CONFIDENTIAL: NOT FOR PUBLIC FILING PENDING COURT REVIEW EXHIBITS TO TRANSITION REPORT TO INDEPENDENT INVESTIGATOR UNITEL INTELLIGENCE GROUP, INC. REGARDING SHOP STEWARD ISSUES
BOOK I EXHIBITS 1 THROUGH 3
Exhibit No. Description
1. Transcripts of Anthony Arguelles depositions 1. December 15 , 2004 PDF version of file 2 January 7, 2005 PDF version of file 2 . Transcript of Stephen Arguelles deposition 3 Transcript of Robert Defeo deposition
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, x Plaintiff, 9 0 CIV 5722 -against- (CSH) DISTRICT COUNCIL OF NEW YORK CITY AND VICINITY OF THE UNITED BROTHERHOOD OF CARPENTERS AND JOINERS OF AMERICA, et.al., Defendants. Independent Investigator Deposition x December 15 , 2004 5 :00 o'clock p.m.
DEPOSITION of ANTHONY ARGUELLES, taken by the Independent Investigator, Walter Mack, Esq., pursuant to letter subpoena, at the offices of Doar, Rieck & Mack, Esqs., 217 Broadway, 7 th Floor, New York, New York 10007-2911, before Stewart Nissenbaum, a Shorthand Reporter and Notary Public of the State of New York. ORIGINAL TANKOOS REPORTING COMPANY, INC. 3 05 Madison Avenue 14 2 Willis Avenue Suite 4 49 P.O. Box 3 47 New York, N.Y. 10165 Mineola, N.Y. 115 01 (212 )3 4 9 -9 6 9 2 (516 )74 1-5 23 5
APPEARANCES:
DOAR, RIECK & MACK, ESQS. 217 Broadway, 7 th Floor New York, New York 10 007 -2 9 11 BY: WALTER MACK, ESQ. Independent Investigator
O'DWYER & BERNSTEIN, ESQS. Attorneys for District Council 5 2 Duane Street New York, New York 10 007 BY: GARY ROTHMAN, ESQ.
U.S. DEPARTMENT OF JUSTICE U.S. Attorney's Office Southern District of New York 8 6 Chambers Street New York, New York 10 007 BY: LISA ZORNBERG, ESQ. Assistant U.S. Attorney
DINO J. LOMBARDI, ESQ. Attorney for Witness 5 2 Duane Street New York, New York 10 007 *
1 3 2 MR. MACK: Let's go on the 3 record. 4 Mr. Arguelles, good evening. My 5 name is Walter Mack, and I want to take 6 a few moments just to go through what's 7 happening tonight. And although most of 8 the people in the room, besides you and 9 I will tune out of this, and the court 10 reporter, there are important messages 11 in what I'm going to say. It is 12 important that you understand what is 13 happening, what your rights are, various 14 aspects of what we are going to do 15 tonight. It is important that some of 16 these matters be raised; and if you have 17 any questions about them, although 18 you're represented by experienced 19 counsel, so experienced that I will give 20 you a special little part which I will 21 talk to you about, what I call a 22 conflict; so it is important that you 23 listen. 24 If there are any questions that 25 you might have, please raise them. And
1 4 2 what I always say, or try to say, early 3 on, is, that if at any time you would 4 like to leave the room and have some 5 private moments with Mr. Lombardi to 6 discuss anything, that's your right to 7 do so, and I would encourage you to do 8 so, rather than guess or make an 9 assumption. You have the benefit of 10 counsel at your side, you might take 11 advantage of that when necessary; and I 12 will excuse you and give you whatever 13 time is necessary for you to get the 14 benefit of his advice. 15 To start from the beginning, my 16 name is Walter Mack; I'm the Independent 17 Investigator. I'm an agent of the 18 Court, Federal District Court Judge 19 Charles S. Haight, Jr., and although 20 there are representatives here who I 21 will introduce you to in a moment, from 22 the Government and from the District 23 Council, this is a proceeding conducted 24 at my request and pursuant to my rules 25 as an agent of the Court.
