, than he needs to refund the donors, as he did not file law suits as he was supposed to. If the bloggers raised money and did not pay Klayman, the bloggers need to refund the money to the donors. The press release, that was issued by Article2Superpac on February 10, 2012 clearly stated, that the donors are asked to donate $25,000 to pay Larry Klayman, that they have 96 hours to raise this large sum of money. The article also stated that the law suits are supposed to be filed within 1 week. It is now or never(see the article above). So, there were clear parameters: this pack ofbloggers was soliciting from the public a large sum of money specitica1ly to pay attorney Larry Klayman: $25,000 to file 2 law suits in FL and CA within a week, by February 17,2012. Those law suits were never filed and the public should be refunded all of the money that was donated for this specific purpose. All of the bloggers, who ran this solicitation, need to provide accounting fur the public, how much money did they raise in total and where did this money go. Actually, donors can report this to their District Attorneys. If the public donated fur specitic purpose and did not get the benefit, the public was defrauded and this is a criminal matter. People went to prison fur things like that.

There are 5 board members of this Article2superpac:

1. Helen Tansey-blogger, president of the Article2SuperPAC

WNW.orl~aitzesq .com'?p=32077 2110


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7/29/13 My~terday's presentation to CCIR and update on article2SuperPAC-LarryKlayman $25,000 fundraising for non-eJdstent lawsuit affair I Dr. OrlyTaitz, Es ...

2. Gany Wihnott, blogger GiveUSLiberty1776

3. Bob Nelson-blogger, runs ORYR (ObamaReleaseYourRecords) or BirtherReport (I got infurmation, that Bob nelson might be a pseudonym fur richard Garoutte, but I am not sure).

4. George Miller runs blog ObamaBallotChallenge together with Pamela Barnett (another supporter stated, that Pamela Barnett is on the board instead of George Miller, I am not sure about that)

5. Kevin Powell, a cameraman, I don't know, what blog does he run

Additionally several other bloggers were nmning solicitation of this Article@superpac on their blogs, among them

Dean Haskins, blogger "BirtherSummit"

Sam Sewell blogger 'steady drip", Charles Kerchner and a few others.

All of these people are supposed to refund the public all of the money, that they raised fur these law suits that were supposed to be filed by Larry Klayman by the February 17, 2012 deadline, as those law suits were never filed. 1be public never got the benefit of the what they paid fur.

1bis is the reason, why I stated before, that if you want to donate to the work of a specific attorney, donate directly and you know, where the money is going. When you donate to a gang ofbloggers, claiming that the money is going to attorneys fur legal expenses, you have no idea where the donations are going.

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4 Responses to "My yesterday's presentation to CCIR and update on article2 S uperP AC-Larry Klayman $25,000 fundraising fur non-existent law suit aifuir"

1. Bloodless Coup February 23rd, 2012 @ 7:20 am

I was intia1ly excited about Larry Klayman, and helped the news about him to go viral Now I am wondering about him and what his true motives might be.

2. Florence Stone February 23rd, 2012 @ 2:51 pm

I srnelled a rat from the get-go. Asking for $25,000 fur 2 lawsuits sounded way out of the ballpark to me, so I did not bite. Seemed like an attempt to scam money on the backs of people wanting to expose Obama, and nothing more. Glad Orly stays on top of things like this for us. WHERE DOES SHE FIND TIfE TIME?? Talk about multi-tasking, I think Orly is the Queen of that as well!

February 27th, 2012 @ 6:54 am

Obama's administration is doing the same to Orly as they did (and are still doing) to Dr Judy Wood regarding "Where did the Towers Go". 1bey slide a sM into "leading honest intention" down a hill and into the forrest and away from the main target. Dr Orly Taitz is the finest there is!

April 9th, 2012 @ 11:48 pm

I have read some excellent stuffhere. Definitely worth bookmarking for revisiting. Thanks!

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driscoll seltzer

March 5, 2012

BY EMAIL AND FIRST CLASS MAIL

Larry E. Klayman, Esquire 2020 Pennsylvania Avenue, N.W., Suite 345 Washington, DC 20006

Richard W. Driscoll' Direct: 703.879.2601 [email protected] 'Admitted in VA, DC and MD

Re: Putative Claim for defamation. etc.

