Ruffley Deposition, Klayman V Judicial Watch

EXHIBIT 1
Case 1:13-cv-20610-CMA Document 80-1 Entered on FLSD Docket 02/28/2014 Page 1 of 130
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1 UNITED STATES DISTRICT COURT
2 SOUTHERN DISTRICT OF FLORIDA
3
4 LARRY E. KLAYMAN,
Plaintiff,
5 Case No. 13-20610-CIV-
ALTONAGA/SIMONTON
6 v.
7 JUDICIAL WATCH, INC.,
et al.,
8 Defendants.
9
10
11
12 DEPOSITION OF CONSTANCE S. RUFFLEY
13 FRIDAY, JANUARY 31, 2014
14 9:01 a.m.
15
16 205 South Broadway, Suite 200
17 Los Angeles, California 90012
18
19
20
21
22
23
REPORTED BY:
24 TRACY WILLIAMS,
CSR #10139, RPR, CRR
25 JOB NO. 109385
Coalition of Court Reporters of Los Angeles
205 South Broadway, Suite 200, Los Angeles, CA 900121213.471.29661 www.ccrola.com
1
1 APPEARANCES:
2
3
4
5
6
7
8
9
FOR PLAINTIFF:
KLAYMAN LAW FIRM
BY: LARRY KLAYMAN, ESQ., PRO SE
(VIA TELEPHONIC CONFERENCE)
NAVEED MAHBOOBIAN, ESQ.
MONA FALAH, ESQ.
2520 Coral Way
Suite 2027
Miami, Florida 33145
(310) 595-0800
Leklaymangmail.com
10 FOR DEFENDANT:
11
12
13
14
15
LAW OFFICES OF SCHWED, KAHLE, KRESS
BY: DOUGLAS J. KRESS, ESQ.
11410 North Jog Road
Suite 100
Palm Beach Gardens, FL 33418
(561) 694-0070
Dkress@schwedpa.com
16 Also Present:
17 JUDICIAL WATCH
18
19
20
21
22
23
24
25
PAUL J. ORFANEDES, Director of Litigation
425 Third Street, SW
Suite 800
Washington, DC 20024
(202) 646-5172
Porfanedes@judicialWatch.org
VIDEOGRAPHER: Elizabeth Collins
2
1 I N D E X
2
WITNESS: CONSTANCE S. RUFFLEY
3
EXAMINATION BY PAGE
4
Mr. Klayman .................................. 8
5
Mr. Kress ................................... 74
6
Mr. Klayman ................................. 76
7
8
9 EXHIBITS
10 EXHIBIT DESCRIPTION PAGE
11 29 Declaration under penalty of
perjury of Constance S. Ruffley 24
12
2 World's Leading Obama Eligibility
13 Challenge Web Site reprint 27
14 9 Driscoll Seltzer document dated
March 5th of 2012, 10 pages 62
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16
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25
3
1 LOS ANGELES, CALI FORNIAi

2 FRIDAY, JANUARY 31, 2014 9:01 A.M.
3
-000-
4
5 THE VIDEOGRAPHER: Today is the videotaped
6 deposition of Constance Ruffley taken on January 31st,
7 2014, at the Coalition of Court Reporters of
8 Los Angeles at 205 South Broadway Street, Suite 200,
9 in Los Angeles, California. In the matter of Larry
10 Klayman v. Judicial Watch, et al., Case No.
11 13-20610-CIV-ALTONAGA in the U.S. District Court for
12 the Southern District of Florida.
13 My name is Elizabeth Collins with Coalition
14 of Court Reporters of Los Angeles, located at 205
15 South Broadway, Suite 200, in Los Angeles, California.
16 We are now commencing at 9:01 a.m.
17 Will all present please identify themselves, beginning
18 with the witness.
19 THE WITNESS: Constance Ruffley.
20 MR. KRESS: Douglas Kress, attorney for Judicial
21 Watch and for the witness, as well.
22 MR. ORFANEDES: Paul Orfanedes with Judicial
23 Watch.
24 MS. FALAH: Mona Falah with Larry Klayman.
25 MR. MAHBOOIAN: Naveed Mahboobian for Larry
4
205 South Broadway, Suite 200, Los Angeles, CA 90012 I 213.471.2966 I www.ccrola.com
1 Klayman.
2 THE VIDEOGRAPHER: And, Mr. Klayman, if you will
3 identify yourself.
4 MR. Ia...AYMAN: Yes.
5 Larry Klayman, Counsel Pro Se for Larry
6 Klayman.
7 Can you all hear me? Because it's breaking up
8 coming through on our end.
9 MR. KRESS: We can hear you fine.
10 MR. Ia...AYMAN: Okay. Well, let's see how we do
11 with the witness. I may have to call back on a
12 different phone.
13 THE VIDEOGRAPHER: Okay.
14 will the court reporter please swear in the
15 witness?
16 THE REPORTER: will you raise your right hand,
17 please?
18 THE WITNESS: (Complies.)
19
20 CONSTANCE S. RUFFLEY,
21 having been first duly sworn was examined and
22 testified as follows:
23
25 You can proceed.
5
1 (No audible response.)

2
3 MS. FALAH: Larry .
4 MR. KLAYMAN: Yes.
5 Who was who said "Larry"?
6 MS. FALAH: You can proceed.
7 Did you get --
8 MR. KLAYMAN: Hello.
9 I think we are going to have to call back.
10 MR. KRESS: If that's what you need to do, that's
11 fine.
12 I mean, can you hear me now?
13 MR. KLAYMAN: I can hear you fine. I can't hear
14 the court reporter at all.
15 MR. KRESS: Let's -- let's try and see if it works.
16 MR. KLAYMAN: All right.
17 Let me -- let's -- starting with Ms. Ruffley.
18 We are not communicating really well over the phone.
19 It won't take long.
20 Can you hear me?
21 THE WITNESS: Yes.
23 THE WITNESS: Yes, I can hear you.
24 MR. KLAYMAN: We are going to have to go to
25 another -- we will call in in just a second.
6
1 MR. KRESS: Okay.

3 Do you want to go off the record, then?
4 MR. KRESS: We will go off the record.
5 THE VIDEOGRAPHER: The time is 9: 03 a. m. We are
6 going off the record.
7
8 (At 9:03 a.m., a recess was taken
9 until 9:06 a.m. of the same day.)
10
11 MR. KLAYMAN: Larry Klayman joining the conference
12 again.
13 MR. KRESS: Hi, Larry.
15 MR. KRESS: We are back.
16 Can you hear us now?
17 MR. KLAYMAN: Yeah, hold on.
18 We are seeing if our speaker works. If not,
19 I'm going to call back on the other phone again.
20 Because I think the problem is at your end, frankly.
21
22 (A brief pause in the proceedings.)
23
24 MR. KLAYMAN: Can you hear me?
25 MR. KRESS: Yes.
7
1 THE WITNESS: Yes.

2 MR. KLAYMAN: You can?
3 MR. KRESS: Yes, we can hear you.
4 MR. KLAYMAN: Okay. All right.
5 Let's start.
6 MR. KRESS: Wait. The videographer is going to
7 turn the video back on.
8 MR. KLAYMAN: Ms. Ruffley, have you been sworn
9 in?
10 THE VIDEOGRAPHER: Okay. The time is 9:06 a.m.
11 We are now back on the record.
12 MR. KRESS: Larry, the videographer was just
13 speaking. If you could ask your question again.
14 MR. KLAYMAN: Yes.
15
16 EXAMINATION
17 BY MR. KLAYMAN :
18 Q. Ms. Ruffley, have you been sworn in?
19 A. Yes.
20 Q. Okay. Would you please state your name?
21 A. Constance Ruffley.
22 Q. When were you born?
23 A. January 14th, 1944.
24 Q. Where were you born?
25 A. Pasadena, California.
8
205 South Broadway, Suite 200, Los Angeles, CA 90012 1 213.471.29661 www.ccrola.com
1 Q. Can you run us briefly through your

2 educational background?
3 A. I graduated from high school in 1961, and I
4 received my B.S./B.M. in 1994.
5 Q. What is an ESBM [sic]?
6 A. It's a Bachelor of Science in Business
7 Management.
8 Q. And where did you receive that degree?
9 A. University of Redlands, California.
10 Q. What did you do after you got that degree?
11 A. The bank I was working for paid for my degree
12 and I continued to work in the bank.
13 Q. Which bank was that?
14 A. Communi ty Bank.
15 Q. Which bank was that?
16 A. Community Bank headquartered in Pasadena,
17 California.
18 MR. KLAYMAN: Can we turn the sound up a bit?
19 You are very faint.
20 MR. KRESS: I don't know if there is
21 One second, please. Let me see.
22
24
25 MR. KRESS: How does that sound to you now,
9
Case 1:13-cv-20610-CMA Document 80-1 Entered on FLSD Docket 02/28/2014 Page 10 of
130
1 Larry?
2 Larry.
3 MR. KLAYMAN: Yes.
4 MR. KRESS: We tried. Let's see how that works.
5 THE VIDEOGRAPHER: Move it closer.
6 THE WITNESS: (Complies.)
7 MR. KLAYMAN: All right.
8 Hold on one second.
9
11
13 MR. KRESS: Hello.
14 MR. KLAYMAN: Yes. Okay. All right.
15 Q. What bank was that, Ms. Ruffley?
16 A. I beg your pardon?
17 Q. What bank did you work for that paid for your
18 education?
19 A. Community Bank headquartered in Pasadena,
20 California.
21 Q. And how long did you stay with the bank?
22 A. Nine years.
23 Q. Who was your immediate supervisor at that
24 bank?
25 A. Richard M. Acu. A-c-u-n-a, with a tilde
10
130
lover the "n."

2 Q. Is he still there?
3 A. No.
4 Q. And what, if anything, did you do after you
5 left the bank professionally?
6 A. I went to work for Judicial Watch.
7 Q. What was your position at the bank?
8 A. First it was executive secretary, and then
9 legal secretary.
10 Q. What was your duties and responsibilities as
11 legal secretary?
12 A. I helped to write business contracts between
13 the bank and the customers; I did filing for my boss;
14 maintained relationships between
15 Q. Who was your boss?
16 A. Richard M. Acu.
17 Q. Is he still with the bank?
18 A. No.
19 Q. Where is he located now?
20 A. I'm -- I'm not sure.
21 Q. Have you had any contact with him since he
22 left the bank?
23 A. Yes.
24 Q. When was that?
25 A. The last time was about two years ago.
11
130
1 Q. And what were the circumstances of that

2 contact?
3 A. He was going to be homeless and wanted to know
4 if he could come and live with me and my husband.
5 Q. Do you know someone by the name of Marian
6 Hurley?
7 A. Yes. She's dead.
8 Q. When did she die?
9 A. September 19th of 2009.
10 Q. Was Marian Hurley the person who introduced
11 you to me?
12 A. She introduced -- yes.
14 introduction?
15 A. Mike Pendleton, the director of the San Marino
16 branch of Judicial Watch, was looking for a secretary,
17 and Marian called Mike after he had been there for a
18 month and said, "I know just the person who will be
19 perfect for you. She can write, she can -- has
20 stamina, and she can work all night, if need be."
21 Q. Michael Pendleton was looking for a legal
22 secretary. Correct?
23 A. He was looking for someone to run his office.
24 Q. The office administrator?
25 A. Basically, office administrator.
12
205 South Broadway, Suite 200, Los Angeles, CA 90012 1213.471.2966 1 www.ccrola.com
130
1 Q. I didn't hear you. I'm sorry.

2 A. Basically office administrator.
3 Q. Okay. But he also was looking for someone who
4 had legal background. Correct?
5 A. I don't remember that.
6 Q. You do have legal background, as you were a
7 legal secretary for Mr. Acu. Correct?
8 A. Yes.
9 The only reason I was a legal secretary is
10 they had enough executive secretaries, and they were
11 looking to get rid of one of the executive secretaries
12 so they changed my title.
13 Q. Michael Pendleton subsequently left Judicial
14 Watch. Correct?
15 A. Correct.
16 Q. Did you hear my question?
17 A. Yes.
18 Q. Michael Pendleton subsequently left Judicial
19 Watch. Correct?
20 A. Yes.
21 Q. When did he leave Judicial Watch?
22 A. I don't remember exactly.
23 Q. Roughly speaking.
24 A. 2004.
25 Q. About the same time that I left Judicial
13
130
1 Watch. Correct?
2 A. No, you left before.
3 Q. Well, I left in 2003, at the end of 2003.
4 You recollect that, don't you?
5 A. Yes. September 22nd of 2003.
6 Q. Right.
7 In fact, Mr. Pendleton was fired by Judicial
8 Watch because I had hired him. Correct?
9 A. No.
10 Q. When Mr. Pendleton left, you were the one who
11 was in the office most of the time. Correct?
12 A. Yes.
13 Q. I had hired someone by the name of Ernie
14 Norris.
15 You remember that --
16 A. Yes.
17 Q. -- correct?
18 Ms. Ruffley, do you hear my question?
19 A. Yes.
20 MR. KRESS: Her answer was: "Yes."
21 BY MR. KLAYMAN:
22 Q. I had hired someone by the name of Ernie
23 Norris. Correct?
24 A. Yes. And I responded "Yes."
25 Q. Okay. Well, the phone broke up, apparently.
14
130
1 Ernie Norris at some point retired. Correct?