1 5 2 I have no independent authority 3 to discipline you, to prosecute you, or 4 to take adverse action against you 5 directly. So what I do have are 6 specific rights set forth in an Order 7 appointing me. And the right and the 8 authority that I have, most pertinent to 9 what we are doing tonight, is that when 10 I receive complaints about the conduct 11 of a carpenter, I have the ability to 12 choose to question that person under 13 oath, and you are amongst many. I want 14 you to understand that I didn't pick 15 your name out of a hat. It is because 16 your name has been given to me through 17 the operation of a hotline as to a 18 number of complaints, and you are among 19 many individuals as to whom I felt it 20 was important to hear from directly. 21 And once I hear your information, it is 22 very likely that it will be part of a 23 shop steward' report to Judge Haight in 24 which I comment on various practices and 25 things that I have found.
1 6
2 So that's a very general way of 3 telling you what we are about tonight, 4 and trying to put you at ease; you're 5 not alone here. The fact that you have 6 been singled out to spend the evening 7 with me, you are amongst an august 8 crowd; and the reason you're here is not 9 because your talent and skills as a shop 10 steward are at issue. There are some 11 questions that need to be dealt with, 12 and no matter what my personal opinions 13 may turn out to be, I have really no 14 authority to impose those; and whatever 15 decision, if any, would be made at the 16 conclusion of my work, will be made by 17 the judge with the help and maybe with 18 the participation of the Government, and 19 most importantly, the District Council, 20 who is responsible for conducting their 21 own disciplinary process and conducting 22 and managing the union. 23 The most important thing I say to 24 you to tonight is coming right now. You 25 will be placed under oath in a few
1 7 2 moments, and if there's some experience 3 to my approximately two years that I 4 have been at it, one stands out, and 5 some of the people in this room, 6 excluding your counsel, have been privy 7 to, recently, a whole series of 8 individuals who made the mistake of 9 lying under oath about subjects they 10 thought would never come out. The one 11 promise I make to everyone that lies 12 under oath or seeks to deceive me, is 13 that if I can resolve that, and it 14 appears to me after a pretty thorough 15 inquiry that an individual came in and 16 did not honor their oath, it is my 17 commitment that I will recommend that 18 that person be charged with perjury or 19 obstruction of justice. You're not 20 being singled out. I say this in one 21 form or another to every carpenter or 22 witness who appears here under oath. 23 There are times when I get frustrated 24 because some people are smart enough to 25 tell the truth, no matter who it helps
1 8 2 and hurts, no matter what the situation 3 may appear to be, and those people are 4 always better off than those individuals 5 who, in their first run-through, lie; 6 because the likelihood is, that in time, 7 one way or the other, the truth will 8 come out; and for each and every 9 individual who has lied under oath, it 10 is my commitment to them that I will 11 recommend -- I'm not a prosecutor, I 12 used to be a prosecutor -- I'm a defense 13 lawyer, so I understand both sides, to a 14 pretty good extent, about the issues. 15 What I really try to emphasize is 16 that it is far better for the witness, 17 for the carpenter, that when the 18 question is asked and answered, that the 19 truth, the whole truth, and nothing but 20 the truth be the result. We've had 21 pretty close to ten, we'll have ten more 22 people who did not follow that advice, 23 and who, in order to avoid being 24 prosecuted for perjury, have returned to 25 correct the record and apologize to me,
1 9 2 and through me to the judge, for 3 dishonoring their oath. I'm not going 4 to dwell on this, I'm not singling you 5 out. It is just a level of frustration 6 with me that individuals, who when they 7 had the first opportunity to deal with 8 the subject matter, have chosen to lie, 9 for whatever reasons. 10 The reasons appeared to be good, 11 and they are reasons such as, I'll get 12 kicked out of the union if I admit this, 13 I'll lose my job if I do this, I won't 14 be able to feed my family, I have to be 15 employed to deal with my 16 responsibilities. These are good 17 reasons, but when placed against lying 18 under oath to a federal officer or an 19 agent of the Court, all of those things 20 are in far greater jeopardy if the 21 person lies under oath. 22 I want to appeal to you. I'm 23 trying to be as clear as possible, so 24 you will tell me the truth. 25 One carpenter this week said,