Dear Mr. Klayman:

This firm represents Judicial Watch, Inc. relating to the above-referenced matter.

Through a series of emails and again during our conversation on Tuesday, February 28, 2012, you advanced vague and unsupported allegations that Judicial Watch, its President Thomas Fitton and an employee are participants in a conspiracy to defame and disparage you based on the recent indictment handed down in Ohio. To date, you have produced no evidence to support these truly outrageous allegations.

As I stated to you during our conversation, Judicial Watch did not authorize, make, or participate in making, any statements regarding your indictment for criminal nonsupport. For this reason, it is not necessary for Judicial Watch to take any action to clarify or correct the statements of others.

Sincerely,

DRISCOLL & SELTZER, PLLC

Richard W. Driscoll

cc: Paul J. Orfanedes, Esquire

a profess/annllimiteJ liability company O:\Client Matters\70007\1 • CorreSpOndencelLCJVUGOO~oc


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Tom Fitton

From: Sent: To: Cc:

Paul Orfanedes Tuesday, August 28, 2012 4:03 PM Connie Ruffley Tom Fitton; Christopher Fedeli; Steve Andersen; Susan Prytherch

Subject: FW: Oriy Taitz posting a Judicial Watch invite to speak on her Website??

Connie:

We've had a couple of inquiries about this posting. Can you make dear to Ms. Taitz or whomever is responsible for the posting that she was invited by UROe and not "the Judicial watch.!' The also needs to be corrected to avoid any

further confusion.

Thanks.

PJO

From: Steve Andersen Sent: Tuesday, August 28, 2012 3:33 PM To: Tom Fitton; Paul Orfanedesi Chris Farrell Cc:: Susan prytherch Subject: RE: Orly Taitz posting a Judicial Watch invite to speak on her Website??

am extremel

Posted on 1 August 22,201214 Comments

The event will be on October 13th, it will be in the "Embassy Suites" in the city of Arcadia, it is about 20 minutes North-West of Los Angeles. I will provide more information later.

Steven C. Andersen Director of Development Judicial Watch 425 Third Street S.W. Suite 800 Washington, D.C. 20024 (202) 646-5198 www.judicialwatch.org

118ecause no one is above the Jaw. II

1 JW000505


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'Those who expect to reap the blessings of freedom, must, like men, undergo the fatigue of supporting it."

-Thomas Paine

Support Judicial Watch by shopping and searching online at igive.com. Get started now at www.iGive.com/JudiciaIWatch

STATEMENT OF CONFIDENTIALITY: The information contained in this electronic message and any attachments to this message are intended for the exclusive use of the addressee(s) and may contain confidential or privileged information. If you are not the intended recipient, please notify Judicial Watch, Inc. immediately at either 202-646-5172 or at [email protected], and destroy all copies of the message and any attachments.

From: JW Info Sent: Friday, August 24, 2012 8:48 AM To: Tom Fitton; Paul Orfanedes; Chris Farrelli Steve Andersen Subject: Orly Taitz posting a Judicial Watch invite to speak on her Website??

Watch - United Event in CA?

It is on her website -- http://www.orlytaitzesq.com/?p=252642

a of mall from Mr. Driscoll

from: Lawrence Driscoll (mailto:lj,[email protected]] Sent: Thursday, August 23, 2012 9:52 PM To: Dr. Orly Taitz ESQ; Orly Taitz Cc: JW Info Subject: Larry Driscoll's "Citizen Submittal Letter re Criminal Barack Obama", LD to OT update

Orly, I resend my earlier email to judicial Watch as per your efforts and presenting them to 'Judicial Watch'. Honestly, from knowing and learning about Judicial Watch over time, I conclude that; they seek donations, they take on 'small battles', Le, avoid 'larger issues', all with intent to support their 'Watchdog Image' to attract more donations, in other words, their actions care only for donations and not justice as per our US Constitution, as opposed to you and you case and subject matter investigative endeavors, as you care always to seek justice upon a matter. At your website you have posted that "Judicial Watch" has asked you to appear at its "Republicans United Event in CAli. Undertake this offer. POSSibly, your appearance will create a "Legal Spine", a devotional caring for truth in Judicial Watch, for as to date. as per the issues that you address, this organization does not have this, especially with regard to larger issues. Sincerely, larry Driscoll

