TUESDAY, MAY 23, 1978
U.S. House of Representatives,
John F. Kennedy Subcommittee of
the Select Committee on Assassinations,
Chicago, Illinois.
called for examination by staff counsel for the subcommitte, pursuant to notice, in Room 1669, South Dearborn, Chicago, Illinois, beginning at eight o'clock a.m., in the matter concerning investigation of the assassinations of President John F. Kennedy, Attorney General Robert Kennedy, Lee Harvey Oswald, et al., when were present on behalf of the respective parties:For the subcommittee:
JOHN W. HORNBECK, ESQ., Senior staff counsel
(Appeared without representation by counsel.)
being first duly sworn, deposeth and saith:
Q. Would you state your name, full name, spelling your last for the record, please?
A. Robert Barney Baker, B-a-k-e-r.
Q. Mr. Baker, our purpose this afternoon is to take your deposition here in Chicago. Prior to the giving of your name for the purposes of this deposition, you were sworn by the United States Magistrate, is that correct?
A. Correct.
Q. And also you were given a copy of the rules of the Select Committee, the resolution establishing that committee, is that right?
A. I was, that is correct.
Q. Do you have any questions with regard to either the taking of your testimony under oath here today or the ruleswhich have been furnished to you prior to the taking of this deposition?
A. None whatsoever.
Q. All-right. I'm going to outline some of the rules that pertain to the taking of this deposition, and if you have any question after I've outlined the particular. rules pertaining to the deposition, please
identify those question areas and we'll attempt to resolve them. First of all, you, of course, are entitled to have the presence and assistance of counsel during any portion of the deposition which we are taking today. You understand that particular right?
A. I do.
Q. You do not have counsel here today. Is that a mat- ter of your own choosing?
A. That's right.
Q. A deposition is a voluntary statement, and by your presence here today I assume that you are appearing voluntarily to have your testimony taken under oath, is that true?
A. That's correct.
Q. If there are any questions that you feel the answer to those questions would tend to incriminate you, you may, of course, refuse to answer that question under the Fifth Amendment privilege of self-incrimination. You understand that?
A. I understand.
Q. Our questioning will primarily deal with the period of the assassination of President John F. Kennedy and Lee Harvey Oswald, that is, 1963. It will cover some years prior! to that time, and perhaps a few years subsequent to that time also. You understand that?
A. I understand.
Q. Let me begin by simply getting some identifying information from you, Mr. Baker. What is your present home address, sir?
A. 5400 North Sheridan Road, Chicago, Illinois.
Q. And your present business or occupation, sir?
A. 8550 West Brynmawr, which is an insurance company.
Q.Mr. Baker, prior to November 1963, what was your home residense?
A. Sandstone, Minnesota, Correctional Institute.
Q. And when did you leave that institution, sir?
A. 1963. I don't remember exactly the months. Could be maybe in June.
Q. The records that I am in possession of indicate a June release date from that institution. Does that square with your memory?
A. That's probably when it was.
Q. Following the release from Sandstone, where did you go and what was your business or occupation?
A. I had no business or occupation. I had no job at all. I just resided in 5900 Sheridan Road in a one-room apartment, one-room efficiency.
Q. At some point following your release I believe you began working for the Chicago Loop Auto Refinishing Company, is that correct?
A. Correct, yes, sir.
Q. Can you tell us approximately when it was you began working for that particular company?
A. Could have been maybe--i'm vague on that--could be six or seven months after.
Q. We're just asking for your best memory.
A. Maybe about six months after release.
Q. So do you think that assumption of employment was at the end of 1963, beginning of 1964?
A. To the best of my recollection, I believe it could
Q. You think sometime within approximately'-
A. (Interrupting) '63, '64.
Q. That company was owned by Mr. Earl Scheib, is that correct?
A. That's correct.
Q. Did you know Mr. Scheib personally?
A. I'd met him prior to my going away, when I was with the unions.
Q. And did you have some relationship with Mr. Scheib prior to your incarceration?
A. No, just got along with him real nice.
Q. Were there any business associations with Mr. Scheib prior?
A. No, I had none. The organization that I worked for had business with him, but I did not.
Q. The union had?
A. Yes. I was not involved in that.
Q. And prior to your going to Sandstone, you were working for the international Teamsters, is that correct?
A. That's correct.
Q. Were you working out of Chicago prior to the Sand- stone?
A. Yes. I was an organizer in Chicago.
Q. Was it due to your Chicago organizing you met Mr. Scheib ?
A. Oh, while I was organizing, yes, I met Mr. Scheib, but wasn't organizational work direct to his company then.
Q. Mr. Scheib's companies had no Teamster affilication, his employees?
A. At that time?
Q. Yes, sir.
A. No. I think they were organized people, and they were, at that time, I believe, were going in for contract negotiations.
Q. Did they eventually become Teamster employees?
A. Yes, they did.
Q. And can you tell us approximately when it was?
A. No. I had nothing to do with that particular organization, and it was a certain local union in Chicago that has the jurisdiction, and that local was 743 Local. But I had nothing to do with that particular event at all, organizing or contract, nothing at all.
Q. What was your job then working for Chicago Loop Auto Refinishing?
A. I was taken on there with the understanding that it could be a temporary basis, and they were in a position of going into masking tape and industrial paint sales, and I more or less was interested in distributing same to companies that I had to solicit, to go into, to see what I could do with the tape, and with this industrial type paint.
Q. Did you have a sales territory at this time? no particular area which to go to, but Chicago was the base.
Q. Did you speak personally with Mr. Scheib in order to obtain this job?
A. I spoke with him on the phone, and then he told me to send a letter to him stating what I was looking for, et cetera, et cetera.
Q. OK. Was there any attempt by you to regain your past employment, that is, with the Teamsters when you were released?
A. Yes.
Q. And what was the problem with resuming that job?
A. Well, they were not sure whether or not I was allowed to go right back to work in labor unions or if I was in the position of being a five-year limitation more or less. We have to more or less wait five years before you can go back to labor unions.
Q. Was the five years a statutory requirement?
A. Under Taft-Hartley, but later on, after doing quite a bit of research on it, I was eligible, but it was a year, year and a half when I did find that out.
Q. After that year and a half, did you then return to the Teamsters at any time?
A. No
Q. Whom did you talk with from the Teamsters Union after your release from Sandstone to see if you could regain your employment?