1 10 2 Mr. Mack, if you were in the same 3 position as I was, if I told the truth, 4 I'll lose my job, wouldn't be able to 5 work in the industry again; and tears 6 welled up in his eyes when he was 7 speaking about it. 8 I said to him, in those 9 circumstances where you feel that the 10 issue is so significant, that's why you 11 have a lawyer to go to, to try to in 12 some way work out a method of trying to 13 protect that carpenter's livelihood and 14 what's happening, and deal with whatever 15 pressures and stresses may be out there. 16 What I said to him, and I say to 17 you, is this: There's no excuse for 18 lying under oath. I don't expect you to 19 lie under oath, but I want to make 20 certain I've done my level best to 21 ensure that should you lie under oath, 22 the potential penalty is a jail 23 sentence, and all of the things that may 24 be motivated for lying under oath, when 25 you put that against leaving and being
1 11 2 in the custody of the State or Federal 3 Government, it is not worth it. 4 There's always an answer to those 5 pressures, and you have an experienced 6 lawyer at your side should that be a 7 situation. I'm not suggesting that it 8 is, you can find a way to deal with that 9 challenge. 10 The other part of that, and 11 again, I don't want you to think that 12 I'm really throwing this on you, I try 13 to say this to every witness who 14 appears, I've had too many people lie 15 under oath. I'm recommending in the 16 very near future, in January, that some 17 people be indicted for perjury; not only 18 perjury, but obstruction of justice. 19 Obstruction of justice means that 20 if I'm conducting an investigation and 21 somebody withholds information from or 22 seeks to deceive me, lies to me, tells 23 me 6 0 percent of the truth, with intent 24 to prevent me from working out whatever; 25 that's obstructing a judicial officer,
1 12 2 and that is a federal offense. 3 I'm going to get off this topic, 4 because I expect you to tell me the 5 truth, and I expect you to honor your 6 oath. Sometimes my expectations have 7 not been fulfilled; I'm hoping and 8 begging and praying that in this 9 situation, they will be. 10 I do want to stress, I can only 11 recommend there will be a criminal 12 prosecution. There have been situations 13 where people have come in and felt that 14 is what the District Council, maybe the 15 Government, have said, that maybe what 16 Mack thinks, but basically, we have a 17 different viewpoint and we'll speak to 18 the judge about our viewpoint. The 19 lawyers for the individuals, it is not 20 Mr. Lombardi, at least, will have their 21 opportunity to speak to the judge as 22 well, about my recommendations. All I 23 can do is recommend. 24 Let me go through another thing. 25 Mr. Lombardi has probably covered this
1 13 2 topic with you. You have a Fifth 3 Amendment privilege as you sit here 4 today. I'm going to ask some pretty 5 broad questions that Mr. Lombardi has 6 heard before with respect to other 7 clients of his, and I'm going to get to 8 that. And you, because this is a 9 judicial proceeding, and not a 10 proceeding of the District Council, you 11 can determine, and I would encourage you 12 to have the benefit of Mr. Lombardi's 13 advice, that you don't want to answer 14 that question because it might tend to 15 incriminate you. That means that you 16 have gotten the benefit of legal advice, 17 because these are difficult questions, 18 not really that difficult, but it is 19 always better to have a lawyer's advice. 20 And so if I ask a question, if you know 21 your answer to it, an accurate answer, 22 would tend to incriminate you 23 personally, not somebody else, it is 24 yours not a right of yours not to 25 incriminate yourself, you can say: With
1 14 2 all due respect, you know, Mr. Mack, I 3 just don't want to answer that question 4 because it might tend to incriminate me. 5 You have that right, it is a 6 constitutional right. This is not a 7 criminal proceeding. I am not a 8 Prosecutor. But if it's a choice of 9 taking the Fifth Amendment or lying, 10 take the Fifth Amendment, because if you 11 lie, you are committing a crime. 12 So I will tell you this: You 13 should be aware, in all fairness, that 14 if you take the Fifth Amendment on a 15 topic which I think is of significance 16 to dealing with an issue within my 17 jurisdiction, such as wrongdoing on a 18 jobsite or something of that nature, the 19 likelihood is, very, very shortly 20 thereafter, that I will refer the matter 21 to-a prosecutor for their own 22 information and evaluation, because I 23 have an obligation, should there be some 24 evidence of criminal wrongdoing, and 25 sometimes that may be all it is, but
