Deposition of Sibel Edmonds
August 8, 2009

This is an HTML version of the PDF transcription available online at BradBlog. The HTML has several advantages over the PDF:  itís easier to read, faster to open and search, and easier to copy text from. Before we get to it first a little background.

Sibel Edmonds is a former translator for the FBI.  While at the FBI she discovered that one of her co-workers was spying for Turkey. Later it became apparent that this involved widespread U.S. government corruption, not merely foreign spies. Because of this corruption Turkey and Israel clandestinely influenced U.S. foreign policy, and acquired U.S. nuclear bomb technology they eventually sold on the international black market.

Ms. Edmondsí attempt to speak out in a legal venue about these matters was defeated three times. When she brought suit against the FBI the government used State Secrets Privilege to get it thrown out. Her testimony before the 9/11 Commission was omitted from the final report. When her deposition was subpoenaed in a lawsuit brought by family members of 9/11 victims, the FBI and DOJ went to the judge and asked him to quash it, again based on State Secrets Privilege, which he did.

The springboard for her public testimony transcribed below was a minor lawsuit brought by one Ohio politician against another. Knowing why she was subpoenaed to testify will help make the transcript clearer.

In 2008 one David Krikorian ran as an Independent in Ohioís 2nd district against incumbent Republican, Rep. Jean Schmidt. The incumbent was reelected. Now some background. The U.S. Congress is infested with committees advocating the interests of other countries: the Congressional Nepal Caucus, the Congressional India Caucus, etc. Schmidt was co-chairman of the Congressional Turkish Committee. After the Ohio election Krikorian accused Schmidt of accepting an unusual amount of money from Turkish interests and suggested it was in return for her helping Congress avoid a resolution that would have declared the Turksí massacre of Armenians during WWI a ďgenocide.Ē

The 1915 massacre may not seem important today, especially in the U.S., but itís important to promoters of Turkey and Israel. (Why Israel? Perhaps because Israeli leaders want the Jewish holocaust to be unique, and because the Armenians were Christian and the instigators of the Armenian massacre were the ďYoung TurksĒ Ė Donmeh or DŲnme Ė descendents of Jewish converts of convenience, who by 1908 had overthrown the Ottoman sultan and established a government of their own. For a sympathetic history of the Young Turks see The DŲnme: Jewish Converts, Muslim Revolutionaries, and Secular Turks by Marc David Baer, Stanford University Press. Soon after the Russian Revolution of 1917 the Bolsheviks further helped establish the new Turkish government.)

For suggesting that she had conducted her campaign improperly Jean Schmidt sued David Krikorian before the Ohio Election Commission. In order to defend his statements about Turkish influence in Congress Krikorian asked the hearing committee to subpoena Sibel Edmonds, who had been outspoken against such influence. This time she was not blocked by the DOJ.  Such is the genesis of her deposition.

She testified under oath. To date, as might be expected from their past behavior, the FBI, DOJ and Congress have done nothing about her revelations, and the major media pathetically little. You wonít hear about her case from the so-called  ďAyn Rand Center for Individual RightsĒ  either.

Here then is the transcript, all on this one webpage, after a few explanatory remarks on the text.

Pagination follows the PDF. Line numbers have been removed. Inconsequential spacing, margins and indentation may differ from the original. Bolding has been added to emphasize some headings, color highlighting has been added to distinguish the labels identifying whoís talking, color dimming has been employed to de-emphasized page numbers. Three obvious transcription errors have been silently corrected, one of spelling and two of capitalization:  ďbenefittedĒ;  ď... to do it. they had ...Ē;  ď... so many ways. itís a very complicated ... .Ē  One missing closing double-quote has been added in square brackets.

For those unfamiliar with hearing transcripts, in the Examinations:
BY MR. ĎXí  on a line by itself identifies the attorney ĎXí questioning Sibel Edmonds.
Q  indicates a question by that attorney to Ms. Edmonds.
A  indicates her answer.
MR. ĎXí  indicates speech by attorney ĎXí to another attorney.
THE WITNESS  indicates speech by Ms. Edmonds not (formally) answering a Q.


page 1

BEFORE THE OHIO ELECTIONS COMMISSION

DEPOSITION




IN THE MATTER OF:
JEAN SCHMIDT, Plaintiff,

v.

DAVID KRIKORIAN, Defendant.

Case No. 2009E-003


Saturday,
August 8, 2009

National Whisteblowers Center
3238 P Street, N.W.
Washington, D.C.  20007

DEPOSITION OF:

SIBEL DENIZ EDMONDS

called for examination by Counsel for the Defendant, pursuant to Notice of Deposition, at the National Whistleblowers Center, located at 3238 P Street, N.W., Suite 690, Washington, D.C., when were present on behalf of the respective parties:


page 2

APPEARANCES:
On Behalf of Plaintiff Jean Schmidt:

    BRUCE FEIN, ESQ.
Of: Turkish American Legal Defense Fund
    Suite 1000
    1025 Connecticut Avenue, N.W.
    Washington, D.C. 20036
    (202) 370-1399, ext 3
    Web: bruce@thelichfieldgroup.com


On Behalf of Defendant David Krikorian:

    DAN MARINO, ESQ.
Of: Luque, Geragos & Marino, LLP
    Suite 800
    910 17th Street, N.W.
    Washington, D.C. 20006
    Tel: (202) 223-8888
    Fax: (202) 223-8677
    Web: dmarino@luquegeragos.com


On Behalf of Deponent Sibel Deniz Edmonds:

    MICHAEL D. KOHN, ESQ.
Of: Kohn, Kohn & Colapinto, LLP
    3233 P Street, N.W.
    Washington, D.C. 20007
    Tel: (202) 342-6980

page 3

TABLE OF CONTENTS


WITNESS DIRECT  CROSS  REDIRECT  RECROSS 
Sibel Deniz Edmonds6105190212

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

page 4

P R O C E E D I N G S

(10:32 a.m.)

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

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

MR. FEIN:  Could I interject an objection here?

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

MR. MARINO:  Why donít you --

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

MR. MARINO:  Why donít you go ahead and identify yourself?

MR. KRIKORIAN:  David Krikorian.

MR. MARINO:  Do you want to? Whoís the next gentleman?

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


page 5

MR. MARINO:  Iíd like to have everyone identify themselves.

MR. FEIN:  Sure.

MR. MARINO:  And youíre Mr.?

MR. FEIN:  Iím Mr. Bruce Fein. Iím counsel for Jean Schmidt in this proceeding.

MR. MARINO:  Okay.

MR. KOHN:  Iím Michael Kohn with Kohn, Kohn & Colapinto, representing the witness Sibel Edmonds, and with me are three law clerks. Thatís it.

VIDEO OPERATOR:  Thank you.

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

THE REPORTER:  Would you please raise your right hand?

Whereupon,

SIBEL DENIZ EDMONDS
was called as a witness by counsel for the Defendant and, having been first duly sworn, was examined and testified as follows:
page 6

DIRECT EXAMINATION


BY MR. MARINO:

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

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

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

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

BY MR. MARINO:

Q:  Iíd like to show you whatís been marked --


page 7

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

BY MR. MARINO:

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

Have you seen that before?

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

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

BY MR. MARINO:


page 8

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

A:  Correct.

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

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

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


page 9

which made quite clear that the Ohio Elections Commission was not ordering Ms. Edmonds to appear, that the Justice Department also considered the subpoena that was issued to her here, and that if she wanted to come to Ohio and they wanted to issue a subpoena in Ohio, thatís up to them.

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

MR. KOHN:  Well, I guess you donít understand ďcourtesyĒ within the legal community --

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


page 10

deposition today.

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

BY MR. MARINO:

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

And I do want to sort of advise you that until the last couple of days, I really had heard nothing about this case, and so some of my questions are going to seem somewhat elementary, and itís not because Iím playing Colombo or anything like that. Itís just because I really donít know the


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information.

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

Have you had your deposition taken before?

A:  In business maybe.

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

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


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

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

A:  Correct.

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

ďAre you a lifetime Cincinnati area resident or did you move here at some point?Ē

Mr. Krikorianís attorney, Mr. Finney, ďObjection. What does this have to do with the case?Ē


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

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

BY MR. MARINO:

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

A:  Yes.

Q:  And you ultimately moved to Turkey


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at some point; is that correct?

A:  Correct, because I --

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

BY MR. MARINO:

Q:  Iím sorry. I didnít get the answer.

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

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

A:  Correct.

Q:  What are --

MR. FEIN:  Objection.

BY MR. MARINO:

Q:  -- those languages?

A:  Turkish is my primary, my mother


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language.

Q:  Okay.

A:  After that, Farsi. Thatís the language spoken in Iran.

Q:  Okay.

A:  And I also have conversational abilities in Azerbaijani.

MR. FEIN:  I just interpose a standing objection so we can move along on relevance grounds that I donít believe that thereís been any establishment that the witness knows anything about the allegations in the complaint. So just to speed things along, Iíll have a standing objection on relevance to every single question asked until thereís some connection between her knowledge of the complaint and the question that relates to the facts in the complaint.

BY MR. MARINO:

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

A:  Correct.


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Q:  And when was that?

A:  1988, July 1988.

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

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

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

A:  Correct.

Q:  And when was that?

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

Q:  And when you became employed at


page 17

the FBI, did you receive a top secret security clearance?

A:  Yes, I did.

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

A:  Okay. I will try to summarize the story so itís not -- it wonít take too long. When I was studying for my Bachelorís degree, criminal justice/psychology, I had applied for internship position with the FBI, and this would be around í97, 1997, 1998, and they never responded to me and except that they were interested in my linguistic abilities because I spoke Turkish and Farsi.

And then I didnít hear back from them, and I was contacted around September 11, 2001, and they said they had obtained top secret clearance for me, and they needed my services for translation in Turkish and Farsi, and they wanted me to start immediately, and because I couldnít work full time, I took the contractorís position with the FBI for


page 18

translation of those languages, and to a certain degree Azerbaijani.

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

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

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

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

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


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to telephone conversations, other types of intercepted conversations that are in foreign languages --

MR. FEIN:  Leading question.

BY MR. MARINO:

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

MR. FEIN:  Objection. Leading.

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

MR. MARINO:  And --

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

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


page 20

the past the chance to work with intelligence officers in these kinds of cases, and I realize that you canít get into sources and methods and so forth. If Iím straying into that area in any way, just let me know and Iíll back off.

BY MR. MARINO:

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

A:  Correct.

Q:  And that would include Turkish organizations?

A:  Correct.

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

A:  April 2002.

Q:  All right. And so from September


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of 2001 until April 2002, you were engaged in this activity of listening to and translating documents and conversation audio, correct?

A:  Correct.

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

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

Q:  So all three of those.

A:  Correct.

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

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


page 22

I used to work for the FBI.

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

A:  Correct, but because the targets could also speak English, and this couldnít have been known to the FBI agents until I first went through the information, I also had to transcribe and make notes of pertinent conversation, pieces of conversation in English also. So I had to listen to a lot of English conversation and notify my bosses in the FBI of the ones that were very important.

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

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


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Division in the FBIís Washington field office, and a few weeks after this person, Melek Can Dickerson -- M-e-l-e-k, middle name C-a-n, last name Dickerson, D-i-c-k-e-r-s-o-n -- and she also had top security clearance.

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

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


page 24

Turkey Republics in Central Asia; both husband and wife, Melek Can Dickerson and her husband, they were still associating and had working relationships with these Turkish entities, individuals and organizations that were the targets of FBI investigations.

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

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


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So thatís a public document report.

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

A:  Correct.

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

A:  Correct.