2 A. Not from Judicial Watch.
3 Q. Well, he started to spend most of his time in
4 Wyoming. Correct?
5 A. No.
6 Q. Where is he now?
7 A. In San Marino.
8 Q. How many times -- let's go back a little bit.
9 From -- during 2013, how frequently was
10 Mr. Norris in the office?
11 A. About six months.
12 Q. How many days per week, if any?
13 A. Three.
14 Q. I didn't hear your response.
15 A. Three.
16 Q. Three days?
17 A. Yes.
18 Q. But he wasn't there every week, was he?
19 A. He wasn't there when he was in Wyoming.
20 Q. And he was in Wyoming quite a bit, was he
21 not?
22 A. Half the year.
23 Q. Mr. Norris is not an office administrator, is
24 he?
25 A. No.
15
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1 Q. Doesn't manage the office, does he?

2 A. No.
3 Q. When did you first -- do you know someone by
4 the name of Orly Taitz?
5 A. Yes.
6 Q. When did you first come to know of her?
7 A. When she was running for Secretary of State of
8 California.
9 Q. And when was that?
10 A. 2008, 2010. I don't recollect exactly.
11 Q. What were the circumstances of your coming to
12 know her?
13 A. I went to a meeting where she was talking
14 about her qualifications for being Secretary of State,
15 and that's when I met her.
16 Q. And at that time did you have discussion with
17 her?
18 A. Just briefly. Just introducing ourselves.
19 That's it.
20 Q. And what was that date again, Ms. Ruffley?
21 A. It was either 2008 or 2010. It was at the
22 Green Hotel in Pasadena, California.
23 Q. Did you offer to assist her in her campaign to
24 become secretary?
25 A. No.
16
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1 Q. Did there come a point in time when you had

2 further contact with Ms. Taitz?
3 A. Maybe -- I think the only time -- other time
4 I had contact with her was in -- when I had gone to a
5 meeting of the California Coalition for Immigration
6 Reform where she was running as a potential candidate
7 to run against Barbara Boxer's seat as the senator
8 from California.
10 A. February 22nd of 2012. And there was another
11 candidate--
12 Q. Did you
13 A. Excuse me?
14 Q. Did you speak with Ms. Taitz at that event?
15 MR. KRESS: I think she was -- she didn't quite
16 finish her last answer.
17 THE WITNESS: I was going to say that the other
18 candidate who was speaking that night was Robert
19 Lauten, L-a-u-t-e-n. And the person who
20 videographed -- took the videotape of that gave me a
21 DVD of the presentation.
22 BY MR. KLAYMAN :
23 Q. Did you have a conversation with Ms. Taitz
24 that day?
25 A. Yes.
17
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1 Q. And what was discussed?

2 A. I don't exactly remember what we were talking
3 about, but
4 Q. But generally.
5 A. "How are you doing?" "How is things?"
6 Q. At the point that you first met Ms. Taitz at
7 that meeting, you had followed her activities, had you
8 not?
9 A. No.
10 Q. You tracked her -- you followed her on the
11 website, on the Internet?
12 A. Never.
l3 Q. You are aware that she has a Internet site
14 called "The World's Leading Obama Eligibility Challenge
15 Web Site"?
16 A. If that's what its name is. I don't remember.
17 Q. And you, from time to time, look at that
18 website, do you not?
19 A. No.
20 Q. You do not believe that President Obama is
21 eligible to be president, do you?
22 A. I don't believe he's eligible.
23 Q. After that second encounter with Ms. Taitz
24 you've had further encounters with you, have you not?
25 A. Once.
18
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2 A. I think it was the -- in November of 2012.
3 Q. And what happened then?
4 A. I had invited her to speak at UROC, United
5 Republicans of California, and she came.
6 Q. And why did you invite her to speak there?
7 A. Because of her -- I thought it was the
8 authority on Obama's eligibility.
9 Q. Did she ultimately come and speak?
10 A. Yes.
11 Q. Did she speak?
12 A. Yes.
13 Q. And how long was her speech, approximately?
14 A. Oh, half an hour, 45 minutes.
15 Q. You invited Ms. Taitz because you have a high
16 regard for her. Correct?
17 A. Yes.
18 Q. You have never known her to lie, have you?
19 A. No.
20 Q. At that event, did you offer to help her in
21 any way or at any time after that event in her
22 endeavors with regard to eligibility?
23 A. We passed the hat for her, and that was it.
24 Q. Did you offer to help her in any of her
25 activities?
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1 A. No.
2 Q. You have helped her, though, in her
3 activities, have you not?
4 A. I beg your -- would you please repeat the
5 question?
6 Q. You have helped her in her activities, have
7 you not?
8 A. No, I have not helped her in her activities.
9 Q. Did there come a time after November 2012 when
10 you encountered Ms. Taitz?
11 A. I'm sorry. Would you repeat that again?
12 Q. Did there come a time after November 2012 when
13 you had contact with Ms. Taitz?
14 A. No.
15 Q. But you did have contact with her in February
16 2013, did you not?
17 A. Yes.
19 contact?
20 A. I was there with some Judicial Watch
21 materials, which I've often taken down to the CCIR
22 meetings, the regularly-scheduled ones, which this one
23 was, and -- excuse me -- I was down there
24 Q. What materials did you take?
25 MR. KRESS: 1--
20
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1 THE WITNESS: I can't hear you.

2 MR. KRESS: If I could just --
3 BY MR. KLAYMAN:
4 Q. What materials of Judicial Watch did you take
5 to that meeting?
6 A. Oh, probably copies of the verdict, several
7 issues of them. And I think we had some Judicial Watch
8 note bags, or something like that. But I -- or
9 calendars. We had some leftover calendars, and so I
10 took them down there to share with the -- the people
11 at CCIR.
12 MR. KRESS: Larry, if I could interject.
13 I believe the date that's been stated was
14 actually incorrect, and I don't want there to be a
15 confusion in the record.
16 There was a mention of February of 2013. I
17 believe from all the records the meeting was February
18 of 2012.
19 MR. KLAYMAN: Oh, thank you. Then I misspoke.
20 MR. KRESS: I think it was actually Ms. Ruff-
21 well, I'm not sure who misspoke. But I believe --
22 just so the record's clear, I think everyone's talking
23 about February of 2012.
24 BY MR. KLAYMAN:
25 Q. So the meeting that dealt with eligibility --
21
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1 you had a meeting in November of 2012 and then before

2 that February of 2012 where Ms. Taitz was in
3 attendance, Ms. Ruffley?
4 MR. KRESS: I object to the form.
5 But you can answer if you --
6 THE WITNESS: I've -- she appeared at -- in
7 November at the UROC Convention in 2012. And prior
8 to that, the last time that I had seen her before then
9 was when she was at the CCIR meeting in February 22nd
10 of 2012. And I have not --
11 BY MR. KLAYMAN :
12 Q. At that meeting Ms. Taitz was advocating for
13 her candidacy for the U.S. Senate, was she not?
14 A. Yes.
15 Q. And did she also discuss eligibility issues
16 at that time?
17 A. I don't remember.
18 Q. You offered to help her in her senate bid,
19 did you not?
20 A. I did not.
21 Q. Did you help her in her run for the U.S.
22 Senate in any way as a volunteer
23 A. No.
24 Q. -- personally?
25 A. No.
22
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1 Q. You were at that -- the CCIR meeting where

2 she advocated her senate candidacy as a representative
3 of Judicial Watch, were you not?
4 A. Who are you talking about, Orly Taitz being a
5 representative of Judicial Watch or me?
6 Q. I'm saying when you went to that meeting at
7 the CCIR with the women's club --
8 A. Yes.
9 Q. -- you were there as a representative of
10 Judicial Watch. I'm not asking you about Orly Taitz.
11 A. Okay. Yes.
12 Q. I'm going to show you what has been -- what
13 I'll ask the court reporter to mark as Plaintiff's
14 Exhibit 10.
15 A. The court reporter is not producing anything.
16 MR. KRESS: Your assistant is.
17 MR. KLAYMAN: Okay. Well - -
18 MR. KRESS: And if -- Larry, if you remember, we
19 did the exhibits consecutively, so there's already an
20 Exhibit 10. I think we are on --
21 MR. KLAYMAN: Okay.
22 MR. KRESS: -- we are on 29, if you don't mind
23 marking it 29.
24 MR. KLAYMAN: Fine. Then we will make it
25 Plaintiff's Exhibit 29.
23
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1 Naveed, would you please hand that to the

2 court reporter so Ms. Ruffley can have a copy.
3 MR. MAHBOOBIAN: (Complies.)
4
5 (Exhibit 29 was marked
6 for identification.)
7
8 MR. KRESS: She has the exhibit.
9 BY MR. KLAYMAN:
10 Q. Exhibit 29 is a Declaration Under Penalty of
11 Perjury of Constance S. Ruffley, is it not?
12 A. Yes.
13 Q. This is your affidavit that was submitted in
14 the lawsuit that you are here on today; correct?
15 A. Yes.
17 BY MR. KLAYMAN :
18 Q. Klayman v. Judicial Watch.
19 A. (No audible response. )
20 Q. Correct?
21 A. I'm sorry. Would you repeat the question?
22 Q. This is an affidavit which was submitted on
23 your behalf in the lawsuit that you are appearing on
24 today, Klayman vs. Judicial Watch. Correct?
24
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1 But you can answer.

2 THE WITNESS: It says -- not an affidavit, it says
3 "Declaration of -- under Penalty of Perjury."
4 MR. KLAYMAN: Okay. Let's call it a declaration.
5 Q. Correct?
6 A. Yes.
7 Q. You signed this declaration under oath.
8 Correct?
9 A. Yes.
10 Q. Do you know what it means, "under oath"?
12 Q. Do you know what being under oath means?
13 A. Right. To tell the truth, the whole truth,
14 and nothing but the truth, so help me God.
15 Q. Thank you.
16 All right. Turn your attention to Paragraph
17 3.
18 Well, take a look at Exhibit 29. That is the
19 declaration which was submitted. Right? That's--
20 A. Yes.
21 Q. -- that's accurate?
22 Okay. Turn to Paragraph 5.
23 A. (Witness complies.) All right.
24 Q. Where it states, "It is my understanding that
25 Larry Klayman has sued me, Judicial Watch, Inc., and
25
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1 other Judicial Watch, Inc. employees alleging that we,

2 on or about February 22nd, 2012, negligently,
3 maliciously and/or willfully published and furthered
4 the publication of a false statement that Plaintiff
5 Klayman had been 'convicted' of a crime for not paying
6 a large amount of child support with regard to his
7 children, on the Internet and elsewhere within this
8 judicial district, Florida, and elsewhere throughout
9 the United States and the world," unquote.
10 Is that a true statement?
11 A. I object to the word "convicted" because I
12 can't remember whether I said "convicted" or, urn,
13 "indicted."
14 Q. In fact, you also told Orly Taitz, did you
15 not, whether or not you can remember using the word
16 "convicted" or "indicted," that this information that
17 you were providing to her should be given to Klayman's
18 donors. Correct?
19 A. What about Klayman's donors?
20 Q. You told Ms. Taitz, did you not, whether or
21 not you used the word "convicted" or "indicted," which
22 you say you can't remember --
23 A. Correct.
24 Q. -- the information about Klayman not paying
25 child support in Ohio should be given to donors.
26
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1 Correct?
2 A. No.
3 Q. All right. I'll turn your attention to what's
4 been marked as Exhibit 2.
5
8
9 BY MR. :Ea.AYMAN:
10 Q. This is the eligibility website of Orly Taitz,
11 a reprint, is it not?
12 A. I'm being handed this by your assistant,
13 Naveed.
14 Q. All right. Take a look at it. Take your
15 time.
16 The question is: This is a reprint of what
17 appeared on Orly Taitz's website on February 23rd,
18 that website called "World's Leading Obama Eligibility
19 Challenge Web Site." Correct?
20 A. That's what it says.
21 MR. KRESS: Okay. Just - - the court reporter is
22 looking confused.
23 We actually have -- we have exhibits - -
24 MR. :Ea.AYMAN: I don't care whether the court
25 reporter is confused or not.
27
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1 MR. KRESS: Well, I --

2 MR. KLAYMAN: Please don't put colloquy in the
3 record now.
4 MR. KRESS: No, no. No . She's --
5 MR. KLAYMAN: Just let me get an answer, and let
6 me move on.
7 MR. KRESS: No, Larry, I'm just trying to clarify
8 something. Your -- because your office is marking this
9 as Exhibit 30. I just want to make sure everyone --
10 MR. KLAYMAN: Oh, no. It's--
11 MR. KRESS: It's already marked as Exhibit 2.
12 MR. KLAYMAN: It's Exhibit 2. Please don't do
13 that.
14 MR. KRESS: Okay. That's -- that's all right.
15 That's it.
16 MR. KLAYMAN: That's all right.
17 MR. KRESS: We don't know what the question is.
18 MR. KLAYMAN: Third paragraph.
19 Q. "Ms. Ruffley actually advised me that Larry
20 Klayman is not licensed in California. She told me
21 that he no longer works with the Judicial Watch and
22 that donors should know about litigation in Ohio, where
23 he was convicted just recently of not paying large
24 amount in child support. She provided a lot of other
25 information. I will publish only what is in the public
28
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1 record. I'm not publishing anything that is not in the