1 15 2 that's up to me, but I don't want you to 3 think that the topic ends there, once 4 you take the Fifth. 5 The District Council, although 6 I'm not entirely clear of their policy 7 on this topic, because it seems to 8 evolve, I think it is evolving in the 9 right direction, that they have the 10 right to ask you to appear before them, 11 and they do, or may not, maybe that's a 12 better way of putting it, recognize a 13 Fifth Amendment privilege, that if it's 14 carpenter business, I believe it is 15 their position they are entitled to have 16 that information in order to see that 17 the unions are run without criminal 18 involvement. 19 I'm going to let Mr. Rothman, if 20 he wishes to speak to that topic, speak 21 to it. I don't want you to think: I 22 take the Fifth Amendment and I can go 23 home. There' would be follow-up by me, 24 because I would try to persuade your 25 counsel rather than going that route, it
1 16 2 is better to tell me about the topic in 3 some way so the truth can be found. 4 My job is finding facts and 5 reporting them. It is not like you're 6 through with the issue, in fact, that 7 may just be the beginning. In terms of 8 evaluating: Should I lie to Mr. Mack or 9 take the Fifth Amendment? Take the 10 Fifth Amendment. Do not lie under oath, 11 because that's a crime, it is as 12 complete as of the moment that you say 13 something untrue. 14 I don't want you to be overly 15 concerned about this, because it is 16 really just the reality of a proceeding 17 conducted by a judicial officer. 18 This is a lot less formal than 19 being in a courtroom, and I'm acting as 20 his agent, and I'm trying to do what he 21 would expect me to do. If you do take 22 the Fifth Amendment, and let's say I 23 have information that certain conduct 24 occurred on the jobsite in which you 25 were shop steward, and I have a lot of
1 17 2 evidence about one site, and I say, 3 well, I want to know what Anthony has to 4 say about this topic, I want to hear his 5 side. You say, I'm taking the Fifth 6 Amendment, Mack, I'm not telling you my 7 side. I have the authority and I can 8 exercise my discretion and say, Anthony 9 had his, choice and therefore I'm going 10 to decide to infer that the guys who are 11 on the other side, telling me all this 12 stuff about the job, Anthony had his 13 chance, I'm going to conclude in my 14 report that in fact what the other 15 people on the jobsite said is true, is 16 true. That's basically permitting me to 17 draw an adverse inference to you, 18 because when you had the choice of 19 explaining, you took the Fifth. 20 Some of these subjects are 21 complex. I'm just a lawyer, not a 22 carpenter, but I'm trying to at least 23 raise the issue, so if you have a 24 question about the subject, you can talk 25 to Mr. Lombardi about it or raise it
1 18 2 with me, because the one thing that I 3 know the judge would be very unhappy 4 about, is if you were misinformed or had 5 a wrongful idea of your rights. 6 Finally, we'll get off what is 7 preliminary, I don't think this is news 8 to you, but it may be a novel concept, 9 and that is: Mr. Lombardi represents a 10 number of carpenters, and those 11 carpenters have appeared, and I'm sure 12 he has exercised his discretion and 13 utilized his professional skills to 14 represent them. While he is here today, 15 though, the only person that he has to 16 have concern about is you, that you 17 weather this inquiry and go through it, 18 as he's done with others, and it's at 19 least theoretically possible that one of 20 his other clients might have an adverse 21 position or have something to say about 22 a job that you were on that's not 23 consistent with your testimony. 24 So in the first instance, he 25 needs to evaluate, under the ethical
1 19 2 rules that the lawyers in this state run 3 by, whether he can represent you and not 4 be conflicted out. In other words, if 5 he had a client which you were 6 testifying against, I'm on this jobsite 7 and so-and-so did this, he would have a 8 real problem in trying the figure out 9 whether he can continue to represent you 10 or not. I don't know, nor do I want to 11 know, what you and he talk about, that's 12 his decision to start with. That's 13 called a conflict, hypothetical 14 conflict. Unless I knew all the 15 conversations he had with his clients, 16 which I don't know, I really can't make 17 that judgment. If there comes a point 18 where I realize you're testifying 19 against somebody, he can't possibly not 20 have a conflict. I don't know that. It 21 is up to him in the first instance. 22 The next obligation of his is to 23 discuss that issue with you, and for you 24 to decide, okay, I understand, 25 Mr. Lombardi has conflicts, but I think
1 20 2 he can represent me, I have confidence 3 in his defending me. Let's say you had 4 information about a contractor, let's 5 pick for instance, because it is one of 6 my favorites, okay, and if he had 7 represented a Prince person, or 8 something of that nature, he would have 9 a hard time not being in a conflict 10 position. Even I can figure that out 11 once I knew that he represented somebody 12 from Prince. 13 I'm not saying any of this is 14 true. In essence, I'm trying to give 15 you a hypothetical to recognize that he 16 has to be careful about: Don't say 17 anything about. Prince, Anthony, you can 18 talk about everybody else; Prince is my 19 guy, you can't talk about it. He would 20 have an ethical problem, and you would 21 have a significant criminal problem. 22 This area can be complex, it is not 23 really that difficult, it is really 24 common sense in many ways. I want to 25 make sure you discussed it with