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

A:  Correct.

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

A:  Correct.

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


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

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

A:  Yes.

Q:  Were there others?

A:  Yes.

Q:  Can you identify them, please?

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

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

A:  Yes.


page 27

Q:  What does that mean to you?

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

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

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

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

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


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which is -- directly works with the diplomatic community in the United States, Turkish diplomatic community, that is. ATAA was another umbrella under which there are various locations and chapters, such as ATA Chicago, ATA Patterson, New Jersey, ATA D.C., and also some that are identified as cultural, such as TACA, Turkish American Cultural Association. There are hundreds of small chapters, and I donít know some of these, but the main ones would be American Turkish Council, ATAA, ATA and its various chapters throughout the country in the United States, TACA. Turkish American Business Association is another primary one.

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

A:  I believe thatís what it is.

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

A:  Just through some cursory reading recently.


page 29

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

A:  I donít recall.

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

A:  I havenít met him personally.

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

A:  I just -- I didnít know that.

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

A:  Okay. Can you repeat that question?

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


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Turkish lobby and there were covert forms. The organizations we were talking about, are they part of the overt Turkish lobby, if you will?

A:  They are part of both overt and covert.

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

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

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


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

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

A:  Correct.

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

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

Q:  Okay.

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


page 32

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

A:  Yeah, social visit they said.

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

A:  Yes, I did.

Q:  For what?

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

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

A:  Absolutely, yes.

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

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


page 33

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

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

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

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

I say ďsubchapterĒ because even though itís not known, ATA is not formally


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known as American Turkish Councilís subchapter, but they do a lot of activities through ATA in various cities and states in the United States, and those individuals were involved in operations that were counterintelligence related, and not -- if they were against the United States interest on security,

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

A:  There were several people.

Q:  And again, just because I donít know, to your knowledge, was the American Turkish Council an organization that was supported by the Turkish government?

A:  I donít know directly, but indirectly --

MR. FEIN:  Thatís conjecture.

THE WITNESS:  -- I mean --


page 35

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

THE WITNESS:  Based on --

MR. MARINO:  You can answer the question --

THE WITNESS:  Based on my personal --

MR. MARINO:  -- just as I asked it.

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

BY MR. MARINO:

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

A:  Without getting into specifics,


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itís hard to explain. They could arrange for intermediary business individuals to make payments for certain activities, lobbying activities or intelligence gathering activities or activities involved in weapon procurement deals between Turkey and the United States.

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

A:  Money when they could, yes.

Q:  So if I said that the American Turkish Council, for example, was an organization supported by the Turkish government, that wouldnít be an unreasonable assumption?

A:  Correct.

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

A:  They were all receiving -- the


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ones that I knew of, yes, theoretically.

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

MR. MARINO:  Okay.

MR. FEIN:  Is that the question and answer?

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

BY MR. MARINO:

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

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


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the way up to the FBI Headquarters -- there was environmental (phonetic) panic. The agent I worked with, Special Agent Dennis Sharshar, informed the counterespionage section, department of the FBI; write a letter to the FBI Headquarters, and he also asked for immediate damage assessment because some of the -- our FBIís counterintelligence primary targets -- the targets were graded in different -- they have different rates -- some primary targets were the ones that Ms. Dickerson was working with closely, and she and her husband associating, but that was the initial response.

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

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


page 39

interrogation. They called it the surprise interrogation session with her that they set up, but they were prevented from pursuing it later.

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

A:  Correct.

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

A:  Yes, I was absolutely truthful.

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

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


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joint operations in Central Asia and Middle East, the front companies for construction or road building, et cetera, and to be able to secure these grants from Congress for those front organizations.

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

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

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

Q:  Can you identify those?

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


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of criminal gangs would be the best way to describe them that may or may not be independent from the central government.

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

A:  Correct.

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

A:  Correct.

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

A:  Correct.

Q:  Now, am I correct that -- I know you donít work for the FBI now, but would you consider yourself sort of still involved in some of the issues that weíve been discussing?


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A:  Somewhat, yes.

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

A:  Yes.

Q:  You post material on that?

A:  Yes.

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

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

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

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


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Inspector Generalís Office, and to the FBI and the Justice Department itself, and basically it acts as a gag order, and the only justification the U.S. government provided for it was ďshe may be right with whatever she knows and she believes is important and crucial, but because the information she has may threaten and affect certain U.S. diplomatic relations and national security, we are asking the courts and the Congress as executive privilege called State Secrets Privilege.[Ē]

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

A:  Correct.

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

A:  And my First Amendment rights, correct.

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


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Privilege to get that lawsuit thrown out.

A:  The first invocation, yes.

Q:  Was there a second invocation?

A:  Yes. I was -- my deposition was subpoenaed by a law firm called Motley Rice. I think itís M-o-t-l-e-y, second word R-i-c-e, who represented thousands of 9/11 victimsí family members, and they subpoenaed my deposition, and I believe this was in 2004. That was when the government, FBI and the Justice Department, went to the judge who was sitting on my case, and asked him to quash it based on State Secrets Privilege, and they cited the State Secrets Privilege together with affidavits from the various individuals in the Justice Department, including the Attorney General, and asked the judge to quash that deposition for the second time.

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


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

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

A:  Macro level, yes. I didnít know what they were planning to ask specifically, but it has to do with certain Turkish lobby and organizations in the United States who also had certain dealings with Saudi Arabian related financial and lobby organizations in the United States and cases that would have been -- that would have involved both Saudi Arabia and Turkey jointly were doing certain things here in the United States, but also outside the United States.

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

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


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questions, and they said all those questions are classified and covered by the State Secrets Privilege and they invoked
(inaudible.)

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

A:  Yes.

Q:  Is Dan Burton one of the people whoís in the gallery?

A:  His picture is there, yes.

Q:  Okay. Why is his picture there?

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


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foreign entities against the United Statesí interests.

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

A:  I believe he is.

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

A:  Yes.

Q:  Okay, and why is his photograph there?

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

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


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Illinois?

A:  At the time he was.

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

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

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

MR. FEIN:  Leading question.

BY MR. MARINO:


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Q:  -- money from these Turkish organizations?

A:  Yes, I do.

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

MR. FEIN:  Thatís pure conjecture. The individual --

THE WITNESS:  No.

MR. FEIN:  -- is totally irrelevant.

BY MR. MARINO:

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

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


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blackmailed for various reasons.

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

A:  He used to be.

Q:  Was, right?

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

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

A:  Thatís what I have read and it was announced, yes, he is.

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

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


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Congress, and including blackmail, in certain members of Congress.

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

A:  And the Turkish government, correct, both.

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

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

THE WITNESS:  Absolutely, yes.

BY MR. MARINO:

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

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


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

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

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

MR. KOHN:  To the extent she can answer that question without -- why donít we just withdraw that question?

MR. MARINO:  Okay. Thatís fair enough.

BY MR. MARINO:

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

A:  Yes.

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


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A:  Correct.

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

A:  Yes.

Q:  Why is he in your gallery?

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

Q:  When you say ďas an operative,Ē what do you mean by that?

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

Q:  Sure.

A:  Just a hypothetical example or --

Q:  Itís okay with me.

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


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is able to as an operative to launder money by foreign entities that were obtained illegally, and some of them had to do with narcotics, and used these Cayman Islands offshore accounts to do that, and then some of that money goes to the congressional people, I would call that not overt. I would call that covert operations, covert operative, operations for that person rather than the classic lobbying operation.

MR. MARINO:  All right. Weíve been going for about 55 minutes. Why donít we take a break, ten-minute break?

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

BY MR. MARINO:

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

A:  Once in a while I do. I donít know when was the last time, but maybe a year


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ago.

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

A:  No. I know many people, they give me mainstream media articles or any reports. They put it in there, but, no, I havenít contributed.

Q:  When youíve looked at it, have you thought that itís generally accurate about most of the statements?

A:  Yes, generally, yes.

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

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


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had been infiltrated by a Turkish and Israeli run intelligence network that paid high ranking American officials to steal nuclear weapons secrets,Ē and they have some footnotes for that, some cites.

Is that correct that youíve made those allegations?

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

Q:  And what is that place?

A:  That would be RAND Corporation.

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

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


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executively appointed officials, foreign entities, not necessarily or not only government related; so if you say Israel and Turkey, not only government but other entities because it has multi-layers.

Q:  All right.

A:  Their operations, and some of these layers sometimes they conduct their operations independently and with the sole purpose of obtaining a profit, and therefore, the information they obtain, letís say, the nuclear or weapons technology, weapons technology related information doesnít necessarily only go to Turkey or Israel, but they sell it to the highest bidder. Thatís how they operate. They contact their people whether itís in ISI, in Washington, D.C. part of the military attache for Pakistani intelligence, or the certain Saudi business people in Detroit may be contacted, and they say, okay, and talk about these Turkish entities. This is we have obtained this


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particular DVD containing this, and this person is willing to pay 500,000. Will you offer more because if you donít, we will give it to this person.

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

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

A:  That person has been identified by others.

Q:  Okay.


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

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

A:  Yes.

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

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

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

A:  Yes.

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


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recall?

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

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

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


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consulting or analyst firm, and there were certain nuclear related operatives who wanted to hire Brewster Jennings and have it pose as a front company.

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

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

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


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brought to the attention of anybody at any point?

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

Q:  Yes.

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

Q:  Right.

A:  No, I didnít do it inside the FBI because at that point I didnít know they were covering up this information. Only after I was fired and the State Secrets Privilege was invoked, and knowing what I knew, I went to Congress and discussed it with certain people in Congress. I brought it up with the Inspector Generalís Office inside during a meeting, and at that point will provide them the details in terms of dates and who were those targets, which I canít provide right now, the direct targets.

Q:  And when you say ďthe Inspector Generalís Office,Ē do you mean a DOJ Inspector


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General?

A:  Correct. Iím sorry. Glenn Fineís, under Glenn Fineís office.

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

A:  There were various relationships and various activities Mr. Grossman was engaged with these individuals, and I donít know which reasons was the top reason for him to do it. Some of them were the monetary relationship, but others dated back to operations that he was leading while he was an ambassador in -- U.S. ambassador in Ankara, in Turkey, until 1997, and some of these operatives dealt with him, and they were doing certain operations in Central Asia for him.

I donít know who he was working for, Mr. Grossman, at the time for his operations.

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


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donít know which one constitutes the biggest reason he was providing this.

Q:  Just going back to the Israeli, weíve talked mostly about the Turkish organizations.

A:  Yes.

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

A:  Not directly, not directly.

Q:  Indirectly?

A:  Indirectly, based on how they work, some of the largest Israeli lobby groups with the entities such as ATC and also the Turkish diplomatic community and how they actually trained and make it possible for the Turkish lobby and these entities to do it. They had training period in í96 and í98 from individuals that were sent to them from both APAC and JINSA, both the lobbying, but also on covering the money track, covering up the


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money track.

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

The entry says, ďEdmonds also accuses Dennis Hastert of taking bribes.Ē I think weíve talked about that; is that correct?

A:  Yes.

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

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

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


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independent operatives.

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

Did you -- did you make that claim?

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

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


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the Inspector Generalís Office. He gave them the documents, the translated documents on the Iranians.

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

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

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


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Q:  Weíve talked about some members of Congress having connections with the Turkish government or Turkish organizations. Are there others that youíre aware of other than the ones weíve discussed already?

A:  Congressional members?

Q:  Congressional members.

A:  Yes.

Q:  Can you identify some of them?

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

Q:  I just -- I looked at the Website but didnít recognize --

A:  Okay.

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

A:  Others have been -- theyíre all identified as public information.

