GENERAL WILLIAM C. WESTMORELAND.} } PLAINTIFF. } VS. } DEFENDANTS. )

Transcription

1 N THE UNTED STATES DSTRCT COURT SOUTHERN DSTRCT OF NEW YORK ACTON NO. 32 ev 7913 (PNL) r. ~ ' \...'. /~ GENERAL WLLAM C. WESTMORELAND.} } PLANTFF. } } VS. } } CBS NC. ET AL.. } ) DEFENDANTS. ) DEPOSTON OF GENERAL GEORGE A. GODDNG PURSUANT TO NOTCE AND/OR By AGREEMENT OF THE PA~T S. THE DEPOSTON OF GENERAL GEORGE A.GODDNG WAS TAKEN. COMMENCNG ON THE 19TH DAY OF APRL AT THE HOUR O. 930 A.M. AT STREET. N.W. SUTE 115. WASH'; D.C. ATTENDED BY COUNSE~. AS FOLLOWS \PPEARA~CES DAVD DORSEN. ESQURE ANTHONY S. MURRAY. ESQURE. OF CAPTAL LEGAL ~~UNDA ON 700 E STREET. S.E. WASHNGTON. D.C ATTORNEYS F~R THE PLANTFF DAVD BOES. ESQURE ONE CHASE MANHATTEN PLAZA NEW YORK. NEW YORK ATTORNEY FOR THE DE;ENDANTS per;d BY DESORAHH. GARRSON. CVR. VJEO OPERATORS GORDON HOOVER (APRL ) R06ERT H. CRACE (APRL ) '"

2 _.._......_ ~ NDEX 2 3 PtGE 4 S T 1 PU L AT ON S 'f 3 5 DRECT EXAMNATON BY MR. 801 ES. t 3 6 CROSSEXAMNATON BY MR. DORSEN REDRECT EXAMNATON BY MR. BOlES 327 '' 8 DEPOSTON CONTNUED ON APRL EXHBTS 10 DEFENDANTS' EXHBT NO. 33 MARKED DEFENDANTS' EXHBT NO. 34 MARKED DEFENDANTS' EXHBT NO. 35 MARKED DEFENDANTS' EXHBT NO. 36 MARKED DEFENDANTS' EXH B T NO. 37 MA R KED. t CERTFCATE OF NOTARY PUBL e t ! 19 '\ e 22 l

3 .. _._.._._. ~ o o c u o /.. ~... STPULATfONS 2 1. THAT THS DEPOSTON SHALL BE GOVERNED EY 3 STPULATONS AS PRE'/OUSLY CON[rmD Ttl!3Y Tle CO'.W;C!. 4 THE PART ES. s. 2. THAT THE WTHN DEPOSTON SHALL SE TAKEN SGTH 6 STEN6GRAPHCALLY AND BY VDEO RECO~DNG THAT THE DEPONENT MAY EXECUTE AN AFFDAVT OF S CHANGE N THE PRESENCE OF ANY NOTARY PUBLC DULY AUTHORZED 9 UNDER ONE OF THE STATES OF THE UNTED STATES. 10! 4. T S FlJRTHER STPULATED 11 BY MR. DCRSEN 12 W08LD LKE TO STATE FOR THE RECORD THAT MR. BOES 13 AND HAVE BEEN DSCUSSNG THE STATUS OF VDEO TAPNG 14 THS CASE AND ARE N AGREEMENT THAT THERE HAD SEEN SOME SPREVOUSDSCUSSON NCLUDNG 16 10F COL. MORR S SO~E TME AGO. DSCUSSON AT THE DEPOS 10 AND BELEVE THAT T S 17 ACCURATE TO STATE THAT. 8ELEVE. FOR THE TME BENG A 19 LEAST WHATEvER THE STATUS OF THE PARTES' UNDERSTANDrG AT 19THAT DEPOSTON OR 20 UNDERSTANDNGS THAT F THERE WERE ANY SUBSEQUENT THAT WLL CONTNUE UNTL WE OTHERW E 21 AGREE. AND THNK TS THE SENSE OF OUR DSCUSSO~ THA AT 22 SOME FNALZNG DEPOSTON THAT WLL TAKE PLACE N THE 23 1 FUTU RE 24 ACCORD 1 THAT WE WLL AGREE TO SCMETHllG THAT WE ARE FUL~Y N Wl'H 2S BY MR. SOlES

4 _..._..._" 4 (AFFRMATVE NOD) "'2" SGNAURE 3 GENERAL GEORGE GODDNG USA?ETRED BENG DU~Y S~nRN 4 TO TELL THE TRUTH THE WHOLE TRUTH AND roth t'g BUT THE TRUTH; 5 OF HS OWN KMOWLEDGE CONCERNNG THE MATT'ER HEREN TESTFEJ 6 AS FOLLOWS 7 DRECT EXAMNATON BY MR. BOES 8 Q. 9 A. 10 Q. 11 A. WOULD YOU STATE YOUR FULL NAME FOR THE RECORD PLEASE? GEORGE A. GODDNG. AND YOUR HOME ADDRESS. PLEASE? 3142 BORGE STREET OAKTON VRGNA.. ~. 12 Q. 13 A. 14 Q. 15 A. 16 Q. 17 A. 18 Q. 19 M Q. 22 A Q. 25 A. ARE YOU PRESENTLY EMPLOYED MR. ~ODDNG? AM. N WHAT CAPACTY? 'M A SENOR ANALYST WTH THE DBM CORPORATON. CAN YOU EXPLAN BREFLY WHAT THAT NVOLVES? AM NVOLVED N VAROUS GOVERNMENT CONTRACTS FO SDM! WHAT S SDM? SDM S A PROFESSONAL SERVCES QRGANZATON THAT COES THE MAJORTY OF THER WORK FOR THE GOVERNMENT. WHAT SORT OF WORK DO YOU DO? DO ALL TYPES OF TACTCAL STRATEGC WORK NVOLV G OPERATONS. NTELLGENCE AND SO FORTH YOU BASCALLY DO WORK WTH THE DEPARTMENT OF DEPARTMENT OF DEFENSE. YES.

5 _.._.._ 5 ' " o Q. N WHAT CAPACTY WERE YOU EMPLOYED N 1967? 2 A. N 1967 'AS N VETNAM. ~AS N THE J2 SECT ON OF 3 MACV. 4 Q. AND WHAT WAS YOUR RANK? WAS A COLONEL. WAS COLONEL OUR NG THE SPR NAND b SUMMER AND N AUGUST WAS PROMOTED TO BRGADER 7 GENERAL. e Q. THAT S N AUGUST OF 1967? 9 A (AFFRMAlVE NOD). THAT'S CORRECT. 10 Q. A Q. 1. A. 1 S.Q. 16 A. 17 Q. 18 A. 19 a "2 A. 2J?.a WHEN DD YOU ARRVE N VETNAM? N THE SPRNG. DO NOT REMEMBER THE EXACT DATE BELEVE N EARLY MARCH. EARLY MARCH OF 1967? '67 YES. so YOU ARRVED N VETNAM N ABOUT MARCH OF 1967 THAT'S CORRECT. AND HOW LONG DD YOU SERVE N VETNAM? LEFT THE FRST PART OF OCTOBER OF AND WERE YOUR DUTES DURNG THAT SX OR SEVEN ~~NTH PEROD THAT YOU WERE N VETNAM BASCALLY THE SA[ e OR DD THEY CHANGE? THEY WERE BAS CALL Y THE SAME WAS N CHARGE OF ALL PRODUCTON FOR GENERAL MCCHRSTAN AS HS DEPUTY A ~''''' ' CONTNUED BASCALLY N THE SAME CAPACTY FOR GENERA~ ; DAVDSON UNTL MY PRO~OlON THEN \'/AS MADE A

6 .. _._._ 6 " " g o v Q. 5 0 A. } 10! A 11 Q A 14 Q. 1S A. 18 Q A. 21 Q 22 A J ; 2".5 SPECAL ASSSTANT AND WAS MORE NVOLVED N. UH. THE OPERATONAL END OF NTELLGENCE SATSFYNG REQUREMENTS N THE FELD RATHER THAN N THE OFF ~ WHEN YOU SAY THAT YOU BECAME A SPECA~ ASSSTANT. DO YOU MEAN A SPECAL ASSSTANT TO GEN DAVDSON? YES SPECA~ ASSSTANT TO GEN. DAVDSON. THAT'S CORRECT. GEN MCCHRSTAN LEFT VETNAM N JUNE OF 1967 S THAT CORRECT? THAT'S CORRECT FROM MARCH OF 1967 UNTL JUNE OF 1967 YOU WOULD H ve REPORTED DRECT~X TO GEN. MCCHRSTAN? THAT'S CORRECT AND FROM JUNE OF 1967 UNTL THE FRST PART OF OCT SER 1967 WHEN YOU LEFT VETNAM YOU WOULD HAVE REPORED DRECTLY TO GEN DAVDSON? THAT'S CORRECT WHAT DD YOU DO BEFORE COMNG TO VETNAM N MARCH OF 1967? MMEJ~TE~Y BEFORE THAT? WAS N JONT CHEFS OF STAFF YOU WEREN'T A MEMBER OF THE JONT CHEFS OF STA~F? WEL~ WASN'T THE ARMY NAVY OR AR FORCE MEr'SE. WAS ON THE J3 STAFF. A DVSON CHEF HAD EUROPE MDDLE EAST. AFRCA SOUTH ASA AS MY ARA OF RESPONSSLTY