A. Jimmy Hoffa.
Q. Did you talk with him personally?
A. Oh, sure.
Q. What was your relationship with Mr. Hoffa at this time?
A. I was employed by Mr. Hoffa under Central States. I was more or less appointed chairman of the Central States Chauffeurs Division, Teamsters Central States Chauffeurs Division.
Q. You are speaking of prior to Sandstone?
A. Oh, yes.
Q. All right. I'm discussing the relationship after your release from Sandstone you spoke with Mr. Hoffa as to whether or not you could regain your past employment, is that correct?
A. That's correct.
Q. What was your relationship with him? Was it as amiable as it was prior to your entering Sandstone?
A. Very amiable, good friends.
Q. And what was Mr. Hoffa's conversation with you with regard to you regaining employment?
A. He'd have to look into the situation more, more or less find out whether I am eligible to take a position with the Teamsters again, labor, or not be able to, and to have to wait that period of time.
Q. And then you did return to the Teamsters Union?
A. No.
Q. You never did?
A. Never did.
Q. All right. Was there any particular reason that if after this year and a half when you discovered that you were eligible to return you were not able to regain your position?
A. Well, Mr. Hoffa had to go into the penitentiary, and I was personally working for him in appointments and organizing and assignments and being not available, I had no one else to go to.
Q. So your relationship to the Teamsters Union primarily was based upon a personal relationship with Mr. Hoffa, is that a fair statement?
A. I was president of the local union, Washington, D.C.. I was elected by the membership. I left that union to go to the Midwest to work for, organizational work for, Mr. Hoffa. My relationship with the Teamsters was not through Mr. Hoffa; I was there prior, thirty some years.
Q. I understand that.
A. I furthered my relationship with the Teamsters and Mr. Hoffa after I met him at several conventions.
Q. How long did you stay with companies owned by Mr. Scheib?
A. I believe it was an eight-month period in which he --then letters were sent out to all regional directors on all these other jobs, other than managers of the--the people that worked in these garages painting cars, they naturally retained them, but any regional directors that he had or any sales that he had outside of that was terminated. Around eight months, I believe, it lasted.
Q. Was there a business reason for this termination?
A. Yes. The masking tape factory closed. They went under. And the so-called paint that we were selling to industry didn't go over too well. Good enough for the cars, I guess, but not for the other industries.
Q. Was that your last relationship in a business sense with Hr. Scheib?
A. Yes, that's all we had to do with each other.
Q. Did you ever meet an individual who also was associated with Mr. Scheib by the name of Jim Braden, B-r-a-d-e-n, sometimes used the name Eugene Hale Brading, B-r-a-d-i-n-g, from Los Angeles?
A. Never. I've never heard the name until just now,
Q. Did you have any social contact with Mr. Scheib after this eight-month period?
A. No, I never had any social contact with the gentleman outside of his conversations.
Q. Did you wish to add something to that answer?
A. No, I had nothing.
Q. Approximately, how many times did you speak with Scheib, let's say, prior to entering Sandstone and then subsequent to entering Sandstone?
A. Prior to entering Sandstone, I never had anything to do with Mr. Scheib. It is when I got out of Sandstone is when I got to know him.
Q. I misunderstood, then, your previous testimony. I thought you had said that you originally met Mr. Scheib while you were still organizing with the Teamsters, which would have been prior to Sandstone?
A. When I was out on--wait now, I've got to get this myself. Oh, I did, but when I went away, everything was all over with. then. When I got out of Sandstone, I renewed my acquaintanceship by asking for a job. Prior to that was before, you're right. You're right.
Q. My question would be, approximately how many personal conversations did you have with Mr. Scheib before you entered Sandstone?
A. Maybe one or two at the most. I picked him up at the airport one time, drove him--it was in the winter, wintertime, and I drove him down to a certain motel, which I don't even remember where he had meetings, so forth, on on.
Q. Was this in Chicago?
A. That was the conversation, yes. That was hello, how are you, my name, et ceters, but no business.
Q. And the other one or two social conversations you would have had with him--
A. (Interrupting) I don't remember any other outside of maybe--I don't know if I took him back to the airport or he went back some other way, but one time I know definitely, I can remember picking him up.
Q. In any of these meetings in which you picked him up at the airport, did Mr. Scheib go to meet Mr. Hoffa?
A. I don't know who he met. I believe he had a meeting with the Teamsters involved and there might have been a committee, might have been Hoffa there at the time.
Q. Could you pinpoint, roughly, the year in which this particular meeting with Mr. Scheib and perhaps members of the committee?
A. Prior to '61.
Q. Before '61?
A. Prior, or could be the start of '61, but I believe it is prior to '61 , '60. That's to the best of my recollection. him trying to pinpoint, but I just don't remember exactly.
Q. Do you recall whether or not Mr. Scheib ever received any loans from the Teamsters Pension Fund prior to '63?
A. If he did, I wasn't that close to that situation where I would know that, no. I don't know that, no.
Q. After your release from Sandstone, in addition to this telephone conversation in which you requested a job from Mr. Scheib, did you have any other conversations with him?
A. No.
Q. Did you and Mr. Scheib ever discuss Mr. Scheib's political views?
A. No; no.
Q. Were you aware of Mr. Scheib's political views, that is, whether or not he was a very conservative political man, whether he was a very liberal political man?
A. No, I didn't.
Q. In November of 1963 you received a phone call from Jack Ruby, is that correct, sir?
A. No. There was a phone call from Jack Ruby. I was not home, so I couldn't have received it. My wife received the call and. a message to call back this number, to ask for Jack Ruby. I came home--do you want me to --
Q. Well, why don't we proceed on a question and answer basis.
A. Fine.
Q. Were you working for Mr. Scheib in November of to the best of your memory?
A. I don't know. I think it was--I don't know exactly. I know it was an eight-month period that I--I don't remember exactly.
Q. All right. Let's return to the telephone conversation that you've alluded to. The record reflects that there was a long distance telephone call from Dallas to number Pa 8-4031. Was that your home phone in November of 1963?
A. I lived at 5900 and I don't remember that number as being my home number, truthfully, but it must be.
Q. All right. You indicated that your wife called you and said, that you had a message or spoke to you personally?
A. I came home. She told me that I had a message.
Q. What was the message, to the best of your memory?
A. To call Mr. Jack Ruby at a number given in Dallas, Texas.
Q. In 1964, on the 3rd of January, there was an FBI interview of yourself?
A. Right.
Q. And it indicates that you stated to them that your wife had told you to return the call and ask for Lou. Does that square with your memory?