Q:  Yes.

A:  Tom Lantos is one of them.


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Q:  All right.

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

Roy Blunt is there. There have been individuals with a question mark there. The reason thereís a question mark is I lacked -- I was terminated by April 2002, but this particular Congresswoman -- the Turkish -- these Turkish organizations and operatives, if they canít do it by money, they do by blackmail. So they collect information on sexual lives and other information like that, and with this particular Congresswoman, it being 2000 until I left, they -- this individual, this Congresswomanís married with children, grown children, but she is bisexual.


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So they have sent Turkish female agents, and that Turkish female agents work for Turkish government, and have sexual relationship with this Congresswoman in her townhouse actually in this area, and the entire episodes of their sexual conduct was being filmed because the entire house, this Congressional womanís house was bugged. So they have all that documented to be used for certain things that they wanted to request when I left. So I donít know whether she -- that Congresswoman complied and gave. Thatís why I couldnít use her name because I donít -- I meant her face because I donít know if she did anything illegal afterwards.

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


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these Turkish entities ran certain illegal operations, and they wanted her husbandís help. But I donít know if she provided them with those. I left. I was terminated.

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

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

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

Q:  All right. So just to make sure I


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understand this, the Turkish entities were at least preparing to blackmail this Congresswoman.

A:  Correct.

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

A:  Yes.

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

A:  I donít know what reasons they had, why they just didnít do money. They needed -- I was trained as a language specialist by my agent for -- to find personal information, and one of the things that we was taught in the FBI -- everyone was taught in the counterintelligence -- that the target U.S. persons, whether they are in Congress or executive branch or whatever, first go by foreign entities to what they refer to as hooking period, and it was very common; itís a very common way of trying to find vulnerability, and that is sexual, financial,


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any other kinds of greeds, and it was -- it was done a lot, was being done a lot, and in some cases certain people from Pentagon would send a list of individuals with access to sensitive data, whether weapons technology or nuclear technology, and this information would include all their sexual preference, how much they owed on their homes, if they have gambling issues, and the State Department, high level State Department person would provide it to these foreign operatives, and those foreign operatives then would go and hook those Pentagon people, whether they were at RAND or some other Air Force base.

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


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information. It always worked for them. So it was not always money.

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

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

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


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of Congress by Turkish entities?

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

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

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


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Q:  With respect to the Congresswoman who they were -- you donít know what happened ultimately because you left, right?

A:  Correct.

Q:  Or you were terminated.

A:  Correct.

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

A:  Yes.

Q:  -- to oppose the Armenian genocide resolution.

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

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

A:  Not at all.

Q:  Why not?


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

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

MR. FEIN:  Objection. Speculation.

MR. MARINO:  You can answer.

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


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because I donít know whether she complied with their -- but those are everything that -- those people are all there, that Website pictures.

BY MR. MARINO:

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

A:  In terms of historically?

Q:  Historically what it is.

A:  Itís the genocide that the -- that was committed in Turkey against Armenians, and there -- I have read certain documents, historical documents in the past because this issue I have been aware of for a long time. Everybody in Turkey, they kind of know but they canít admit they know, and itís basically what was available in Turkey was very limited. So my knowledge would be just very, very limited knowledge of what occurred.

Q:  All right. So just based upon,


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you know, your background, your experience, in your opinion is the Armenian genocide something thatís generally accepted as an historical fact?

A:  In Turkey?

Q:  Yeah.

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

Q:  What about elsewhere?

A:  In other countries like --

Q:  Outside of Turkey.

A:  -- outside Turkey?

Q:  Yeah.

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

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

A:  Correct.

Q:  -- as something that happened.

Are you aware of anyone and


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serious scholars, serious people who dispute that those genocides took place?

A:  Throughout the years, because I used to be on the E-mail list of certain student associations that have international students, so I would get from the Turkish parts of those communities E-mails from this professor or that from Turkey visiting to give that lecture, but I donít even remember their names of those people.

Is that the question? Did that answer the question?

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

A:  I did.

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

A:  Absolutely.

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


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genocide took place?

A:  Iím not.

Q:  Why is Roy Blunt in your gallery?

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

Q:  And what foreign entities?

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


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campaigns.

Q:  Are you familiar with some of those PACs?

A:  No, not really.

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

A:  Yeah.

Q:  So, I mean, youíre aware that the PACs exist, but you wouldnít be able to identify any of them?

A:  Correct, not by names, correct.

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

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


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government of Turkey, and he is registered under Foreign Agentís Registration Act.

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

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

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

A:  Yes, I do.

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


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Turkish organizations?

A:  No, I just have (unintelligible) information based on what I read that he joined the lobby firm for -- that represents Turkey, the lobby that Mr. Hastert got hired, but I donít have any information.

Q:  For the firm called DLA Piper?

A:  Yes.

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

A:  Yes.

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

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

She meets with Livingston and


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Rogers or Livingston Group when theyíre escorting members of the Turkish parliament to a reception. She receives fact sheets from the Livingston Group talking about Turkish relations; goes to luncheons in honor of the Turkish Foreign Minister, and she opposes Armenian genocide resolution and, in fact, refuses to even recognize the genocide as a historical fact.

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

MR. FEIN:  Object. Thereís no showing at all that sheís got any expertise. Itís speculation here. Heís asking purely for an opinion. Itís totally irrelevant and objectionable.

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


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classic fit of how individuals who happen to owe their position and favors to a foreign government, in this particular case Turkey, behave at and the kinds of people they associate with. That modus operandi classically matches of the individuals I know who were serving Turkish governmentís and other Turkish entitiesí interest.

BY MR. MARINO:

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

MR. FEIN:  Objection. Pure speculation?

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


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us, and that has been the case at least up till 2002.

BY MR. MARINO:

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

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

A:  Some of it.

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

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

THE WITNESS:  Sure.

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

(Whereupon, the foregoing matter


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went off the record at 12:16 p.m. and went back on the record at 12:27 p.m.)

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

BY MR. MARINO:

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

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


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inimical to American interests and had, in fact, resulted in both the direct and indirect loss of American lives.Ē

Do you recall saying that in your declaration?

A:  Yes.

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

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


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then to Turkey to give them passports, and then funnel them in 1997, 1998 to certain Eastern European countries and the Balkans.

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

Q:  Okay. Well, I donít want to burden you too much, but I would like as complete an answer as you can give us in terms of what you were referring to.

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

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


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information, and not only for Turkey, but passing this information to what they refer to as highest bidders and whoever bid highest, whether these people were nation-states or they were just individuals that they were pursuing under counterterrorism after September 11. That would be another example of activities that they were involved that were against the security and the interest of the Americans with cost in terms of lives.

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

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


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damage to asset both in terms of effectiveness, which was neutralized and that Brewster Jenningsí front company for CIA have to be immediately absolved that summer after this information was obtained, but also they were accessing U.S. people who were compromised because of that by -- within these foreign governments. Thatís another.

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

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


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the mujahideen.

A:  Correct.

Q:  Itís now called al-Qaeda.

A:  Right.

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

A:  Correct.

Q:  And that cost American lives?

A:  Correct.

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

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


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bringing in heroin from source from Afghanistan to Turkey, but from Turkey into both United States, but also directly to Belgium, large quantity, very, very large quantity of heroin.

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

A:  Correct.

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

A:  Yes.

Q:  Can you tell us who that is?

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


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religious activist figure in Turkey, and he landed on Turkish governmentís wanted list and was going to be persecuted for wanting to throw Turkish secular government -- replace it with Islamic shariah kind of type of government.

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

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


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billion.

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

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


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Islam.

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

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

Let me ask a different question.

A:  Okay.

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

A:  One hundred percent, absolutely.

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


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

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

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

A:  Yes.

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

A:  Iím not sure. I know of some in


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Texas. I know one in Virginia, but I donít know. They are multiplying, and theyíre spreading rapidly. Thereís Islamic madrasahs or universities everywhere. So I havenít kept track of the locations. I donít know.

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

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

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

Q:  All right. Thatís fair enough. I take it then from what youíve told me that the


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people youíve identified, the people that youíve talked about today youíre certain about.

A:  Yes.

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

A:  No.

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

(Pause in proceedings.)

BY MR. MARINO:

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

A:  Not directly.

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

A:  No.

Q:  Caused a loss of American lives?

A:  No. And not only American lives.


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Even in other countries and some innocent Turkish lives, too, but American lives, too, yes.

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

A:  None whatsoever.

Q:  Iíve asked you about members of Congress, but I havenít asked you about staff. Are you aware of senior staff for members of Congress who have also been corrupted by the Turkish government?

A:  Absolutely.

Q:  Can you identify them?

A:  The pictures are there.

Q:  Who is Larry Franklin?

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


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believe, Israeli lobby ATAC. Active participants in ATC, American Turkish Council around these Turkish operatives.

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

MR. FEIN:  I have many questions, but I donít know whether you want to take a break yet. I suspect the questions may be at least an hour or two hours. So you need to estimate whether you want to break now or whatever you want to do or whatever counsel wants to do as well.

MR. MARINO:  Yeah, weíll take a lunch break.

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

THE WITNESS:  How long for?

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


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to counsel here. Whatever you want is fine.

MR. MARINO:  Well, I think personally I always ask the witness how much time she wants, and then I ask the court reporters because theyíre captives here. So I always try to -- yeah, why donít we go off the record?

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


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AFTERNOON SESSION

(1:31 p.m.)
Whereupon,
SIBEL DENIZ EDMONDS
resumed as a witness called by counsel for the Defendant and, having been previously duly sworn, was examined and testified further as follows:

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

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

MR. MARINO:  Thank you.


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MR. FEIN:  I guess weíre beginning the afternoon session.

CROSS EXAMINATION

BY MR. FEIN:

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

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

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

Q:  And how did you learn of that?

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

Q:  And who spoke to you?

A:  I spoke with Mr. Krikorian.

Q:  And what did he ask you to do?

A:  He asked whether I would be


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available to be deposed if he and his attorneys before the trial they were going to have would want to seek my deposition.

Q:  And what did you respond?

A:  I donít recall exactly, but I said -- I said, well, if I get a subpoena or just let me know what it is, then I will speak with my attorneys.

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

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

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

A:  Do you mean the actual legal


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complaint?

Q:  Yes.

A:  No.

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

A:  No.

Q:  So you donít know whatís actually in the complaint; is that correct?

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

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

MR. KOHN:  Objection.

MR. FEIN:  I apologize.

MR. KOHN:  Asked and answered.

MR. FEIN:  Well, I apologize.

BY MR. FEIN:

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


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deposed, did you say yes?

MR. KOHN:  Asked and answered.

BY MR. FEIN:

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

A:  I read the letter.

Q:  So that you knew that you didnít have to appear here.

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

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

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

MR. FEIN:  Okay. Go ahead and


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answer.

MR. KOHN:  What is the question?

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

MR. KOHN:  Do you have a copy?

MR. FEIN:  -- enforce the subpoena?

What?

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

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

MR. FEIN:  I think it speaks for itself.

THE WITNESS:  I read the letter.


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BY MR. FEIN:

Q:  So in your view are you here voluntarily?

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

MR. FEIN:  I know.

BY MR. FEIN:

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

MR. KOHN:  -- is under --

BY MR. FEIN:

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

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

MR. FEIN:  Sure.

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


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MR. FEIN:  No.

MR. KOHN:  I agree.

MR. FEIN:  Itís not -- go ahead.

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

BY MR. FEIN:

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

A:  Can you be more specific?

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

A:  I have responded to requests about comments about today as I donít know. There are going to be questions, and I donít know what questions Iím going to be asked, and after it is over and before, my attorneys will be present to make comments.