-- Forwarded Message ---from: Lawrence Driscoll <[email protected]> To: "info@;udicialwatch.org" <[email protected]> Cc: Dr. Orly Taitz ESQ <dr [email protected]>; Orly Taitz <[email protected]> Sent: Thursday, August 9,20128:26 PM Subject: Larry Driscoll's "Citizen Submittal Letter re Criminal Barack Obama"

Tom Fitton and Judicial Watch,

I forward to you my attachment "Citizen Submital letter re Criminal Berack Obama" sent to my Arizona First District Representative Paul Gosar at his Washington, DC. Office and to others cc'd as you will review.

I have asked you, Tom Fitton and your organization Judicial Watch, before that you would align your legal knowledge and support of Attorney Taitz's endeavors, with common goal of allegience, to remove THE CRIMINAL BARACK OBAMA

2 JW000506


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FROM HIS PRESENTLY UNCONSTITUTIONALLY HELD OFFICE, but you have chosen not to do this. If you continue not to support Atrtomey Taitz, I ask that you remove me from your data base and never attempt to contact me again

Sincerely, Larry Driscoll

--- Forwarded Message --From: lawrence Driscoll <[email protected]> To: "[email protected]" <[email protected]>; "[email protected]" <[email protected]>; "[email protected]" <[email protected]> Cc: Orly Taitz <[email protected]>; Dr. Orly Taitz ESQ <dr [email protected]> Sent: Thursday, August 9,20128:00 PM Subject: Larry Driscoll's "Citizen Submittal letter re Criminal Sarack Obama"

News at World Net Daily, Letters at Wond Net Daily, Joseph Farah, David Kupelian,

I attach to this email my "Citizen Submittal Letter regarding Criminal Sa rack Obama" which as you see in original postal mail form was sent to my Arizona First District Representative Paul Gosar at his Washington, DC office, with ce, copies sent to Attorney Taitz, Arizona Sheriff Arpaio, Washington Times Columnist, Kuhner and House Speaker Boehner.

Next, Mitt Romney and Mitt Romney for PreSident, Donald Trump, Fox news manager and fox news tips, Jonathan Paton, my new to be Representative in AZ to be, and Chelsea Schilling of WND were email sent same letter.

I ask that WND constantly attend to, and announce to the public via its internet webSite, that not only is Barack Obama a "Liar and Deceiver" in his daily conduct and actions from before 2008 to the present, that even worse, is the fact that, Barack Obama is, 'most and more importantly' to be noted, addressed and described, not as a "Presidenf', but as a CRIMINAL", as per all of of the previous lieing and deceiving actions and deeds carried out by him against the American Citizen voting public with regard to his stolen Social Security Number and his fraudulent Selective Service Registration Card which carries a fraudulent Postal Indicia.

Sincerely, Larry Driscoll 10827 Mesa View Rd. Williams, AZ 86046

3 JW000507


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Tom Fitton

From: Sent: To: Subject:

(From my sister-in-law)

Constance Ruffley <[email protected]> Monday, January 07,2013 2:41 PM Tom Fitton; Paul Orfanedes; Chris Farrell Fw: Judge orders eligibility attorney to stay away

Klayman is at it againl Read if you're interested. The truly disturbing thing, however, is that the judge DID refer to a fictitious movie to make his ruling!!