A. Not Lou, Jack Ruby. That's a wrong statement. I don't know where you got that, but it is not correct.
Q. Well--
A. There's no Lou involved in that.
Q. All right. You remember, of course, that you were interviewed by the FBI in January 1964?
A. Yes, definitely.
Q. I may use the FBI statement at some point to see whether or not, one, you made that particular statement to the FBI or, two, if you recall making that particular statement. Again, we are not vouching to whether the statement is true or not. What we want here is, of course, your best independent recollection.
A. I'm under oath at this moment. I don't want no headaches. I'm giving it to you straight.
Q. Insofar as your previous statement, it may or may not be accurate, but it may refresh your memory.
A. Right.
Q. To one extent or another.
A. All right.
Q. Then we will use the statement on that basis.
A. All right.
Q. Your memory is that you had a definite return call, message to return a call to Jack Ruby?
A. Right.
Q. And did you do that the same day?
A. I must have done it the same day my wife told me, yes.
Q. Now, again, the FBI statement reflects that you recalled the date as November 11 of 1963. The toll records, however, reflect a date four days earlier, that is, November 7th of 1963. At this time do you have any memory as to which date is correct?
A. The date that he called me at my house is the authentic date.
Q. Well--
A. That's the only time he called, the first time.
Q. Well, if the record, telephone toll records reflect that you called Ruby collect from your home phone on November 7th to return his call--
A. (Interrupting) That's the operator's number, all this stuff?
Q. Right. Would November 7th square with your memory as to the date of the call?
A. Is that about the same time as he called me
Q. Yes, sir, that's what the record reflects.
A. I'll go with that, then.
Q. Could you tell us the substance of the call with Mr. Ruby ?
A. Oh yes. Jack Ruby told me a mutual friend told me to call you in regard to a labor trouble that he had in Dallas with the union that wouldn't let him put on local talent shows in a burlesque night club that he owned, would intervene for him as the mutual friend said that I could probably help him. I then asked him who the mutual friend was and he was evasive in mentioning the mutual friend. I don't know why but he didn't tell me, so I went further with the conversation.
Q. Complete the conversation and then I'll come back. Fine. Then I told him that I just got out of a correctional institute and that I'm not allowed to be involved with any labor management relation affairs and this would be putting me in a position of that kind, so we've got to forget about it. I asked him again who the friend was. He said, 'Well, if you can't do it for me, you can't help me, what the hell, forget about it."
Q. All right. When he said mutual friend, was it singular or plural?
A. No, a friend, mutual friend.
Q. Just one?
A. Yes.
Q. When you say he was evasive as to the mutual friend did he indicate that he had talked to the friend by telephone personally or where the friend be?
A. No. The way he talked was like somebody that might have been visiting out there with him, sounded like, and he must be buying him a few drinks or something, I don't know, something like that. Like somebody was there, you know.
Q. Was there any indication that this mutual friend was a Chicago resident or a Dallas resident?
A. Didn't mention anything like that. Dallas I wouldn't know, I never was there, never was in Dallas.
Q. You'd never been to Dallas?
A. Texas, forget about it.
Q. All right. He stated to you that his problem was his inability to put on a local talent show and amateur show?
A. Something like that, yes.
Q. Now, the union which he was dealing with, did he state what union?
A. Actors Guild Variety, I think, AGV
Q. Were you familiar with that particular union?
A. No. I know a lot of people in unions, but I never knew that particular union, I wouldn't know.
Q. In 1963 did you know anyone connected with the AGVA Union, either on a national or local level?
A. I couldn't tell you because there were a lot of people in the Central Labor bodies. Could be an AGVA guy, could be Muscians Union. You meet all the trade unions when you go do these meetings. I might have said hello to a guy that could be one but not identified as one; never even questioned him what union he was with. So I say no, and somebody calls up and says you remember me, you met me, I wouldn't know.
Q. Would it be a fair statement that your testimony today is that you have no memory of knowing a particular in- dividual and knowing that that individual was an AGVA affil- iated person?
A. Absolutely; absolutely.
Q. Had you in any of your previous union dealings had to contact AGVA for any particular labor problem?
A. Not at all.
Q. What was your knowledge or opinion of AGVA in terms of the kind of union it was, its strength, its abilities? Did you have any such opinion?
A. I never gave it a thought. Teamsters and all the unions that we worked with, blue collar labor, that's the ones that we associated ourselves with. We never come in contact with AGVA, I didn't, in any respect.
Q. Did you ever tell Jack Ruby that you had no contact with AGVA people and that was not exactly your particular line?
A. No, I didn't tell him that. I just told him I cannot interfere or have labor management relations because of my release from this institution, federal correctional, and that if I did, I'd only be putting myself in a bind. I let it go at that.
Q. There is an indication in the FBI statement again that Ruby said that his competitors were "attempting to knock me out".
A. Right, he did say that. Thank you for reminding me. He did mention that, that's right.
Q. Did he elaborate on that at all?
A. Yes. He says, "They allow them to operate but they won't allow me to operate."
Q. Did he mention any particular competitors by name, either individual or clubs?
A. No. He just says the other guys that own the same type of businesses that I got, the competition to me. He said, "They let them operate; they don't let me operate."
Q. He indicated to you then that AGVA was showing some kind of favoritism?
A. No. He didn't mention AGV
Q. He did not?
A. No, but that I assumed. The only one in entertainment business, actors, singers, et cetera, in that field would be AGV
A. I mentioned that myself, I guess, because I figured that--I've been around the labor organizations so Iong, jurisdictional, I know where they belong.
Q. There is another statement in the FBI that Ruby related he had several strip shows operating in Dallas, in the Dallas area, and said that the American Guild of Varieties, are giving me a headache. He told Baker that competitors through the help of AGVA are "giving me a fit". Does that refresh your memory as to any of the conversation?
A. Words to that effect, right.
Q. So those particular words--
A. (Interrupting) His talking; his talking. Yes, that refreshes me a lot in memorizing exactly what it was about. He was doing most of the explaining, excited, whatnot, over the situation; how he's being taken over a hurdle, so to speak, trying to push him out of business, and I think he did mention several of the competitors.