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

A:  To -- you mean this --

Q:  Mr. Krikorian.

A:  You mean what Iím going to say during deposition today?

Q:  Yes.

A:  No, no.

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

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

A:  I have --

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

MR. FEIN:  No, I donít want an attorney. I donít want client -- attorney-


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client privilege.

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

BY MR. FEIN:

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

A:  Around that time.

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

A:  Yes.

Q:  And where were you employed?

A:  Had my own company with my husband.

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

A:  Technology for retail industry.

Q:  And when was that company formed?

A:  About 1996.

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


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was registered?

A:  I believe Alexandria, Virginia.

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

A:  Marketing.

Q:  Marketing.

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

Q:  Iím -- could you be a little more specific? Youíre saying itís a market -- itís a retail marketing company. Do you offer your services to retailers? Do you actually sell retail items?

MR. KOHN:  Do you have a relevant question?

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

MR. MARINO:  I object. Itís outside the scope of the direct examination.

THE WITNESS:  The position I had


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involved providing inventory, supply chain management related software and services, IT services for retail chains.

BY MR. FEIN:

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

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

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

A:  IT services.

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

A:  No.

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

A:  No.

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


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A:  Thirty-one.

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

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

MR. MARINO:  Objection. Compound.

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

BY MR. FEIN:

Q:  Could you be more explicit? Whatís citizen journalism? Iím not familiar with that concept. If you could, explain that concept to me.

A:  Conducting research and write


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editorial pieces, whether the political situation in Iran or whether the articles I had written or meetings I have discussed, the journalists -- protection of journalists in Turkey, other human rights, because of the -- my involvement with Committee to Protect Journalists, political and civil liberties related issues.

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

A:  I had not published any books.

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

A:  Itís hard for me to tell how many of the stuff I had written have been picked up by international press, whether in Turkey or elsewhere. I have to check. I donít know.

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


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articles and they tell you itís going to be published or not.

Did you have any such arrangement with any publication?

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

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

MR. KOHN:  Can we have a time period?

MR. FEIN:  The time period when you were working on your -- with your company. I guess it began in í96.

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


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estate related businesses.

It depends. During, between í96 and í99 for Alexandria Court and sexually abused children I would spend about 15 hours a week working on that case. On researching and writing and reading about political related issues, including journalism, civil liberties, during that period of time itís hard to estimate. I would say in the range of maybe ten hours a week.

BY MR. FEIN:

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

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

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

A:  When they advertised and told me


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about it, no, but upon my hiring --

Q:  Thatís -- thatís a good enough answer. And was that --

MR. KOHN:  Had you completed your answer?

THE WITNESS:  No.

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

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


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Wolves, Turkey, Turkish ultra nationalists.

So I donít know how much role it played, his opinion, but that was one of the criteria that he wanted to have for his translator.

BY MR. FEIN:

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

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

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

A:  After my application, yes.

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

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


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me to start immediately. So as I was working, they were actually completing my contract. My contract was not completed because they wanted me to start immediately.

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

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

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

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

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

A:  As far as I know, they donít have


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it for contractors. They have it for full-time employees.

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

A:  I was a contractor.

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

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

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

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

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

Q:  Okay. Letís go -- Iíll -- Iíll -- letís go thought item by item. What was your compensation rate?

A:  I donít recall exactly. It was in


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the range of 35 to $40 per hour.

Q:  So they paid you on an hourly basis.

A:  Correct.

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

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

Q:  Did you actually apply for a full-


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time position?

A:  No.

Q:  No.

A:  They couldnít pay me enough. I couldnít do that.

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

A:  They told me everything was up to me because they couldnít find someone with my expertise in language skills and the background checks. So anything I could do, even if it was ten hours I could spare, would be great because they wanted me to work for them full time or overtime.

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

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


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time period, correct. I donít remember what it was.

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

A:  That may have been the case. It was eight years ago. I donít recall.

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

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

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


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MR. KOHN:  She was a contract employee.

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

BY MR. FEIN:

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

A:  Independent contractor.

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

A:  No.

MR. KOHN:  I presume youíre


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talking in her area.

MR. MARINO:  Yeah, in -- in --

THE WITNESS:  Language.

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

THE WITNESS:  No. I know several. There were more than 200, 300 people in that department, combination of full time and contractors, and my knowledge is limited to the Farsi Department and maybe Turkish Department because things were changing. Some people would start as contractors and wanted to work full time. So I canít give you an exact number.

BY MR. FEIN:

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

A:  I donít.

Q:  You didnít know?


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A:  I didnít know.

Q:  You didnít know about any other kind of arrangement. And tell me exactly what were the work place arrangements for you to perform your work? Did you go to a fixed office at the FBI? Were you given opportunity to choose where you wanted to listen to tapes? How did that work?

A:  I canít give you details because of the area, but it was combination. As far as my main work that I was asked to do because it was top priority outside counterterrorism, it was only Washington field office, and that was where from other field offices they would send information related to Turkish related area and I would translate.

But for certain counterterrorism tasks I had to go to Philadelphia or New Jersey to the Special Agents. In some cases I had to interrogate 9/11 detainees that were shackled in rooms who didnít speak English and they spoke either Turkish or Farsi. It was a


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combination of different tasks.

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

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

Q:  So let me be clear in my own mind. You would translate an answer, but you wouldnít be the one making up the questions for the detainees or is that inaccurate?

A:  It depended because after September 11th, some of the FBI agents, they didnít know anything, and they were very nice and good to know that they didnít know anything. So they would defer to my expertise to ask the right questions from detainees and some of the immigrants they had rounded up. In some cases there were certain Kurdish individuals, and even the Special Agent in


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Charge would take me out and say, ďWhat kind of questions do you think needs to be asked?Ē and I would tell them this and this, and because of the region this person from Turkey had come, itís not a very religious city. So -- or this person seems to be from the area and a family background that is ultra nationalist. So they would ask me to actually draft the questions to trick the detainees and get the right answers.

So, yes, in fact the Special Agents in Charge deferred to me to draft questions because they didnít know where Turkey even was.

Q:  Can you give me -- and I donít want to intrude on intelligence sources and methods --

A:  Right.

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

MR. KOHN:  I think that would be --


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THE WITNESS:  I canít make it up.

MR. FEIN:  Withdraw the question.

BY MR. FEIN:

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

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

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


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substantiated?

MR. MARINO:  Objection. Foundation. You havenít established that the OIG looked with the other allegations.

BY MR. FEIN:

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

A:  Yes.

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

A:  I donít recall. It may have been one of those that it was not conclusive or they didnít have other witnesses. Iím not sure. Itís been a while since I read the report, but we can bring the report and I can go over that.

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

A:  Not at all.


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MR. KOHN:  I donít think she knows you well enough to be surprised.

BY MR. FEIN:

Q:  After April when you were discharged or you werenít renewed by the FBI, what then did you turn to for employment or work or what then occupied your time?

A:  What period of time youíre referring to?

Q:  Well, why donít we -- letís take it year by year and maybe we can abbreviate it if thereís some years that are the same. So from April in 2002 to the end of 2002, what were you doing after you left the FBI?

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

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


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A:  Yes.

Q:  And what about 2002 to 2003?

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

Q:  Okay. Whatís the name of the organization?

A:  National Security Whistleblowers Coalition.

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

A:  Itís 501(c)(4).

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

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

Q:  End of 2004?


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A:  Correct.

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

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

Q:  Who are the officers of that organization?

A:  Itís myself.

Q:  Whatís your title?

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


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of Texas.

Q:  And who is the other senior advisor?

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

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

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

Q:  Any others?

A:  No, not that --

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

A:  That would be me.

Q:  Thatís all you?

A:  Yes.

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

A:  No.

Q:  Itís a non-stock corporation. How


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do you receive your revenues, your receipts? How is it funded?

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

Q:  Do you solicit any contributions?

A:  No, not right now.

Q:  Are the revenues zero?

A:  Correct, because I am independently wealthy at this point, and I donít need to owe anything to anyone. So I donít have to raise funds.

Q:  What is the street address of this organization?

A:  It has a P.O. box.

Q:  It has a P.O. box.

A:  Correct.

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

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


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several membersí partner organizations will have me doing this. So they are also my partners.

Q:  And how many volunteers have you had?

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

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

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


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of these documents. Then there will be a period that will be quite, like any other NGO.

Q:  What about getting articles that the organization has written published in the media? Does that happen?

A:  Yes. I was published by the Journal of Atomic Scientists on nuclear black market and nuclear whistleblowers, and that was published, I believe, in 2006, and I was published, together with my partner, Professor William Weaver, I believe itís Federal Times publication on intelligence related whistleblowers.

Q:  So you began the organization, you think, in 2004. About how many hours per weak do you devote to this organization?

A:  It depends. Certain period --

Q:  Do you have a range?

A:  Totally depends. During congressional activities, I may spend 70 hours a week, and during some quiet time, it may end up being ten hours. It just depends.


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Q:  Now, other than this organization that you are the director of, any other employment, work-related activities that youíve undertaken since your discharge?

A:  Continuing my company together with my husband as a consulting company for retail.

Q:  So those --

A:  Until now.

Q:  So does that exhaust the universe of your work activities? You worked as a consultant on the retail and inventory. You are running -- youíre the director of the whistleblowers 501(c)(4), and does that exhaust your work-related activities?

A:  No, it doesnít because I spend a lot of time both researching and writing not only for my Website, but for my blog and also working with individuals from the intelligence community on issues of interest.

Q:  And could you identify those particular issues that have been of interest


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to you? Letís start out with the most recent year. Letís not take -- how about the year 2009? What have been the intelligence activities, national security activities that have been of interest to you that you pursued?

A:  Civil liberties related issues, including the misuse and abuses of State Secrets Privilege; the recent congressional activities on legislation for whistleblowers, for the inclusion of national security whistleblowers who are currently not included in the legislation or the mark-up.

Also, it has been on the -- on the general, mainstream media, a trend of not reporting on certain areas and issues, whether itís related to national security whistleblowers or certain geographic regions or certain cases, this, for example. Like this will be something I will be working on in the next few months.

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


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regard to foreign governments corrupting the State Department, Defense Department, and members of Congress to get weapons material, nuclear material, bribery and that kind of thing; has that been an area that youíve pursued since you left the FBI?

A:  Itís not only that I have pursued. Itís been because of my background, a lot of sources and people have started contacting me, and I have gotten to see more documents in the newspaper articles, et cetera, on these areas than I even had before the time or interest me.

Q:  Now, you testified that the government of Turkey has corrupted the U.S. Congress and the State Department, et cetera. What other countries do you know have also corrupted the United States Congress, State Department, Defense Department, National Security Council through bribes, blackmail or otherwise?

MR. KOHN:  I think she identified


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specific individuals, not entire institutions.

MR. FEIN:  No, she identified the government of Turkey. That question was raised, the government of Turkey, and she said the government of Turkey had corrupted the United States Congress, amongst others.

THE WITNESS:  So the question is what other --

BY MR. FEIN:

Q:  What other countries other than Turkey have corrupted the U.S. government and various of its organs based upon your under -- you have testified most of it is money, but sometimes itís blackmail -- but what other governments have also accomplished that feat?

MR. KOHN:  Objection. I object to the breadth of the question. The other questions were based on specific individuals.

MR. FEIN:  Answer the question, please.

THE WITNESS:  Based on my information, I had knowledge and have


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knowledge to particular activities that was done in conjunction, together jointly with those entities, the Turkish entities, including the ones connected to the Turkish government, that were working and they were with Israeli lobby groups and certain people from the diplomatic community of Pakistani Embassy that were operating out of Washington, D.C., together with those Turkish entities.