7 ._.._. 7 ' " ; o u.. ~ o o. 3 '.. Q S 6 A. 7 Q. a 9 A. 10! Q. 12/ A. 13 Q. A A. S Q. 16 A. 17 Q. 18 A. 19 Q. 20 A. 21 Q ' A 25 Q. WOULD YOU EXPLAN WHAT NJ3" MEANS. N THS CONTEXT? J3 S OPERATONS. JONT OPERATONS. AND J2 M CV WAS NTELLGENCE. JONT NTELLGENCE. AND HOW LONG DD YOU SERVE WTH THE JONT CHEFS OF STAFF? THREE YEARS. WHAT DD YOU DO MMEDATELY AFTER LEAVNG N OCTOBER OF 1967?. WAS ASSGNED TO HAWA. TOOK. OVER AN NTELLGE VETNAl CE COMMAND N HAWA. WHAT NTELLGENCE COMMAND WAS THAT? TOOK OVER THE ARMY SECURTY AGENCY. PACFC. HOW LONG DD YOU STAY N THAT POSTON? TWO YEARS. WHEN DD YOU LEAVE THE ARMED SERVCES? LAST OF AUGUST. AND WHEN DD YOU JON SDM COMPANY? THE DAY AFTER 'LEFT THE SERVCE. AND YOU'VE 8EEN WTH 80M EVER SNCE? THAT'S CORRECT. N CONNECTON WTH YOUR WORK AT SDM. DO YOU CONT NUE TO DEAL WTH PEOPLE WHO ARE NVOLVED N MLTARY NTEl.LGENCE? YES. WHAT SORT OF WORK DO YOU DO FOR THESE PEOPl.E? J ST

8 _..._......_ o 2 A. 3 Q. 4 A. 5 Q. 7 A Q. 11 A. 12 Q. 13 A A. 17 Q. 18 A Q A. GENERALL Y.. (NO VERBAL RESPONSE). AS OF THE PRESENT TME. DO THREAT ANALYSS GENERAL TERr. GUESS WOULD BE A GOOD CAN YOU BE A LTTLE MORE SPECFC WHAT DON'T THNK T ADDS ANYTHNG AT ALL. THAT MEA1S? T S A THREAT WHAT S A THREAT TO THE UNTED STAT s? THAT'S WHERE 'M CALLED. YOUANALYZE THREATS TO THE UNTED STATES? YES. UNDER GOVERNMENT CONTRACT? (AFFRMATVE NOD) DEPARTMENT OF DEFENSE. WHO YES. H. SAY! S RESPONSBLE FOR AWARDNG THESE CONTRACTS TO YOU OR TO BDM? DEPARTMENT OF DEFENSE. ANY PARTCULAR PERSON N THE DEPARTMENT OF DEFE~SE? NO T'S ACROSS THE BOARD. VAROUS OF THE PRoe AGENCES. PROCURE~ENT ARMS OF THE DEPARTMENT OF DEFENSE. AM NOT NVOLVED N PRO~UR NG CONTRA SO ~ORTH. AM ~~ED MANLY AS A WORKER ON THOS ANALYST. WHAT WAS THE FR~r WORK THAT YOU DD UPON ARRVNG N VETNAM N MAR~H OF 1967? AND' WELL. ON ARRVAL r WAS ASSGNED AS CHEF OF PRO UCTCN

9 .r..!! ~ e! 1 AND. N THAT THE NCUMBENT WAS STLL THERE THAT WAS e 7 B lj Q. A. Q. A. REPLACNG TOOK A FE\~ 1'EE1(S(JR' DON'T REMEr~T' EXACT TME. TO TOUR VETNAM MD 70 TALK TO Mr.ry OF COMMANDERS ON THE GROUND. WHO WAS THE NCUMBENT CHEF OF PRODUCTON THAT WAS STLL THERE WHEN YOU ARRVED? 1 DON'T REMEMBER WHAT HS NAME WAS. 9 T".. DO YOU RECALL WHEN YOU BECAME CHEF OF PRODUCTON? WOULD SAY THAT T WAS SOME\~HERE BETWEEN THE 10TH AN' 15TH OF MARCH UH VERY EARLY. THERE WAS VERY LTTLE OVERLAP. 1 HAD BEEN 'D BEEN N VETNAM OFF AND ON QUTE A BT PROR TO 'THS TME SO KNEW VETNAM FARLY WELL. THE MAN REASON FOR MY GONG OUT~ WAS TO SEE SOME OF THE COMMANDERS AND SEE WHAT REQUREMENTS WERE N THE FELD? Q. COULD YOU EXPLAN WHAT "NE" STANDS FOR? A. NE S THE NATONAL NTELL.CENCE ESTMATE. HER Q. AND COULD YOU EXPLAN WHAT THE NATONAL NTELL ENCE ESTMATE S? 20 A. THE NATONAL. NTELLGENCE ESTMATE S A COMPLA ON C~! NTELLGENCE AGANST ANY.TARGET AREA. AND T C N J 24 5 ENCOMPASS ONE OR MORE COUNTRES. OR T MAY JUST BE A COUNTRY OR T MAY BE SOMETHNG SPECFC TOWARDS CllE ELEMENT OF A THREAT AND SO FORTH. AND ALL OF TH GOVERNMENT AGENCES CONTRaUTE TO THS AND U.S. PROV DE AN L

10 .r 10.! ' 2 Q. 3 4 A. s 6 Q. 7 8 A Q A Q A. 22 Q. 23 A. 25 Q. NPUT. HAVE YOU BEEN NVOLVED MORE THAN A FEW TMES l~ THE PREPARATON OF NATONAL NTEllGENCE ESTMATES? NOT THE NE PER SE. HOWEVER HAVE BEEN NVOl ED ~ NTERNATONAL ESTMATES AND SO FORTH FOR SOME TME. HOW MANY TMES HAVE YOU BEEN NVOLVED N PREPARNG A NATONAL NTELLGENCE ESTMATE? HAVE HELPED CONTRBUTE NUMEROUS TMES BUT TH TME THAT SAT AT THE TABLE WAS N THE AUGUST!ME FRAME OF.1967 WHEN CONTNGENTS. AND WHEN YOU SAY "SAT AT THE PARTCPATED N THE NATONAL PROCESS THE DECSON MAKNG? CAME BACK WTH THE MACV ONLY.. TABLE".YOU MEAN AC1TUALLY NTELLGENCE ESTM TE S THAT WHAT YOU MEAN? YEAH THE FNAL PROCESS. YES. HAD PROVDED NFORMATON PROR TO THS THAT WAS COMPLED r=or THE ARMY OR SOME OTHER ELEMENT AND TAKEN TO THE TABLE. BUT THS TME WAS THERE. THS TME YOU WERE AT THE FNAL DECSON MAKNG PROCESS? THAT S CORRECT. AND THAT WAS THE ONLY TME THAT YOU THAT'S THE ONLY TME THAT 'VE GOT TO THE NE YES. THAT' CORRECT. BEFORE OR SNCE?

11 _... _' ;. lr e L 1 A. 2 Q. 3 4 A. 5 6 Q. 7 a A Q. 12 A. 13 Q. 14 A. 15 Q. 16 A. 17 Q..18 A Q A. 25 Q. THAT'S CORRECT. AND THS NE N WHCH YOU PARTCPATED WAS N AU'UST OF THAT'S CORRECT. WHO ELSE PARTCPATED N THE FNAL DECSON MAKG PROCESS AT THS AUGUST NATONAL NTELLGEN E ESTMATE? WELL. THERE WERE REPRESENTATVES OF ALL THE NTELLGENCE AGENCES N THE GovERNMENT. THE DOD ELEMENTS CA. THE SERVCES. CAN YOU DENTFY THOSE? (NO VERBAL RESPONSE). WHO WAS PRESENT FROM EACH OF THOSE SERVCES? NO DO NOT REMEMBER THE NAMES OF PEOPLE. DO YOU REMEMBER ANY OF THE NAMES? (PAUSE) NO. (NEGATVE GESTURE). YOU DON'T REMEMBER ANY OF THE NAMES? THE. U ALL DON'T RE' ~BER. WELL. KNOW WHO CAME FROM CNC?AC. UH. WAS HAMP HRE. DO NOT REMEMBER WHO WERE FROM THE DEPARTMENT 0 ARMY NAVY. AR FORCE. MARNES. STATE AND SO FOR H NO. DO NOT REMEMBER. WELL. YOU REMEMBER THAT THERE WAS A MR. HAMPSHR CORRECT? THAT'S CORRECT. DO YOU REMEMBER THE NAMES OF ANYONE WHO WAS PRES NT.

12 12 2 A. 3 Q. 4 OTHER THAN YOURSElF AND MR. HAMPSHRE? WEll GAN~S HAWKNS CAME WTH ME FROM VETNAM. ES. SO OKAY. YOU REMEMBER HAMP~HRE AHD HAWKNS. D YOU REMEMBER THE NAMES OF ANYONE ElSE WHO WAS PRESENT. \.~ 5 OTHER THAN YOURSElF HAMPSHRE AND HA~/KlNS? 6 A. WEll THERE WERE SEVERAL CA PEOPlE THfT ~ERE THE E Q. THAT WERE PRESENT. GEORGE CARVER WAS THERE. DON'T REMEMB~R ANY OF THE NAMES. THE ONlY NAMES OF THE PEOPlE WHO WERE PRES~NT (PASE"! THA YOU; 10 REM~MaER OTHER THAN YOURSElF ARE HAMPSHRE HAW.NS 11 AND CARVER; S THAT CORRECT? 12.A. 13 Q. 14 A. THAT'S RGHT. BUT YOU DO RECAll THAT THERE WERE OTHER PEOPLE TH RE? YES THERE WERE PROBABlY TWENTYSOME PEOPLE THERE. " ". 15 Q. 16 A Q A WHAT WAS THE PURPOSE OF THS NE THAT YOU ATTENDE? THE PURPOSE OF THE NE AS STATED BEFORE WAS TO DRAW TOGETHER FROM THE VAROUS NrEllGENCE AGENCES OF THE GOVERNMENT THER BEST ESTMATE OF WHAT THE THREAT WAS N VETNAM. THS NE WAS CONFNED TO AN ASSESSMENT OF VETNAM. PROR TO ATTENDNG THS AUGUST 1967 NE MEETNG 0 ASSESS WHAT THE THREAT \1AS N VETNAM AS YOU PU T WAS THERE PREPARATORY WORK THAT YOU HAD DONE TO PREPARE YOURSelF TO ATTEND nls t'.eetng? WELL THE MACV FGURES WHCH CARRED BACK wer5 A '~'r