Q. Did he indicate to you what it was exactly that he wanted done?
A. Yes. He wanted somebody that can go in and talk to these, talk to International or somebody, of this organization that had jurisdiction over his particular field of employment, and sit them down, I guess, and talk to them and negotiate the situation whereby he should be given the same understanding that they gave the others, other places
Q. Did he ever suggest to you that he would want anything more than negotiation or want to know anyone that you might know who could help him to do anything more than negotiate?
A. No, but he was an excited sort of individual on the phone. He was doing most of the talking. 'Well, I'll get somebody else." He says, "I know people", bragadosha, this and that, but I mean he didn't mention--he wouldn't, anyhow--he wouldn't mention the mutual friend, and that bothered me, and that I didn't know him, never knew him. When I come into Chicago, I believe he was already out of Chicago.
Q. Yes. I'm curious. Did he ever bring up his Chicago background with you just at the beginning of the conversation?
A. No. I cut him short. After he got through with his spiel, as you read it, then I told him, I gave him my situation where I couldn't be in a position to help him, that I'd like to but I couldn't, more or less along chat line.
Q. O.K. Now, there is an indication that you, of course, would not give Mr. Ruby any satisfaction so he said that he would contact some other people?
A. Oh, yes, he hinted like that.
Q. Hinting in a way that he had a lot of contacts?
A. Oh, sure.
Q. Did he specifically name any of the contacts, wheth- er they were in labor or--
A. No.
Q. (Continuing) --any other field?
A. No. He more or less was disgusted with the answer gave him.
Q. Now, did you at some later time try to find out who Jack Ruby was and/or who the mutual friend might have been?
A. The mutual friend bothered me. I don't know why, I mean, it was about business, but the phone call was strange, the excited--the attitude that the fellow had on the phone towards the end of the conversation, devil may carish, so on. It did bother me to the extent where I wanted to find out what idiot must have given this idiot my name, I want to know.
Q. So whom did you contact to try to find out?
A. I think, I believe, I called him back. I think I called him back. Have you got a statement there that I gave? Yes, I must have.
Q. I'll say that the FBI statement does not indicate that there was a second phone call; also say that our records indicate that on November 8th of 1962, the next day, at 5:22, Jack Ruby called you--
A. Again?
Q. (Continuing) --from his club.
A. Again?
Q. Again, and the conversation lasted for approximately 14 minutes. Does that refresh your memory?
A. Probably I did call. Maybe he did call me. Maybe he did call me, in his desperation, and the party that he says, mutual friend, might have been even there at the time for all I know. I might have told him this guy can do bragadosha, you know, with the guy. Must have known me, he had my number. I didn't give it to him.
Q. Well, during this period of time in November of 1963, you had been released from Sandstone three, four months, what ever?
A. Something like that.
Q. Had you received any calls like Ruby's request for labor assistance?
A. Help?
Q. Yes, sir.
A. No, not for labor assistance.
Q. So his call would have been an unusual one? A Sure was, especially from a stranger that you don't know. You can get a request from someone you know. Here's a man I never met, don't know him, don't know nothing about him. He come on like gang busters, so to speak.
Q. Do you have any memory of the second conversation that you had with Jack Ruby?
A. I think he was trying to tell me that I could do something along the lines in helping him, but I don't have to do it personally, I must know people that can do something, or along that lines, but I paid no attention to it.
Q. Are you saying he was looking for other names, for other leads, from you?
A. Probably. Probably did. I mean, I know--I tell you the truth, I can't conceive of a 14-minute conversation, unless he said, "Hold the wire", went and had a drink or something, go to the lavatory, come back. I never talked long with him.
Q. Your memory of either one of the conversations is that they were not as long as 14 minutes?
A. No.
Q. You think they were much briefer than that?
A. Sure. They couldn't be that long. That's a long time.
Q. Well, what would your estimate be of either one of the conversations?
A. In what respect?
Q. In time.
A. Maybe the first time it could have been around seven, eight minutes maybe, because he was doing all the talking, maybe ten minutes, off the top of my head. I'm just guessing now. But I never heard from him again after all that.
Q. All right. did you attempt to contact any individuals in the Chicago area who might have known Ruby ,in order to determine how it was that he called you?
A. No, because, first of all, I never knew he actually was a Chicago man. I found that out when I watched television weeks later, months later. I don't know how much later.
Q. You're discussing, then, the Oswald shooting?
A. Yes, where he hit the buy.
Q. And after the Oswald shooting, did you connect the Jack Ruby who called you on the telephone with the Jack Ruby who shot Lee Harvey Oswald?
A. The burlesque place was shown on the TV or the store front place was shown on TV. Sure, I did. I said it had to be him.
Q. First of all, where were you when you heard the news that Jack Ruby had shot Oswald?
A. Sitting on the couch in my living room watching
Q. Was there anyone else with you?
A. My wife.
Q. What was your first reaction to that event?
A. I said, "Holy God, this is the fellow that called me on the phone." I said, "Here we go again, I'll have another visit." I always figured that somebody is going to find out he called me.
Q. So you were not very surprised when the FBI showed up ?
A. Oh, no, no; no. I figured sooner or later. I don't under-rate no one. I know they're going to hit them right away. But I was going through unnecessary quizzing at the time. I was innocent of the event. I didn't even know this guy.
Q. Did you then attempt to find out from any of your friends or acquaintances who Jack Ruby might have been?
A. To tell you the truth, after that--I'd just got out of that correctional joint. I didn't want to know who he was. I didn't even want to look at the TV any more. I didn't want no part of it. I couldn't duck it.
Q. There's a statement attributed to you in the FBI report that he, Mr. Baker, stated, however, after the assassination of President John. F. Kennedy and subsequent murder of Lee Harvey Oswald by Jack Ruby, he made inquiry of numerous persons in an attempt to determine who referred Ruby to him. He stated the results of the inquiry were negative and he still has no idea as to the identity of the individual who suggested that Ruby contact him in Chicago. First, did you make that statement to the FBI?
A. Yes, I told them that I was interested to know, and then after that thing happened I did get around to asking people did you ever know this guy Ruby on the west side, in restaurant on the west side.
Q. Who were the people. that you contacted?
A. Just general conversation, at a table. There is a place here where they have Jewish food. They all congregate in there. General talking. Never one person by name that I can identify. Everybody sittin' at the table. That was the conversation, the big conversation, at the time. Just happened, all this tumult. And who he'd know from Chicago that would give him my name and who he would hang out with. Nobody hangs out with that guy. We talked. He was a loner. They didn't want nothing to do with him. He's a nut. Things like that.