BY MR. FEIN:

Q:  So your testimony is under oath here that the government of Pakistan and the government of Israel worked in conjunction with the government of Turkey to give money and to blackmail Congress people and people in the government in order to get things favorable from the U.S. in their foreign policy?

A:  I said individual connected to those offices.

Q:  Now, letís go back. When you testified earlier, I think to one of Mr.


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Manionís (phonetic) questions, you did use the word ďgovernment of TurkeyĒ had corrupted the Congress and the establishment and the executive branch through money and blackmail and otherwise. You used the word ďgovernment of Turkey.Ē You didnít identify, oh, it was only the Prime Minister or people in the embassyís office. You used the word ďgovernment of Turkey.Ē

Now Iím asking you are you also saying that the government of Pakistan, the government of Israel also worked in collaboration with the government of Turkey to corrupt members of Congress and the executive branch establishment through money or blackmail in order to get foreign policy favors.

MR. KOHN:  I object. I believe you have taken her testimony somewhat out of context.

MR. FEIN:  Iím repeating. I know the word ďgovernment of TurkeyĒ was used. Iím


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not taking it out of context.

MR. KOHN:  Well, the word ďgovernment of TurkeyĒ may have been used, but I donít recollect it being used in the exact context youíre using it.

MR. FEIN:  Please answer.

THE WITNESS:  Individuals connected, working with these governments, with these governments, in their official capacity.

MR. FEIN:  Well, youíre not asking my question.

BY MR. FEIN:

Q:  Iím asking you to use, as you used the word ďgovernment of Turkey,Ē in the same sense that you understood ďgovernment of TurkeyĒ when you used it in answering Mr. Manionís (phonetic) question to apply that same understanding in Pakistan and Israel as to whether or not the government of Pakistan and the government of Israel collaborated with the government of Turkey in corrupting U.S.


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Congress people and members in the executive branch of the United States government to win favors in the foreign policy and national security.

MR. KOHN:  Object to the form of the question and unintelligible. Can you give a simple question, please?

MR. MARINO:  I join in the objection. I canít understand the question.

BY MR. FEIN:

Q:  When you testified earlier that the government of Turkey was corrupting the U.S. Congress and the executive branch officials by money, bribes, and blackmail, what did you mean by ďthe government of TurkeyĒ?

A:  Individuals and certain individuals and operatives with official capacity, and that official capacity being the employees and members of Turkish government.

Q:  So you did not mean the government of Turkey in the sense that there was an


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official government of Turkey policy that involved bribery. You meant that these could have been rogue elements that werenít operating under the aegis of the Prime Ministerís office and doing this on their own for their own personal greed or pecuniary benefit.

MR. KOHN:  Are you identifying a specific person or the totality?

MR. FEIN:  Well, Iím just trying to get a clarification between her understanding of individual members who belong to a government. Take, for example, in the United States, you can have one individual who is subject -- whoís found guilty of bribery in the executive branch. It doesnít necessarily mean that that individual was operating under the aegis and the sponsorship of the President of the United States and the government.

It might be or it might not. It could be rogue or it could be in collaboration with the government itself, the policy of the


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government.

BY MR. FEIN:

Q:  Do you understand that distinction, Ms. Edmonds?

A:  (Nodding.)

Q:  All right. Now Iím trying to take that distinction and applying it to your use of the word ďthe government of TurkeyĒ is bribing and blackmailing members of Congress and the executive branch to doing favors in its foreign policy and national security arena.

Were you think government of Turkey in the sense that these individuals that youíre referring to were acting at the behest and the aegis and the sponsorship of the Prime Minister and his government, or were they acting as rogue elements? Which one were you referring to?

MR. KOHN:  Object to the question. It is -- for example, I donít think the United States government itself can engage in


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unlawful conduct. Individuals of government may be, and the government in itself may be viewed as being engaged in illegal conduct, but the government, but a country cannot engage -- this country cannot engage in illegal conduct. So --

MR. FEIN:  Well, there --

MR. MARINO:  Wait, wait, wait, wait, wait.

MR. KOHN:  Excuse me. The problem, the perception is when the President of the United States does something illegal, the government has done something illegal, and so I think it is difficult to try to pull them apart.

Youíre asking this individual to speak on behalf of actions taken on behalf of the government or taken on behalf of the representatives of the government, and I believe itís beyond her capacity to give you the specific answer youíre looking for.

MR. MARINO:  Can I make an


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objection?

MR. FEIN:  Of course.

MR. MARINO:  I think these questions are very argumentative. Theyíre very convoluted. I mean, I feel like youíre just making an argument and then asking the witness a question which is unintelligible, and it seems like youíre defending the government of Turkey and not cross-examining.

MR. FEIN:  No, Iím responding to actually something thatís in the complaint rather than something thatís totally irrelevant because one of the charges that Mr. Krikorian makes against Jean Schmidt in his various campaign literature thatís subject to the complaint is that the government of Turkey, the government of Turkey gave money to Jean Schmidt, and the government of Turkey, government sponsored PACs gave money, and thatís the phraseology he uses, ďgovernment of Turkey,Ē ďgovernment,Ē not individuals, and thatís why Iím trying to get your assessment


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when you testified the Turkish government what you meant by that.

MR. MARINO:  Okay. Iím going to object. I think youíre mischaracterizing. Why donít you show the witness the complaint instead of you trying to characterize it? Because I think youíre mischaracterizing it.

MR. FEIN:  I will --

MR. MARINO:  Show her the complaint. Thereís a copy right here.

MR. FEIN:  Yeah, Iíll show her the exhibits, which is perhaps more relevant.

MR. MARINO:  Show her your clientís complaint which you just characterized.

MR. FEIN:  This is the -- why donít we do this? You read through -- take your time -- the complaint and exhibits to the complaint that form the gist of the outstanding petition, and then we can ask you questions about it.

MR. MARINO:  All right.


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MR. KOHN:  Is there a specific question or is she supposed --

MR. MARINO:  May I see what youíre showing the witness, please?

MR. FEIN:  Sure.

MR. MARINO:  Is this the whole --

MR. FEIN:  There are additional exhibits, but those arenít part of the question. If you want to show them, show her your copy. Thatís fine.

MR. MARINO:  It doesnít matter. I just need to give the witness an opportunity to review it.

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

MR. FEIN:  Yeah, that would probably make sense.

(Whereupon, the foregoing matter went off the record at 2:14 p.m. and went back on the record at 2:25 p.m.)

MR. FEIN:  Ms. Edmonds, let me try


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to accelerate this.

BY MR. FEIN:

Q:  I believe on one of the exhibits the sentence I underlined there is the statement to the effect -- and I think Mr. Krikorian clarified this in his own deposition -- that Jean Schmidt had received money from the government of Turkey.

Do you have any personal knowledge that Jean Schmidt received money from the government of Turkey?

A:  No.

Q:  Youíll see also, I believe, on some of these, I think there are two other places in that exhibit I underlined. Thereís the statement that Jean Schmidt received money from Turkish government sponsored PACs. Do you have any personal knowledge as to whether or not Jean Schmidt received any money from the Turkish government sponsored PACs?

A:  Youíre asking specifically about Jean Schmidt?


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Q:  Jean Schmidt.

A:  No.

Q:  Okay. Thatís enough.

Now, I want to go back to the time frame in which I think you were identifying for Mr. Manion (phonetic), those members of Congress who your judgment was had received bribes, and you had mentioned Mr. Blunt and Mr. Hastert and Mr. Burton and some others. Now, was your knowledge based upon information you had acquired prior to your leaving the FBI?

MR. KOHN:  Her knowledge would have been based on information outside the scope of her employment. Thatís how this deposition has been set up.

MR. FEIN:  Okay, but I am --

BY MR. FEIN:

Q:  So, number one, your knowledge was not related to anything you learned in your FBI employment, but Iím also asking whether or not that knowledge outside your government


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employment was acquired prior to your leaving the FBI.

MR. KOHN:  Let me rephrase it. Thereís much of what she learned while she was employed with the government that she happened to also learn through additional sources after she left the government. So if there was a corroborating source that she learned it from, whether or not she learned it in the government, she would have revealed it here.

MR. FEIN:  Right, but I guess this is what Iím trying to clarify, is the time frame in which the information related. Were they bribed in 2001, 1998 or whatever.

BY MR. FEIN:

Q:  So what Iím asking is: is the information you acquired, whether it was corroborating information in the public record or not, relating to the bribery, were the bribes, the blackmail in a time frame that was prior to April of 2002 when you left the FBI?

MR. MARINO:  Iím going to object


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to the question. I think itís really mangled, and I donít know what specific things youíre talking about. You keep compounding things that have been --

MR. FEIN:  The question is very simple.

MR. MARINO:  No, itís not.

MR. FEIN:  Okay. I will go back --

MR. MARINO:  Let me just finish.

MR. FEIN:  Okay.

MR. MARINO:  I would ask -- youíve been doing this for the entire cross-examination -- I would ask that you just ask simple, direct questions and on specific things, not combining all the things youíve talked about. Was that based upon informa -- you know, break it down. I just want to have a clear record.

MR. FEIN:  Letís take one of those.

BY MR. FEIN:


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Q:  Mr. Burton you said received bribes from the government of Turkey. What years were those bribes received?

A:  My information that is limited for the time period 1997 until January 2002.

Q:  Is that also true for all the others that youíve identified for Mr. Manion (phonetic), that time frame?

MR. KOHN:  ďAll the othersĒ is a very broad --

MR. FEIN:  No, Iím saying the ones that you had -- were on your blog. Those, I think, were the ones that you related to Mr. Manion (phonetic). They were the pictures there that he was recounting: Mr. Hastert, Mr. Blunt, and I think there were some others there that I assume that you had identified on your blog.

MR. MARINO:  Again, same objection. I mean, I went through them one by one.

MR. FEIN:  Okay. Iíll go through


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them one by one.

MR. MARINO:  I think thatís what you should do.

MR. FEIN:  All right. Letís go through.

BY MR. FEIN:

Q:  So Mr. Burton, your information related to the time frame 1997 up to January of 2001.

MR. MARINO:  Two.

BY MR. FEIN:

Q:  Mr. Blunt, what was the time frame of the information relating to bribery?

A:  Mr. Blunt, to the best of my recollection, the same time period.

Q:  Mr. Hastert?

A:  To the best of my recollection, the same time period.

Q:  Steven Solarz?

A:  To the best of my recollection it would be 1999 to January 2002.

Q:  Mr. Gephardt, Richard Gephardt.


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A:  And Iím sorry. I have to go back. Mr. Solarz, referring to his capacity as his firm. He was not an elected representative during those -- so weíre not talking about congressional. Weíre talking about --

Q:  The people that you had --

A:  Okay, and that would -- their activities of receiving or those kinds of activities in the context that I explained for Mr. Solarzís role would be 1999 until January 2002.

Q:  And Mr. Richard Gephardt?

A:  I donít have any information on Mr. Gephardt.

Q:  Having received any government bribes --

A:  No.

Q:  -- or otherwise?

A:  No.

Q:  Do you have any information relating to bribery and blackmail of incumbent members of Congress that were after January of


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2002?

A:  You mean direct information?

Q:  Yes, based on personal knowledge.

A:  No.

Q:  Do you know who Jean Schmidt is?

A:  Limited to the news articles I have come across.

Q:  Before Mr. Krikorian spoke to you about ten days ago, did you know anything about Jean Schmidt?