13 ' 13 r' cr '. g o y o. ~ s s 7 Q. s RESUL T OF A CONSTANT UPDATE. NTELL GENCE S A DYNAMC STUATON OF WHERE DALY CHANGES. THE PREPARATON WAS BASCALLY MY AN. SO. JOB OF PRODUCT N. OF WATCHNG THE NTELLGENCE ESTMATE AS T EVOLVED T CHANGED BASED ON ADDTONAL NFORMATON AS T AR VED AND SO FORTH. WHAT WERE THE SSUES THAT WERE DSCUSSED AT THS NE MEETNG? 9 A. " WELL. T. T COVERS THE WHOLE SCOPE OF NTELLGENCE. 10! AND ONE OF THE FGURES. ONE OF THE THNGS WERE T E! FGURES OF THE VAR OUS STRENGTHS OF TH.E ELE~lENTS THAT 12 WERE NVOLVED THE MAN FORCE. THE NVA. THE VC THE 13 GUERRLLAS. THE SELFDEFENSE FORCES. THE POLTC L S Q. 25 CADRE. THE HOME DEFENSE FORCES. THE VAROUS COOL ETYPE PEOPLE THAT ASS STED AND SO FORTH. ALL CF THESE FGURES WERE LOOKED AT. ALSO. WHAT ARE THE CAPABLTES? WHAT ARE THE LMTATONS? WHAT THE MORALE? WHAT. UH. S THE FOCD STUATON WHCH HAS A BEARNG ON THE MORALE. WHAT S THER LEADERSH' p? ALL OF THE THNGS THAT PERTAN TO MAKNG A FGHTNG FORCE WHAT T S. AND WAS THERE ULTMATELY A REPORT THAT CAME OUT NE MEETNG? YES. THE ~ATONAL CAME OUT AS THE FNAL REPORT. NTELLGENCE ESTMATE ON VETNAM F THE

14 _._. 14 Q.. 2 A Q A. 12 Q A WHEN WAS THAT PUBLSHED? DON'T KNOW THE EXACT DATE. BUT T WAS SUBSEQUE T TO OUR MEETNG N VETNAM N SEPTEMBER THE FRST P"RT OF' SEPTEMBER. SO. CONSDE~NG TEN DAYS TO TWO WEEK AFTER THEY RETURNED TO vlash NGTON. THE GROUP THA OUT TO VETNAM TO LOOK AT OUR DATA WOULD SAY SOMETME BETWEEN 15 SEPTEMBER AND THE 25TH. OR SOMETHNG LKE THAT. NOW~ 'M JUST GUESSNG ON THAT. YOU MENTONED A TRP TO VETNAM THAT FOllOW D YOUR MEET! NG? THAT'S CORRECT. WHO PARTCPATED N THAT' PROCESS? THE TRP TO VETNAM? AGAN THERE WERE REPRESENTATVES FROM EACH OF TH vew;" NTELLGENCE AGENCES. GEORGE CARVER FROM CA A~D _ GANES HAWKNS AND FROM MACV. AND. UH. THE PU1RPOS OF T WAS TO LOOK AT THE DETAl OF THE FGURES WHCH.. ~ l Q 5 A THE DETALS. WHCH WE HAD N OUR THOUGHTS. SO THERE WAS A MEETNG N AUGUST 1967 N WASHNGTON? THAT'S CORRECT

15 . 15 [" " Q. 2 3 A. THAT'S CORRECT. 4 Q. 5 A AND THAT MEETNG WAS V ETNA'1?.. CONTNUED N SEPTEMBER WTH BASCALLY THE SAME PARTCPANTS? REDUCED TO WHERE THERE 1ERE TWO THREE. FOUR REPRESENTATVES FROM EACH OF THE AGENCES AT THE NE MEETNG AND WHERE THERE WAS BASCALLY ONE POSS BLY TWO N SOME NSTANCES. REPRESENTATVES FROM THE 9 NTELLGENCE AGENCES N WASHNGTON. WHEN THEY W NT Te 10 V ETNAM. Q A. 14 Q. 15 A Q. 18 A Q A. NOW. YOU SAY THA~ YOU CAME TO AN "MPASSE" AT TH WASHNGTON MEETNG CORRECT? THAT'S CORRECT. WHAT WAS THE NATURE OF THAT MPASSE? THE DFFERENCE N FGURES AS TO THE VAROUS CATE CRES' OF THE STRENGTHS. CAN YOU BE MORE SPECFC? THERE WAS BASC AGREEMENT AS FAR AS THE NVA AND C WERE CONCERNED. BUT AS FAR AS THE VAROUS CATEGC ES OF RREGULAR AND SUPPORTNG FORCES WERE CONCERNE POLTCAL CADRE THERE WERE DFFERENCES ON THA AND THAT WAS BASCALLY THE AREA OF CONTENTON. WHEN YOU SAY THAT THERE WERE "DFFERENCES" CAN OU 55. MORE SPECFC AS TO WHAT YOU MEAN BY"DFFERENCES? WE!..!.. THERE WERE DFFERENCS N STRENGTH AND 'L' JUS ~

16 . _. 16 2!. 3 4 TAKE YOU look AT NTERROGATON OF PRSONERS. YOU look AT SOME DOCUMENTS AND YOU COME UP WTH A FFURE AND YOU SAY UH 'THERE'S 10000' look AT THESE SAME FGURES AND COME UP WTH ' o u ~ ;. o ~ ~ o 5 ' THESE TYPES OF DFFERENCES ARE SASED ON THE EXPERENCE 7 8 q 10 ' A 23 Q. OF THE VAROUS ANALYSTS AND ALSO THE SOURCES THAT ARE AVALABLE. N MANY NSTANCES THNGS THAT WERE TALKED ABOUT N THE PREVOUS DSCUSSO~ ~/ERE PEOPLE le;; TALKNG ABOUT NFORMATON. AND NFORMAT!uN S BASCALLY ONE SOURCE. AND YOU MAY COME UP WTH r SOURCE AND BASED ON THS SOURCE AND SOME EXTRAPoLATON COME UP WTH A VERY HGH FGURE WHERE MULTPLE SOURCES WHCH CALL NTELLGENCE CONVERTNG T TC NTELLGENCE AND LOOKNG AT THE MULTPLE SOURrES SAY 't's THAT'S ALL THAT CAN BE JUSTFEr". WELL MR. MORE SPECFC N MY YOU SAY THAT YOU GODDNG LET ME TRY TO BE. PERHAPS. A LTTLE QUESTON. REACHED AN "MPASSF" AT MEETNG N AUGUST OF 1967 N WASHNGTON. M~ WHAT THE MPASSE WAS WEll. AS SFECFC AS YOU CAN NOW REMEMBER? TH S yn! E CAN O.J JELL 24 A. MAYBE "MFMSSE" S A lttle STRONGER TERM TH'N 25 WNT TO USE. WE HAD AN HOr~EST 0 FFE'<ENCE AS FAR AS

17 .~ hr"' 17. " g c " o " r " ~ o STRENGTH WAS CONCERNED. WE FELT VERY STRONGLY BASEO 2! ON OUR "~"LYSS OF EveRYTHNG THT ~E HD Tl;\T HE 3 j FGURES WERE AT THS LEvEL AND THE CA AND OTH R ~ PEOPLE FELT THAT THE FGURES WERE UP ANb DOWN ASED 5 ON THER ANALYSS. b Q WELL LET ME LET ME COME BACK TO THE QUEST! ON OF '10 11 WHAT S AND S NOT "HONEST DFFERENCE" OF OPN N. BUT FRST WHAT 'M TRYNG TO GET S YOUR BEST PRESENT RECOLLECTON AS TO WHAT THE POSTONS W RE THAT WERE DFFERENT. THAT S. YOU SAY THAT YOU HAD ONE POSTON AND THE CA AND' SOME OTHERS HAD A 12 DFFERENT POS T! ON 13 NOW CAN YOU DEFNE WHAT THE POSTO WAS THAT YOU HAD b A 171 Q 18 A. AND WHAT THE POSTON WAS THAT THE CA AND THE HAD? 19 BY MR. DORSEN (NO VERBAL RESPONSE) F YOU ~AN NOW RECALL AT ALL? WELL THNK 20 OBJECT TO THE FORM OF THE QUEST! ON 21 TEST MONY CONT NUED BY DEPONENT THNK THAT YOU'RE USNG A TERM HERE THAT LTTLE STRONGER THAN WE were USNG ~ND THAT S 24 DRECT EXAr~N~TJON CONTNUED BY "R BOES 2S Q WHAT TERM S THAT? THERS S A

18 ====~~==~~==~'~~~=~=~"~j~ 18.. A 2 Q. 3 A. 4 ;.."POSTlON". UH DDN'T YOU JUST USE THE TERM "POSTON"? MAY HAVE. TOO; BUT THE FGURES. BASED ON ~...'ALYjS ~ THAT WE HAD WERE AS A RESULT OF VERY DETALED ~ ~.... e l TO 9 Q. 11 A. ANALYSS OF EVERYTHNG THAT WAS AVALABLE TO US. ~ND. AS SAY T WAS AN AN HONEST DFFERENCE. ~ASED ON WHO WAS DONG THE ANALYSS AND WHAT WAS AVAL BLE TO THE~. WELL NOW. GENERAL. YOU'VE USE THE TERM "HONEST DFFERENCE" A COUPLE OF.TMES. UM HUM. (AFFRMATVE NODl. 12 Q. YOU'RE AWARE ARE YOU' NOT. THAT S0ME OTHER PEOPL CHARACTERZED THOSE DFFERENCES AS BENG SOMEWHA~ OTHER THAN HONEST PERSONS THAT WERE PRESENT WTH YOU AT THAT NE CONFERENCE. YOU'RE AWARE OF THA? AREN'T YOU? 17 BY MR. DORSEN 18 OBJECTON TO THE FORM OF THE QUESTON. 19 DRECT EXAMNATON CONTNUED BY MR. BOES 20 Q LET ME ASK THE QUESTON DFFERENTLY F YOU HAVE 21 TROUBLE WTH THAT QUESTON. ~ BY MR. DORSEN 23 OBJECT TO THE NFERENCE STATED. MR. SOlES. HE CON'T HAVE '''OUBLE. OBJECTED TO T. 24 HAV ZS BY ~R SO!S