Q. Were these people whom you spoke with in Chicago people who had known Ruby in Chicago years ago?
A. I imagine they might have because he was a West Side guy, they were raised with him, they went to school with him.
Q. Some of the other people that Jack Ruby called, roughly the same time period, are people that you and Jack Ruby may have had in common in terms of knowing their name or having some association with them. Let me ask you if you know Irwin Weiner.
A. Yes, sure.
Q. And how long have you known him?
A. Well, he's been in the bail bond business downtown. I think we had some business with him, taking out pickets and things like that. I then met him in a restaurant. We had a good friend, I think, in Milwaukee. Phil was a friend of his.
Q. This is Phil Avarigio?
A. Yes, that's right. And he used to go in the restaurant. I used to see them together. I know him, hello, how are you, this other gentleman. In fact, I see him now, very friendly.
Q. Did you have any knowledge that Jack Ruby had a conversation with Mr. Weiner?
A. No. I didn't know if Ruby had a conversation with anyone outside of me, outside of what the FBI agents told me, that he contacted other people in this area.
Q. Did they tell you who he contacted?
A. No; they didn't mention no names.
Q. Did they say what the subject matter of the conversation Ruby had with any of these other individuals?
A. No, but I understand it was his problem, that he was trying--
Q. (Interrupting) You understood from--
A. My own thinking that he contacted them people here at the same time he contacted me, because of his labor situations that he had there, troubles, looking for help.
Q. You mentioned Mr. Weiner, Mr. Avarigio. Did you ever have any business with either of those two gentlemen other than that which you've indicated with Mr. Weiner, prior to going to Sandstone?
A. In business, none. Prior to going to Sandstone, you said?
Q. Yes, sir.
A. No.
Q. What about subsequent to that time, anything after Sandstone ?
A. Well, not with Mr. Weiner, but I think they had some, kind of a warehouse where they were selling salvage material, goods, you know, Mr. Alvarigio, and through his people I might have--not might have, but I probably bought some various things, watches and things like that, try to sell them, you make a profit, make a living, but he had the sales people in this warehouse. It was open for the public.
Q. Do you know an individual named Michael Shore from Los Angeles ?
A. No.
Q. Did you ever know anyone who was affiliated with Reprise Records, R-e-p-r-i-s-e? No; no.
A. No; no
Q. Did you know an individual by the last name of Mazzei, who's also from Los Angeles?
A. That West Coast area. I'm very much unknown to everybody there. I don't know too many people there.
Q. What about "Dusty" Miller?
A. Yes. "Dusty" was a vice president. Then he was the secretary-treasurer now of our International Union. Hell of a nice guy.
Q. Approximately how many years did you know Mr. Miller?
A. Quite a few. You see, I've been with the Teamsters quite a while. Nine. ten years maybe; I don't know. I mean, that I know him, see him coming to conferences, meetings. He was a director, I believe, of the Southern Conference Teamsters.
Q. Your relationship with Mr. Miller was very friendly?
A. Well, not as much as other V.P.'s that I knew from the Midwest. But very gracious, real nice person. Sit down, have coffee at the meetings or something, somebody be at the table with him other people.
Q. Did you have any knowledge that Jack Ruby had called "Dusty" Miller?
A. I believe it is in my report that they told me that didn't they? The FBI, I think, told me that. I'm just asking you because I did hear--
Q. You're welcome to review the report. I don't find that.
A. No; no; no. Either them or somebody told me that he contacted Miller. And the story I got, this guy had enough moxey or guts that he--I think he mentioned my name. He's a friend of mine all of a sudden.
Q. You think that Jack Ruby mentioned your name to Mr. Miller?
A. I heard that somewhere, I think so.
Q. Do you have any memory of talking to Mr. Miller and discussing the fact that Jack Ruby might have called him?
A. No, I haven't no recollection of that at all.
Q. Did you--
A. (Interrupting) But he's, this fellow is, nervy enough to go anywhere angels fear to tread, mention names, or do anything to get what he wants.
Q. Your memory is that you heard that Jack Ruby mentioned your name to Mr. Miller as an entre to Mr. Miller?
A. I believe that he might have told me that himself. I don't know who told me. Somewhere I heard that.
Q. Could it have come from Mr. Miller?
A. Maybe.
Q. Could have come from Mr. Miller, could have come from some other source?
A. Maybe, or maybe somebody working for mr. Miller. He might have mentioned it to someone else who had been working for him. I just can't put my finger on it.
Q. Did you have any personal contact with Mr. Miller after your release from Sandstone?
A. Well, no, I never had no contact with Mr. Miller. The only contact I would have had would be with the gentleman I was working for, with Hoffa.
Q. What knowledge or relationship, if any, did you have with a Joe Glaser?
A. Joe Glaser?
Q. Yes.
A. He used to manage a band or something like that in Chicago. That's all I know about him.
Q. Did you have any personal relationship with Mr. Glaser?
A. I don't remember having any relationship with Joe Glaser; I don't remember having any at all with him; seeing him in restaurants and such; different places where he would go to eat, but I personally had nothing to do with Mr. Glazer.
Q. What relationship, if any, have you had with Paul Dorfman?
A. Paul Dorfman was a friend of Hr. Hoffa's, and I met him, and he's a real nice man, and any business relationships, I had no business relationships at all. I believe he had his own union, some independent waste paper union, something, AFL-CIO.
Q. Well, the Waste Handlers Union in Chicago, which Mr. Dorfman had from approximately 1947 to sometime in the late 1950's was a union in which Jack Ruby had originally been an organizer in the late '40's.
A. Not with Mr. Dorfman. With Mr. Dorfman?
Q. No. The history is that in 1947 the president of that union, Leon Cook, was killed.
A. I didn't know that.
Q. And Mr. Doffman became president of that union after the death of Mr. Cook.
A. I see.
Q. Did you have any knowledge of that history that I've just laid out to you?
A. No; no.
Q. Did you ever discuss Jack Ruby with Mr. Dorfman?
A. No reason to. Q It never came up? The subject never came up in any conversation?
A. No; no.
Q. What relationship, if any, did you have with Allen Dorfman?
A. Allen Dorfman, the only relationship I have with him is that I'm employed by him now, I work for him.
Q. Did you have any contact with Allen Dorfman in 1963, '64?
A. I was always friendly with Allen, and talking about making money. Business ways, none whatsoever.
Q. In any of your conversations with Mr. Ruby, did he ever mention anything about a lawsuit that he might file or trying to get an injunction or anything like that?
