Willis Carto archive

Judgment Debtor’s Examination of Willis A. Carto — 6/21/2001

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SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN DIEGO, NORTH COUNTY BRANCH

_________________________________
                                 *
LEGION FOR THE SURVIVAL OF       *
FREEDOM, INC., a Texas           *
corporation,                     *
                                 *
Plaintiff,                       *
vs.                              * Case No. N64584
                                 *
WILLIS CARTO, et al.,            *
                                 *
Defendants.                      *
_________________________________*

1 DEBTOR’s EXAMINATION OF WILLIS A. CARTO
2
3 Pursuant to Notice to Take Debtor's
4 Examination, taken on the 21st day of June, 2001,
5 commencing at the hour of 10:10 O'Clock a.m., at
6 2139 First Avenue, Second Floor, in the City of
7 San Diego, County of San Diego, State of California,
8 before me, Sheri L. Somers, Certified Shorthand
9 Reporter, personally appeared:
10 WILLIS A. CARTO,
11 called as a witness by the Plaintiff, who, being by me
12 first duly sworn, was thereupon examined as a witness
13 in said cause.
3

1 EXAMINATION
2 BY MS. ARONSON:
3 Q. Would you please state your name and spell
4 it for the record.
5 A. Willis A. Carto, W-i-l-l-i-s, C-a-r-t-o.
6 Q. And what does the A stand for, sir?
7 A. Allison, A-l-l-i-s-o-n.
8 Q. Now, you've had your judgment debtor's
9 examination taken before, so you do know how this
10 procedure works, correct?
11 A. Yes.
12 Q. Have you had a chance to discuss this with
13 your counsel, also, so you know the procedure?
14 A. Yes.
15 Q. Do you have any questions before we begin?
16 A. No.
17 Q. Just for the record, this is not any kind of
18 an endurance test. If you want to take a break or if
19 you want to speak to your counsel outside the hearing
20 of the court reporter or myself, you're more than
21 welcome to do so at any time. Just let me know.
22 A. Thank you.
23 Q. Of course, as always, the court reporter is
24 taking down everything that we say so please respond
25 either affirmatively or negatively. We can't have head
4

1 shaking yes or no or uh-huh or huh-uh’s because it
2 looks the same on the record. Okay?
3 A. Uh-huh.
4 Q. You can put the giggles down in parenthesis.
5 That’s a yes, correct, sir?
6 A. Yes.
7 Q. Now, you said your name is Willis Allison
8 Carto. Have you used any other names in the past?
9 A. Yes.
10 Q. And what would those be?
11 A. E.L. Anderson, Frank Tomkins, and other
12 nom de plume for the purposes of writing, which I don't
13 really remember.
14 Q. And when you say you used these other names,
15 was that what they were were pen names?
16 A. Yes.
17 Q. And they were used solely for the purpose of
18 writing?
19 A. Yes.
20 Q. Did you ever use a name because you felt
21 unsafe in your home or house for --
22 A. Yes, that’s right. And that name is Young,
23 Bill Young.
24 Q. And it’s my understanding, sir, that you
25 gave that name so that people wouldn't know it was you
5

1 that owned your residence or who lived at the place
2 that you were living --
3 A. Correct.
4 Q. — for safety purposes, correct?
5 A. Yes.
6 Q. For the record, please let me finish my
7 questions before you respond simply because it’s easier
8 for the court reporter to get everything down.
9 A. Of course.
10 Q. What is your home phone number, please.
11 A. (760) 746-4842.
12 Q. And your home address?
13 A. 1718 Quail Ridge Road, Escondido.
14 Q. The Quail Ridge Road in Escondido, has this
15 always been your resident address?
16 A. No.
17 Q. What were your other residence addresses
18 within the last five years?
19 A. Within the last five years it has been, yes.
20 Q. It has been. What about in Washington D.C.,
21 do you have a residence there?
22 A. No.
23 Q. Have you ever had a residence in Washington
24 D.C.?
25 A. Well, I rented a room at one time years ago.
6

1 Q. Okay. Now, I might be incorrect on this,
2 but if my memory serves me correctly, you testified in
3 front of Judge Maino that you were a resident of
4 Washington D.C. By that did you mean that you had a
5 residence in Washington D.C.?
6 A. I have an address. I have a room in the
7 building where I sleep when I am in Washington, and
8 since I'm there a good part of the time, I am, I
9 suppose, a resident of Washington.
10 Q. And what is the address of that building?
11 A. One — one — the address would be
12 300 Independence Avenue, Southeast.
13 Q. And that’s the same building in which
14 Liberty Lobby is presently --
15 A. Well, it’s an annex. It’s right next-door.
16 Q. Again, sir, you have to let me finish my
17 questions before you respond just so the court reporter
18 can take down the entire record.
19 A. Okay.
20 Q. What is your date of birth, please.
21 A. 7-17-26.
22 Q. And where were you born, sir?
23 A. Indiana.
24 Q. Hoosier. Are you married?
25 A. Yes.
7