1 21 2 Mr. Lombardi. If you haven't, you 3 should discuss it with him, and I want 4 to make sure you're content, given that 5 type of scenario, with proceeding today. 6 Have you discussed this potential 7 conflict with him, the situation? You 8 should say yes or no. If not, you 9 should -- 10 MR. ARGUELLES: I think we did. 11 MR. MACK: Do you want to talk 12 about it one more time? 13 MR. ARGUELLES: Sure. 14 MR. MACK: Step out and take a 15 moment. We'll wait for you to come 16 back. Take your time. 17 (Pause.) 18 MR. MACK: You've had a few 19 moments to discuss it with Mr. Lombardi. 20 Do you have any questions you want to 21 ask about the subject at all? That's 22 the first thing I should ask. 23 MR. ARGUELLES: No. 24 MR. MACK: Second of all, having 25 had the discussion, having thought about
1 22 2 it, are you willing to proceed tonight 3 with Mr. Lombardi as your lawyer? 4 MR. ARGUELLES: Yes. 5 MR. MACK: Fine. I'm going to 6 come back to you in a minute about 7 another topic. I want to introduce 8 everybody and ask Mr. Lombardi for his 9 wisdom, and any comment he would like to 10 impart before we begin. 11 MR. LOMBARDI: Nothing at this 12 time. 13 MR. MACK: You're content with 14 your situation on conflict? 15 MR. LOMBARDI: Yes. 16 MR. MACK: Fine. 17 Let me introduce the people. 18 Gary Rothman is a lawyer for the 19 District Council. He is here as my 20 guest, as is Lisa Zornberg, an Assistant 21 United States Attorney with the Civil 22 Division of the U.S. Attorney's Office, 23 but she , she's not a criminal Prosecutor, 24 does represent, as does Gary, the 25 parties in this litigation before Judge
1 23 2 Haight, which has gone on under the 3 Consent Decree for a long period of 4 time. And both of them, as parties, 5 have consented to my appointment, 6 resulting in the judge's Order. 7 They are here, both of them are 8 here to represent their clients, in 9 Gary's situation, the District Council, 10 the broad group. He doesn't represent 11 you directly, but you may wish to, with 12 your counsel, discuss issues about the 13 District Council with him. 14 Ms. Zornberg and Gary are here as 15 my guests. They will be given 16 opportunities to question, if there's 17 something that I have omitted or 18 something they feel that needs to be 19 clarified. 20 My main reason for doing that is 21 because many of my investigations take a 22 series of months. I have been talking 23 to shop stewards now pretty much during 24 the year 2004 , and I'm going to write a 25 shop steward report eventually. Rather 24 1 24 2 than causing them to be in ignorance of 3 my concerns about topics, by having them 4 as my guest, not only do they see I 5 don't overlook something or raise points 6 that should be raised that the judge 7 should hear, but they also have that 8 information available to them much 9 earlier than they would have if they 10 have to wait for my report. If there's 11 are changes that need to be made, they 12 - have the same information and are able 13 to use it. That's why they are here and 14 they are here at my invitation. They 15 may ask you some questions if there's 16 something that needs to be clarified. 17 Having made that introduction, 18 let me ask Mr. Rothman if he has any 19 comments he would like to make. 20 MR. ROTHMAN: Your right to 21 exercise your Fifth Amendment privilege 22 against self-incrimination, Mr. Mack 23 explained to you that if you do that, 24 and certainly it is your right to do so; 25 I would add that the likelihood is, if
1 25 2 you do that, that you would soon be 3 asked to come in to talk to the District 4 Council. The District Council, from 5 where you are appointed as a shop 6 steward, if you take the Fifth Amendment 7 here with respect to your duties as a 8 shop steward, the District Council would 9 be interested in talking to you about 10 that. 11 At the District Council, you 12 would not have the same Fifth Amendment 13 right, because you couldn't put yourself 14 in a position for criminal prosecution 15 from the District Council. One other 16 individual has exercised his right to 17 his Fifth Amendment privilege here, and 18 the District Council has suspended that 19 member's shop steward skill, pending the 20 completion of an investigation, or until 21 that person provides answers to the 22 questions so that the District Council 23 can determine whether it is appropriate 24 to continue to assign that person out as 25 a union shop steward.