2 public record."
3 That's an accurate statement of what you told
4 Ms. Taitz. Correct?
5 A. I never said any -- no, it's not correct.
6 Because where it says that "donors should know about
7 litigation in Ohio."
8 Q. It says, "She provided a lot of other
9 information. II
10 What other information did you provide to
11 Ms. Taitz?
12 A. The only other information that I provided is
13 that you are not licensed in the State of California.
14 I told her about the issue of the -- the child support.
15 And also there was the issue -- excuse me -- of a
16 lawsuit that was down in Florida.
17 Q. Was that an eligibility lawsuit for Michael
18 Dolz?
20 Q. But it was an eligibility lawsuit. Correct?
22 Q. Well, what was the subject matter of the
23 lawsuit?
24 A. Basically, that you had taken money for a
25 lawsuit and not performed.
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1 Q. You offered information to Ms. Taitz about

2 this, did you not?
3 MR. KRESS: I'm going to object to the form.
4 You can answer.
5 THE WITNESS: I told Ms. Taitz only what could be
6 found on the Internet. I told her nothing else.
7 BY MR. KLAYMAN:
8 Q. You told her what could be found in the public
9 record. Correct?
10 A. Correct.
11 Q. Did you say "Yes"?
12 A. Yes.
13 Q. And the public record would include court
14 files. Correct?
15 A. Well, as I found it on the Internet, it was
16 not in the court files. It was public information.
17 And she had the ability to look up those -- those
18 things on the Internet herself.
19 Q. And you gave her that information you
20 volunteered that information. She didn't ask you for
21 it. Correct?
22 A. Yes.
23 Q. And you did that because you were trying to
24 help Ms. Taitz?
25 A. No.
30
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1 Q. You did that because you were trying to hurt

2 me, Larry Klayman. Correct?
3 A. No.
4 Q. So you just gave the information because it
5 came to your head in some kind of epiphany?
6 MR. KRESS: Objection to the form.
7 You can answer.
8 BY MR. KLAYMAN:
9 Q. Is that the reason?
10 A. No.
11 Q. You did it because you thought it would curry
12 favor with the directors of Judicial Watch, Mr. Fitton
13 and Mr. Orfanedes --
14 A. Absolutely.
15 Q. -- to follow which had been adverse to me.
16 Correct?
17 A. No.
18 Q. Then why did you do it?
19 A. Because she asked me.
20 Q. You just told me you volunteered the
21 information. Which is right, she asked you or you
22 volunteered it?
24 You can answer.
25 THE WITNESS: Would you mind repeating the
31
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1 question again? Whether I volunteered it, or --

2 BY f'.1R. KLAYMAN:
3 Q. You previously testified in this deposition
4 under oath that you volunteered the information in
5 this case.
6 A. Yes.
7 Q. That's correct, is it not?
8 A. That's because she asked me.
9 Q. What did she ask you?
10 A. She asked me if you were still with Judicial
11 Watch. And I told her no.
12 Q. But she didn't ask you about my children, and
13 she didn't ask you about whether I was licensed in
14 California, did she?
15 A. I did not provide her any information that
16 was not available on the Internet.
17 Q. But the question --
18 A. This was a completely private conversation
19 between the two of us, and it was not to be -- I did
20 not have any expectation of her putting it out there
21 on the web.
22 f'.1R. KLAYMAN: Non responsive. Move to strike.
23 Q. In fact, she didn't ask you about my children,
24 and she didn't ask you about my being licensed in
25 California, did she?
32
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1 A. No.
2 Q. And, in fact, I had already left Judicial
3 in 2012, in February 2012, I had been gone from
4 Judicial Watch eight to nine years. Correct?
5 A. Could have been.
6 Q. So you didn't have any -- and you didn't have
7 any contact with me in those years, did you?
8 A. No.
9 Q. So you would have no way of knowing whether I
10 had become licensed in California or not when you said
11 that to Ms. Taitz. Correct?
12 A. I would know whether you were not licensed
13 because I -- anyone can go to the State Bar and look up
14 and plug in a name and see if that person is licensed
15 In California or not.
16 Q. But you hadn't done that before telling
17 Ms. Taitz that I was not licensed in California.
18 Correct?
19 A. Wrong. Because I did look it up, and you were
20 not licensed.
21 Q. When did you look it up? Afterwards? After
22 you had the conversation with Taitz?
23 A. Prior to that.
24 Q. Why did you bother to look it up?
25 A. Because I wanted to see if you had become
33
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1 licensed at some point.

2 Q. And why was that?
3 A. Just because I wanted to know.
4 Q. Because you didn't want me representing anyone
5 with regard to eligibility, did you?
6 A. No.
7 Q. Because you wanted to try to hurt me.
8 Correct?
9 A. No.
10 Q. Then what business was it of yours?
12 You can answer.
l3 THE WITNESS: Would you mind restating the
14 question properly?
15 BY MR. KLAYMAN:
16 Q. What business was it of yours whether I was
17 licensed in California or not?
19 You can answer.
20 THE WITNESS: I f I want to look up anyone, I
21 can -- there's nothing that prohibits me from looking
22 up someone's name in the State Bar.
23 BY MR. KLAYMAN :
24 Q. Then I'm asking you why you did it, then.
25 What caused you to do it?
34
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1 MR. KRESS: Objection to the form. Asked and

2 answered.
3 You can answer it one more time.
4 THE WITNESS: Because I had looked it up several
5 years before, maybe once a year, something like that,
6 and this was just something that happened.
7 BY MR. KLAYMAN:
8 Q. Why bother looking it up if I'm not with
9 Judicial Watch anymore?
10 A. Why not?
11 Q. What caused you to look up any situation with
12 regard to my kids?
l3 MR. KRESS: I object to the form.
14 You can answer.
15 THE WITNESS: It was just one of the things that
16 happened to pop up.
17 BY MR. KLAYMAN :
18 Q. In fact, Ms. Taitz [sic], you were aware that
19 I had been in litigation with Judicial Watch and its
20 directors before you met with Ms. Taitz on
21 February 22nd, 2012. Correct?
22 A. You addressed me as Ms. Taitz.
23 Q. Ms. Ruffley.
24 A. Restate the question, please.
25 Q. In fact, you knew at the time that you met
35
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1 with Ms. Taitz on February 22nd, 2012 that I, Larry

2 Klayman, had been in various litigations with Judicial
3 Watch and its directors. Correct?
4 A. Yes.
5 Q. And you knew that we were adverse to each
6 other. Correct?
8 You can answer.
9 THE WITNESS: Yes.
10 BY MR. KLAYMAN:
11 Q. And that was the basis for your looking up
12 whether I was licensed in California and in order to
13 be able to get information about my children. Correct?
15 You can answer.
16 THE WITNESS: No.
17 BY MR. KLAYMAN:
18 Q. The Judicial Watch directors asked you to
19 track me, did they not?
20 A. No.
21 Q. You conveyed the information about my not
22 being licensed in California and the information that
23 you claimed pertains to my children to the directors
24 of Judicial Watch, though, didn't you?
25 A. No.
36
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1 Q. You never talked to them about my being

2 licensed in California?
3 A. No.
4 Q. Or my children?
5 A. No.
6 Q. Why is it, then, that you gave this
7 information to Ms. Taitz?
8 MR. KRESS: I obj ect to the form. Asked and
9 answered.
10 You can answer it one more time.
11 THE WITNESS: Well, I had an expectation of
12 privacy with Ms. Taitz. And, in fact, she said that
13 she was going to call me the next morning, and I've
14 never heard from her since. Well, except for when I
15 invited her to speak at UROe.
16 BY JVIR. KLAYMAN:
17 Q. And why did you have an expectation of
18 privacy?
19 A. Because the conversation was between she and
20 myself, and there weren't any other people around.
21 Q. But that doesn't answer the question.
22 Why did you give her the information, apart
23 from expectations of privacy?
24 MR. KRESS: I object to the form. Asked and
25 answered.
37
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1 You can answer.

2 THE WITNESS: I still just had the expectation of
3 privacy that it would be just information between
4 herself and myself. I had no idea that she would have
5 ever put that up there on her website.
6 BY MR. KLAYMAN:
7 Q. Why did you -- why did you give her the
8 information?
9 A.
I --
10 Q. I'm not talking about expectations of privacy.
11 Why
12 A. So that she could --
13 Q. did you give her the information?
14 A. So that she could look it up for herself.
15 Q. And why did you want her to look it up for
16 herself?
17 A. To make sure that what I said was correct.
18 Q. Ms. Ruffley, we will stay here for hours.
19 I will get an answer to this question. So you can
20 answer it now. Do you want to go two hours more on it?
21 I will ask it for two hours.
22 MR. KRESS: What question is before her?
23 BY MR. KLAYMAN:
24 Q. Why did you give her the information?
25 MR. KRESS: She just answered that question.
38
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1 THE WITNESS: So that she -- I gave her the

2 information and told her where she could find it on --
3 excuse me. I didn't tell her where she could find it
4 on the web. But if she did a Google search, she would
5 have been able to find it.
6 BY MR. KLAYMAN:
8 MR. KRESS: Maybe you can ask your question
9 differently. Because--
10 MR. KLAYMAN: No, she understands what I said.
11 She's highly educated. She has a college degree. She
12 was a legal secretary. She understands what I said.
13 I'm asking it the way I want to answer it -- ask it.
15 MR. KRESS: Objection.
16 You can answer.
17 THE WITNESS: So that she could look it up for
18 herself and make sure that the information was correct.
19 I believe in giving correct information, not lies or
20 innuendos or anything else.
21 BY MR. KLAYMAN:
23 A. I just told you --
24 MR. KRESS: We are going to have to
25 She has answered the question.
39
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1 IVlR. KLAYMAN: Oh, you didn't give me the

2 information.
3 Q. So she could look it up. What was the
4 underlying purpose of giving her the information so she
5 could look it up on the Internet?
6 A. So that she would have the correct
7 information.
8 Q. For what reason?
9 IVlR. KRESS: I don't know how many times she can
10 tell you.
11 BY IVlR. KLAYMAN:
12 Q. For what reason?
13 IVlR. KRESS: If you have any different answer, you
14 can give it to him. But--
15 THE WITNESS: I don't have a different answer.
16 You can say that all day long if you want to
17 say "And for what reason," and it's not going to help.
18 BY IVlR. KLAYMAN :
19 Q. You do not want to answer the question; do
20 you, Ms. Ruffley?
22 Q. You do not want to answer this question, do
23 you?
24 A. I believe I've answered the question three or
25 four times already.
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130
1 Q. I'm asking you -- the underlying question

2 is
3 A. You don't -- you are not asking me an
4 underlying question, you are asking me about the same
5 thing--
6 Q. I'm asking information about anything that she
7 could look up on the Internet, why did you do it?
8 I'm not asking about her looking it up on the
9 Internet
10 MR. KRESS: This is getting --
11 BY MR. KLAYMAN:
12 Q. -- I'm asking about what was the reason that
13 you gave her that information; what was in your mind
14 why you gave it to her.
15 MR. KRESS: Is that a different question, or do
16 you have
17 THE WITNESS: Is that a different question?
18 MR. KLAYMAN: No, it's the same question. But
19 you can answer it.
20 MR. KRESS: This is getting close to the point of
21 just being harassing. She's been answering the
22 question. You don't like the answer, but that's not
23 her problem.
24 MR. KLAYMAN: That's your problem, not mine.
25 MR. KRESS: Well, we will see about that.
41
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1 BY MR. KLAYMAN:
2 Q. Answer the question, Ms. Ruffley.
3 MR. KRESS: Are you asking her - - you have asked
4 her if she was intending to harm you. She said no.
5 MR. KLAYMAN: I don't want the testimony. That's
6 inappropriate.
7 MR. KRESS: Well, you --
8 MR. KLAYMAN: I'll phrase it --
9 Will you, Madam Court Reporter, please read my
10 last question back.
11 Thank you.
12
13 (Whereupon, the record was read
14 by the reporter.)
15
16 MR. KLAYMAN: Please answer that.
17 THE WITNESS: Because she asked me about you.
18 BY MR. KLAYMAN :
19 Q. What did she ask you?
20 A. She asked me what I knew about you.
21 Q. Did she say why she asked me [sic] what you
22 knew about me?
23 A. No.
24 Q. The time that you gave Ms. Ruffley that
25 information, you knew that Orly Taitz had an
42
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1 eligibility website. Correct?