1 Q. And would you please state your spouse's
2 full name for the record.
3 A. Elisabeth — with an S — Oldemeir — maiden
4 name, O-l-d-e-m-e-i-r — Carto.
5 Q. Does she have a middle name, sir?
6 A. I just said Oldemeir, yes. I mean — does
7 she have — well, yes, she does. And her middle
8 name — oh, yes. Her middle name is Waltraud,
9 W-a-l-t-r-a-u-d.
10 Q. What was the date of your marriage? Men
11 always screw this one up.
12 A. I hope she doesn't read this. September the
13 17th, 1957.
14 Q. For the record, your wife responded to that
15 question quite quickly.
16 Have you ever had any marriages other than
17 this one, sir?
18 A. No.
19 Q. Do you have any children?
20 A. No.
21 Q. What is your social security number?
22 A. 311-24-4945.
23 Q. What is your driver’s license number,
24 please.
25 A. I don't know.
8

1 Q. Do you have your driver’s license with you?
2 A. I hope so. Yeah. D0061255, California.
3 Q. And when does that expire, sir?
4 A. 7-17-01. My God, that’s next month.
5 Q. Now, we already stated your home address is
6 the Quail Ridge property, correct?
7 A. Yes.
8 Q. Do you own that home?
9 A. No.
10 Q. Do you rent it?
11 A. Yes.
12 Q. Would you mind explaining your rental
13 arrangement.
14 A. It is owned by a corporation, in spite of
15 what Judge Maino believes.
16 Q. Is that corporation the Herford Corporation?
17 A. That’s correct. Which we transferred the
18 stock to my wife’s nephew more than ten years ago
19 and — as an estate planning and we pay the — all the
20 expenses including the taxes. So that’s the rent.
21 Q. So you pretty much have a life estate in
22 it --
23 A. That’s correct.
24 Q. — and the remainder would go to the nephew?
25 A. That’s correct.
9

1 Q. Would you please state your nephew’s name
2 for the record and spell it.
3 A. His name is Hans Dirk — D-i-r-k --
4 Oldemeir.
5 Q. And when did you initially purchase the
6 Quail Ridge property?
7 A. Back in 1979.
8 Q. And you've lived at that residence
9 consecutively since that time?
10 A. Yes.
11 Q. What was the purchase price of the
12 residence?
13 A. $300,000.
14 Q. And what is your estimate of the current
15 value of the residence?
16 A. Oh, probably around 600.
17 Q. And when you say 600, you mean $600,000?
18 A. I'm sorry?
19 Q. When you say 600, you do mean 600,000?
20 A. Yes.
21 Q. Have you made any improvements to that home
22 since the time of its purchase?
23 A. Oh, yes.
24 Q. What have you had done to it, sir?
25 A. We had a new deck put on it and she’s always
10

1 fixing things on it indoors and stuff.
2 Q. Any additions made to the house?
3 A. No new additions.
4 Q. Have you had any appraisals completed on the
5 residence within the last five years?
6 A. No.
7 Q. Are you aware of any homes which recently
8 sold in your neighborhood and how much they may have
9 been sold for?
10 A. No.
11 Q. How many square feet are in your current
12 home?
13 A. I think it’s 1,800.
14 Q. And how many rooms does it have?
15 A. Three bedrooms, two baths, living room,
16 dining room, kitchen.
17 Q. And out of those three bedrooms, is one of
18 those your home office, sir?
19 A. I have an office downstairs.
20 Q. That’s separate from the three bedrooms?
21 A. Yes — yes.
22 Q. And does your wife have an office?
23 A. She has a desk there in a little side room.
24 Q. Would that side room be separate from any of
25 the rooms we discussed, living room, three bedrooms or
11

1 your office?
2 A. Well, it’s connected on the same floor.
3 It’s connected to the living room.
4 Q. So it’s part of the living room, the little
5 room off of it?
6 A. Yes.
7 Q. Are there any mortgages on that home?
8 A. No.
9 Q. And are there any liens other than ours on
10 that home?
11 A. No.
12 Q. When I say ours, I mean the plaintiff LSF,
13 okay?
14 A. Yes.
15 Q. Do you have a homestead filed on that
16 residence?
17 A. Yes.
18 Q. And when was that homestead filed?
19 A. I really don't remember. A few years ago.
20 Q. Do you believe it was during the time of
21 this litigation?
22 A. I believe it was.
23 Q. Do you have any tenants in your residence?
24 A. No.
25 Q. So you're not accepting rent from any
12

1 person?
2 A. No.
3 Q. Do you run any businesses out of your
4 residence?
5 A. I have an office.
6 Q. And out of that office would you run the
7 business of, I believe, Liberty Lobby on the West
8 Coast?
9 A. Well, I am the West Coast representative.
10 I'm the executive publisher of the Spotlight and I'm
11 the publisher of The Barnes Review.
12 Q. Do you have any other corporations or
13 institutions or foundations that you work out of your
14 home for?
15 A. No — well, yes. The Barnes Review is
16 published by another corporation, a separate
17 corporation, The Foundation for Economic Liberty, Inc.
18 Q. Okay. And The Foundation for Economic
19 Liberty, Inc., is that also situated in the
20 300 Independence Avenue building in Washington D.C.?
21 A. Yes. They have three rooms upstairs on the
22 third floor.
23 Q. What other corporations or foundations or
24 business entities are housed within the
25 300 Independence building?
13