1 2 6 2 So that you should just be aware 3 of that, and that could be something you 4 might factor into your consideration 5 with Mr. Lombardi, if the situation 6 presents itself. 7 MR. MACK: I'll add to that, I 8 think I said it, I want to reiterate it 9 in light of what Gary just said. 10 At any time tonight, not only can 11 you go out and talk to Mr. Lombardi 12 about any subject, but should you two 13 wish to discuss with Gary Rothman as the 14 attorney for the District Council, 15 hypotheticals or particular situations, 16 that's fine. He represents the District 17 Council and there may be information or 18 questions you may have. That's a right 19 I would give you, that opportunity, 20 during questioning tonight. 21 Anything else, Gary? 22 MR. ROTHMAN: That's it. 23 MR. MACK: Ms. Zornberg, anything 24 you would like to add or mention 25 concerning our preliminary proceedings
1 2 7 2 here? 3 MS. ZORNBERG: No. 4 MR. MACK: I want to cover a 5 couple of other things that may be 6 important. 7 These six files represent 8 complaints that have been made about 9 you, is what it boils down to, and the 10 various subjects, and I will tell you 11 what they generally are, and don't be 12 scared by the paperwork. We copy large 13 quantities to intimidate you. I'm 14 joking. There are various matters that 15 were put together. I want to say this. 16 There have been a number of people, most 17 of them anonymous, although some we know 18 who they are, who have made reports 19 about your activity as a shop steward. 20 I'm going to tell you the gist of what 21 those complaints are. And the reason I 22 say that is, I think it is very 23 important that the likelihood of my 24 knowing an accurate answer on questions 25 I ask you, some of the individuals have
1 2 8 2 come in and sort of gambled that I would 3 not figure it out, but the reality of it 4 is that, sooner or later, maybe not 5 immediately, you know, the truth comes 6 out. That's been my experience after 7 many, many years in the investigatory 8 area. 9 In your case, there are many 10 people that have had things to say about 11 you. That doesn't mean anything; that 12 may mean they're jealous of your 13 proficiency and honesty, what have you. 14 I'm going to give you the nature 15 of what they say, so that you have some 16 idea. Besides the most recent 17 interaction, which I'm going to ask you 18 about in a moment, the general subject 19 matter has been that your time as a shop 20 steward frequently was shorter than it 21 should be, that you would leave a job 22 early, or would not be present, and that 23 you would bestow favors upon the 24 contractors or give them benefits that 25 they were not entitled to have. That's
1 2 9 2 the general nature. Plus the fact, 3 significant complaints about your moving 4 from one, the Bloomberg Building, to 5 another Prince job. 6 I just wanted to point out to 7 you, a lot of questions are going to 8 deal with your service as a shop 9 steward. I think it is very, very 10 important that you listen to the 11 question, and make sure you answer 12 truthfully. I would say this: 13 Virtually every shop steward here has 14 gotten into trouble with me because they 15 have lied about questions I've asked 16 them. They have felt they didn't want 17 to admit something that happened, they 18 wanted to describe it in a way that 19 wasn't accurate. And so, I mean, I 20 really want to reach out to you and say, 21 that you're far better off in a 22 situation of just saying this is what 23 happened, because there's considerable 24 question, based upon my investigation, 25 about what's the right way to do things;
1 3 0 2 was this system the way it should be; 3 who told you what the system is. So if 4 it happened a certain way, it is for 5 other people to resolve whether that was 6 wrong at the time it happened or not. 7 And there's considerable question about 8 whether things -- whether this is the 9 right way, this is how you do something 10 or not. 11 So I guess what I'm saying is, 12 frequently, the subject matter is not 13 worthy of a lie. You just dig yourself 14 into a far deeper hole by talking about 15 something which there's considerable 16 question as to whether the matter was 17 wrong or incorrect at the time, or 18 something has changed. But by lying 19 about it and not being forthright and 20 saying yes, you're right, I did do this, 21 you know, this was the reason, those |