19 +'rr ~ 19 " " ; ; "! 1! 2 YOU ~A Y OBJ ECT TO WHATEVER YOU WHAT. DEBATNG THS. NCDENTALLY. MR. GCDD!NG. ARE YOU HERE AT THS DEPOSTON? PRESENT? 6 BY DEPONENT 7 YES. (NDCATNG MR. DORSEN). 8 BY MR. BOES a 10 BY DEPONENT. HE S YOUR ATTORNEY? \'E' RE NOT REPRESEN~E~ DO YOU HAVE AN ATTORN~Y 11 ARE YOU (MS. DORSEN) MY ATTORNEY OR NOT? 12 BY MR. BO r ES WELL 'M NOT ASKNG HM. 'M ASKNG YOU. ATTORNEY? 15 BY DEPONENT 16 YES. 17 BY MR. SOlES 18 YOU ARE AWARE THAT HE S GENERAL WESTMORELAND'S 19 ATTORNEY N THS ACTON; AREN'T YOU? 20 BY DEPONENT 21 THAT'S CORRECT. BY MR. BO!ES 23 AND YO~ SELECTE~ FOR YOUR ATTORNEY. HERE. GE~ER'L 24 WES 'MORELAND' S A TTlRNEY?! L

20 120 r;~ hrr ~~ ' BY MR.! (PAUSE) HAVE BEEN WORKNG WTH THEM ALSO ~ES. BOES BY DEPONENT WHEN YOU SAY THE "THEM" N THAT ANS1ER? 'VE BEEN WORKNG WTH THEM ALSO" HAVE talked TO THE CAPTAL LEGAL ASSOCATON +0 S YES.... ' 7 BY MR. BOES s AND BY the CAPTAL LEGAL ASSOCATON YOU MEAN TH~ 9 CAPTAL LEGAL FOUNDATON THAT'S 10 BY DEPONENT 11 FOUNDATON ALL RGHT. 12 BY MR. BOSE REPRESENTNG GENERAL WESTMORELAND? BY DEPONENT THAT'S RGHT. l a = S BY MR. BOES AND WHEN YOu REFER TO THS PERSON STTNG NEXT T~ YOU YOU'RE REFERRNG TO MR. DORSEN CORRECT? BY DEPONENT MR. DORSEN YES. BY MR. BOSE AND YOU KNOW THAT MR. DORSEN ALTHOUGH HE S NOT PART OF THE CAPTAL LEGAL FOUNDATON S ALSO AN ATCR~E'f WTH ANOTHER LAW FRM THAT S REPRESENTNG GENER~L WESTMORELAND? YOU KNOW THAT? L

21 " \. " g o " o '. a a \ 1 BY DEPONENT 2 'M AWARE OF' THAT. (AFFRMATVE NOD).! 3 BY MR. BOES AND KNOWNG ALL THAT KNOWNG THAT THESE were TtE PEOPLE WHO WERE REPRESENTNG THE PLANTFF N THS ACTON YOU SELECTED THEM AS YOUR ATTORNEY TO REPtESEN7 YOU HERE? 8 BY DEPONENT 9 HAVE NOT SELECTED AN ATTORNEY. 1 HAVE. UH. 10 HAVE TALKED TO THESE PEOPLE AND HAVE BEEN 11 NTERVEWED BY THEM THE SAME AS HAVE BY YOU. 12 BY MR. BOES 13 YOU'VE BEEN NTERVEWED BY ME. SR? 14 [ BY 1 S! DEPONENT HUH? 10 BY MR.. BOES 17 YOU'VE BEEN NTERVEWED BY ME? 18 BY DEPONENT 19 SAD 'M 9ENG NTERVEWED BY YOU. 20 BY MR. BOES. 21 WHEN ARE YOU BENG NTERVEwED BY ME? 22 BY DEPONENT 23 RGHT NOW. 24 BY MR. BOES "S ' WHEN YOUR TESTMONY S BENG TAKEN? _.. ~~~rnl tt~1 ~ +

22 22 " BY DEPONENT ~.. 2 YEAH. 3 BY MR. BOES ~. 4 BUT YOU HAVEN'T TALKED TO ME BE~ORE? 5 BY DEPONENT 8 NO. 7 BY MR. BOES s AND WHEN YOU'RE BENG NTERVEWED BY ME ATTORNEY FOR 9 THE PLANTFF ARE PRESENT ARE THEY 'NOT? 10 BY DEPONENT 11 THEY ARE YES. 12 ~Y MR. BOSE' BY DEPONENT WERE ANY ATTORNEYS FOR THE DEFENDANTS PRESENT WH~N WERE NTERVEWED BY THE PLANTFFS? YOu! =.~ 16 NO. 17 BY MR. SOlES 18 JUST YOU AND THE ATTORNEYS FOR THE PLA NT! Fr. 19 BY DE?ONENT 20 THAT'S RGHT. 21 BY MR. BOES 22 WAS THERE ANY RECORD KEPT OF THAT NTERVEW? 23 BY DEPONEH 24 DO N01 KNOW. 25 8Y r~r. SOlES L _....nn ~. nr

23 . r...~~ hr ' 23 2 YOU KNOW THAT A RECORD S BENG KEPT OF THS TESTMONY? BY MR. YES AM AWARE OF THAT. BOES '. 8 BY DEPONENT.\... 9 NO. 10 BY MR. BO ES DD YOU ASK THAT ANY RECORD BE KEPT OF YOUR WTH THE PLANTFF'S ATTORNEYS? 11 DD MR. DORSEN OR ANY OF THE OTHER ATTORNEYS NTE~VEW 12 REPRES~NTNG GENERAL WESTMORELAND ADVSE YOU THAf 13 THERE MGHT BE A CONFLCT OF NTEREST SETWEEN TH~R 14 REPRESENTNG YOU AND THER REPRESENTNG GENERAL! ";' L 15 WESTMORE~AND? 16 BY DEPONENT 17 18! BY MR. aoes NO. HAVE NOT H~RED THEM AS MY ATTORNEY. TALKED TO THEM S ALL. AND WAS TOLD THAT WOULD BE PRESENT HERE AND THAT'S ALL THAT'S THAT'S TRANSPRED. 22 THAT S YOU'RE NOT PAYNG THEM? 23 BY DE?CNENT Z4 NO. 'M NOT PAYNG ANYBODY. 25 SY MR. SOTES HAVE THEly! ''LL

24 +. ~~~~ ~r~ ~r 24 _ GENERAL WESTMORELAND S PAY NG THEM. YOU KNO~? "' L 2 BY DEPONENT 3 DON'T HAVE ANY DEA. 4 BY MR. BOES 5' YOU DON'T KNOW HOW THEY ARE BENG PAD? 6 BY DEPONENT 7 NO. HAVE NO DEA. 1'M HERE BECAUSE WAS TOl.f THA 8 WOULD BE SUBPOENAED AND DD THEY WANT UH THE 9 WAS ASKED F WANTED TO BE FORMALLY SUBPOENAED R 10 WOULD COME OF MY OWN FREE W l. L. SA D THAT! '! l.t. 11 COME UP AND'MEET WTH YOU AT THE PREARRANGED TM~. 12 BY MR. BOES 13 WHEN YOU SAY THAT YOU WERE TOLD THAT YOU WOULD Sf 14 SUBPOENAED. YOU MEAN SUBPOENAED TO GVE THE TEST~MONY 15 THAT YOU ARE GVNG HERE? 16 BY 'DEPONENT 17 THAT'S CORRECT. 18 BY MR. 80 ES 19 YOU WEREN'T TOL~ THAT YOU WERE GONG TO 8E SUSPO~NAE~ 20 WHEN YOU MET WTH PLANTFF'S ATTORNEYS? 21 BY DEPONENT 22 NO. 23 BY MR. BOES 24 HOW MANY TMES HAVE YOU MET WTH THE PLANTFF'S 25 ATTORN;YS PROR TO HS TEST~10NY?

25 . rrmnr 25 BY DEPONENO 2 THNK TWO ~MES. 3! 4 BY MR. BOES WHEN WERE THEY? 5! BY DEPONENT LAST FRDAY AND UH (PAUSE) 1 DON'T REMEMBE~ when THE OTHER TME WAS QUTE SOME TME SEVERA~ MONTHS AGO. 9 BY MR.. BOES 10 WHO DD YOU MEET WTH LAST FRDAY? 11 BY DEPONENT 12 MR. DORSEN AND MR. MURRAY. MR. DORSEN. 13 BY MR. BOES 14 THE TWO ATTORNEYS WHO ARE PRESENT WTH YOU HERE? 15 BY DEPONENT 16 (AFFRMATVE NOD). 17 BY MR. BO ES 18 WHERE DD YOU ~EET THEM? 19 BY DEPONENT 20 AT THE CAPTAL LEGAL FOUNDATON. 21 BY MR. BOES 22 HOW LONG DD YOU SPEND WTH THEM? 23 BY DEPONENT 24 ABOUT TWO AND A HALF THREE rours. 2S BY MR. BOES L.~

26 "' 2 NOW YOU SAY THAT YOU MET WTH PLANTFF'S ATTORN~YS PREVOUSLY A FEW MONTHS AGO. S THAT CORRECT? 3 BY DEPONENT 4 UM HUM (AFFRMATVE). 5 COLLOQUY CONT NUED BY MR BO ES 6 Q. 7 A. sq. 9 A Q. 12 A. 13 Q. 14 A. 15 Q. WHERE DD YOU MEET THEM THEN? CAPTAL LEGAL FOUNDATON. WHO WAS PRESENT THEN? MR. BURT AND MR. MURRAY. AND UH. ONE OTHER PERSO~. DOM'T REME'1BER HAT HER NM1E WAS. A.WOMAN LAWYER? UM HUM. (AFFRMATVE) HOW LONG DD THAT MEETNG TAKE? ABOUT AN HOUR. NOW OTHER THAN THESE TWO MEETNGS WTH PLANTlFF'S..2 l!. ~ LAWYERS. HAVE YOU DSCUSSED THS CASE WTH PLA!N~FF GENERAL WESTMOREl.AND. PR OR TO YOUR TESTMONY HER!? 18 A. 'VE TAl.KED TO GENERAL WESTMOREl.AND OVER THE TEl.~PHC~5 19 SEVERAl. TMES SUBSEQUENT TO. UH. THE CBS PRESENT~TCN Q A. 24 THS. 5 Q. SO THAT THE ONLY TME THAT YOU'VE DSCUSSED THE L.~ _.._.