Connie

--- On Sun, 116113, Price Sloan <psloan350f!JiJfa.rr.com> wrote:

From: Price Sloan <[email protected]> Subject: Judge orders eligibility attorney to stay away To: [email protected] Date: Sunday, January 6,2013, 7:14 PM

Holy crap! Do these people running our country have no brains? Quoting the fictitious judge from the movie "Miracle on 54th Street" no less. I think the scarecrow from Wizard of Oz has more brains than these jokers!

http://www.wnd.com/2013/01/judge-orders-eligibility-attorney-to-stay-awavl

1 JW000508


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Tom fitton

From: Connie Ruffley Sent: Friday, October 11, 2013 7:38 PM To: Tom Fitton; Paul Orfanedes; Chris Farrell Subject: Article about Larry Nichols, LEK, and Truckers for the Constitution

FYI.

c.

http://freedornoutposLcom/2013/l0/forrner-hillary-associa!:£!:=jaims-personal-hit-man-admits-killing-monev!

1 JW000509


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Former Hillary Associate Claims to Have Been Her Personal Hit M ... http://fi·eedomoutpost.coml2013/1 O/fonner-hi Ilary-associate-ciaims-...

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Former Hillary Associate Claims to Have Been Her Personal Hit M .. . http://freedomoutpost.coml20 131 1 O/former-hillary-associate-claims-.,

been B '/oice cryti1g ou( il1/he .vifdem i"ss slilCH he blough! to /igl ll (he sexlIcll [Ji'u(;'fli ly of Bdl t.:linmll dvring

Ius reign ~!; Go vpn101 in AI*an$~-1S Tha t li lfon nalion IVOl lld@ven lu,ilty playa key role ,'0 Clin/(.lI' :S

it IJIJedcfm lent If} tiN? {l0' <; Lall), Stiys he maAes no apologies

The}' sent mg. ovel5~as [0 kill p !:!op.'e for them and told Fn~;t Wd'.$ for IJI@goodofthe Countr}' So If/iJe.'! th@jI

d5kedrne iu do if ((lJ Inemin 1/18 5lo-ftt?s It f21t no difff:!r~nt Ttrt:! r'A'f/ tlUtll 1$, I (lid it fOf thr: rnom?y~~md I didn't

give ri slul.,bout the I'./olnenl beat d OC' flJe men II1lurdered The eli/,to) 1$ cl" ';' b~id p eople Bod I (,ltd bacl

thing:; (Of them Jltad to li,,'e with th .. 'ft ,il/ of NIese ya.-us ~JJ cf l1oW ))~/5tdolllcilrl? anym(;f@ ! ~/JlO kl1(J;J;-5 It.

L -ff'rv nWlltail"t5 the Clli1to17s B'~er@ 11110 so nldf1Y lJieg,.1I ofictivdit?s dt !hl? fin lc?, Ih,;;-V IHd to Ikwe ,:t team 01

Inercefur;as ll kide up of ,ri2nd$ dnri stn(!~~troopers to cO~/er it dll up nl1(/ keep tlleor protected flom tile

public fil)clJi19 OLlI. Accord,i )g 10 Lc'm J' Nichol s. both BtU nnd HiflalY WiHe wtld and out of "'ont,,,! and both

iVi!:tre ,-e/Bofles:. Ii ; their PUr5w! IVI lMney dnd power.. FI OIn runnin9 drug:;, In the rape and be~fjng of

\'lon'~n dnd young g irls, botl! of the a m/oils ffre gwlt!1 of tile u"speaAalJle cdll1~s

1\I7le" Pete Bsked Lalrr about Genllif,,! Flow",, " nldhll9 h,,~dllJles /a;; ! """". e/,mning 81l{ ikld (old MI

HJU~wy IMd eaten more pussy ({'-'to IJp./1ad Ldrry 91d th .. il:; old ns~~'s, dnd Ji1de~d it 15 LdflY had n ).;)de that

Sdme- s tdtemenf on the Pet@SnnMli$I )Ow eilrlj' {~5t spring LaITY ;s .:1d'if)1,111! fl1at Hil/~/y Clinton ;,S it ~[)Vk1J '<

.Jnd ,i'/wdYs hiS been.

Ol'lt? (/1i119 (know for sur@Shedlelhave enol.Jg hsc?)(Iy,d!/}/ J}e>lJtohaveakid, J)v( if w.-lsnl Bill CIt" tC/)',<; Kid.:;i1e

h ,d enel, ,,,, is " e/ually 1/1" dallg',121 of W<>b HuN,ie,

NichClls nod m rlHy o t /1e1 ;n:;icl~J'S ctilh ll Clinton began "'.-l~'!;- lg sex it/lUI Hubble 10 9 d1i J t?mploymenf d t T/U?