2 A. No.
3 Q. You were very knowledgeable about eligibility
4 issues, though, were you not?
5 A. Probably more than the average person.
6 Q. You are telling me that you would look up
7 whether I was a California lawyer and about my children
8 on your own, but you never looked at Orly Taitz's
9 eligibility website
10 A. No.
11 Q. -- up to the point --
12 MR. KRESS: Objection to form.
13 BY MR. KLAYMAN:
14 Q. of November 22nd, 2012? Is that what you
15 are saying?
17 You can answer it.
18 THE WITNESS: Would you restate the question,
19 please?
20 MR. KLAYMAN: Please read it back.
21
22 (Whereupon, the record was read
23 by the reporter.)
24
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2 THE WITNESS: No, I never looked up her website.
3 BY MR. KLAYMAN:
4 Q. But you knew she had a website?
5 A. I don't believe I did.
6 Q. Based on your experience in public interest
7 activities and politics, you are aware that nearly all
8 people have websites these days. Correct?
9 A. Yes. A lot of people do. I don't.
10 Q. People that are running for the U.S. Senate
11 have websites. Correct?
12 A. I'm not sure whether all people do or not.
13 I don't know.
14 Q. Well, any credible candidate would have one.
15 Correct?
17 You can answer, if you know.
18 THE WITNESS: I don't know.
19 BY MR. KLAYMAN:
20 Q. You are aware that Ms. Taitz is an activist,
21 a conservative activist, in addition to having run for
22 the U.S. Senate. Correct?
23 A. Yes.
24 Q. Conservative activists generally have websites
25 so they can communicate with the public. Correct?
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1 A. I don't know.
2 Q. You didn't tell Ms. Taitz not to publish the
3 information that you gave her on the Internet, did you?
4 A. She said she would call me the next day.
5 Q. You did not tell Ms. Taitz not to publish
6 the information you gave her about me on the Internet,
7 did you?
8 A. No, I did not. Because I had -- I had
9 anticipated that the conversation was just between
10 the two of us, and that was it. And that if she wanted
11 to do any further research, she could do that on her
12 own.
13 And I object to your inserting your children
14 into this. I -- the only reason I mentioned that was
15 because it happened to pop up on one of the searches
16 that I did. And that was about Cuyahoga County,
17 et cetera. And that's where your children came in.
18 But I did not deliver --
19 Q. Before your deposition today, this morning,
20 you met with the lawyer for Judicial Watch in this
21 lawsuit and Mr. Orfanedes its director, one of its
22 directors. Correct?
23 A. Yes.
24 Q. And you discussed your testimony today, did
25 you not?
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130

2 THE WITNESS: No.
3 BY MR. KLAYMAN:
4 Q. I didn't hear your response.
5 A. No.
6 Q. You didn't discuss anything about your
7 testimony today?
8 MR. KRESS: I'm going to object to the extent you
9 are getting into or very close to the attorney-client
10 privilege.
11 MR. KLAYMAN: No, I'm - you know, Doug, I'm not
12 getting into that. I'm just identifying whether there
13 was a discussion. I'm not asking for the content.
14 MR. KRESS: Okay. If you want to know whether
15 there'S a discussion, you can -- you can inquire.
16 MR. KLAYMAN: Okay.
17 Q. You had a discussion about your testimony
18 today, did you not, earlier before this deposition
19 began with Mr. Kress and Mr. Orfanedes?
20 A. Maybe two minutes.
21 Q. Was your response "two minutes"?
22 A. Yes.
23 Q. Okay. But you had discussions before today
24 with one or both of them. Correct?
25 A. Yes.
46
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1 Q. And when did you have discussions with him

2 about your testimony?
3 A. Again --
4 MR. KRESS: You can answer, but don't give him
5 any of the substance.
6 THE WITNESS: Yesterday.
7 BY MR. KLAYMAN:
8 Q. How long was your discussion?
9 MR. KRESS: You can answer that.
10 THE WITNESS: Approximately two hours.
11 BY MR. KLAYMAN :
12 Q. The affidavit which has been marked as
13 Exhibit 29, you didn't actually draft it, did you?
14 A. Parts of it, yes.
15 Q. Who presented to you the first draft of it?
16 MR. KRESS: I object
17 THE WITNESS: I don't remember.
18 MR. KRESS: And I will just object along this line
19 to be careful not to reveal confidential communications
20 with any lawyers.
21 BY MR. KLAYMAN:
22 Q. Was it Mr. Orfanedes who sent it to you?
24 Q. But you do have a computer at Judicial Watch?
25 A. Yes.
47
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1 Q. And have you deleted any communications

2 concerning this lawsuit from that computer?
3 A. No.
4 Q. Did you check your computer today about
5 A. NO
I
because I didn't go in the office.
6 Q. the various documents that were relevant to
7 this case?
8 A. No.
9 Q. Have you ever checked your computer In that
10 regard?
11 A. No.
12 Q. Have you ever checked your computer in that
13 regard?
14 A. No.
15 Q. I'm going to ask you to check your computer in
16 that regard I Ms. Ruffley. Because there were documents
17 that were requested by me from Judicial Watch I and
18 obviously you are at the eye of the hurricane here.
19 MR. KRESS: Well I when you say II in that regard
l
II
20 that's a little broad and open-ended.
21 I will -- SOl as you know I we've objected to
22 numerous document requests.
23 MR. KLAYMAN: No I I understand. But I obvious 1 Y I
24 she should have done a search for the documents I so I'm
25 asking that a search be conducted.
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1 THE WITNESS: Well, the search was not conducted

2 because there weren't any documents related to this.
3 MR. KLAYMAN: Well, you just testified
4 Ms. Ruffley, you are under oath. Okay? So let me ask
5 the questions.
6 THE WITNESS: I remember that I'm under oath.
7 MR. KLAYMAN: I'm not asking for gratuitous PYA
8 responses when I don't have a question pending.
9 MR. KRESS: Please be polite to the witness.
10 MR. KLAYMAN: Excuse me?
11 MR. KRESS: I -- I -- I don't think we need to
12 engage in this.
l3 MR. KLAYMAN: Well, I used an acronym. It's not
14 appropriate for her to inject stuff before questions
15 are made.
16 MR. KRESS: Please move on.
17 BY MR. KLAYMAN :
18 Q. You just testified that you hadn't checked
19 your computer. So I'm asking you politely and
20 courteously to check your computer.
21 MR. KRESS: I will confer with Ms. Ruffley, and
22 we will be sure to do that.
23 BY MR. KLAYMAN:
24 Q. Let's turn to Paragraph 7.
25 A. (Witness complies.)
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1 MR. KRESS: This is of the declaration. Correct?

2 MR. KLAYMAN: The affidavit of the 29th.
3 THE WITNESS: Declaration.
4 MR. KLAYMAN: Declaration.
5 Q. "On or about February 22, 2012, I attended the
6 monthly meeting of the California Coalition for
7 Immigration Reform in Garden Grove, California.
8 Orly Taitz was one of the speakers at the meeting.
9 I am familiar with Orly Taitz. Ms. Taitz is a
10 California resident who was, at the time, running on
11 the primary ballot for one of the California seats on
12 the United States Senate.
13 "After the meeting, I was seated at an
14 information table for Judicial Watch, displaying
15 various forms of Judicial Watch literature. Orly Taitz
16 approached me and we discussed a number of issues.
17 We eventually discussed Larry Klayman. The only
18 information that I conveyed to Ms. Taitz about Larry
19 Klayman was information that I had learned from public
20 records, including information related to court
21 proceedings for failure to pay child support."
22 In reference to public records, you were not
23 talking about the Internet, were you?
24 A. Yes, I was talking about the Internet.
25 Q. You were talking about court records, were you
50
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1 not?
3 THE WITNESS: No.
4 BY MR. KLAYMAN:
5 Q. In fact, you had gone into court records in
6 Cleveland, Ohio with regard to my custody proceeding
7 with my children. Correct?
8 A. No.
9 Q. In fact, you have a tremendous curiosity about
10 me -- don't you, Ms. Ruffley -- at a minimum?
11 A. Morbidly.
12 Q. What do you mean by "morbidly"?
13 A. You are an interesting person. I just wanted
14 to keep abreast of what your dealings were.
15 Q. And that's morbid. Correct?
18 THE WITNESS: Well, I'm sorry. That was probably
19 an offhand word. But, uh, just a curiosity.
20 BY MR. KLAYMAN :
21 Q. You don't usually use offhand words, do you?
22 A. Yes.
23 Q. Paragraph 8, "My expectation was that Orly
24 Taitz would not restate my comments to any other person
25 or entity. II
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1 In fact, you didn't know one way or the other

2 whether Orly Taitz would restate your comments --
3 A. I had no --
4 Q. -- to anyone else or the public, did you?
5 A. I had no way of knowing whether she would.
6 And I never gave her permission to restate my comments
7 to any other person or entity.
8 Q. But you never told her not to. Correct?
9 A. I thought that that was understood.
10 Q. You are aware that Orly Taitz communicates
11 with the public on the Internet?
12 A. I do now.
13 Q. And you are aware that she communicates in
14 public by either giving speeches like she gave at the
15 Garden Grove Women's Club
16 A. She
17 Q. -- or that she gave earlier at UROC?
18 A. She gave her candidacy for U.S. Senator. And
19 Robert Lauten was there and another candidate who gave
20 his statements for running for Barbara Boxer's seat.
21 Q. So you are aware that Orly Taitz's activities
22 as a U.S. senator candidate requires her to communicate
23 with the public. Correct?
24 A. Well, if that's what you have to do to run,
25 yes.
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1 Q. Let's look at Paragraph 9. "The information

2 that I conveyed to Orly Taitz was gathered through my
3 own independent research. No one from Judicial Watch
4 advised me of this information or instructed me to
5 convey the information to Orly Taitz."
6 A. That's true.
7 Q. And your independent research entailed looking
8 in court records in Cleveland
t
Ohio about Larry Klayman
9 and his children. Correct?
12 THE WITNESS: No. There's no way that you can get
13 into the -- the court records in any court.
14 BY MR. KLAYMAN :
15 Q. Subsequent to your making these statements
16 that are the subject of this lawsuit to Ms. Taitz
t
17 you have researched and learned that I was not
18 convicted of any crime for nonpayment of child support.
19 Correct?
20 A. Convicted
t
indicted. I don't know.
21 Q. I'm talking about convicted.
22 A. I don't know when I used the word "convicted"
23 or "indicted."
24 Q. I'm not even asking you what word you used at
25 this point. We have already been over that.
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1 You are aware today that I was never convicted

2 of any crime. Correct?
3 A. True. Yes, I am aware that you --
4 Q. How did you learn that?
5 A. Pardon?
6 Q. How did you learn that?
7 A. That you were not convicted of any crime?
8 Q. Correct.
9 A. It's on the Internet.
10 Q. Where on the Internet did you find that?
12 Q. You went into the court records of the
13 Cleveland family court and found out that I was not
14 convicted of any crime. Correct?
15 A. I went onto the Internet and found that.
16 It was not in the court records.
17 Q. You looked in the court records, though,
18 didn't you?
19 A. No.
20 Q. Did you make any effort before you made the
21 statement that I was convicted to determine
22 definitively whether I was convicted or not?
24 But you can answer it.
25 You can answer if you know the -- if you
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1 understand the question and you know the answer.

2 THE WITNESS: I don't know about any convictions.
3 BY MR. KLAYMAN :
4 Q. You have never known about any convictions,
5 have you?
6 A. No.
7 Q. Did you tell anyone at Judicial Watch after
8 you gave this information to Ms. Taitz that you had
9 talked to her about me?
10 A. No.
11 Q. You are aware that I ran for the U.S. Senate
12 in Florida?
13 A. Yes. That's why you left Judicial Watch.
14 Q. You are aware that I've been involved in
15 many lawsuits involving Fidel Castro for the CUban
16 community in Miami?
17 A. Somewhat, yes.
18 Q. You are aware that I traveled while at
19 Judicial Watch to Europe to lobby on behalf of
20 victims of Castro?
21 A. Yes.
22 Q. You are aware that I was involved while at
23 Judicial Watch with trying to help the Elian Gonzalez
24 family?
25 A. Sure. You brought Donato Dalrymple out, who
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1 was holding Elian Gonzalez when he was -- when Elian