27 .. ~r"m1 T1r.....! 27 l.~ ; A. 5 Q. 6 A. 7 Q. 9 A. 9 Q. 10 A..11 Q. 12 A Q A Q SUBJECT MATTER WTH GENERAL WESTMORELAND SUBSEQUeNT TO THE JANUARY 1982 CBS BROADcAstHAS BEEN OVER THE TELEPHONE? THAT'S CORRECT. AND YOU'VE DONE THAT SEVERAL TMES? YES. WHEN WAS THE MOST RECENT TME? EXPECT T WAS AUGUST SEPTEMBER OF '82. AND WHAT OCCASONED THAT TELEPHONE CONVERSATON? GENERAL WESTMORELAND CALLED ME. AND. UH. WHAT DD HE SAY TO you? WELL HE UH HE SAD THAT A~D WHETHER THS WAS DON'T REMEMBE~ SUBSEQUENT TO THE FLNG 'M ~UTE SURE T WAS TO THE FLNG OF THE COURT ACTON ~ND. ' UH WHETHER T WAS TO THE CHANGE OF VENUE OR NOT. DC NOT KNO\~ BUT HE WAS DSCUSS [rg THAT THERE ~AS!A COURT ACTON AND SO FORTH. WHAT DD YOU DSCUSS WTH PLANTFF'S ATTORNEYS JHEN! YOU MET WTH THEM FC"'. TWO LAST FRDAY.? AND A HALF TO THREE HoulRS BASCALLY A FOLLOW THROUGH. VERY SMLAR TO WHAT ~CU HAVE ASKED ME HERE. WHAT WAS MY POSTON. WHAT ~AS THE PURPOSE OF THE NE WHAT TOOK PLACE SUBSECUE~T THE NE. AND. UH. BASCALLY THE AREA WHCH WE WE~T DD THEY SHCW YOU ANY DOCUMENTS? TO ON.

28 _._ T~rnl ~r~' 28 A. NO. YES TAKE T BACK THEY DD.! Q. 5 A. 6 Q. 7 A. a Q A. 11 Q. 12 A THE UH ASKED TO SEE THE PERNTREP THAT ~A8 PREPARED WAS ANYTHNG ELSE? NO THAT WAS ALL. N ON THE PREPARATON OF. THAT WAS THE ONLY DOCUMENT THEY SHOWED YOU? (AFFRMATVE NOD). AND WHAT \~AS YOU?.THAT DOCUMENT AGA N' THAT THEY SHO"~D... PERNTREP. PERODC NTELLGENCE REPORTS FROM V!~TNAM. AND CAN YOU DESCRBE THAT DOCUMENT? T'S A A SUMMARY OF ALL THE NTELLGENCE UH. OPERATONS THAT TOOK PLACE WTHN THE PRECEDNG MONTH. T'S PUBL! SHED NEAR THE END OF EACH MONTH. AND lt! ENCOMPASSED SUCH THNGS AS THE NFLTRATON THE ENEW. CASUALTES WHCH WERE GVEN BY THE OPERATONS PE~PLE. AND ANY SPECAL REPORTS THAT MAY HAVE COME UP 'SUCH AS NEW WEAPONS OR ANY SUCCESSES OF OPERATONS OR ANY CAPTURED MATERAL. DOCUMENTS SOMETHNG LKE THA~ 20 WAS OF NTEREST. 21 Q. 22 A. 23 Q. 24 A. 25 AND THS WAS THAT'S CORRECT. PREPARED AT THE END OF EVERY MONTH? DD YOU SEE ONLY ONE SUCH REPORT? NO. SAW A SERES OF REPORTS. FROM ABOUT MARCH to OCTOBER. ~ REMEMBER CORRECTLY. _. ~ 11"11"'1' +

29 ~~~rn ~r~r _ Q. 3 A. 4 Q. 5 6 A. 7 Q. 81 A Q A Q A A. 22 Q AND ALL OF THESE REPORTS WERE SHOWN TO you BY PLANTFF'S ATTORNEYS LAST FRDAY? THAT'S CORRECT. DO YOU KNOW WHERE PLANTFF'S ATTORNEYS GOT THESE REPORTS? NO. DON'T. HOW VOLUMNOUS ARE THESE RE~RTS? OH THEy'RE ANYTHNG FROM ABOUT TWENTY PAGES UP TO ABOUT FFTY PAGES DEPENDNG ON HOW MANY SPECAL ARTCLES AND SO FORTH ARE NCLUDED N THEM. WHEN YOU WERE N VETNAM FROM ABOUT MARCH TO EARLY OCTOBER OF 1967 DD YOU PARTCPATE NTHE PREPARATON OF THESE REPORTS? THAT WAS MY RESPONSBLTY YES. DD PREPARED THOSE FOR THE J2. THAT S YOU PREPARED THEM FOR GEN. MCCHRSTAN ANll AFTER GEN. MCCHRSTAN LfFr FOR GEN. DAVDSON? THAT'S CORRECT. G~NERAL MCCHRSTAN AND GENERAL DAVDSON WOULD HA~E BEEN THE J2's? THEY WERE THE J2S THAT'S CORRECT. WHEN YOU MET WTH PLANTFF'S ATTORNEYS LAST FRDAY DD YOU DSCUSS WTH THEM AT ALL THE QUESTONS THAT YOU WOULD BE ASK;O TODAY? THAT S QUESTONS THAT MGHT ASK YOU?

30 ..."''. _. 30 r ; A. 2 Q. 3 4 A. 5 Q. 6 7 s A. 9 Q A. 12 Q. 13 A. 14 Q. 15 A S NO. DD THEY DSCUSS WTH YOU AT ALL THE DEPOSTON THAT HAD BEEN TAKEN OF GENERAL WESTMORELAND? NO. SO YOU ARE AS YOU ST HERE NOW ENTRELY UNAWA~E WHAT TESTMONY GENERAL WESTMORELAND GAvE; S TH~T TESTMONY? AM. ARE YOU AWARE THAT COL. MORRS HAS PREVOUSLY G~vEN TESTMONY? NO AM NOT. DO YOU KNOW WHO COL. MORRS S? YEAH WHO KNOW COL. MORRS. S HE? WELL COL. MORR SS AN ARMY COLONEL THAT CA~E NTO OF YOUR; VETNAM ABOUT THE SAME TME THAT GENERAL DAVDSGN TOOK OVER AS J2 AND UH UH GENERAL DAVDSON MA~E HM HS SPECAL ASSSTANT. DON'T REMEMBER W;;THER HE CALLED T SPECAL ASSSTANT OR EXEC BUT HE WAS N HS FRONT OFF E THAT CONTROLLED ACCESS MEAN THE PEOPLE CO~NG l~ AND OUT AND THEN WATCHED VAROUS PUBLCATON~ AND DOCUMENTS AND SO FORTH AND SCREENED THOSE FOR the GENERAL. HE HAD WORKED FOR HM PREVOUSLY.

31 'rm"t nr' 31 Q. WHEN DD COL. MORRS ARRVE N VETNAM ; "' 2 J! S 9! A. Q. A. Q. A. Q. THNK SOMETME N JUNE. ABOUT THE TME THAT GEN DAVDSON TOOK OVER AS THE J2. AND HOW LONG DD HE REMAN HE WAS ST L'L THERE WHEN N VETNAM? L Err N OCTOB ER DD YOU SEE THE CBS BROADCAST THAT S THE SUBJEC~ OF THS lawsut WHEN YES SAW AND DD YOU T. T WAS BROADCAST? NTERPRET THAT BROADCAST AS HARMNG THE REPUTATON OF THE OFFCER CORPS AND THE ~RMED SERVCES? A. YES. THNK THAT T WAS. UH. 'A LOT OF THNGS WERE TAKEN OUT OF CONTEXT AND OUT OF TME SEQUENCE. ~HCH. UH. MADE T VERY SENSATONAL NSTEAD OF A DOCUMENTARY.' 15 THE WAY T SHOULD HAVE BEEN Q. MOVE TO STRKE THE ANSWER AS NONRESPONSVE. MY QUESTON TO YOU. SR. S WHETHER OR NOT AS YOU SAW l 18 THE BROADCAST THAT YOU SELEVE THAT THE BROADCAS~ WAS 19 1 HARMFUL TO THE OFFCER CORPS AND THE ARMED SERV~~S? r' ~ A. Q. A. Q. AS SAD BEFORE. YES. AND AND DD YOU BELEVE QUALFED T. DD. DD YOU BELEVE THAT T WAS HARMFUL TO YOUR REPUTATON AS A FORMER MEMBER OF THE OFFC~R CCR~S ' "~ "\'.. 25 THE ARMED SERVCES?