A:  Very small amount that had to do with some computers in 2006 that had a glitch during election because this was on the headlines, but no, I didnít.

Q:  Did you know anything about the Turkish Coalition of America until it was raised in the question by Mr. Manion (phonetic) this morning?

A:  Either that or maybe in the past one year I may have received some of these E-mails that this organization sends on supporting Turkish, you know, vote against


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Turkish genocide because I get those from Stevenís association. They name may have been there. I donít recall.

Q:  Do you know anything other than what youíve just described here about whatís known as TCA?

A:  TCA? Yes, I donít know.

Q:  You donít know who the officers are.

A:  You work with them.

Q:  I think Iím Turkish American Legal Defense Fund.

A:  Okay. Then all right, all right.

Q:  But you would know that I work with them just because I told you. You didnít know it independently from the informants; is that correct? Or did you know that independent?

A:  Your name just came up in, you know, associated with that organization. Maybe it was in the article that I read in Politico.


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Q:  Okay.

A:  But no.

Q:  Okay. I think you testified in the direct examination about state secrets and how that had been -- the State Secrets Privilege had been employed in some of the litigation that you had initiated to obtain dismissal, I think, of your case and then blocking is it Motley Rice having access to a deposition?

Now, the State Secrets Privilege is a legal document. Have you read Supreme Court cases that identify what the elements of the state secret is?

A:  I have read so much on State Secrets Privilege and so many court documents. Are we talking about any recent Supreme Court?

Q:  Well, how about Doe v. Webster?

A:  No, I havenít.

Q:  You havenít read that. Have you read Reynolds v. United States?


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A:  Yes.

Q:  Totten v. the United States?

A:  Yes. Again, these were -- I read all of those during my court case, and my court case was active. So it would be three, four years ago, namely, those cases.

Q:  Have you testified on the pending legislation on state secrets that I think Jerry Nadler is the chief sponsor? Have you testified for any of the congressional committees considering state secrets legislation?

A:  No. I have to qualify that. Congressional members have a kind of a gag order on them because of the retroactive classification and order they got from Justice Department during, I believe, Attorney General Ashcroft. So they donít even know if they can have me there.

Q:  Well, Iíve testified at the hearings, and they donít get into anything like that. Itís just what the law ought to


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be, but thatís aside. Letís move on.

Have you put in a fair amount of -- do you study lobbyists and lobby groups and how they operate in Washington?

A:  I have been reading.

Q:  And what have you read about how lobby groups operate in Washington?

A:  It depends on what I have read.

Q:  Give me the books that youíve read.

A:  More than books --

Q:  Let me put a time frame. I donít want it to be endless. Say since you left the FBI, it has been mainly articles published both by mainstream media and also alternative media on at least the cases that have come up, whether it is on, you know, APAC or the conflict of interest case, such as the recent case that had to do with the defense contractors being related to a particular Congressman Murtha and how that lobbying caused -- so it would be mainly mainstream


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media related article of the consequences of the foreign lobbies and the conflict of interest between certain business sectorsí lobby and congressional relations.

Q:  Have you ever read the Foreign Agents Registration act?

A:  Several years ago, yes, and I believe it is Department of Justiceís Website. This would be around maybe 2006 or 2005.

Q:  And whatís your understanding of when you have to register as a foreign agent?

A:  Again, itís been a while. It was my understanding that if you work and you lobbied on behalf of that foreign government.

Q:  If youíre a lawyer do you have -- if you represent a foreign government as a lawyer, do you have to register?

A:  I donít know.

Q:  What about the Lobbying Disclosure Act? Are you familiar with that statute?

A:  Not as an expert and somewhat very familiar with the technical language, but very


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broad kind of understanding when I was reading, again, with just the regular mainstream media and all kinds of media articles about this topic.

Q:  Do you have any personal knowledge of the campaign that was run by Mr. Krikorian in 2007-2008 election cycle in which he ran as an independent against Jean Schmidt in the 2nd District of Ohio?

A:  No.

Q:  If I used the word ďa government sponsored political action committee,Ē what is your understand of a government -- a foreign government sponsored political action committee? What does that mean to you?

In specifics, does that mean the foreign government is giving money to that political action committee or other things of value?

A:  Iím not sure.

Q:  Does it have any meaning to you at all?


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A:  Government --

Q:  Sponsored.

A:  -- sponsored --

Q:  -- political action --

A:  -- political action committee?

Q:  Un-huh.

A:  I guess, again, I donít know. I havenít read the description or definition of that particular terminology. The meaning to me would be it would be either by, commerce, commerce/business sponsored, and doesnít mean necessarily money or the lobbying and the advocacy for by a certain group.

Q:  Okay. If itís not money, what are the other things that come to mind?

A:  Iím not sure.

Q:  But money would be the most prominent thing that would come to mine or not? Other things compete with money as to what it means?

A:  I guess that depends on which country, foreign country youíre dealing with


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and what --

Q:  Dealing with Turkey, if itís Turkey, if itís the Turkish government sponsored.

A:  If itís a Turkish sponsored PAC, up until, letís say year 2000 to January, it meant certain things. I donít know what has meant since then, but up until 2002, it would have meant something.

Q:  And what was that?

A:  When their donations are made to a certain PAC or a lobbying, well, during that time period it was only done to PACs or PACs that are related to congressional candidates who have made covertly promises and deals because they have overt promises. Yeah, I will be promoting commerce, et cetera, but covertly to further certain interests or agendas of certain business and entities and sometimes or most of the time those work hand in hand with certain government agents, foreign government agency.


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Q:  So that was giving money prior to 2002; government, Turkish sponsored PACs would be giving money to the PACs to give the money to the members of Congress?

A:  No. You asked for the reason. You said why would they give and I --

Q:  No, no. If I spoke that, it was inartful. Iím not asking why they gave. Iím just saying a government, a Turkish government sponsored PAC prior to 2002 -- I think that was the time frame you were referring to -- meant in your understanding that the government of Turkey gave money to the PAC in order to give to members of Congress.

Iím not asking what they sought in exchange.

A:  Right, and they did so overtly and covertly. For example, sometimes the money in the form of a suitcase of cash would go to a certain person or business entity, and from that business person/entity, would be divided to ten people in order to not trace the origin


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of that money to that particular Turkish government agent or Turkish government group. So they did it in steps. So it just depends.

Q:  So it would be like you would use or they would use the middle men. All right. It has come -- the origin of the money is the government of Turkey. They give till it looks like a private business or entity, and they tell them you then turn around and maybe give it to another middle man so that there is some kind of chain of custody that separates the government of Turkey directly from the end user, but the origin of the money is from Turkey.

A:  Or a government entity associated with the --

Q:  A government owned corporation or enterprise of some type.

A:  Or it can be an entity, letís say. Letís say it can be a military attache person that is doing that, that the Turkish military attache and that person is -- you know, that


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military attache person is employed by the Turkish government, and suddenly he says, ďOkay. I have a suitcase of $45,000, and how are we going to distribute that?Ē Unless they have a candidate in mind, there are ways they did it, and that would be -- one way would be to give some of that cash. They get the citizens, Turkish people who are citizens here. You know, they give them cash, and they have each one of those citizens write some amount like under $200, letís say, to a particular candidate.

Even though that money didnít come from those U.S. citizens, the money came from Turkish Embassy, and as long as it was under 200, they can get 500 Turkish people. Each one write $200. So thatís one of the ways they do it.

Q:  Okay. All right. That answers my question.

If a PAC gave campaign contributions to a member of Congress who was


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a sponsor of the Armenian genocide resolution, then youíre pretty certain that would not be a PAC that got any money from the Turkish government?

MR. MARINO:  Objection. Foundation.

MR. FEIN:  Excuse me?

MR. MARINO:  Foundation.

BY MR. FEIN:

Q:  Oh, I think that you testified earlier in response to Mr. Marinoís question. I think he was asking you to speculate a little bit that one of the ways in which the Turkish government was able to obtain promises and influence against an Armenian genocide resolution, which you identified was a concern, was that they would audit -- they would invariably extract iron-clad promises from members who were going to receive their money that they would vote in particular ways. They would do the bidding. They didnít leave that open to chance so that they would not


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give money to a candidate or to a member of Congress who wasnít pledged to oppose the genocide resolution.

So Iím really asking -- I guess I can ask it in a similar language. That is, if a PAC did give money to members of Congress who were sponsors of the genocide resolution, then is it your conclusion or opinion that PAC was not receiving any money from the Turkish government?

MR. MARINO:  Objection. Itís an incomplete hypothetical.

THE WITNESS:  That would be impossible to guess because Armenian genocide was one criteria, but there were other criterias also, and that included, as I said, the criteria thatís related to the weapons purchase from the United States, and which general in Turkey is going to get a claim of this thing, and whoís going to get what money.

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


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criteria that they considered and honored in order to give money or not only money, but also other ways of giving position, a certain company to the son of certain congressional person or keeping certain things secret or et cetera. So that was one of -- the Armenian genocide bill was one of them.

So maybe Iím saying in a hypothetical situation that particular candidate may be a sponsor of Armenian genocide, when on the other three criteria that are extremely important or two other criteria, that person or candidate may be doing important, very important favor or giving important favor.

So I canít -- I canít tell you. It just depends on the situation.

Or that candidate may be in a or incumbent may be in a very sensitive committee in Congress or Senate and in the position of obtaining some very important classified information they may want. So it can be other


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things under that scenario that we just discussed.

BY MR. FEIN:

Q:  Right. So they look at a variety of criteria. Even if they donít satisfy all of them, they may be some money because they view some of the issues as more important than others.

A:  May be.

MR. KOHN:  Can we take a short break for one second?

MR. FEIN:  Sure.

(Whereupon, the foregoing matter went off the record at 2:46 p.m. and went back on the record at 2:47 p.m.)

BY MR. FEIN:

Q:  Ms. Edmonds, have you ever been called as an expert witness in any litigation?

A:  No.

Q:  Have you ever been called to testify at a committee hearing before


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Congress?

A:  Yes.

Q:  And what hearings were those?

A:  I donít recall. Theyíre all available on the House Website, and I have had several testimonies during hearings on whistleblower legislation, and also I believe it was House Government Reform Committee that I was providing testimony for civil liberties related issues, excessive secrecy and classification. I believe that was was a entitle 2005 -- you have to look at the Website for House bill. I donít remember.

Q:  I think you did testify about, you know, your knowledge of the Armenian genocide, the resolution. Have you ever read the genocide convention of 18 -- I mean of 1948?

A:  No.

Q:  Have you ever read the U.S. genocide statute?

A:  No.

Q:  Do you know what the elements of


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genocide are?

A:  Not technically.

Q:  If you donít know what the elements of genocide are, do you know whether or not the United Nations has ever voted a resolution that endorsed the Armenian genocide claim?

A:  No.

Q:  Do you know whether Great Britain parliament has ever endorsed the Armenian genocide claim?

A:  Iím not sure about Great Britain.

Q:  Thatís the only question Iím asking right now.

A:  Yes, I know.

Q:  How about government of Sweden?

A:  I donít know.

Q:  Do you know the author Bernard Lewis?

A:  Yes.

Q:  Heís at the University of Princeton, correct?


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A:  Yes.

Q:  Heís written voluminously about the Middle East. Is that your understanding?

A:  I canít make objective -- any comment, answer about Mr. Bernard --

Q:  Iím just have you read -- only asking about --

A:  Yeah, it is.

Q:  -- things in the public domain.

A:  Yes, correct.

Q:  Has he been a White House consultant?

A:  Yes.

Q:  Do you consider him a person of stature in the community of scholars?

A:  No.

Q:  You donít. Why do you not place him into that category?