A. None.
Q. Never discussed that possibility. Did he ask you for any advice?
A. No; no.
Q. What relationship, if any, have you ever had with Nofio Pecora? Have you ever heard that name, New Orleans?
A. None whatsoever. That's strange.
Q. What relationship, if any, have you had with Dave Yaras?
A. Oh, friend.
Q. How long were you associated with Mr. Yaras?
A. Not associated. A friend; liked him very much, him and his family, and he was more or less a resident in Miami Beach, I think.
Q. Did you have much contact with Mr. Yaras during 1963?
A. Not much contact, no; no. I believe he tried to help me one time get a job, I think, while I was in-between, and that was some laundry that his son was heading, some kind of uniform company, and he asked me if I would want to go to work on a commission basis. He said, "You must know a lot of people, places; maybe you can bring in some business; work on commission." I was interested in a salary. I couldn't wait for commissions. I says, "Dave," I says, "I've got to get a set salary, something to take home."
Q. Did you have--
A. (interrupting) Once or twice I spoke to him on the phone in Florida. I think I called him back. I'm not sure now, but I know we did talk on the phone.
Q. There was a phone call on November 21, and the records indicate that call was from you to Mr. Yaras.
A. Possibly telling him that I was thinking over what I told him, that I had to talk it over, think about it, and I called him back, telling him that I appreciated it but I couldn't take it, so forth, so on.
Q. Did you ever discuss Mr. Ruby with Mr. Yaras?
A. I don't think anything occurred with Mr. Ruby in calling me before that happened, where he offered me a job.
Q. Well, I'm--
A. (Interrupting) I don't recall that.
Q. (Continuing) --looking to the possibility of whether or not after the Oswald shooting--
A. After the whole smear was over.
Q. (Continuing)--whether or not you had any conversation with Yams?
A. Pertaining to--
Q. Yes, you may have discussed Ruby coming from in Chicago, whether he knew him.
A. Yes, I knew him well enough to ask him that. I never did, no.
Q. Did you know that Mr. Yaras, and Jack Ruby were from the same neighborhood in Chicago?
A. It is a known fact that every Jewish family grew up came from a certain place called the West Side, or something, Chicago, and that's possible. I can just put and two together; they must have came out of the same area. But I never questioned or asked anybody after the incident where he come out of. It was known then, you know, that he come out of the West Side of Chicago.
Q. Did you have any conversation with Lenny Patrick about Jack Ruby?
A. I haven't seen Lenny Patrick. I saw him maybe once in my whole life or twice in my whole life, only visioned him, and I've never had any conversation pertaining to anything with Lenny Patrick. In fact, I don't even see him around no more.
Q. In 1962 there were several reported conversations in which Mr. Hoffa made some statements about Bobby Kennedy and about killing Attorney General Bobby Kennedy.
A. I was around Mr. Hoffa a great deal, end I don't think there was anybody any closer to Jimmy than I was, and I know he had a running battle with Bob Kennedy. It seemed like both of them enjoyed the fight, and I was before that committee. You know it.
Q. Yes, sir.
A. And I never heard him saying, I never heard him say: kill Bob Kennedy. He'd like to knock his brains out maybe, have a fist fight with him. That could have happened in the courtroom the way both of them were tangling, but not that extreme, no. I never heard it, no.
Q. Did you know a Frank Chavitz?
A. I met Frank Chavitz, yes. I met him in the International office.
Q. Approximately when, can you recall?
A. Yes, sure, around four days before Jimmy went away, at the International office in Washington, D.C.
Q. Was there some special kind of meeting?
A. Well, he was going away, people were going in to see him, wish him well.
Q. Was that the first time you had met Frank Chavitz?
A. Yes.
Q. Did you have any knowledge that Frank Chavitz had made threats against Attorney General Robert Kennedy?
A. No, really.
Q. Did you ever hear that he had come to Washington, D.C., with a rifle to shoot Attorney General Robert Kennedy?
A. Can't believe it. I mean, I can't believe it. Wait a minute. I've never heard it, no. But I just added to it I just can't believe it.
Q. Well, what is there about Frank Chavitz or about that particular incident that you would not believe that would be possible?
A. Well, the guy has to be insane to do anything like that, for God's sake. These guys, they're doing their job. They had a job to do. They're taking you on. Win, lose or draw, Buddy, you don't result to that, you don't kill people. I can't see anybody doing it. That's why it surprised me when you say came in for a purpose. That would be an awful thing.
Q. You have testified that you never heard Jimmy Hoffa make any kind of threat against the life of Robert Kennedy?
A. No, none on the life of Robert Kennedy.
Q. And I take it also that that would include President John Kennedy also?
A. Oh, a great guy; thought he was a good man.
Q. What was--
A. (Interrupting) He was on the committee, by the way I liked him. He was all right. He treated me fair.
Q. Was Mr. Hoffa's, let's say, anger or dispute with the Kennedy administration more directed towards Robert Kennedy or the administration as a whole?
A. No. It was a personal matter. He thought that it was a vendetta against him by Bob, to get Jimmy.
Q. And what was Mr. Hoffa's then response if he thought that there was this personal vendetta by the Attorney General?
A. Oh, he was there to defend himself legally, to show him that he was wrong, that he was just intimidating, framing him. That's the expression. Things of that sort.
Q. It is an expression used by Mr. Hoffa?,
A. Yes; big frame; never did anything like that. Here's a guy coming in with all kinds of statements and words to that effect, I mean, you don't think he's going to like him. Here's a guy that's going to break him, send him to jail. He's not going to have him.
Q. That's the point that we're trying to get to.
A. Yes. But it never reach Jimmy mentally where he would express himself viciously to kill a guy, like you made the statement that he might have said. I never heard it.
Q. Could Jimmy Hoffa get to such anger, just for even a moment, where he might say something like that without really meaning it?
A. Oh, sure. God, people say a lot of things in anger! and could be expressions:that come out, never ever doing what they will say in their anger. But I never heard him say that.
Q. The McClellan Committee hearings and the Justice Department investigation of Jimmy Hoffa had gone on for some number of years prior to November of '63?
A. A lot of years.
Q. And Mr. Hoffa had, as you say, expressed the view that there was a personal vendetta with an effort to frame him?
A. Yes.
Q. In November of '63, if you can recall that time period, Mr. Hoffa again had some very serious legal problems. I believe that was when they we re getting ready for the second trial down in Chattanooga or maybe Nashville at that time. Were you in touch with him during that period of time to find out what his attitude was toward things?