32 _..._ 32 J A. HELL THNK THAT T WAS A SLAM AGANST ANY ANY 2 OFFCER HHO WAS NVOLVED N THE PROCESS THE 3 NTELLGENCE PROCESS THERE. YES. 4 Q. NOH LET 14E GO SACK TO '~HAT WE WERE TALK lflg ABOUT A. 5 FEW MOMENTS AGO. AND THAT S THE EXTENT THAT TH'E!SE 6 DFFERENCES AT THE NE WERE AS YOU ~UT T BEFORe 7 uhonest DFFERENCES". 8 ARE YOU AWARE OF ANY OF THE PEOPLE THAT PARTCP~TED 9 N'THE HE P'RCCESS THAT BELEVED THA THE DFFER~NCES ' A Q A Q WERE OTHER THAN HONEST DFFERE~CES? AT THE T~E NO. UH THE DFFERENCES WERE LAD ON THE TASLE AND THEY WERE DSCUSSeD N A VERY GENTLEMA~LY MANNER AND SO FORTH. AND UNT L RECENTLY. A YEAR OR SO!! AGO. UH. HAD NO REASON TO BELEVE THA EVER~BODY WAS NOT HONEST N THER OPNONS.! WHEN WAS THE FRST TME THAT.YOU HAD.<EASON TQ sallev1 THAT EVERYONE WAS NOT HONEST N THER OPNON? SECA4E A LTTLE BT SUSPCOUS WHEN GEORGE CR!..l (PHONETC) FRST CALLED ME ASKNG SEVERAL QUESTONS AND STATNG WHAT HS PURPOSE WAS TO PROVE THA1. UH. THE PRESDENT. CONGRESS AND PUBLC HAD BEEN MSLEAD. UNTL MR. CRLL AS YOU DESCRBE HM. CALLED you AND THAT'S WHAT HE SAD HS NAME WAS? HE S~!J Hl3 NAME WAS CRlL?

33 33 1 GEORGE CRLE. 'M SORRY. WHEN THS PERSON C~LLED YOU. ACCORD!G TO YUu~ TESTMONY THAT WAS THE FRST TM~ THAT YOU HAD ~Y A. REASON TO BELEVE THAT ANY OF THE DFFERENCE~ NE WERE OTHER THAN HONEST DFFERENCES. TESTMONY? THAT'S CORRECT. AT THE S THAT YOUR!.! 8 Q. 9 NOW SUBSEQUENT TO THOSE CONVERSATONS HAVE YOU BECOME AWARE OF VEWS OF SOME OF THE PEOPLE THAT /... PART~PATED. WTH YOU AT THAT NE MEETNG AS TO WHETHER OR NOT THE DFFERENCES OF OPNON EXPRESSED 13 A. 14 THERE WERE OTHER THAN HONEST DFFERENCES? WELL F.ROM THE UH TV PRESENTATON AND SEVERAL ARTCLES THAT HAVE BEEN ~RTTEN SUBSEQUENT TO THSN 15 HAVE BEEN MADE AWARE OF HOW SEVERAL PEOPLE FELT; YES. 16 Q. WHAT PEOPLE? 17 A. 18 WELL GANES HAWKNS AND UH. DON'T REMEMEER WHO ALL HAS WRTTEN EDTORALS BACK HERE. AND SO FCRlH. N 19 VAROUS PAPERS AND SO FORTH. AT VAROUS LEVELS. 20 Q. OFFCER HAMPSHRE? 21 A. HAVEN'T OTHER THAN ON TV. HEARD WHAT.HAMPSHRS e SAD. THE OFFCERS FROM CCV AND SO FORTH WHO wsre ON THE PRESENT.l.T10N. THE TV PRESENHT.ON THAT MA!lE 'HE STATEMEN' 5 THERE THAT UH. WERE. UH BASED ON 25 NFORMATON NOT NTELLGENCE. ~~..

34 ._ 34.~. 2 3 A Q. 7 A 8 Q 9 A 10 Q A Q A 21 Q Q. YOU REFER TO THE OFFCERS FROM CCv. DOES THAT "'. NCLUDE LT. RCHARD MCARTHUR?. WOULD HAVE TO. UH. TO TE THE CONVERSATON SACK DOWN TO THE NDVDUAL TO SAY THAT THERE were SEVERAL OF THOSE THAT MADE STATEMENTS THERE. NOW. WHEN YOU SAY "MADE STATE1ENTS THERE". MADE STATEMENTS ON THE TV PRESENTATON SY THE TV PRESENTATON YOU r'.ean THE CBS BROADCAST? CBS BROADCAST. RGHT N JANUARY. AND UNTL THAT CBS BROADCAST N JANUARY. S T ~OUR TESTMONY THAT.YOU WERE UNAWARE THAT GANES HAWKNS AND HAMPSHRE AND MCARTHUR AND THE OTHERS FELT ~HE THAT THEY FELT? THAT S CORRECT THERE \~AS NO NDCATON OF THAT DURNG ANY TME OF THE NE PRESENTATON. NOR THE PRESENTATON AND DSCUSSONS THAT WE HAD AT MACY.N SEPTEMBER YOU KNWCOL HAWKNS DUR1"G THE ENTRE TME THAT YOU '" / '. 0""". WERE N VETNAM? T!AT'S CORRECT. AND DD YOU HAVE HGH REGARD FOR HS CAPABLTaS AS "'..."... ' AN OFFCtRAN~ A PERSON? "" YES~L.G.M.NS1}'l(~S P...~_!_VERY GOOD JP5 OF..... ~ H~M~~~A ~.~.. _AN~THE!oNAL Y~s..L.S C.r WAY 25

35 35.1 Q 2 A. 3 Q. 4 5 A. e 7 8 Q. 9 A. 10 Q A Q A. L "Q. 21 A. 24 Q. 25 AND DD YOU HAVE AN OPNON OF HS NTEGRTY? DD YOU HAVE ANY REASON TO QUESTON OFFCER... HAl4PS~.LL'L.1~G.R~fT;('?...~'... WAS NOTHAL.c.L.Q~ELY ASSOCATED WTH HAM~SHR~. ~."" ~~"."... HA]1!'..sH.lRQ.WASAT' C NCPAC AN.Q..! '. ljm 0 ON' T SEE TOP "". ""... "~""... MUCH OF HM UNTL WE GOT TO THE NE. "". BUT YOU DD SEE A LOT OF COL. HAWKNS? WELL YES. HE WDRKED DRECTLY FOR ME. NOl YOU ARE AWARE ARE YOU NOT SR. THAT COL. HAWK t'ns HAS DESCR BED THE MACV POS T ON US NG WORDS! LKE "DECEPTON"? SR? YOU ARE AWARE OF THAT ARE YOU NOT. HAVE SEEN SOME OF THAT N THE ARTCLES ~RTTEN N THE TV PRESENTATON. YES. HAVE YOU TALKED WTH COL. HA~KNS BROADCAST? AND AT ALL SNCE THE TV YES TALKED TO COL. HAWKNS RGHT AFTER THE TV PRESENTATON. YES. WHAT DD YOU SAY TO HM? JUST ASKED HM F UH. F WHAT WAS PORTRAYED THERE WAS HS REAL FEELNGS AND SO FORTH. AND HE WAS RATHER! EVASVE AND NOTHNG CAME OUT OF THE CONVERSATlON. THAT S THAT T S YOUR TESTMONY THAT YOU ASKED HM WHETHER THAT WAS HS REAL FEELNGS AND HE EVADED YOU.

36 ...' " 2 A. 3 Q. 4 A. 5 Q. 6 ' 7 A. s 9 Q. 10 A. 11 Q A. 15 Q. 16 A Q A =~~.~.~~ DDN'T YOU GVE YOU AN ANSWER? HE DDN'T GVE ME AN ANSWER. THAT'S YOUR TESTMONY? YES. AND YOUR TESTMONY S THAT YOU CAN'T REMEMBER ELSE ABOUT THAT CONVERSATON? ANY11"H lng' T WAS A VERY SHORT CONVERSATON AND UH BASCALLY ASKED HM THAT ONE QUESTON. THAT WAS T. YOU CALLED HM? YES. CALLED HM. OTHER THAN THS ONE TELEPHONE CONVERSATON. N WHCH YOU CALLED HM HAVE YOU HAD ANY CONVERSATON WTH HM SUBSEQUENT TO THE BROADCAST? NO HAVE NOT. DD SOMEONE SUGGEST THAT YOU CALL COL. HAWKNS?. UH THNK THAT N TALKNG TO GENERAL WESTMORELAND. SUBSEQUENT TO THE BROADCAST THAT T EVOLVED THAT \~OULD TAL K TO A FE\~ P EOPL E AND F '10 OUT JUST WHAT THER REAL FEELNGS WERE. NOW WHEN YOU SAY THAT N TALKNG WTH 6ENERAL WESTMORELAND THAT T"EVOLVED" THAT YOU WOULD CALL THESE PEOPLE YES. AS. AS OUR DALOGUE WENT ON AND SO FORTH P DSCUSSNG S~ME OF THE hspects OF WHAT TOOK PL~CE AND SO FORTH N THE TV PRESENTATON. 36! ;

37 ~' l Q. 4 A. TRYNG TO UNDERSTAND A LTTLE MORE WHAT YOU MEAN By T EVOLVED DO YOU l'lean THAT GENERAL \'EST~~ORELAlD SUGGESTED THAT YOU CALL THESE PEOPLE? CANNOT SAY THAT GENERAL WESTMORELAND SUGGESTED THAT 5 CALL THEM OR THAT UH AFTER OUR DSCUSSON THAT 6 SAD MAYBE OUGHT TO CALL HM AND ASK HM. 7 Q. 8 A S 19 Q A. Q. 25 A. YOU JUST CAN'T SAY WHCH T WAS? CAN'T SAY WHCH T WAS. NO. SO SAY T EVOLVED. T CAME OUT OF THE CON VERSA T ON. \~HE'lER HE SA J D. ' T MGHT BE GOOD. GEORGE. FOR YOU TO CALL HM' OR t SAD 'T SEEMS. LKE HE WAS ONE OF 'HE MOST ADAMANT AND SO FORTH ON THS AND HAD SOME SOME DSPLEASURE WTH THE ESTMATE PROR HERETO WTH GEN. MCCHRSTAN.'l SAD THAT NONE OF THS WAS EVDENT DURNG THE TME THAT WAS TALKNG TO HM N THE NE OR AS WE WEMT BACK AND THAT THS WAS SOMETHNG 'THAT'S COME U. NOW'. SAD ' WOULD L KE TO KNO~ WHAT T! S." NOW WHCH WAY T CAME UP. DO NOT REMEMSE~. SUT YOU DO REMEMBER THAT THESE CONVERSATONS THAT yeu HAD WTH GENERAL WESTMORELAND ARE ALL OVER THE TEl.EPHONE? THAT'S CORRECT. WHEN \~AS YOUR FRST CONVERSATON \~TH GENERAL WESTMORELAND ABOUT THE SUBJECT OF YOUR DSCUS510N? T WAS WTHN A WEEK OF THE cas TV PRESENTATON. _...;11;;; jnr~ j