2 was stripped from his arms.
3 Q. In fact, shortly after 9/11 occurred in 2001,
4 I took a trip to Belgium -- you remember, do you not
5 to have Fidel Castro and others indicted for crimes
6 against humanity?
7 A. Somewhat.
8 Q. And after that happened, we had a -- a
9 judicial international conference in Miami when I
10 returned from Belgium. Correct?
11 A. Yes. I was there.
12 Q. Right.
13 And you were aware that Miami is my home town.
14 Correct?
15 A. 11m not exactly aware of that.
16 Q. You are aware that I lived in Miami many
17 years?
18 A. Yes.
19 Q. You are aware that I began my legal career
20 there?
21 A. Yes.
22 Q. You are aware that the eligibility lawsuits
23 that I brought were in Florida?
24 A. Not really.
25 Q. You -- you had become aware of that, though,
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1 haven't you?
2 A. Not completely.
3 Q. I couldn't hear your response.
4 A. Not completely.
5 Q. But partially?
6 A. Partially.
7 Q. I was the founder of Judicial Watch, was I
8 not?
10 You can answer.
11 THE WITNESS: Yes.
12 BY MR. KLAYMAN :
13 Q. You have a high regard for me, don't you?
14 A. On a personal level, yes.
15 Q. And you're aware that I was always nice to
16 you, wasn't I?
17 A. Always.
18 Q. And I was nice to other people in the San
19 Marino office --
20 THE REPORTER: Pardon me. Repeat that.
21 BY MR. KLAYMAN:
22 Q. -- correct?
23 MR. KRESS: I think he said, "I was nice to other
24 people in the San Marino office."
25 THE WITNESS: Yes. Yes.
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1 BY MR. KLAYMAN:
2 Q. And that I would come out there frequently to
3 visit to make sure that the office was running in a
4 productive way?
5 A. That you would come out and visit when you had
6 other things to do. But I don't remember, you know,
7 coming out to make sure that it was being run properly.
8 I remember on a personal level when I was
9 going through the cancer it was the chemo and the
10 radiation back in September through May of 2002 that
11 you, as head of Judicial Watch -- that there was a
12 beautiful bouquet from the most expensive florist in
13 town. And it was gorgeous. And it said on the card,
14 "From your friends at Judicial Watch."
15 And two days later, I received a second
16 bouquet from the same expensive florist that said,
17 "From Larry Klayman and your friends at Judicial
18 Watch."
19 Q. I appreciate that, Ms. Ruffley. I wish you
20 well. I want you to know that.
21 A. Thank you. I'm still here.
22 Q. How is your health today? You don't have to
23 tell me, but I hope it's well.
24 A. It's well. Thank you.
25 Q. You don't have to answer that.
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1 A. I thought I did.
2 Q. Okay. All right.
3 Is it good?
4 A. Yes. Thank you.
5 Q. I hope so. Okay.
6 Are you aware that I asked after the
7 statements were published by Ms. Taitz, the ones that
8 we are here on today, that I asked Judicial Watch and
9 its lawyers to correct those statements?
10 A. Did -- are you asking whether Mr. Kress and
11 Mr. Orfanedes asked me to correct any statements?
12 Q. No.
13 Are you aware that shortly after the
14 February 22nd, 2012 meeting
15 A. Right.
16 Q. -- with Ms. Taitz that I asked Judicial Watch
17 to correct those statements?
18 A. I'm not aware of that.
19 Q. Did you have any contact with anyone by the
20 name of Richard Driscoll after February 22nd, 2012?
21 A. That name is completely unfamiliar to me.
22 Q. Did anyone from Judicial Watch after
23 February 22nd, 2012, before this litigation was filed
24 that you are here on today, ask you whether you had
25 made those statements to Ms. Taitz?
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1 A. No.
2 Q. Was the answer "No"?
3 A. Correct.
4 Q. Have you ever had discussions with Mr. Fitton
5 about the statements that you are here on today that
6 were published by Ms. Taitz on her website?
7 A. No. The only communications I had with
8 Mr. Fitton are a beautiful Christmas card every
9 Christmas. And that's it.
10 Q. Otherwise, you don't talk to him at all?
11 A. Nuh-uh. Right. I do not speak with him at
12 all.
13 Q. And you have not spoken with him since I left
14 Judicial Watch?
15 A. That's not entirely correct.
16 I have as a daughter of the American
17 Revolution, I have gone back to Continental Congress in
18 Washington, D.C. where I was a part of the -- where I
19 was Vice Chairman of the National Resolutions
20 Committee. And, as such, I would have a little time
21 off, and so I would go over to Judicial Watch
22 headquarters and visit.
23 So I would spend maybe five minutes with each
24 person such as, you know, Mr. Orfanedes and Mr. Fitton
25 and Mr. Farrell if they were in the offices. And
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1 Mr. -- but it was just chitchat. I don't -- and that's

2 it. Your name never came up.
3 Q. Did you ever talk to Mr. Orfanedes about the
4 statements that Ms. Taitz published on her eligibility
5 website concerning me?
6 A. No.
7 Q. Did you ever talk to Mr. Farrell about them?
8 A. No.
9 Q. Did you ever talk to anyone at Judicial Watch
10 about the statements that Ms. Taitz published on the
11 website about me?
12 A. No.
13 Q. Did you?
14 A. No, I do not -- did not, have not.
15 Q. If I was not convicted of a crime, are you
16 sorry that this wound up on Ms. Taitz's website?
18 MR. KLAYMAN: I'll withdraw the question.
19 THE WITNESS: Did you say you wi thdrew the
20 question?
21 MR. KRESS: Right.
22 MR. KLAYMAN: I'll withdraw this question.
23 THE WITNESS: Thank you.
24 BY MR. KLAYMAN:
25 Q. The -- I'll turn your attention to Exhibit 9.
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1 MR. KLAYMAN: If my colleague would put that in

2 front of you or your attorney.
3 THE WITNESS: It's still here.
4 MR. KRESS: No, that's a different one.
5 THE WITNESS: Oh. I'm sorry.
6 MR. KRESS: This one (indicating).
7
10
11 THE WITNESS: Okay. I'm looking at something that
12 says Driscoll Seltzer dated March 5th of 2012. It's
13 addressed to you --
14 MR. KLAYMAN: Right.
15 Q. I want to turn your attention to a document
16 that is labeled "Judicial Watch, Bates No. 000508."
18 Q. Do you see that?
19 A. Okay.
20 Q. That's an e-mail that you sent to Tom Fitton,
21 Paul Orfanedes, and Chris Farrell --
22 A. Right.
23 Q. -- correct?
24 Okay. It says, "From my sister-in-law."
25 A. Right.
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1 Q. And then the subject is, "Judge orders

2 eligibility attorney to stay away."
3 Who is your sister-in-law?
4 A. Carolyn Kwan Sloan.
5 Q. It says, "Klayman is at it again!"
6 Exclamation point.
7 You meant that in a negative way?
8 A. I don't know. Because I don't know what this
9 thing is where it says, "Judge orders eligibility
10 attorney to stay away."
11 Q. Why did you write to the judicial directors,
12 "Klayman is at it again! II exclamation point?
13 A. I don't know. I don't remember.
14 Q. You were trying to curry favor with them,
15 were you not
17 BY MR. KLAYMAN:
18 Q. -- the Judicial Watch directors?
19 A. No.
20 Q. It says, "Read if you are interested. The
21 truly disturbing thing, however, is that the judge
22 DID," capital DID, "refer to a fictitious movie to make
23 his ruling!!" double exclamation point.
24 A. Right.
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1 A. Yes, I see it.

2 Q. You were disturbed that the judge had made
3 a -- a stupid ruling about something that was a
4 fictitious movie. Right?
6 You can answer.
7 THE WITNESS: Yeah. I mean, when a judge makes a
8 ridiculous ruling, then it affects everyone.
9 BY MR. KLAYMAN:
10 Q. But you would you would like Barack Obama
11 to be ruled ineligible by a court of law. Correct?
12 A. I'm sorry. What was that?
13 Q. You would like a court of law to make a ruling
14 that President Barack Hussein Obama isn't eligible to
15 be president.
16 MR. KRESS: I object to the form. And relevancy.
17 You can answer.
18 THE WITNESS: I'm sorry. 1--
19 BY MR. KLAYMAN:
20 Q. Correct?
21 A. I'm sorry, Larry.
22 Q. You would like -- you would like the Court to
23 make a ruling that Barack Obama is ineligible to be
24 president. Correct?
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1 You can answer.

2 THE WITNESS: It would be great.
3 BY MR. KLAYMAN :
4 Q. And you were aware at the time that you met
5 Ms. Taitz that she had several lawsuits trying to
6 declare Obama ineligible. Correct?
7 A. Correct.
8 Q. And you were very supportive of her efforts
9 to do that. Correct?
10 A. On a personal level.
11 Q. And you were supportive of her attempts to
12 raise money for those efforts. Correct?
13 A. I was aware of it.
14 Q. You weren't against her raising money for
15 those efforts, were you?
16 A. No.
17 Q. Were you?
18 A. No.
19 Q. So when you gave her the information about my
20 children and me and had given it to the donors, you
21 were trying to help Ms. Taitz. Correct?
23 THE WITNESS: This memo -- this e-mail was dated
24 January 7th of 2013, not 2012.
25 MR. KLAYMAN: I'm not talking about the date.
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1 Q. I'm saying at the time that you gave Ms. Taitz

2 the information
3 A. Right.
4 Q. about me and my children and suggested that
5 it would be given to donors, you were trying to help
6 Ms. Taitz. Correct?
8 THE WITNESS: Objection because I did not tell her
9 to give it to donors.
10 BY MR. KLAYMAN:
11 Q. But you don't remember what you said, do you?
14 THE WITNESS: I do remember what I said on a
15 limited basis.
16 BY MR. KLAYMAN :
17 Q. But you read Ms. Taitz's posting, did you not?
18 A. I didn't read her posting until months later.
19 Q. Having read it months later, did you ever tell
20 her to correct it?
21 A. No.
22 Q. You were aware that giving that information to
23 donors could hurt Larry Klayman. Correct?
25 THE WITNESS: I did not give it to her to hurt --
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1 to have her put it on a website or hurt you.

2 MR. KLAYMAN: Let's back up on this.
3 Q. Turn your attention to -- who is Price Sloan?
4 A. My brother who died last June.
5 Q. Who is it?
6 A. Price--
7 Q. Who is Price Sloan?
8 A. Price Newton -- well, there are two Price
9 Sloans. There's Price William Elmer Sloan, who lS my
10 father. And there's Price N. Newton Sloan, who is my
11 brother.
12 My brother died on
13 Q. On the e-mail that I just -- on the e-mail
14 that I just read to you, which is Judicial Watch
15 Document 508, it says Sloan Price Sloan. Which
16 Price Sloan is that?
17 A. My brother, as my father died on December 14th
18 of 2001.
19 Q. Turn your attention to a document Judicial
20 Watch Bates Number 505. It's part of that same
21 Exhibit 9.
24 A. Okay.
25 Q. Ms. Ruffley, do you see that?
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1 A. Yes, dated August 28th.

2 Q. Yes.
3 There's an e-mail there from Steve Andersen
4 of Judicial Watch to Tom Fitton, Paul Orfanedes, and
5 Chris Farrell. Copy to Susan prytherch. Subject:
6 "Orly Taitz posting a Judicial Watch invite to speak on
7 her website??"
8 And it states, "I am extremely proud, I just
9 got a call from the 'Judicial Watch,' and was asked to
10 be a speaker at their event, 'Republicans United,' on
11 October 13th in California."
12 That's a posting on Orly Taitz's website, is
13 it not?
14 A. Right.
15 Q. You said "Right"?
16 A. Yes.
17 Q. Now, that's in -- when Andersen sent that to
18 Fitton, Orfanedes, and Farrell, that then generated an
19 e-mail from Paul Orfanedes to you Tuesday, August 28th,
20 2012 at 4:03 p.m., which is above what I just read to
21 you on that page
22 A. Right.
23 Q. -- Bates Number 505. Correct?
24 A. Correct.
25 Q. And that e-mail says, "Connie: We've had a
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1 couple of inquiries about this posting. Can you make

2 clear to Ms. Taitz or whomever is responsible for the
3 posting that she was invited by UROC and not 'The
4 Judicial Watch.' The posting also needs to be
5 corrected to avoid any further confusion. Thanks.
6 PJO."
7 A. Right.
9 A. Yes.
10 Q. PJO is Paul J. Orfanedes. Correct?
11 A. Correct.
12 Q. The person who is in the room with you today?
13 A. Yes.
14 Q. One of them. Correct?
15 A. (Nods head in the affirmative.)
16 Q. What was this about?
17 Well, strike that.
18 In fact, Mr. Orfanedes was concerned that
19 Ms. Taitz had posted something incorrectly on her
20 website
21 A. Right.
22 Q. -- as she was being invited by Judicial
23 Watch --
24 A. Well --
25 Q. -- to a Judicial Watch event rather than UROC.
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1 Correct?
3 THE WITNESS: Correct.
4 MR. KRESS: But you can answer it. That's fine.
5 THE WITNESS: She had only known me as Judicial
6 Watch. And the fact that -- you know, because that's
7 the way I had introduced myself. And so when I called
8 her on the phone, which was around 8:42 p.m., she was
9 still at her office doing work. And I called her on
10 her cell phone and asked her if she would speak at
11 UROC.
12 And because of Ms. Taitz's heavy accent --
13 well, it's not a heavy accent, but it's an accent.
14 She was just confused about the -- the UROC. I mean,
15 I don't know when this woman ever sleeps. So that's
16 why she said that.
17 But she -- and I said -- and I told her
18 United Republicans of California. She got confused and
19 put in there Republicans United. So I called her and
20 asked her to correct it. And I think she did.
21 BY MR. KLAYMAN :
22 Q. But you never called her, as you testified,
23 to ask her to correct anything she wrote about me,
24 did you?
25 A. No.
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1 Q. Ms. --
2 A. Actually
3 Q. Someone
4 A. Let --
5 Q. at Judicial
6 A. let me --
7 Q. Watch --
8 A. Wait a
9 Q. had called
10 A. minute.
11 Q. after --
12 A. Let me -- wait a minute. The court reporter
13 is having a little trouble keeping up.
14 Let me restate that last comment. I never
15 never corrected her on that. I was just, you know,
16 stunned and didn't know that she would actually print a
17 retraction or a correction.
18 Q. Well, regardless of whether you were stunned
19 or not, you didn't feel like you had an obligation to
20 correct her claimed misquotes with you?
21 A. I'm not sure whether
22 MR. KRESS: I'm going to object to the form.
23 But you can answer it. You can answer it,
24 if you know.
25 THE WITNESS: I really don't know. I didn't feel
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1 like I, uh -- I just kind of object to the word