A. No. All through that Tennessee dealings I never contacted him or he me.
Q. Well, what was the reason for that?
A. I don't understand. I figured how am you, call, something, you know. But that was, you say, what year?
Q. November of '63.
A. Well, I was out then--no; no.
Q. Well, how many--
A. (Interrupting) I saw him in Chicago when I came out. They had a meeting at the Edgewater Beach Hotel. That is where I confronted him on my chances of getting back; had had so many years there. I come out without a pension program, things Like that. I said, "Hey, I'm a senior citizen now, buddy, take it easy with me."
Q. Who was present at that meeting at the Edgewater after your release?
A. Regular Executive--not Executive but Central States that they had. That was one of the meetings that the Central States, I believe, had.
Q. Was there any kind of formal request by you to talk to anyone?
A. No; no. I can always walk in, open the door. They never had the door closed when I went back. I could always open the door, say, "Jimmy, how are you?" Not only me but any member of the union could walk in on him and he'd give them the first crack to talk because he knew that they had to get back to work. He was strictly a labor man.
Q. How often did you see Jimmy Hoffa during the fall of 1963?
A. Not often at all. Just at that going away when-well, that was later.
Q. Yes, that was later.
A. '63 I come out. I saw him that one time, and then He was preparing to go in when I came out.
Q. I think that was a couple of years after.
A. he was fighting it then, fighting the case. Maybe he was in the courts, what-not. Because I know that I in Washington the week end that he had to turn himself in.
Q. So I take it, then, from what you've said that your contact with him in the fall of '63 after you got out were certainly not very close, maybe one time, maybe two times?
A. That's right.
Q. I just want to get into a short area of some places where you might have traveled that Hr. Ruby also traveled. Have you ever been to Cuba?
A. No.
Q. Did you ever discuss with anyone the fact that Jack Ruby had been to Cuba? Did anyone ever tell you they saw him there ?
A. I didn't even know he was there, no.
Q. What about Las Vegas? What trips, if any, did you take to Las Vegas, and I want to just put this in a time period, 1960?
A. One in 1946. All right, kid, I went there. They were building a hotel. I went there to look at this skyscraper that was being built on the desert. That's all.
Q. That was the Flamingo?
A. I said '46. It was '47 that I went.
Q. That was the Flamingo?
A. Yes. Opened in '46. '47 I went. You're right. The green felt jungle.
Q. We already indicated--
A. (Interrupting) I haven't been in Vegas--this is unusual--never since '47, '48, little desire. I, would like to go sometime. I've never been there since '47.
Q. You've indicated before that you were never in Dallas ?
A. That's right.
Q. What about New Orleans?
A. I never was in New Orleans.
Q. What about Miami?
A. Oh, I've been there; worked around there; lived there, you know.
Q. Let's discuss the period late 1950's, up to the time you went to Sandstone.
A. Well, late '50's. I think you have a record on it better than I because you fellow do a very good job on that. I was there recuperating from a heart ailment that I had, the type that I had in Washington, D.C., when I was com- mitted to the Washington-Jefferson Hospital. After that, I got out and went back to Chicago. Then from Chicago I took my wife down to Florida to rest. That was in the '50's. I don't remember exactly the year, but I was there, '50's.
Q. Were you working while you were in Florida or just resting?
A. No, I was relaxed, taking it easy.
Q. Was Mr. Yaras down there at this time with you?
A. Not with me, but he, at one time, was at a club where they had a pool room, Jewish get-together, a golf club, and I went over there, too.
Q. Who were your social acquaintances during this Miami ?
A. Social acquaintances, Sea Gull Hotel, on Twentythird Street, we used to eat in Woolfies. Money wasn't too big. I made acquaintances. I didn't go to anybody. I could have gone to people, seen people, but I didn't.
Q. Did you meet or ever know a Norman Rothman while you were there?
A. Norman Rothman, what business is he in?
Q. In Miami.
A. I don't want to tell any lies because you're liable to crucify me.
Q. I'll give you Mr. Rothman's background. He's from Miami. He spent time in Cuba in gambling circles.
A. No;no; no.
Q. While you were in Miami or at any other time, did you ever meet Santos Trafficante?
A. No.
Q. The Miami incident triggers something in my memory, and that is years ago you worked, as I recall, at the Colony Club in--
A. Colonial in Green Acres.
Q. In Hollywood, Florida?
A. I was a matride.
Q. What time period was that, roughly?
A. '45, 1946, maybe '44. This is seasonal. So many months Of the winter the northern area people come down to Florida. That was in Hallandale, H-a-l-l-a-n-d-a-l-e.
Q. Was there ever an individual there at the club by the name of Jack Rubenstein?
A. Not that I know of.
Q. This would have been an individual who perhaps gambled at that--
A. (Interrupting) I know a lot of them gamblers but I never knew of that name, Jack Rubenstein. It is not familiar.
Q. Who were the acting owners of that club during the times you worked there?
A. Jake Lansky. And there was quite a few owners there.
Q. Do you recall any of the other owners who had been active?
A. Joe Adonis.
Q. Any other people you can recall?
A. As owners, now, I don't know now. It could be-- let's see. I used to report to Jake. But I know there was lot of people around.
Q. Did you have any relationship with JAKE Lansky after the Colonial?
A. No; that was it. Only when I was down there did I have any relationship, in seating people, bringing people into the casino, taking them into the entertainment room.
Q. So after the Colonial, you would have had no contact with Jake Lansky?
A. No.
Q. What about Meyer Lansky, what contact would you have had with him?
A. None whatsoever with Meyer because he was busy flying around, or wherever he goes, personal business, but knew that he was quite a gentleman, really.
Q. You had met Meyer Lansky on occasion?
A. Oh, sure.
Q. Approximately how many times, if you recall?
A. A lot of times: in the club, he was eating there; I seen him there with his wife. Not that I had anything to do with him personally. As a guest; I was working there. But I seen him a lot.