38 rt! n. At 38 ~ Q. 2 A. 3 Q. 4 A ~ 10 Q. 11 ' A. 14 Q. 15 A. 16 Q. 17 A Q. AND GENERAL WESTMORELAND CALLED you? YES. AND WHAT DD HE SAY TO YOU? HE ASKED ME DD SEE T AND SAD. "YES". "WHAT DC YOU THNK OF T?" AND. SAD. " THNK THAT. UH. TME SEQUENCNG WAS AS FAR AS THE FGURES AND SO FORTH TAKEN OUT OF CONTEXT." AND SAD. " FeEL! ~. ' "C. THAT THERE ARE PEOPLE THAT ARE NOW SAYNG THNGS WHCH THEY HAD NOT SAD PREVOUSLY." MOVE TO STRKE THE ANSWER AS NONRESPONSVE. MY QUESTON TO YOU. SR. S WHAT GENERAL WESTrl0RELA"ND SAD TO YOU HE ASKED ME N THAT CONVERSATON. F SAW THE PRESENTATON. DD HE SAY ANYTHNG ELSE TO YOu? HE ASKED WHAT THOUGHT OF T. DD HE SAY ANYTHNG ELSE TO YOU? THAT CONVERSATON. THNK THOSE ~ERE "ME TWO ~A~l PONTS. 20 PROGRAM? 21' A. 22 Q. 23 A. HE ~DN'T N ANY. SENSE TELL YOU WHAT HE THOU~HT OF ~ 1'' (NO VERBAL RESPONSE). S YOUR TESTMONY? (PAUSE) YES. THNK THAT HE AT THAT TME SAD THAT 24 HE WAS VERY DSTURBED WTH T. T00~ YES. 25 Q. DD HE TALK TO YOU ABOUT THE HONOR OF THE OFFC!R

39 ..r 39 ' ~ CORPS? NO. HE DD'NOT. HE DDN'T TELL YOU T'S YOUR TEST1MONY THAT HE 4 BELEVED THAT THE PROGRAM WAS HARMFUL TO THE OFFCER 5 CORPS OR THE ARMED SERVCES? sa. NOT N THS CONVERSATON NO. 7 Q. 8 A. N A SUBSEQUENT CONVERSATON? N A SUBSEQUENT CONVERSATON HE UH N SUBSEQUENT 9 CONVERSATONS HE STATED THAT HE FELT THAT THS WAS. 10. UH. DRECTED AGANST H!J'~. AGtdNST THE OFFCER CORPS. 11 THE ARMY AND SO FORTH. YES. 12 THE FRST ONE THERE DON'T THNK THAT HE HAD GONE 13 ANY FURTHER THAN LOOKNG AT THE CONTENTS. AND. AS 14 SAY ASKNG QUESTONS AND SAYNG THAT YES. HE WAS 15 DSSATSFED. 16 Q. WHEN WAS THE FRST CONVERSATON THAT. YOU RECALL N 17 WHCH GENERAL WESTMORELAND SAD TO YOU N WORDS OR N S SUBSTANCE THAT THE BROADCAST WAS HARMFUL TO THE HONeR A Q. OF THE OFFCER CORPS? WOULD SAY THAT THS WAS PROBABLY WTHN THE FRST THRTY TO SrXTY DAYS AFTER AFTER THE JANUARY PRESENTATON. DD GENERAL WESTMORELAND TELL YOU WHAT T WAS ABOUT 24 THE BROADCAST THAT HE BELEVED S HARMFUL TO THB HorOR 2S OF HE OFFCERS CORPS?

40 40. ~. A. (PAUSE) NC HE DDN'T GC NTO OTHER THAll 70 SAY THAT HE WAS MSQUOTED AND THAT HS PRE~EN7ATON WAS 3 TAKEN OUT OF CONTEXT AND THAT THE WAY THAT T WAS 4 TWSTED AROUND THAT HE HAD MSLED THE PRESDENT. UH 5 CONGRESS AND SO FORTH. 8 Q. THAT'S WHAT GENERAL WESTMORELAND TOLD YOU? 7 A. (AFFRMATVE NOD). 8 Q. DD GENERAL WESTMORELAND TELL YOU HOW HE HAD BEEN 9 MSQUOTED WHAT HE HAD BEEN MSQUOtED AS SAYNG? 10 A. NOT EXACTLY NO. 11 Q. WHAT DD HE TELL YOU GENERALLY? 12 A. AS FAR AS THE WAY THAT T WAS PUT WAS BASCALLY ~S 13 HS BASC APPROACH. AND SUBSEQUENT TO that WHEN 14 GOT THE SCRPT UH COULD WAS ABLE THEN TO LOOK 15 AT T A BT CLOSER. 16 Q. WHEN YOU SAY "WHEN GOT THE SCRPT" WHAT ARE ~OU!. ; A. 19 Q. 20 A. 21 Q. 22 A. TALKNG ASOUT? GOT THE CBS SCRPT ON THE PRESENTATON. DO YCU MEAN THE TRANSCRPT OF THE BROADCAST? YES. TRANSCRPT. WHERE DD YOU GET THAT? DON'T REMEMBER WHETHER GENERAL WESTMORELAND SENT T 22 TO ME OR THE CAPTAL LEGAL FOUNDATON SErlT T TO ME. 24 Q WHEN DD YOU GET T? 2S A. LAST SUMMER SOMETME. _.._.

41 r''' ;''"11"1 l1r._. ~! 1 o. 2 3 A. 4 Q 5! A 6 Q. 7 A Q A Q. 25 WHAT OTHER DOCUMENTS HAS GENERAL WESTMORELAND OR THE CAPTAL LEGAL FOUNDATON SENT YO~? NONE. NONE? NONE. JUST THS SCRPT? THAT'S THE ONLY THNG THAT 'VE RECEVED FROM ANY5JDY. OTHER THAN WHAT HAVE TAKEN OUT OF THE NEWSPAPERS MYSELF TV GUDE AND SO FORTH. DD YOU BY READNG THE TRANSCRPT OF THE BROADCAST. UNDERSTAND WHAT T WAS THAT GENERAL WESTMORELAND MEANT WHEN'HE SAD THAT HE WAS MSQUOTED? WELL THE WAY THAT THE TV BROADCAST WAS STRUCTURED T MPLED FOR NSTANCE THAT THE NFLTRATON WAS MUCH GREATER THAN T ACTUALLY WAS OR WAS KNOWN AT THE TME THAT T WAS QUOTED N THERE. FeR NSTANCE. THAT THE FOUR TO FVE MONTHS PROR TO TET THAT THE ln~ltraton WAS THERE S NOTHNG THAT SUESTANTATE5 THS. HOWEVER THS WAS LAD ON AS A PONT A;D THEN Tf;lS WAS; BEAT AGANST WESTMORELAND'S TESTMONY WHERE HE $AD THAT THE NFLTRATON WAS TO THE PRESDENT T~E CONGRESS SOMEWHERE WAS SX TO F REMEMBER THE FGURE CORRECTLY. THNK HE SAD. AND THAT'S WHAT YOU MEANT WHEN YOU SAY THAT GE~ERAL WESTMORELANt SAD THAT HE 'WAS MSQUOTED? 41

42 .. " ~. ~ ~ " A. Q. 4 T WAS PULLED OUT OF CQNTEXT. YES. WELL. YOU SAD THAT GENERAL \'EsmORELAND SAD THA H= HAD SAD THAT HE HAD BEEN MSQUOTED. NOW. DD YOU MEAN "MSQUOTED" OR DD YOU MEAN ntaken OUT OF 5 ' CONTEXT"? OR DO THOSE TWO TH NGS MEAN THE SAME TH NG s TO you?.. 7 ~ A. AS FAR AS MY ANALYSS WAS CONCERNED T WAS TAKEN OUT s OF CONTEXT. SAY THAT HE SAD THAT HE WAS MSQUOTED 9 Q. HE SAD THAT HE WAS MSQUOTED? 10 A. (AFFRMATVE NOD). 11 Q. NOW. DD HE TELL YOU WHAT HE WAS MSQUOTED AaOUr? 12 A. HE" DDN'T GO NTO THE DETALS ON THS AT ALL. AND. 13 UH. THS WAS WHEN ASKED TO GET THE SCRPT AND SO 14 FORTH SO THAT COULD LOOK AT T A LTTLE BT FURTHER Q. MYSELF. SO YOUR TESTMONY S THAT HE NEVER TOLD YOU WHAt T A. WAS THAT HE BELEVED THAT HE WAS MSQUOTED ABOUT? NOT SPECFCALLY. NO. 19 Q. WELL. DD HE TELL YOU GENERALLY? 20 A. NO. HE JUST SAD THAT HE WAS MSQUOTED. 21 Q. DD YOU EVER ASK HM WHAT HE WAS MSQUOTED ABOUt? 22 A. NO. DDN'T. 23 Q DD YOU EVER WONDER WHAT HE WAS MSQUOTED A80UT; 24 A. THAT'S WHY ASKED F~~ THE SCRPT. AND THE AREA THAT 25 FELT TH~T WAS THE MOST CCMPETENT TO LOOK AT WAS THE ~ r