2 "obligation," or whatever it was that you used.
3 BY MR. KLAYMAN:
4 Q. You don't know of anyone at Judicial Watch
5 calling her to ask her to correct the statements with
6 regards to Larry Klayman that are at issue here, do
7 you?
8 A. No.
9 Q. If you were so stunned about what Ms. Taitz
10 had published about your conversation with her
11 A. Right.
12 Q. -- why you did you invite her to the November
13 conference to speak?
15 THE WITNESS: Well, she really does know from
16 the -- the times that I have seen her speak and
17 everything and from all of the -- I -- this goes back
18 to when I first met her when she was running for
19 Secretary of State, how she had been to visit all of
20 the Secretaries of State and all -- in the union, and
21 I didn't know anyone else who did that.
22 So that's one of the reasons why she was
23 invited to speak
24 BY MR. KLAYMAN:
25 Q. That impressed you. Right?
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1 A. -- to UROC.
2 I beg your pardon?
3 Q. That I'm pressed you?
4 A. Well, it should impress anyone. She was
5 taking the time to get out there to gather the correct
6 information.
7 Q. So you didn't think it was that important that
8 she allegedly misquoted you, you just wanted her to
9 speak?
11 THE WITNESS: It had nothing to do with what she
12 had put on the website. I just wanted her to speak to
13 the attendees at the UROC Convention and discuss --
14 BY MR. KLAYMAN:
15 Q. You saw her at the UROC Convention, did you
16 not?
18 Q. You saw her at the URoe Convention, did you
19 not?
20 A. Yes.
21 Q. You didn't ask her to correct what she had
22 published on her website about Larry Klayman, did you?
23 A. No.
24 MR. KLAYMAN: I have no further questions.
25 We will leave this deposition open because you
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1 need to look for the documents on your computer,

2 Ms. Taitz -- Ms. Ruffley.
3 I just want you to know that I wish you no
4 harm. And I trust that we can get the documents that
5 you haven't looked for yet, and that we can resolve
6 this case appropriately.
7 But thank you for your time.
8 MR. KRESS: I
9 MR. KLAYMAN: And
10 MR. KRESS: I do have
11 MR. KLAYMAN: and that concludes the question
12 session.
13 MR. KRESS: I do have a couple questions for her,
14 Mr. Klayman.
15
16 EXAMINATION
17 BY MR. KRESS:
18 Q. First of all, do you know for certain when it
19 was that you first read Orly Taitz's website posting
20 about Mr. Klayman?
21 A. It was probably several months after the --
22 several months after the incident.
23 Q. Was it -- do you know whether
24 MR. KLAYMAN: Objection. Move to strike.
25 Speculative.
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1 BY MR. KRESS:
2 Q. Do you know whether it was before or after the
3 UROC Convention?
4 A. It would have been before the UROC Convention.
5 Q. Okay. At the -- back in February of 2012,
6 did you understand the difference between the words
7 "convicted" and "indicted"?
8 A. No.
9 Q. When you did the work as a legal secretary,
10 did you do any criminal work?
11 A. Never.
12 Q. Okay. Did you -- at the time that you first
13 read Orly Taitz's website, did you also see that she
14 had made a correction of the statement?
15 A. No, I didn't.
16 MR. KLAYMAN: I didn't hear that.
17 MR. KRESS: I asked if -- if she -- I asked if
18 she recalls -- well, I asked if she saw Orly Taitz's
19 correction, and she said no.
20 MR. KLAYMAN: I didn't hear the question.
21 MR. KRESS: The question was --
22 MR. KLAYMAN: Can you repeat?
23 MR. KRESS: Sure. I'll paraphrase, if that's all
24 right.
25 I asked her if she had seen Orly Taitz's
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1 correction on the website. And she answered no.

2 And those are all of the questions that I
3 have.
4 J.VIR. KLAYMAN: I obj ect to that. That presumes
5 facts not in evidence that there was a correction.
6 J.VIR. KRESS: I have no further questions.
7 J.VIR. KLAYMAN: I have a few more.
8 J.VIR. KRESS: All right.
9
10 Examination
11 BY J.VIR. KLAYMAN :
12 Q. You have spent a good deal of time working
13 with Ernie Norris, who is former Deputy District
14 Attorney of Los Angeles County --
15 A. Yes.
16 Q. -- at Judicial Watch. Correct?
17 A. Yes.
18 Q. Correct?
19 A. Yes.
20 Q. Ernie is a -- Ernie was a criminal prosecutor
21 for a number of years with the District Attorney's
22 Office of Los Angeles. Correct?
23 A. 32 years. Yes.
24 Q. In fact, he played a role in the prosecution
25 of O.J. Simpson underneath Deputy D.A. Gil Garcetti.
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1 Correct?
2 A. I'm sorry. I didn't hear the first part of
3 the question correctly.
4 Would you mind repeating it, please, Larry?
5 Q. Ernie Norris, as Deputy Assistant District
6 Attorney underneath the District Attorney Gil Garcetti,
7 played a substantial role in the prosecution of O.J.
8 Simpson.
9 You are aware of that?
10 A. No, he did not have anything to do with the
11 O.J. Simpson trial. The O.J. Simpson trial was given
12 to his underling, Marcia Clark, and to Chris Darden.
13 But Ernie did not have
14 Q. You are aware that you have talked about
15 the O.J. Simpson case with Mr. Norris. Correct?
16 A. Oh, off and on.
17 Q. And Mr. Norris was quite -- was quite
18 despondent or upset that O.J. Simpson was not convicted
19 of the crime of murder. Correct?
20 A. I can't speak to his feelings on that or
21 emotions.
22 Q. You are aware that O.J. Simpson was indicted
23 but never convicted for murder. Correct?
24 A. Did you say "Ernie Simpson" or "O.J. Simpson"?
25 I'm sorry.
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1 Q. O.J.
2 A. Yes.
3 Q. Okay.
4 A. I'm aware that he was not convicted.
5 Q. Therefore, you do know the meaning of the word
6 "convicted" as opposed to "indicted." Correct?
7 A. More now. But at the time -- but at the time,
8 I was not aware of a difference between indicted and
9 convicted.
10 Q. So during the time of the O.J. Simpson trial,
11 you thought that O.J. Simpson was convicted because he
12 was indicted?
13 A. No.
14 Q. You are a highly intelligent person; are you
15 not, Ms. Ruffley?
16 A. Thank you. Yes.
17 Q. Newspaper regularly?
19 Q. You do read the newspaper, do you not --
20 A. No.
21 Q. -- regularly?
22 A. No.
23 Q. You watch Fox News, don't you?
24 A. I'm forced to watch it, yes. I hate it.
25 Q. You prefer MSNBC?
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1 A. No, I don't watch anything else except Fox.

2 It's my husband who watches Fox from in the morning
3 until late at night. And I just -- I'm stuck with it.
4 MR. KLAYMAN: I have no further questions at this
5 time.
6 Thank you for your time.
7 MR. KRESS: No further questions.
8 Thank you.
9 THE WITNESS: Thank you.
10 THE VIDEOGRAPHER: Any stipulation?
11 MR. KRESS: We will read -- he will read the
12 transcript.
13 What other stipulations are you looking for?
14 THE REPORTER: Who receives it.
15 MR. KRESS: Who receives it? I would prefer if
16 the transcript would be sent to me for review, if that
17 is acceptable.
18 Mr. Klayman.
19 MR. KLAYMAN: Excuse me.
20 MR. KRESS: In terms of reading the transcript, do
21 you mind if the court reporter just sends the
22 transcript to me for review so that I can send it to
23 Ms. Ruffley for review?
24 MR. KLAYMAN: No, I don I t mind. But we want a
25 copy, too --
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1 MR. KRESS: Sure.

2 MR. IaAYMAN: - - contemporaneous.
3 MR. KRESS: All right.
4 THE VIDEOGRAPHER: This concludes today' s
5 videotaped deposition of Constance Ruffley in the
6 matter of Larry Klayman vs. Judicial Watch.
7 We are off the record. The time is
8 10:33 a.m.
9 THE WITNESS: P.M.
10 Oh, it is A.M.
11 MR. IaAYMAN: Thank you.
12 You have also a very courteous counsel. So
13 I'll say that, as well.
14
15 (At 10:33 a.m., the proceedings
16 were concluded.)
17
18
19
20
21
22
23
24
25
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1 STATE OF CALIFORNIA
2 COUNTY OF LOS ANGELES
3
4 I, Tracy Williams, CSR #10139, Certified
5 Shorthand Reporter, do hereby certify:
6 That prior to being examined, the witness
7 named in the foregoing deposition was by me duly
8 sworn;
9 That said deposition was taken down by me in
10 shorthand at the time and place therein named and
11 thereafter transcribed under my direction;
12 I further certify that I am neither counsel
13 for, nor related to, any party to said proceedings, not
14 in any way interested in the outcome thereof.
15 I declare under penalty of perjury under the
16 law of the State of California that the foregoing is
17 true and correct.
18
19 Dated: February 14, 2014
20
21
Tracy Williams
22 CSR No. 10139, RPR CRR
23
24
25
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1 DECLARATION UNDER PENALTY OF PERJURY

2 I, Constance S. Ruffley, do hereby certify under
3 penalty of perjury that I have read the foregoing
4 transcript of my deposition taken January 31, 2014; that I
5 have made such corrections as appear noted on the
6 Deposition Errata Page, attached hereto, signed by
7 me; that my testimony as contained herein, as
8 corrected, is true and correct.
9
10 Dated this
day of ____________________ _
11 2014, at
------------------------------------------
12 California.
13
14
15
16 CONSTANCE S. RUFFLEY
17
18
19
20
21
22
23
24
25
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1 DEPOSITION ERRATA SHEET

2
3 Page No. Line No.
4 Change:
5 Reason for Change:
6 Page No. Line No.
7 Change:
9 Page No. Line No.
10 Change:
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22 Change:
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25 CONSTANCE S. RUFFLEY Dated
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#10139 1:1013981:4 accurate 25:21 29:3 63:5,12 (9) 53:11 54:24,2555:1
57:1058:2560:2
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65:14 70:471:23,23 (49)
'judicial 68:9 activist 44:20,21
ago 11:25 answered 35:2
'republicans 68: 10 activists 44:24 37:9,2538:2539:25
al 1:74:10 40:2476:1 (7)
'the 69:3 activities 18:7 19:25
20:3,6,844:7 52:21 (7) allegedly 73: 8 answering 41 :21
000508 62:16
actually 21: 14,20 alleging 26: 1 anticipated 45:9
1320610civ 1:5 27:2328:1947:13
71:2,16 (7) along 47:18 anymore 35:9
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130
130
EXHIBIT "13"
130
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 13-20610-CIV-ALTONAGAlSimonton
LARRY E. KLAYMAN,
Plaintiff,
v.
JUDICIAL WATCH, INC., eta/.,
Defendants.
______________________
DECLARATION UNDER PENALTY OF PERJURY OF CONSTANCE S. RUFFLEY
STATE OF CALIFORNIA )
)
COUNTY OF LOS ANGELES )
CONSTANCE S. RUFFLEY, pursuant to 28 U.S.C. 1746, makes the following declaration
under the penalty of perjury:
1. I am over the age of eighteen (18) and I am capable of making this affidavit.
2. I have personal knowledge of the following facts and, if called upon as a witness,
could testify competently thereto.
3. I am a resident of the State of California.
4. I am employed as the Office Administrator for Judicial Watch, Inc. 's Western
Regional Headquarters in San Marino California.
5. It is my understanding that Larry Klayman has sued me, Judicial Watch, Inc., and
other Judicial Watch, Inc. employees alleging that we, on or about Febnuu:y 22, 2012, "negligently,
maliciously and/or willfully published and furthered the publication of a false statement that Plaintiff
130
Klayman had been 'convicted' of a crime for not paying a large amount of child support with regard
to his children, on the internet and elsewhere within this judicial district, Florida, and elsewhere
throughout the United States and the world."
6. I deny Klayman's claims and I deny that I am liable on Klayman's claims for
defamation, defamation by implication, tortious interference with a contract, and intentional
infliction of emotional distress.
7. On or about February 22,2012, I attended the monthly meeting of the California
Coalition for Immigration Reform in Garden Grove, California. Orly Taitz was one of the speakers
at the meeting. I am familiar with Orly Taitz. Ms. Taitz is a California resident who was, at the
time, running on the primary ballot for one of the California seats on the United States Senate. After
the meeting, I was seated at an information table for Judicial Watch, displaying various forms of
Judicial Watch literature. Orly Taitz approached me and we discussed a number of issues. We
eventually discussed Larry Klayman. The only information that I conveyed to Ms. Taitz about Larry
Klayman was information that I had learned from public records, including information related to
court proceedings for failure to pay child support. I do not recall stating that Mr. Klayman had been
convicted for the crime offailure to pay child support. This was the only discussion that I had with
Ms. Taitz regarding Larry Klayman.
8. My expectation was that Orly Taitz would not restate my comments to any other
person or entity. I never gave Orly Taitz permission to restate my comments to any other person or
entity. I did not expect or anticipate that OrIy Taitz would restate my comments on her website or in
any other format. I expected that Orly Taitz would keep my comments to herself and only use the
comments to conduct her own research into the publicly-available information related to Larry
2
130
Klayman.
9. The information that I conveyed to orty Taitz was gathered through my own
independent research. No one from Judicial Watch advised me of this information or instructed me
to convey the information to Ody Taitz.
10. I did not make any statements about Larry Klayman in the State of Florida. I did not
intend for any of my statements about Mr. Klayman to be published or restated in the State of
Florida. I did not intend to cause any injw'Y. harm, or damage to Larry Klayman.
11. I do not: (I) own or lease any real property in Florida; (2) have a telephone listing or
mailing address in Florida; (3) have any Florida bank accounts; (4) have any Florida property tax
liability; (5) have any Florida registered vehicles or a Florida driver's license; (6) hold allY Florida
professional licenses; (7) vote in Florida; (8) operate, conduct, engage in, or carryon any personal
business in Florida; (9) travel to Florida except as referenced below; (10) contract to insure any
person or thing in Florida: (11) commit tortious acts in Florida; (12) cause injury to people or
property in Florida; or (13) enter into or breach contracts that are to be performed in Florida.
12. I have travelled to Florida only twice in my life, both times on Judicial Watch
business. The last time I travelled to Florida on Judicial Watch business was in 2001.
FURTHER DECLARANT SA YETB NAUGHT.
I declare under penalty ofperjury that the foregoing is true and correct.
Executed on June 28, 2013. in San Marino, California.
7""")
/'"'l' -:-T' . ,/ / / " /I ." /'
(F lL-r;;J-dpL t!: e" \ I- tt<.. /'':: i.. /Jl
, ~ / _ ~ r I
CONSTANCE S. RUFFLEY / .". .
3
130
130
It
7129113 presentation to CCIR and tate on article2SuperPAC-Larry $25,000 fuldraising for rlOIr-eJdstent ICfNsLit affair I Dr. OrlvTaitz, Es ..
Dr. Orly Taia, Esquire
Defend Our Freedoms Foundation
29839 Santa Margarita Pkwy. Ste 100
Rancho Santa Margarita CA 92688
Copyright 2013
World's Leading Obama Eligibility Challenge Web Site
If you love your country, please help me fight this creeping tyranny and corruption.
'Ill;: articles posted represent 01 opinion
of the writerS anO do not
represent the ogoon . q. , who
haS rp .means of chec,kIllg.UIt: vera9Itv of all
the CIaIlUS and allegamns m the artices.
Donations no matter how small will help pay for airline and travel expenses.