Q. Any relationship with him after the Colonial?
A. None whatsoever.
Q. Did you ever know an individual from Chicago by the name of Lawrence Meyers?
A. Lawrence Meyers? By name, no. I don't know by name now.
Q. Frank Goldstein?
A. No.
Q. Alex Gruber?
A. No.
Q. Al Gruber?
A. No.
Q. Harry Hall?
A. No.
Q. Sometimes Mr. Hall used the name of Harry Hallet or Helthgott.
A. No.
Q. Arthur Lewis Clark?
A. No.
Q. Joe Campisi who is from Dallas?
A. No.
Q. James Franiano from the West Coast?
A. No.
Q. You're saying you don't know these people?
A. At all.
Q. Gus Alex from Chicago?
A. I know of him, but I've never met him.
Q. But you don't know him?
A. No.
Q. Did you know Sam Giancana?
A. Know of him but never met him when I read the papers.
Q. What about John Roselli?
A. No.
Q. Did you ever meet John Roselli?
A. No.
Q. Did you ever meet an individual, Russell D. or R. D. Mathews from Dallas who is now working in Las Vegas?
A. What?
Q. R. D. Matthews.
A. Matthews, what is he, gambling business?
Q. In the gambling business.
A. No, never met him.
Q. Sammy Paxton?
A. No. Might have met some people I don't know, you know.
Q. Eugene or Clyde Smahldone from Denver?
A. No.
Q. Roger Bauman, B-a-u-m-a-n?
A. No. Q, "Happy" Meltzer, Los Angeles?
A. No. Wait now, hold still. "Happy" Meltzer?
Q. Meltzer, yes.
A. There was a "Happy"--could he be in the sixties or seventies? I don't know the last name now, but I once met in Chicago a fellow named "Happy".
Q. Under what circumstances, do you remember?
A. No. It was no business deal or nothing like Nothing with unions or anything like that. But somebody, California fellow, "Happy", meet "Happy". That wouldn't be the fellow that's married to or was going with that actress's mother. What's her name? Big Mouth, Raye.
Q. Martha Raye?
A. Yes.
Q. That I don't know.
A. Now, if that's the one, I might have.
Q. O.K. Joseph, Fred or George Sica, C-i-c-a?
A. No.
Q. Lou Lederer?
A. No. MR. HORNBECK: Let's just take a break for a minute (Thereupon a short recess was taken.) Mr. HORNBECK: Just a couple more things. BY MR. HORNBECK:
Q. Did you ever meet or have any relationship with Carlos Marcelo, New Orleans ?
A. No.
Q. Did you have any knowledge that Mr. Marcelo and Mr. Hoffa were related in any way, in a business sense?
A. Not that I know of.
Q. If they had been involved in any kind of a business deal, prior to your entering Sandstone, in the early '60,'s, would it be something that you think you would have been aware of?
A. I don't think so. Kept me with the labor situation and any other businesses, you wouldn't be informed or know anything about. My job was Central States, organizational work, wherever he would send me, but that would be pertaining to Teamsters Union work. That was it.
Q. Did you have much to do with the pension fund business, that is, loan applications, granted or received, any of those negotiations ?
A. No, not at all.
Q. There was a real separation?
A. Labor Union guys had nothing to do with that. That was strictly their own body, voted by whatever, trustees or what-not. That had nothing to do with the Teamsters, Teamsters' officials as such.
Q. Did you know or have any relationship at all with James Palmieri of New York?
A. Is this back in the '40's or '30's? I don't know the name. I left there in '40-some-odd, New York.
Q. Did you have any knowledge of or relationship with Dominick Bartone of Cleveland?
A. I met Dominick Bartone. I only met him because he had some meetings with Mr. Hoffa. That's all.
Q. Can you pinpoint, roughly, when that would have been and what the subject of that particular meeting was?
A. Years ago, had to be years ago, had to be better than seven, eight, nine. Let's put it that way. In Chicago. Wait now. Got to be better than that.
Q. Could it have been somewhere in the early 1960's?
A. Before I went away, yes, sure.
Q. All right.
A. '59, '60, could be.
Q. O.K. There was more than one meeting?
A. He was there a couple of times to see Jimmy.
Q. In relationship to what particular problem?
A. I don't know.
Q. Were you present at any of the meetings between Mr. Bartone and Mr. Hoffa?
A. No. I was never taken into that confidence. I don't know. Whatever business they had.
Q. Was a Mr. Tricaro with Mr. Bartone?.
A. I don't know if Lou Tricaro was with him or not, but I know Lou very well. It is possible that he was; it's possible. I can't pinpoint it that it is so.
Q. Did you ever have any knowledge of Mr. Hoffa and Mr. Bartone being involved in any deal to sell airplanes to Cuba ?
A. Not to my knowledge. I haven't heard that.
Q. Were you aware of any business interests that Mr. Hoffa might have had in Cuba?
A. Hoffa?
Q. Yes, sir.
A. No.
Q. And that kind of a question would surprise you, is that what you're saying?
A. Sure does. It would surprise me if he did.
Q. Mr. Hoffa never mentioned Cuba, American gambling interest in Cuba, to you?
A. No; no. "I've been pretty close to the man. He never mentioned to me anything.
Q. Did Mr. Hoffa ever discuss with you any investments, any business interests, that he might have in Las Vegas?
A. No, none whatsoever.
Q. Did he ever discuss with you any loan interests that the Teamsters had in Las Vegas?
A. No, outside of reading papers. You find out things in them.
Q. I'm not asking for media information. I'm asking for any conversations--
A. No.
Q. (Continuing) --any knowledge whatsoever.
A. No, I haven't.
Q. Did you ever meet a Robert Maheu?
A. Let's see. I got to know--
Q. Working for the Hughes Organization?
A. No.
Q. Again I'm restricting this to the early 1960's.
A. No.
Q. Did you have any relationship with any member of the Hughes Organization?
A. Not that I know of. I never ran into anybody.
Q. That question would entail either you personally or through Mr. Hoffa.
A. No.
Q. All right. It is customary at the conclusion of our testimony in Washington that the committee members permit the witnesses to give any brief statement that they wish to, either placing their testimony in context or commenting on the areas of questioning that have preceded this five- minute period. This is a deposition. The same rule does not apply. However, it is our practice to permit the witness if he has a particular statement or observation that he would like to state, that it is his perogative to so state on the record. So at this time, if there is anything that you would like to add for the record that pertains to this investigation, we would appreciate that.
A. No. The only thing I can say is the questions you asked me I answered them truthfully, honestly, and any date situations there that I don't know about, that's the only thing.
Q. We indicated before, to the best of your memory, is all we can ask at this time.
A. I gave everything to you straightforward, truthful.
MR. HORNBECK: That will complete the deposition. Thank you for your appearance.
(Witness excused.)