A:  I have my own personal reasons. Theyíre based on my personal opinions.

Q:  And why is that? What is -- why is it that you do not view him in the category


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of scholars in the Middle East?

A:  Because I consider objectivity as one of the criterias for being considered scholarly and reputable, and I donít believe his agenda -- heís not agenda driven. I believe heís not objective. Thatís my personal opinion.

Q:  If you were -- if you were hiring faculty at the University of Princeton, would you not hire Bernard Lewis as a scholar?

MR. KOHN:  Objection.

THE WITNESS:  I donít know because of the situation.

MR. KOHN:  Speculation.

MR. FEIN:  Sheís speculated on all sorts of things.

BY MR. FEIN:

Q:  Are you aware of outstanding trials in Cambodia for the atrocities of Pol Pot?

A:  Not the details.

Q:  Is it your view that what Pol Pot


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did was genocide?

A:  Was it genocide?

Q:  Un-huh.

A:  I would consider it a genocide.

Q:  Do you know that, in fact, there have been none of those who are on trial have been accused of genocide?

A:  If they havenít been on trial --

Q:  No, theyíre on trial right now.

A:  Correct.

Q:  Theyíre not being charged with genocide.

A:  Okay. (Inaudible.)

Q:  Now, I want to go through a list, and maybe we can add more, of the persons that you identified to Mr. Manion (phonetic) that had been -- had committed crimes either related to bribery or stealing classified information or otherwise. My list was Mr. Roy Blunt, Mr. Tom Lantos, and Mr. Dennis Hastert, Mr. Dan Burton, Mr. Stephen Solarz, Mr. Robert Livingston.


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Are there other current or former members of Congress to your knowledge who have also committed crimes that have not been -- none of these members have been prosecuted, but have also committed crimes that have not been prosecuted?

A:  Based on the definition, possibly one.

Q:  And who is that?

A:  The lady we just talked about, Congresswoman.

Q:  But that would be the only addition you would make?

A:  Based on my knowledge, research, yes.

Q:  Now, what about -- I think itís fair to say in the executive branch you identified Marc Grossman as always as someone whoís guilty of a crime. Are there any other individuals in the executive branch who you know are also guilty of crimes of bribery, selling or leaking classified information to


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obtain a --

MR. KOHN:  I think the witness has identified activity she viewed to be criminal, not that they were guilty of criminal activities.

MR. FEIN:  Well, somebody had -- if thereís criminal activity, somebody has to commit the crime. It canít be a crime in the abstract. You have to have a defendant --

MR. KOHN:  Guilt is a legal determination. Itís not when you committed an act thatís wrong.

MR. FEIN:  I understand. Iím asking -- sheís -- bribery, I assume, when you mean bribery, youíre not using that in a colloquial sense, that it means something that you didnít like. Bribery is the specific elements of a crime, just like if you accuse somebody of murder, you donít get to decide what murder is. Thatís defamatory if you donít have any foundation for saying that, even though murder is a criminal concept.


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BY MR. FEIN:

Q:  Now, Iím asking you. You had identified Marc Grossman as someone who was guilty of basically --

MR. KOHN:  Did not use the word ďguiltyĒ when you referred --

MR. FEIN:  Engage in criminal activity.

THE WITNESS:  And I didnít identify. I said that name has been identified by other sources who have spoken to the media, main media, has it before that date, and yes, itís on the Website. His picture is there, but I did not make any specific allegations about or I donít have specific information about Mr. Grossman. I said he has been identified to me, and when I was asked is it correct, I said yes.

BY MR. FEIN:

Q:  Okay. Do you have any personal information that Mr. Grossman has committed criminal activity?


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A:  Yes.

Q:  And thatís based on your personal knowledge?

A:  Yes.

Q:  Now, are there any other current or former members of the executive branch -- and letís take the time frame 2001-2009 -- that you have personal knowledge have engaged in criminal activity?

A:  I canít cover time frame after January 2002.

Q:  Okay. Letís take the time frame 1997 up to 2002. Now, other than Mr. Grossman, do you have any other direct personal knowledge of executive branch officials, meaning executive branch in the United States, who were involved in criminal activity?

A:  Yes.

Q:  And could you identify those?

A:  My Website identifies them by pictures.


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Q:  Iím sorry. I donít -- Iím not familiar with your Website. Could you just enumerate the names for me?

A:  Sure, www.Just --

Q:  No, no. I just would like the names of the individuals, not the --

A:  I havenít named them. I have their pictures. I havenít named those individuals. There are pictures there. If you were to ask me and name them yourself and ask me questions about them, then I will answer you.

Q:  No, Iím asking you can you identify the pictures on your Website?

A:  Yes, I can.

Q:  Okay. What are -- those pictures that you have on your Website, identify those pictures on your Website --

A:  I donít have any --

Q:  -- who are -- who are executive branch officials who you say are -- have been involved in criminal activity?


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A:  I donít have any in front of me.

Q:  You donít remember whatís on your Website? Youíre under oath. You donít know the pictures of the people who are on your Website?

A:  Yes, I do, and I --

Q:  Then Iíd like you to -- Iím just asking you. Just tell me who they are.

A:  I have to look at them right now, in front of me in order to identify each one of those individuals.

Q:  Do you have any name other than Marc Grossman that comes to mind?

A:  Yes.

Q:  Name that person.

MR. KOHN:  Would you like to talk to counsel?

THE WITNESS:  Yes.

(Whereupon, the foregoing matter went off the record at 2:56 p.m. and went back on the record at 2:57 p.m.)


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MR. KOHN:  We have objected to the question as it is formed with reveal of classified information.

BY MR. FEIN:

Q:  Is the picture youíre maintaining on your Website classified information?

MR. KOHN:  The picture is not classified, but asking information related to why the picture is on the Website would be.

MR. FEIN:  So Iím getting to the end here.

BY MR. FEIN:

Q:  If I visit your Website, your testimony is that the people whose pictures are there on your Website have been involved to your personal knowledge in criminal activity?

MR. KOHN:  She wonít answer that question.

MR. FEIN:  The answer is yes.

MR. KOHN:  The witness will not answer that question as it relates to


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classified information.

MR. FEIN:  Iíll just visit the Web.

I think thatís all.

MR. MARINO:  I have just a couple of follow-up before youíre done.

REDIRECT EXAMINATION

BY MR. MARINO:

Q:  I want to go back to some of the questions Mr. Fein asked you about contributions, government-sponsored acts. Itís back to that category.

You had answered the question, I think, in part by saying thereís covert support and thereís overt support. In your experience, for example, I think you said you had not really hear of the Turkish American Council or --

MR. FEIN:  Coalition.

MR. MARINO:  Iím sorry. Which one?

MR. FEIN:  Coalition.


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BY MR. MARINO:

Q:  Turkish Coalition of America. That was the one you had not --

A:  Because there are so many abbreviations itís so hard, but I donít --

Q:  Okay, and I think earlier you testified and said you hadnít heard about the Turkish American Heritage PAC.

A:  Again, they have so many names and abbreviation that I donít recall now, but I may have known. I just canít -- I donít recall it right now, specific names of various PACs because there are so many different kinds that they set up.

Q:  And you described -- I think what you were describing when you were describing the covert kinds of support the situation where an official has a suitcase full of cash, gives it to ten people who are not government officials, and those ten people make a contribution separately to --

A:  Correct.


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Q:  -- the PAC that then gives money to the left, and that would be something that would be considered covert.

A:  That was one of the covert ways.

Q:  Ways to do it.

A:  Right.

Q:  And so you wouldnít expect -- if that happened, for example with the Turkish American Heritage PAC with some Turkish official who with a suitcase full of cash to ten different then made contributions to the PAC, you wouldnít expect the PAC to put it on their Website that they got money from the Turkish government.

A:  They never do. I mean up until, based on my knowledge, experience to 2000, they donít.

Q:  If they were doing that, you wouldnít have to listen to their phone conversations and figure out. We wouldnít really need counterintelligence operations, right?


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MR. KOHN:  Objection as to listening to phone conversations.

BY MR. MARINO:

Q:  And in fact, if the treasurer of the PAC submitted an affidavit and said, ďOur PAC is not, never has been sponsored by the Turkish government and has never received any money or non-monetary support from the Turkish government,Ē as far as we know, that treasurer may not even know that the contributions came in from --

A:  Right.

Q:  -- those ten people, right?

A:  Correct, or in some cases the treasurer may be the key person involved, carrying out these illegalities, as it was in Chicago.

Q:  Would you expect them to give us an affidavit saying, ďYes, we got money from the Turkish government through covert sourcesĒ?

A:  I wouldnít think so, no.


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Q:  If they would do that, you wouldnít have to --

A:  Right.

Q:  -- review telephone conversations.

You said that -- I want to ask you a kind of personal question. You donít have to answer if you donít want.

You indicated that you were independently wealthy, and I assume that what you mean by that is you donít really have to work in a day-to-day job if you donít want to. You have sufficient means that you donít necessarily have to do that.

A:  Currently.

Q:  Okay.

A:  Currently. My husband and I, yes, we worked very, very hard for 18 years, and before that he did. So, yes, we donít have to right now work like that.

Q:  I got the impression from your testimony that when you went to work for the FBI back in 2001, that money was not the


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motivating factor for you.

A:  Absolutely not.

Q:  They offered you a chance to be a FBI Special Agent.

A:  With the highest level GS the moment I graduated from Quantico because of the language abilities and the Masterís degree. It was just all the stuff which would have qualified me to start at GS-12 or GS-13 versus the GS-8 that regular agents start. That was part of the offerings they were giving as part of this package, yes.

Q:  Would it be fair to say the FBI found you to be a fairly valuable resource, by the way?

A:  Absolutely, and I had and they have several commendation letters from all the agents. These are field agents that I worked with, and they all submitted commendation letters, and most of them request specifically me for their own projects, yes.

Q:  All right, and then when the


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issues that got you, letís say, cross-wise with the FBI when they terminated your contract, the FBI, the Office of OIG actually investigated and determined that youíre -- they really didnít pay enough attention to your allegations, and that they were substantiated, correct?

A:  Right.

Q:  And Mr. Fein asked you about the travel allegations, but the four allegations about Ms. Dickerson, they were substantiated, correct?

A:  Correct. They were all substantiated.

Q:  And so if it wasnít money, then why did you go to work for the FBI in the capacity that you did? What was it that motivated you to do that?

A:  One reason only. Immediately after September 11th, the FBI, the Justice Department, they kept coming on TV, radio, and they said they were desperately in need of


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language specialists in these areas simply because we didnít know if we were going to have other attacks, et cetera. It just was like a going and enlisting with the Army or whatever. If there is a war and youíre attacked, then somebody taps you.

So I -- I just joined in order to do something as a citizen to contribute because I did have those languages and the education, the background. So I was serving the FBI during the crises and the need, so-called desperate need that they had.

Q:  So you had skills and experience that would be helpful to your country, right?

A:  Correct.

Q:  And out of love for this country you offered those skills and experience, correct?

A:  Correct.

Q:  When you reported to your superiors at the FBI that you detected a case of attempted espionage, why did you do that?


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Why did you tell them about that?

A:  Because I was, first of all, obligated for that security clearance and that informant. One of the things I signed, my basic question was if somebody tries to recruit me, if I come across suspicious activities or recruitment, that kind of an incident, the first thing I have to do was to go and report it to my superiors and the Security Office.

So I -- I -- not only did I believe that I have to go and do it. I was obligated to do it.

Q:  And did you feel morally that out of loyalty to your country that you should report it?

A:  Absolutely.