Mail donations to:
Defend Our Freedoms Foundation, c/o Dr. Orly Taitz
29839 Santa Margarita Plwy, Ste 100
Rancho Santa Margarita, CA 92688.
Contact Dr. Taitz at
orly .taitz@gmail.com
l.n case of emer!!"DCY, call 949-683-5411.
When Ihe people fear Iheir Ihere is tyranny.
When the government fears Ihe people. there is liberty.
- Thomas Jefferson
Durmg times of universal deceit. telling the truth
becomes a revolutionary aCL - George Orwell
Firs l/hey ignore you. theil/hey ridicule you. then Ihey
fight you. then you win. - Mahatma Gandhi
Apr(aline DCllli,try
(If F Jr'!'" tJt,rr,,,',
..
('J"', 71 ...
My yesterday'S presentation to CCIR and update on
article2SuperPAC-Larry Klayman $25,000 fundraising for non-
existent law suit affair
Posted on 1 Februal)' 23,201214 Comments
Anicle2supcrpac $25000 solicitation RJr Lan'" KlamJiln
Screen shot $25 000 sQljcitatKm lor Lany Klavman lawsuits FebruaJ:Y 10 2012
Plantiff'sl Defend .. ", Exhibil ---i...".,...
Witness : <:"
Dale I I .,
r,cy Williams, CSR, RPR, J139
'U) ('1<")
Yesterday I gave a 2hour presentation of my platfonn as a candidate for the US Senate. 'Ill;: presentationwas given to some 100 CA voters in the Women's
club of Garden Grove. I was tokl, that a representative of the Judicial Watch drove fur over an hour from San Marmo to hear me speak and talk to me. I got
a very wann reception, after my presentation peopk: stood up and applauded. 1bi5 member of the judicial watch approached me and gave me her card. Her
WNN.orl}tljtzesq .com'?p= 320n 1/10
130
7/29/13 My)Sterday's presentation to CCIR and update on $25,000 fundraising for non-eJ<istent lawsuit affair I Dr. OrlyTaitz, Es ...
name is Constance RuftJey and she is an office administrator fur the Judicial Watch in their Western Regional Headquarters at 2540 Huntington Dr., San
Marino. She told me, that she used to work fur the FBI and that she worked fur the Judicial Watch for many years. She actually initiated the discussion about
Larry Klayman and told me that she heard that he is involved in birther cases. I told her that this group, article2superpac was soliciting money, that they sent an
e-mail and posted on their site an advertisement on February 10, asking for $25,000, claiming that they need to raise $25,000 in 96 hours, as the cases in
Florida and Califumia need to be filed within a week. I told her, that it was a hard sell, they wrote it is now or never, saying finally Obarna's team met their
match, dis sing 4 years ofmy tireless work in the process, and in the end nothing was filed by Larry Klayman. It is not clear what happened to all of the money
that was raised, who got it.
Ms. Ruffiey actually advised me that Larry Klayman is not licensed in California, she told me that he no longer works with the Judicial Watch and that donors
should know about litigation in Ohio, where he was convicted just recentlty of not paying large amount in child support. She provided a lot of other
infonnation I will publish only, what is a public record. I am not publishing anything, that is not in public record.
A number of individuals sent me this information:
Larry Klayman, 60, of Los Angeles, Califurnia, was indicted on two (2) counts of criminal non-support. He owes $78,861.76 for his two children ages 11 and
14. Two hearings were held in Domestic Relations Court between 2009 and 2010. The last voluntary payment was made on August 30, 2011, in the amount
of$I,014.26. Arraignment is scheduled for February 7, 2012.
FWIW, you might want to read this suit (below) filed against Kayman ... from the time this suit was filed against Klayman (2007), he has not honored his
promise to pay back what the court ordered, even though it was nowhere near the $25,000 he was trusted with. I would be worried too, if I had donated
money to this man.
IN THE SUPREME COURT OF FLORIDA
THE FLORIDA BAR, Supreme Court Case
No.
Complainant,vs. No. 2011-70,621(IIA)
LARRY ELLIOT KLAYMAN,
Respondent.
COMPLAINT
3. On or about November 11,2007, Natalia Humm ("Humm') filed a grievance against Respondent (Larry Klayman) alleging that he had had fuiled to
provide services in her criminal case after she paid him a $25,000 retainer.
Yesterday I got an e-mail from Pamela Barnett titled: "Larry Klayman did not get nearly his retainer". When Barnett wrote that Klayman did not get nearly his
retainer, it means, that he got something. Barnett did not disclose, what did he get. What does it mean? According to the solicitation by a pack ofbloggers in
this article2Superpac, all of these bloggers were heavily soliciting a total of$25,000. Nobody knows, how much did they actually raise. Additiona1ly, Barnett
claims, that she and George Miller are no longer connected with the article2superpac, however the Article2superpac and solicitation fur donations fur
article2superpac is located at the top of the blog, ObamaBallotChallenge which is administered by Barnett and Miller. The link
http://www.art2superpac.com/floridaballot.html shows the actual article. The PDF and screenshot are at the top of the page.
"Not nearly his retainer" can be $15,000 out of$25,000, it can be$1 0,000. Bottom line, nobody knows, how much Klayman actually got. The question is,
why was he paid anything, ifhe did not file the law suits, as he was supposed to?
Later I got an e-mail from Tony Dolz, who is not on the board of the Article2Superpac, but who is in contact with a mnnber of the board members of this
PAC, who stated, that he had a discussion with George Miller, who is on the board of the Article2superpac, who runs a blog ObamaBallotChaIlenge together
with Barnett. According to Dolz, Miller stated, that Klayman was not paid anything.
The question is: who is lying? Was Klayman paid or not? Ifhe was paid, than he needs to refund the donors, as he did not file law suits as he was supposed to.
If the bloggers raised money and did not pay Klayman, the bloggers need to refund the money to the donors. The press release, that was issued by
Article2Superpac on February 10, 2012 clearly stated, that the donors are asked to donate $25,000 to pay Larry Klayman, that they have 96 hours to raise
this large sum of money. The article also stated that the law suits are supposed to be filed within 1 week. It is now or never(see the article above). So, there
were clear parameters: this pack ofbloggers was soliciting from the public a large sum of money specitica1ly to pay attorney Larry Klayman: $25,000 to file 2
law suits in FL and CA within a week, by February 17,2012. Those law suits were never filed and the public should be refunded all of the money that was
donated for this specific purpose. All of the bloggers, who ran this solicitation, need to provide accounting fur the public, how much money did they raise in
total and where did this money go. Actually, donors can report this to their District Attorneys. If the public donated fur specitic purpose and did not get the
benefit, the public was defrauded and this is a criminal matter. People went to prison fur things like that.
There are 5 board members of this Article2superpac:
1. Helen Tansey-blogger, president of the Article2SuperPAC
.com'?p=32077 2110
130
7/29/13 presentation to CCIR and update on article2SuperPAC-LarryKlayman $25,000 fundraising for non-eJdstent lawsuit affair I Dr. OrlyTaitz, Es ...
2. Gany Wihnott, blogger GiveUSLiberty1776
3. Bob Nelson-blogger, runs ORYR (ObamaReleaseYourRecords) or BirtherReport (I got infurmation, that Bob nelson might be a pseudonym fur richard
Garoutte, but I am not sure).
4. George Miller runs blog ObamaBallotChallenge together with Pamela Barnett (another supporter stated, that Pamela Barnett is on the board instead of
George Miller, I am not sure about that)
5. Kevin Powell, a cameraman, I don't know, what blog does he run
Additionally several other bloggers were nmning solicitation of this Article@superpac on their blogs, among them
Dean Haskins, blogger "BirtherSummit"
Sam Sewell blogger 'steady drip", Charles Kerchner and a few others.
All of these people are supposed to refund the public all of the money, that they raised fur these law suits that were supposed to be filed by Larry Klayman by
the February 17, 2012 deadline, as those law suits were never filed. 1be public never got the benefit of the what they paid fur.
1bis is the reason, why I stated before, that if you want to donate to the work of a specific attorney, donate directly and you know, where the money is going.
When you donate to a gang ofbloggers, claiming that the money is going to attorneys fur legal expenses, you have no idea where the donations are going.
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Comments
4 Responses to "My yesterday's presentation to CCIR and update on article2 S uperP AC-Larry Klayman $25,000 fundraising fur non-existent law suit aifuir"
1. Bloodless Coup
February 23rd, 2012 @ 7:20 am
I was intia1ly excited about Larry Klayman, and helped the news about him to go viral Now I am wondering about him and what his true motives might
be.
2. Florence Stone
February 23rd, 2012 @ 2:51 pm
I srnelled a rat from the get-go. Asking for $25,000 fur 2 lawsuits sounded way out of the ballpark to me, so I did not bite. Seemed like an attempt to
scam money on the backs of people wanting to expose Obama, and nothing more. Glad Orly stays on top of things like this for us. WHERE DOES
SHE FIND TIfE TIME?? Talk about multi-tasking, I think Orly is the Queen of that as well!
February 27th, 2012 @ 6:54 am
Obama's administration is doing the same to Orly as they did (and are still doing) to Dr Judy Wood regarding "Where did the Towers Go". 1bey slide a
sM into "leading honest intention" down a hill and into the forrest and away from the main target. Dr Orly Taitz is the finest there is!
April 9th, 2012 @ 11:48 pm
I have read some excellent stuffhere. Definitely worth bookmarking for revisiting. Thanks!
Leave a Reply
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lMM'I.orlytaitzesq .com'?p=320n 10110
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driscoll seltzer
March 5, 2012
BY EMAIL AND FIRST CLASS MAIL
Larry E. Klayman, Esquire
2020 Pennsylvania Avenue, N.W., Suite 345
Washington, DC 20006
Richard W. Driscoll'
Direct: 703.879.2601
rdriscoll@driscollseltzer.com
'Admitted in VA, DC and MD
Re: Putative Claim for defamation. etc.
Dear Mr. Klayman:
This firm represents Judicial Watch, Inc. relating to the above-referenced matter.
Through a series of emails and again during our conversation on Tuesday, February 28,
2012, you advanced vague and unsupported allegations that Judicial Watch, its
President Thomas Fitton and an employee are participants in a conspiracy to defame
and disparage you based on the recent indictment handed down in Ohio. To date, you
have produced no evidence to support these truly outrageous allegations.
As I stated to you during our conversation, Judicial Watch did not authorize, make, or
participate in making, any statements regarding your indictment for criminal non-
support. For this reason, it is not necessary for Judicial Watch to take any action to
clarify or correct the statements of others.
Sincerely,
DRISCOLL & SELTZER, PLLC
Richard W. Driscoll
cc: Paul J. Orfanedes, Esquire
a profess/annllimiteJ liability company
O:\Client Matters\70007\1
130
Tom Fitton
From:
Sent:
To:
Cc:
Paul Orfanedes
Tuesday, August 28, 2012 4:03 PM
Connie Ruffley
Tom Fitton; Christopher Fedeli; Steve Andersen; Susan Prytherch
Subject: FW: Oriy Taitz posting a Judicial Watch invite to speak on her Website??
Connie:
We've had a couple of inquiries about this posting. Can you make dear to Ms. Taitz or whomever is responsible for the
posting that she was invited by UROe and not "the Judicial watch.!' The also needs to be corrected to avoid any
further confusion.
Thanks.
PJO
From: Steve Andersen
Sent: Tuesday, August 28, 2012 3:33 PM
To: Tom Fitton; Paul Orfanedesi Chris Farrell
Cc:: Susan prytherch
Subject: RE: Orly Taitz posting a Judicial Watch invite to speak on her Website??
am extremel
Posted on 1 August 22,201214 Comments
The event will be on October 13th, it will be in the "Embassy Suites" in the city of Arcadia, it is about 20
minutes North-West of Los Angeles. I will provide more information later.
Steven C. Andersen
Director of Development
Judicial Watch
425 Third Street S.W.
Suite 800
Washington, D.C. 20024
(202) 646-5198
www.judicialwatch.org
118ecause no one is above the Jaw. II
1
JW000505
130
'Those who expect to reap the blessings of freedom, must, like men, undergo the fatigue of supporting it."
-Thomas Paine
Support Judicial Watch by shopping and searching online at igive.com. Get started now
at www.iGive.com/JudiciaIWatch
STATEMENT OF CONFIDENTIALITY: The information contained in this electronic message and any attachments to this
message are intended for the exclusive use of the addressee(s) and may contain confidential or privileged information. If
you are not the intended recipient, please notify Judicial Watch, Inc. immediately at either 202-646-5172 or at
info@judicialwatch.org, and destroy all copies of the message and any attachments.
From: JW Info
Sent: Friday, August 24, 2012 8:48 AM
To: Tom Fitton; Paul Orfanedes; Chris Farrelli Steve Andersen
Subject: Orly Taitz posting a Judicial Watch invite to speak on her Website??
Watch - United Event in CA?
It is on her website -- http://www.orlytaitzesq.com/?p=252642
a of mall from Mr. Driscoll
from: Lawrence Driscoll (mailto:lj,driscoll@yahoo.com]
Sent: Thursday, August 23, 2012 9:52 PM
To: Dr. Orly Taitz ESQ; Orly Taitz
Cc: JW Info
Subject: Larry Driscoll's "Citizen Submittal Letter re Criminal Barack Obama", LD to OT update
Orly,
I resend my earlier email to judicial Watch as per your efforts and presenting them to 'Judicial Watch'.
Honestly, from knowing and learning about Judicial Watch over time, I conclude that; they seek donations, they take on
'small battles', Le, avoid 'larger issues', all with intent to support their 'Watchdog Image' to attract more donations, in other
words, their actions care only for donations and not justice as per our US Constitution, as opposed to you and you case
and subject matter investigative endeavors, as you care always to seek justice upon a matter.
At your website you have posted that "Judicial Watch" has asked you to appear at its "Republicans United Event in CAli.
Undertake this offer. POSSibly, your appearance will create a "Legal Spine", a devotional caring for truth in Judicial Watch,
for as to date. as per the issues that you address, this organization does not have this, especially with regard to larger
issues.
Sincerely,
larry Driscoll
-- Forwarded Message ---
from: Lawrence Driscoll <Ij.driscoll@yahoo.com>
To: "info@;udicialwatch.org" <info@iudicialwatch.org>
Cc: Dr. Orly Taitz ESQ <dr taitz@yahoo.com>; Orly Taitz <orly.taitz@gmail.com>
Sent: Thursday, August 9,20128:26 PM
Subject: Larry Driscoll's "Citizen Submittal Letter re Criminal Barack Obama"
Tom Fitton and Judicial Watch,
I forward to you my attachment "Citizen Submital letter re Criminal Berack Obama" sent to my Arizona First District
Representative Paul Gosar at his Washington, DC. Office and to others cc'd as you will review.
I have asked you, Tom Fitton and your organization Judicial Watch, before that you would align your legal knowledge and
support of Attorney Taitz's endeavors, with common goal of allegience, to remove THE CRIMINAL BARACK OBAMA
2
JW000506
130
FROM HIS PRESENTLY UNCONSTITUTIONALLY HELD OFFICE, but you have chosen not to do this. If you continue
not to support Atrtomey Taitz, I ask that you remove me from your data base and never attempt to contact me again
Sincerely,
Larry Driscoll
--- Forwarded Message --From: lawrence Driscoll <ILdriscoll@yahoo.com>
To: "news@worldnetdaily.com" <news@worldnetdaily.com>; "Ietters@worldnetdaily.com" <Ietters@worldnetdaily.com>;
"dkupelian@worldnetdaily.com" <dkupelian@worldnetdaily.com>
Cc: Orly Taitz <orly.taitz@gmail.com>; Dr. Orly Taitz ESQ <dr taitz@yahoo.com>
Sent: Thursday, August 9,20128:00 PM
Subject: Larry Driscoll's "Citizen Submittal letter re Criminal Sarack Obama"
News at World Net Daily, Letters at Wond Net Daily, Joseph Farah, David Kupelian,
I attach to this email my "Citizen Submittal Letter regarding Criminal Sa rack Obama" which as you see in original postal
mail form was sent to my Arizona First District Representative Paul Gosar at his Washington, DC office, with ce, copies
sent to Attorney Taitz, Arizona Sheriff Arpaio, Washington Times Columnist, Kuhner and House Speaker Boehner.
Next, Mitt Romney and Mitt Romney for PreSident, Donald Trump, Fox news manager and fox news tips, Jonathan Paton,
my new to be Representative in AZ to be, and Chelsea Schilling of WND were email sent same letter.
I ask that WND constantly attend to, and announce to the public via its internet webSite, that not only is Barack Obama a
"Liar and Deceiver" in his daily conduct and actions from before 2008 to the present, that even worse, is the fact that,
Barack Obama is, 'most and more importantly' to be noted, addressed and described, not as a "Presidenf', but as a
CRIMINAL", as per all of of the previous lieing and deceiving actions and deeds carried out by him against the American
Citizen voting public with regard to his stolen Social Security Number and his fraudulent Selective Service Registration
Card which carries a fraudulent Postal Indicia.
Sincerely,
Larry Driscoll
10827 Mesa View Rd.
Williams, AZ 86046
3
JW000507
130
Tom Fitton
From:
Sent:
To:
Subject:
(From my sister-in-law)
Constance Ruffley <sarawick@pacbell.net>
Monday, January 07,2013 2:41 PM
Tom Fitton; Paul Orfanedes; Chris Farrell
Fw: Judge orders eligibility attorney to stay away
Klayman is at it againl Read if you're interested. The truly disturbing thing, however, is that the judge DID
refer to a fictitious movie to make his ruling!!
Connie
--- On Sun, 116113, Price Sloan <psloan350f!JiJfa.rr.com> wrote:
From: Price Sloan <psloan3500@ca.rr.com>
Subject: Judge orders eligibility attorney to stay away
To: Undisc1osed-Recigient@yahoo.com
Date: Sunday, January 6,2013, 7:14 PM
Holy crap! Do these people running our country have no brains? Quoting the fictitious judge
from the movie "Miracle on 54th Street" no less. I think the scarecrow from Wizard of Oz has
more brains than these jokers!
http://www.wnd.com/2013/01/judge-orders-eligibility-attorney-to-stay-awavl
1
JW000508
130
Tom fitton
From: Connie Ruffley
Sent: Friday, October 11, 2013 7:38 PM
To: Tom Fitton; Paul Orfanedes; Chris Farrell
Subject: Article about Larry Nichols, LEK, and Truckers for the Constitution
FYI.
c.
http://freedornoutposLcom/2013/l0/forrner-hillary-associa!:!:=jaims-personal-hit-man-admits-killing-monev!
1
JW000509
130
Former Hillary Associate Claims to Have Been Her Personal Hit M ... http://fieedomoutpost.coml2013/1 O/fonner-hi Ilary-associate-ciaims-...
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h ,d enel, ,,,, is " e/ually 1/1" dallg',121 of W<>b HuN,ie,
NichClls nod mrlHy ot /1e1 ctilhll Clinton began sex it/lUI Hubble 10 9 d1i J t?mploymenf dt T/U?
Ros& Law FI' m IV/1ich sIre be/ielled would event(fdlly i'tdV.fJ!1C6 Bill Ciinton's chances of becon ling Gopernor
of Ark"n:;as,
Th' above quote-s came from d radic interview ! have obtaIned a video tha.t Is po::; ted on the 5iHn pdge It 1$ .4
how ,;; tong I rave not had time to the Illewe idea what $egrnent of the- show copt('llns
them I am po::;t ing t he vi<jeo for tho:;\? who might hdye time to Ii"tffi to it WARNING: Som" content in ttl" v1(l&o
may be uffensive to in ;hi '; audience up the vieIRo around the I HI OgMil' k
This b d perfect Qxampte of how major :',torte5 cltn I)e sqU8.sjled by large media I llI'1<l'Jiore of thi$
,tory lIntit today Is n 1m",' Maybe 00 el1d rnaybe not The pOl ll! til At II a foomer aooocld'" makes the,e
it should be cover c-<I by the media even if their only intent is: to comment::;,
ldJ I y I-.Jichot s. tll efe .and j1- know", V/hnt hapPGl1ed. Is he tying? Thai'c only he and otherz, thaI
wei e there truly know
If the ... thntare flyi ng 011 the Santilli ::.tlOVl are true, it is" ju<.; t I"or e- evidence thdt we c<"nnot h,lLy
put ollr tru:::.t in f" 0)(' I\:-\:Jl$.
Editor' s Note: TIl .. prevlou, photo lip tdp.d '" Larry Nlcllol s was 1101 the _oJ'ry Nichol<; this art ICle is about, Otll
apotogie&. The r.;hoto has been updated
Don't forget to Like Fr<!edom Outpo.t on Fac ohook. Googlo Plus, Party Community & Twi tter.
Truth .-\J,W)t.r
Siftilol l \ 'ioir ,) kt-I ..lrl
;;""'''_I .' .lUjf.. ,'lt.-,1
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f]llll t IoIIW.' Srrll Ull- hl ;-\<'t' Al t" rll POI"\ Po"'( r ) Tu [I'} [: .. bll:
\ 'I '\.>(o , 1.",1.11):; d!\ I"1Y Timr")
Freedom Outpost
JVVOOO511
130
Former Hillary Associate Claims to Have Been Her Personal Hit M ... http://freedomotitpost.coml20 13/1 O/former-hillary-associate-c1aims-...
TV
JWO00512
130
Tom Fitton
From:
Sent:
To:
Subject:
Paul Orfanedes
Wednesday, August 29,20127:27 PM
Tom Fitton; Christopher Fedeli; Susan Prytherch; Steve Andersen
FW: UROC Fall Convention, Saturday, October 13, 2012
From: Constance Ruffley [mailto:sarawick@pacbell.net]
Sent: Tuesday, August 28,20127:00 PM
To: Orry Taltz
Subject: UROC Fall Convention, Saturday, October 13, 2012
Dear Dr. Taitz,
Here is the information about the Fall Convention for United Republicans of California (URGC). It will be held
on Saturday, October 13, 2012, 9:00 a.m. to 3:00 p.m., at the Embassy Suites, 211 East Huntington Drive,
Arcadia, CA.
For further information, anyone can call 626-422-1699.
As soon as possible, PLEASE replace the information you currently have on your website with the above! In
addition, please remove any reference to lithe Judicial Watch" as Judicial Watch has no connection to UROC
whatsoever. I work for Judicial Watch but, on my personal time, I am Chairman ofUROC.
Thank you very much. If you have any questions, please feel free to call me at 626-422-1699 or my home, 626-
287-4540.
Sincerely,
Connie Ruffley
Chairman, United Republicans of California (URGC)
1
JWO00513
130