Ros& Law FI' m IV/1ich sIre be/ielled would event(fdlly i'tdV.fJ!1C6 Bill Ciinton's chances of becon ling Gopernor

of Ark"n:;as,

Th€' above quote-s came from d radic interview ! have obtaIned a video tha.t Is po::; ted on the 5iHn€ pdge It 1$ .4

how ,;; tong ~nd I rave n ot had time to j~o(i.lte the comment~ ~o Illewe r~O idea what $egrnent of the- show copt('lln s

them I am po::;t ing the vi<jeo for tho:;\? w ho might hdye time to Ii"tffi to it WARNING: Som" content in ttl" v1(l&o

may be uffensive to ~OIne in ;hi '; audience Pic!~ up the vieIRo around the I HI OgMil' m~, k

This b d perfect Qxampte of how major :',torte5 cltn I)e sqU8.s jled by large media out!~t$ I wa~, llI'1<l'Jiore o f thi$

,tory lIntit today Is n 1m",' Maybe 00 el1d rnaybe not The pOl ll! i~ til At II a foomer aooocld'" m akes the,e

accll~tions it should be coverc-<I by the m edia even if their only intent is: to c1i~credlt ~Llcl 1 comment::;,

ldJ Iy I-.Jichots. vla~ tll efe .and j1€- know", V/hnt hapPGl1ed. Is he tying? Thai'c ~oP1etI 11r. g th~t only he and otherz, thaI

wei e there truly know

If the ... 'lCClI~lio'l: thntare flying 011 the ~ete Santilli ::.tlOVl are true, it is" ju<.; t I"or e- evidence thdt w e c<"nnot h,lLy

put ollr tru:::.t in f" 0)(' I\:£-\:Jl$.

Editor's Note: TIl .. prevlou, photo lip tdp.d '" Larry Nlcllols was 1101 the _oJ'ry Nichol<; this art ICle is about, Otll

~inc@re apotogie&. The r.;hoto has been updated

Don't forget to Like Fr<!edom Outpo.t on Fac ohook. Googlo Plus, Te~ Party Community & Twi tter.

Truth .-\J,W)t.r AlUWltl~ '

Siftilol l \ 'ioir ,) kt-I .. lrl ;;""'''_I .' .lUjf.. ,'lt.-,1

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\ 'I '\.>(o l:~h,)d:.Jll.~ j :~U!l't 1:> (" , 1.",1.11):; d!\ I"1Y Timr")

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Former Hillary Associate Claims to Have Been Her Personal Hit M ... http://freedomotitpost.coml20 13/1 O/former-hillary-associate-c1aims-...

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Tom Fitton

From: Sent: To: Subject:

Paul Orfanedes Wednesday, August 29,20127:27 PM Tom Fitton; Christopher Fedeli; Susan Prytherch; Steve Andersen FW: UROC Fall Convention, Saturday, October 13, 2012

From: Constance Ruffley [mailto:[email protected]] Sent: Tuesday, August 28,20127:00 PM To: Orry Taltz Subject: UROC Fall Convention, Saturday, October 13, 2012

Dear Dr. Taitz,

Here is the information about the Fall Convention for United Republicans of California (URGC). It will be held on Saturday, October 13, 2012, 9:00 a.m. to 3:00 p.m., at the Embassy Suites, 211 East Huntington Drive, Arcadia, CA.

For further information, anyone can call 626-422-1699.

As soon as possible, PLEASE replace the information you currently have on your website with the above! In addition, please remove any reference to lithe Judicial Watch" as Judicial Watch has no connection to UROC whatsoever. I work for Judicial Watch but, on my personal time, I am Chairman ofUROC.

Thank you very much. If you have any questions, please feel free to call me at 626-422-1699 or my home, 626-287-4540.

Sincerely,

Connie Ruffley Chairman, United Republicans of California (URGC)

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Documents

Ruffley Deposition, Klayman v Judicial Watch