Q:  And when you -- after you left the FBI and you testified before congressional committees, testified before the 9/11 Commission, et cetera, why were you doing that? Why were you telling them all of the


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things you were telling them?

A:  Because all along -- and that even includes my court cases -- I -- the government gives the State Secrets Privilege and classification to cover up operations and activities by Turkish entities, something within government, some rogue elements, and certain criminal U.S. persons that have nothing to do with national security of the people in the United States, that had nothing to do with the national interest. It only had to do with covering up these criminal activities because of those high level people and officials and other people who benefited from it.

And in fact, it jeopardized and still does American security not having those people accountable and not pursuing those people criminally, and that was not only my belief. It was the belief of all the agents I work with who work on Turkish counterintelligence.


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Even the Department of Justice was told by State Department to shut down their investigations of particular operations. These agents covertly continued it. Okay? And I have been through these commissions and going and testifying before Congress, inside secure compartmentalized facilities, and even my court case was to put this information forth and force the issue so that it would be publicly addressed first. American people would know whatís been happening and what this information involved, not national security, not their security first, just the opposite.

And second, it would be truly pursued and investigate and prosecuted. So you would see accountability, not only ending it, but also you will see accountability. Because treason, these kinds of criminal activities, theyíre serious. These are serious crimes, and these were the beliefs of the agents I worked with.

And some of these agents have


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talked with the members of the media. Thatís why you have seen some of these articles. They havenít gone by one or two sources. They have gone to multiple sources, and it hasnít happened to date.

But that was the reason. That has been the reason why I have pursued it by all the expenses and expulsion, through courts, Congress, Inspector Generalís Office, basically every legal available channel that was out there.

Q:  Now, have you written any books?

A:  Iím in the process of writing a book, and I am also writing a book, academic book, which would be studied at Johns Hopkins and Georgetown University with Professor Weaver called Shoot the Messenger. That has to do with whistleblower legislation, specifically national security whistleblowers and intelligence whistleblowers, which will be published at the end of 2010 by Kansas University Press.


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Q:  Now, Professor Weaver, I think you said, I think you said he previously worked for NSA; is that correct?

A:  Correct. A long time ago, 30 years ago.

Q:  And can you tell us what his position with NSA was?

A:  He was a member of Air Force, and it had something to do with -- I donít know. It was highly classified that had to do with communications, which is obvious for NSA, but Iím not sure.

Q:  Okay. Mr. Fein asked you about certain counties and whether they had passed resolutions recognizing the Armenian genocide. Do you recall that?

A:  Correct.

Q:  Have some countries actually passed resolutions recognizing --

A:  Yes. For example, France did that, and it was important because France was also frightened in their relationship with


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Turkey would end and they were going to be rewriting it and they were going to become destitute, et cetera, and they didnít. They did what they felt was right, and the relationship has been good as far as I know.

Q:  And the United States has not passed a resolution recognizing the Armenian genocide so far?

A:  No, as far as I know, it hasnít.

Q:  And thatís in part because Congress will not vote for it because theyíre lobbied by the Turkish lobby.

MR. FEIN:  Thatís a leading question.

MR. MARINO:  Thatís okay. You can answer.

THE WITNESS:  Also the executive branch pressuring the Congress because thereís always some reason. Itís today Iraq, and before that it was Cold War, and now itís going to be Afghanistan. Then itís going to be Central Asia, which is going to be


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(unintelligible) maybe. So thereís always a reason underway.

BY MR. MARINO:

Q:  Are you pretty sure that the Turkish lobby is lobbying legislators and government officials in other countries as well to stop them from passing such resolutions?

A:  I donít know.

Q:  Why do you feel that Bernard Lewis is not objective?

A:  I have read some of his scholarly articles, and especially those that have to do with the strategy for the United States on foreign policy, that includes Afghanistan and Central Asia as very agenda driven, that fulfills the agenda of certain entities that I happen to know about.

Q:  And by agenda driven, you mean it starts with a point heís trying to make as opposed to doing real analysis?

A:  Correct.


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Q:  And what entities are you talking about when you say itís agenda driven?

A:  Certain business entities, the military-industrial complex in oil, and also certain business entities, foreign business entities, and that even includes certain business entities in Turkey.

Q:  I think you said that since youíve been working with the organization youíre working with now, the whistleblowers organization, you said that you continue to get information --

A:  Absolutely.

Q:  -- from people.

A:  Including from Turkey, yes.

Q:  From Turkey, youíre getting information from current government people, from --

A:  CIA, Defense Intelligence Agency, FBI, National Security Agency, every single intelligence agency we have. I have lots of contacts in all of them, and these are even


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people who havenít blown the whistle publicly yet.

(Counsel conferred.)

BY MR. MARINO:

Q:  To your knowledge, do you have any information about the Turkish government sponsoring chairs at universities, like Princeton, University of Utah, and other places?

A:  Georgetown University, and not only that. Some of these academic experts also are recruited agents who actually steal U.S. military and intelligence related information because they have security clearances and they have obtained position in high level institutions, and one good example would be RAND Corporation, and Professor Sabri Sayari in Georgetown University who has stole tens of millions of dollars worth of secrets by actually recruiting people there that has been identified to him by his superiors, handlers, and he does it currently in -- was


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doing it in 2002 with RAND Corporation, one of the individuals. Thatís an example of academic expert that they recruit.

Q:  And how do they recruit them? With money and other things?

A:  Money and in some cases combination of money and sexual related favors and information.

Q:  Now that you have had a chance to read the complaint that --

A:  No, I really -- I read the article, but I didnít have time to read the complaint.

Q:  Okay. I wonít ask you about the complaint then.

A:  Okay.

Q:  I wonít ask you to read it.

MR. MARINO:  Do you have anything else?

(Counsel conferred.)

BY MR. MARINO:

Q:  If you donít mind, do you still


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have the complaint in front of you?

A:  Yes.

Q:  If you would look at Paragraph 14 of Ms. Schmidtís complaint, please, and Iím referring specifically to her reference to a letter from Mr. Krikorian. She quotes it as saying that Ms. Schmidt insanely, quote, ďdenies the Christian Armenian genocide at the hands of the Muslim Ottoman Empire.Ē And then it goes on to say a couple of lines down, ďJean Schmidt has taken $30,000 in blood money from Turkish sponsored political action committees to deny the slaughter of 1.5 million Armenian men, women and children by the Ottoman Turkish government during World War I.Ē

Do you see that?

A:  right.

Q:  Now, do you think that based on everything that you know that Mr. Krikorian is coming out of left field by saying something like that?


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A:  As I said, based on my first hand information, my own knowledge, anybody who strongly comes and denies this and also has that kind of relationship with the Turkish sponsored PACs and organizations, et cetera, at least in the past, has been exactly for this particular reason. Itís been representing the other foreign interest and not being objective represent the United States interest.

So this, again, as I said, it fits. I donít know anything about this lady, but it fits the modus operandi of all the others who were on the payroll one way or another. To just do this, they were on the payroll of the Turkish government entities, certain Turkish government --

Q:  So it wouldnít surprise you at all for Mr. Krikorian to say something like that under the circumstances, right?

MR. FEIN:  Thatís purely hypothetical and pure speculation. This goes


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over the top. She said she hadnít even met Mr. Krikorian until nine days ago, Mr. Manion (phonetic), and youíre asking her to get inside his head?

MR. MARINO:  You can answer.

THE WITNESS:  I mean, thereís no -- that doesnít surprise me.

BY MR. MARINO:

Q:  If you look at Paragraph 20 of her complaint, she says it would be a crime under federal law for the Turkish government or any foreign national to fund a political action committee that made donations to a federal candidate seeking election to Congress, among other federal offices, and she cites a federal statute. Do you see that?

A:  Yes.

Q:  Now, many of the things that you describe which you have personal knowledge of would be crimes under U.S. statutes, correct?

A:  Absolutely, and they would have these people in jail, those people.


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MR. MARINO:  One moment. Bear with me. Iím sorry.

(Counsel conferred.)

MR. MARINO:  Let me just ask. The passage Iím looking for, which is part of her complaint, is the statement that Mr. Krikorian made requesting that it be put to the voters.

BY MR. MARINO:

Q:  By the way, youíre not a voter, are you, from Ohio?

A:  No.

Q:  And youíre not making contributions to Mr. Krikorianís campaign?

A:  I havenít contributed to anyway.

Q:  If Mr. Krikorian asked the question -- this gentleman asked the question of those voters, why would you want to vote for someone who has taken money from the government, whose policies and practices cost American lives? Would that be a crazy question for him to ask under your -- based on your experience?


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A:  Absolutely not, and thatís where I would even go further. For any candidate who starts really getting that kind of a close relationship with any foreign government to that degree and to get that kind of support because of that, I -- that would be a very valid -- that would be a valid question, and I would not want to vote for someone.

MR. MARINO:  Thank you, maíam. Thatís all I have, and I want to thank you again for coming.

MR. FEIN:  I just have two questions.

RECROSS EXAMINATION

BY MR. FEIN:

Q:  One, Ms. Edmonds, have you requested that the incumbent Attorney General, Eric Holder, investigate the crimes that youíve identified at this deposition today?

A:  I have asked his predecessor, Attorney General Ash --

Q:  Iím just asking Mr. Holder.


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A:  Asked him to review -- revoke my State Secrets Privilege basically. Thatís what I --

Q:  Excuse me. I did not ask about the State Secrets Privilege. Have you asked Mr. Holder, the current Attorney General, to investigate the crimes that youíve identified at this deposition today?

A:  Not, not directly.

Q:  Okay. The second thing is I believe in response to the last question Mr. Manion (phonetic) said if you were a voter you certainly would not be inclined to vote for a candidate who had received and was receiving money from a foreign government.

MR. MARINO:  Thatís not what --

MR. FEIN:  Thatís not what? Okay. What was it?

MR. MARINO:  The record said what it says, but youíre mischaracterizing it again.

MR. FEIN:  The record says what it


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says, and if I can go back, I can show you this here.

BY MR. FEIN:

Q:  I believe the sentence that he was referring to, Mr. Manion (phonetic) was, and now Iím quoting, ďI asked the people of Ohioís Second Congressional District to ask themselves if our representative in Congress should be taking money from a foreign government that is killing our soldiers, and if that assertion is true, would you be inclined to vote against that candidate?Ē

MR. MARINO:  That wasnít what I asked, but I donít have a problem with you asking that question.

THE WITNESS:  The question is would I vote for that person?

MR. FEIN:  Yes.

THE WITNESS:  If somebody who --

MR. FEIN:  Yeah.

BY MR. FEIN:

Q:  If a candidate was taking money


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from a foreign government.

A:  Candidate was taking --

Q:  Taking money from a foreign government, and that government was the government of Turkey or it could be any other.

A:  Any other government. No, I would have serious questions about that.

MR. FEIN:  Okay. Thatís all I have.

MR. MARINO:  Thatís all I have. I thank you very much.

Do you have any other questions?

MR. KOHN:  No, just to note for the record that the Justice Department apparently declined to attend the deposition and that weíve had no communications with them other than the written communications of yesterday.

MR. MARINO:  That concludes it. You have a right to read the transcript and make corrections.

THE WITNESS:  Right now, you mean?


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MR. MARINO:  No, no.

MR. KOHN:  We would like a copy provided to the witness.

MR. MARINO:  So should we give it to Mr. Kohn?

THE WITNESS:  That would be great.

MR. KOHN:  That will do it.

MR. MARINO:  Thanks again. Appreciate it.

Off the record.

(Whereupon, at 3:21 p.m., the deposition of Sibel Deniz Edmonds was concluded.)


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