43 43... ENEMY STRENGTHS AND SO FORTH THE NFLTRATON ASPECT ~ j 6 Q. 7 A. AND SO THAT'S WHAT PUT MY FOCUS ON. WAS NOT PRESENT NOR DD HAVE HS NTERVEWS WTH GEORGE CR LE SO DO NOT KNOW \''HAT WAS WHAT WAS TAKEN OUT OF CONTEXT 1 UNDERSTAND OR MSQUOTED. '" e BY VDEO OPERATOR o l o roo 1 9 WE NEED TO CHANGE THE (VDEO) TAPE. 10 (RECESS) 11 DRECT EXAMNATON RESU~lED BY MR. SOlES 12 Q A. 16 Q A. 21 Q. 22 A'. 23 Q. 25 Q. GENERAL GODDNG WOULD LKE TO GO STATED AND BACK TO THE TME MMEDATELY PROR TO YOUR LEAVNG VETNAM TO ATraND THS NE MEETNG N WASHNGTON N AUGUST OF ALL RGHT. AT THAT TME YOU KNEW DD YOU NOT THAT THE?E W*S A DSPUTE BETWEEN THE MACV COMMAND "ND THE C A OVE;! THE ENEMY STRENGTH FGURES OR WHAT YOU HAVE DESCRBtD AS THE ENEMY THREAT? DD NOT KNOW THAT THERE WAS ANY YOU DD NOT? DD NOT KNOW NO ONE HAD TOLD you? NO. AT THAT TME NO. HAD YCU'TALKED TO COL. HAWKNS? DFFERENCE. _.._ ' ''

44 r. 44 A. YES. ~. HAD TALKED TO COL. HAWKNS. 2 Q. AND COL. HAWKNS HAD NEvER NDCATED TO YOU THAT TlERE! 3 ~AS ANY 0 SAGREEMENT BET\'EE~ THE MACV COMMAND POS! cr; 4 AND THE CA? 5 A. NO. ENTERNG NTO A MEETNG. 1 WAS AWARE THA ANYTME 6 YOU GO TO A MEETNG THAT THERE ARE PONTS TO BE "/ ~ 7 0 SCUSSED; BUT AS FAR AS ANY DFFERENCE WAS CONC!ERNE~ s NO THERE WAS NOTHNG APPARENT AT THS TME. 9 Q. PROR TO THE NE MEETNG HAD MACV MADE TS POSTON. 10 OR TS BELEF OR NFORHAON. ABOUT THE NUMBERS 11 AVALABLE TO THE CA? 12 A. 13 Q A. 16 Q. 17 A. S Q. (NO VERBAL RESPONSE). DD THEY KNOW WHAT YOU WERE GONG TO SAY AT THE NE MEETNG? YES. 19 BY MR DORSEN DD YOU KNOW WHAT THEY WERE GONG TO SAY? NO. 1 DD NOT KNOW. UH CAN YOU EXPLAN WHY 20 THNK HE S NOT FNSHED WTH HS ANSWER. 21 DRECT"EXAMNATON RESUMED BY MR. BOES 22 Q. DO YOU HAVE MORE TO ANSWER THAT? 23 A. YES DO. 24 Q WHAT QUESTON ~RE YOU NOW ANSWERNG? 5 A. 'M ANSWERNG YOUR FRST QUESTON DD THE CA KNew

45 45 =!... ; " WHAT OUR FGURES WERE? THE CA KNEW WHAT OUR FGURES WERE BECAUSE \~E PUT 0"tJ'r'TH~r1'O'NHL Y PER 100 C NTELLGENCE REPORT WHCH CONTA~ED ALL OF OUR FGURES. WE PUT OUT DALY AND WEEKLY NTELLGENT SUMMARES. WHCH AD OUR FGURES tl THEM. THE BASC FGURES THAT THE CA HAD WERE GATHERED FROM THE 7 MLTARY NTELLGENCE PEOPLE N VETNAM. THE Q. ADDTONAL FGURES OR ANY DFFERENCES OR ADDTQNAL NFORMATON. YOU MGHT SAY. THAT THE CA HAD WAS FROM THER AGENTS WHO WERE OUT N THE FELD TALKNG TO THE VETNAMESE; THE SOUTH VETNAMESE OR SOME PRSONERS. POSSBLY. AND T S YOUR TESTMONY THAT YOU DDN'T KNOW WHAT CA'S POSTON OR NFORMATON WAS UNTL YOU ARRVED ls WASHNGTON AUGUST OF 1967? 16 A. 17 Q A Q 2S THAT'S CORRECT. DD T COME AS A SURPRSE TO YOU N AUGUST OF 19S7. WHEN YOU ARRVED N WASHNGTON. THAT THE CA HAD SUCH DFFERENT NUMBERS? NO. T DDN'T COME AS A SURPRSE AGAN. GO BACK 70' MY WORD "HONEST" THNK THAT THER ANALYSS FRO~l AFAR AND OUR ANALYSS NCOUNTRY. THERE ARE BOUND TO SOME DFFERErCES WELL. YOU SAY YOU GO BACK TO YOUR WORD "HONEST LET ME GO BACK TU SOMEBODY WHO TALKED ABOUT BEFORE. LT '_._._..._ "n lt1rr1

46 '' 46 ; ';. ~!! 2 3 A. 41 Q. 5 A. RCHARD MCARTHUR. YOU'RE AWARE OF THE SOCALLED PKE Cor~M TTEE HEAR NGS ARE '{GU NOT ;1 R. HAVE HEARD OF THE!. WHAT WERE THE PKE COMMTTEE HEARNGS? DON'T KNOW. JUST 've HEARD THEM. HAVE 8 HEARD OF THEM YES. 7 Q. 8 & A Q A Q. 19 A. 20 Q. 21 A. 22 Q DO YOU BELEVE THAT THE PKE COMMTTEE HEARNGS were HARMFUL TO THE HONOR OF THE OFFCER CORPS? DO NOT KNOW ENOUGH OF THE DETALS TO ANSER THAT QUESTON GVE AN ANSWER TO THE QUESTON. ARE YOU AWARE THAT LT. RCHARD MCARTHUR TESTFED BEFORE THE P'KE COMMTTEE THAT THER WAS 'RECKLESS FALSFCATON OF NFORMATON GONG ON N MLTARY 1 NTELLGENCE N VETNAM WTH RESPECT TO ENEMY STRENGTH' t FGURES? t 'M NOT AWARE OF HS TESTMONY BEFORE THE PKE COMMTTEE NO. AT ALL? NO. NO ONE HAS EVER TALKED TO YOU ABOUT THAT? NO. BUT 25 A. NO. N ANY EVENT T'S YOUR TESTMONY NO ONE EVER TOLD YOU ABOUT THAT AT THE TME THAT YOU WERE N VETNAM THAT SOMEBODY BELEVED THAT? ~ ;.. _.

47 _. ~_r~~rnl ~r~~ t '1 Q 3 41 $ 6 A. 7 Q 8 A. 9 j Q. 10 A 11 Q. 12 A Q. 15 A 16 Q. 17 A S Q A 25 Q..._._._.. ". 47 LET ME SHOW YOU SOMETHNG THAT HAS BEEN MARKED AS DEFENDANTS' EXHBT NO. 32. SOMETHNG THAT ~AS ~AR~EC DURNG GENERAL WESTMORELAND'S DE?QSTON. WHC~ MCARTHUR'S TESTMONY BEFORE THE PKE COMMTTEE. YOU EVER SEEN THAT BEFORE? HAVE NOT SEEN THS DOCUMENT BEFORE. NO. PLANTFF'S COUNSEL DDN'T~SHOW TOLD YOU WHAT THEY HAD SHOWN r~e. THAT'S ALL THEY SHOWED YOU? THAT'S ALL THEY SHOWED ME. THE NE. THAT TO YOU? AND THEY NEVER SHOWED YOU THS DOCUMENT? NO ONE SHowED ME THS AND THS DOCUMENT FROM ANY OTHER SOURCE WELL. T'S A PUBLC DOCUMENT. HAVE HAD NO ACCESS TO KNOW. BUT SAD HAVEN'T HAD ACCESS TO T. THAT S. YOU HAVEN'T S.EEN T? HAVEN'T SEEN T. CAN READ T? WELL YOU CAN. F YOU LKE. THE PORT ON THAT AS REFERRNG TO S LT H/vE S ON THE SECOND PAGE OF THE DOCUMENT UP N THE FRST PARAGRAPH; THE SECOND PAGE OF THE TESTMONY. WHCH S THE LAST PAGE OF THE DOCUMENT. RGHT UP HERE (NDCATNG) WHERE HE TALKS ABOUT THE RECKLESS FALSFCATON OF (WTNESS REVEWS DOCUMENT) DO YOU SEE THT? NFORMATON. ; l... +

48 48 '. 2 Q. 3 4 A. SEE THE STATEMENT. YES. 5 A. NO. 6 Q BUT. YOU HAVE NEVER SEEN THAT BEFORE? NO ONE HAD EVER TOLD YOU TH\ T SOMEBODY 'N Tlt WCV CQMr1MD FEL T TH' T WAY? NO ONE HAD EVER TOLD YOU THAT? LET ME ASK YOU TO LOOK AT A DOCUMENT THAT HAS BEEN MARKED AS DEFENDANTS' EXHBT 2. WHCH S A LETTE~ DATED JUNE FROM COL. HAWKNS TO MR. VAN GORDON SAUTER OF CSS NEWS. WOULD DRECT YOUR ATTENTON PARTCULARLY TO THE LAST'FOUR SENTENCES. ON rhe FRST PAGE. YOU CAN READ THE ENTRE LETTER.F YOU' 12 WSH BUT WOULD' LKE YOU PARTCULARLY TO DRECT YOUR ATTENTON TO THE LAST FOUR SENTENCeS. AFTER YOU HAVE READ l't SUFFCENTLY TO HAVE THAT N CONTEXT WCULD YOU PLEASE LET ME KNOW? BY MR. DORSEN '7 DO YOU HAVE ANOTHER COpy OF THAT? 181 BY MR. BO!S 19 THAT WAS MARKED AS AN EXHBT. DON'T HAVE 20 MADE COPES AT THE TME. AND YOU HAVE THEM. YOU CAN ; ~ 21 LOOK OVER HS SHOuLDER. ~ 22 BY to'r. DORSEN 24 OVER T. 2S A. THAT'S ALL RGHT. (WTNESS REVEWS COCU~ENT). AFTER YOU'RE FNSHE~. 'LL LdoK "' 1