Ruffley Deposition, Klayman V Judicial Watch

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Ruffley Deposition, Klayman V Judicial Watch

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EXHIBIT 1

1 LOS ANGELES, CALI FORNIAi

1 (No audible response.)

1 MR. KRESS: Okay.

1 THE WITNESS: Yes.

1 Q. Can you run us briefly through your

lover the "n."

1 Q. And what were the circumstances of that

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

1 Ernie Norris at some point retired. Correct?

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

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

1 Q. And what was discussed?

1 Q. And when was that?

1 THE WITNESS: I can't hear you.

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

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

1 Naveed, would you please hand that to the

1 But you can answer.

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

1 MR. KRESS: Well, I --

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

1 Q. You offered information to Ms. Taitz about

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

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

1 licensed at some point.

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

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

1 Q. You never talked to them about my being

1 You can answer.

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

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

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

1 eligibility website. Correct?

1 You can answer it.

1 MR. KRESS: Objection.

1 Q. And when did you have discussions with him

1 Q. And have you deleted any communications

1 THE WITNESS: Well, the search was not conducted

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

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

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

1 You are aware today that I was never convicted

1 understand the question and you know the answer.

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

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

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

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

1 A. Yes, I see it.

1 You can answer.

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

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

1 A. Yes, dated August 28th.

1 couple of inquiries about this posting. Can you make

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

1 need to look for the documents on your computer,

1 correction on the website. And she answered no.

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

1 MR. KRESS: Sure.

1 DECLARATION UNDER PENALTY OF PERJURY

1 DEPOSITION ERRATA SHEET

Case 1:13-cv-20610-CMA Document 80-1 Entered on FLSD Docket 02/28/2014 Page 85 of

UNITED STATES DISTRICT COURT