1 A. Well, there’s the Government Education
2 Foundation.
3 Q. Do you work for that?
4 A. It’s a — well, work for it. I don't
5 receive any salary, no.
6 Q. Do you do volunteer work, any type of work
7 for it whatsoever?
8 A. Yes.
9 Q. And what is your position with them?
10 A. Volunteer.
11 Q. How many volunteers or employees does the
12 Government Education Foundation have?
13 A. The work — the Government Education Fund
14 has no direct employees.
15 Q. So would they all be volunteers?
16 A. The work that is done for maintaining the
17 Government Education Foundation is offset on the books
18 for the fair value, but there’s no registration with
19 the IRS or there’s no — and there’s no official
20 employees.
21 Q. Is the Government Education Foundation a
22 subsidiary of Liberty Lobby?
23 A. No.
24 Q. Is it related to Liberty Lobby in any way?
25 A. How do you mean related?
14

1 Q. Do they have contracts or agreements with
2 one another, like do the workers of Liberty Lobby
3 perform the work of the education foundation?
4 A. Yes. There is a melding of personnel to
5 attain the greatest efficiency so that — some people
6 do work for both corporations, which is offset on the
7 books --
8 Q. Okay.
9 A. — by the controller of Liberty Lobby
10 Mr. Hutzel, H-u-t-z-e-l.
11 Q. Now, you said the Government Education
12 Foundation is a corporation?
13 A. Yes.
14 Q. Is that a for-profit corporation?
15 A. No.
16 Q. Is it tax exempt as a nonprofit
17 organization?
18 A. No.
19 Q. Does it have officers and directors?
20 A. Yes.
21 Q. Who would the officers be?
22 A. I frankly don't remember.
23 Q. Are you an officer, sir?
24 A. No.
25 Q. Are you a director?
15

1 A. No.
2 Q. Do you know who any of the directors are?
3 A. Yes.
4 Q. Who are the directors, sir?
5 A. Okay. I believe — I believe that
6 Mr. George Kadar — K-a-d-a-r — is a director.
7 Q. Anybody else that you know of, sir?
8 A. I would have to review that. I really
9 don't — I have to ask Mr. Kadar. I don't recall any
10 other names at this time.
11 Q. And do you personally do any work for the
12 education foundation?
13 A. Yes.
14 Q. What do you do for them, sir?
15 A. Well, I am their representative on the West
16 Coast when they need a representative, and I am a
17 fund-raiser for them.
18 Q. Do they solicit funds separate and apart
19 from Liberty Lobby?
20 A. Oh, yes.
21 Q. And do they have their own publication?
22 A. No.
23 Q. What is the type of work that the Government
24 Education Foundation does?
25 A. It has sponsored seminars relating to
16

1 government education and politics and the influence of
2 government.
3 Q. Does it do anything other than conduct
4 seminars?
5 A. It — well, I guess you could call it a
6 rental agency. It rents furniture and equipment to
7 Liberty Lobby and other corporations.
8 Q. Do you know who was the person who started
9 up the Government Education Foundation?
10 A. I can't remember.
11 Q. Were you part of the start-up of it?
12 A. I cannot remember who the director — who
13 the incorporators were. It was incorporated years ago
14 under the District of Columbia nonprofit corporation
15 laws.
16 Q. Do you believe that you were one of the
17 incorporators, sir?
18 A. I'm sorry. I cannot remember. I don't
19 think so.
20 Q. Okay. You had stated that part of what it
21 does is rents furniture to Liberty Lobby and other
22 corporations. Do you know where the initial start-up
23 monies came for this corporation to have bought the
24 furniture that it rents out?
25 A. I can't say. That’s a question you have to
17

1 ask the accountant.
2 Q. Who is the accountant for the foundation?
3 A. Mr. Hutzel.
4 Q. Is Mr. Hutzel also the accountant for
5 Liberty Lobby?
6 A. Yes — for what?
7 Q. Liberty Lobby.
8 A. Yes.
9 Q. And as I understand, he’s also an officer
10 and director, so he would be maintained within that
11 same building, 300 Independence Avenue?
12 A. An officer and director of what?
13 Q. Liberty Lobby.
14 A. No.
15 Q. I'm sorry. Did you testify earlier that he
16 was in some way involved with Liberty Lobby?
17 A. Yes. He’s an employee and he is the
18 controller.
19 Q. What is his position there?
20 A. Controller. He handles the books.
21 Q. That’s what I needed to know. So he would
22 be the bookkeeper or accountant?
23 A. He is — yes.
24 Q. Who is the president of Liberty Lobby?
25 A. We have no president.
18

1 Q. Do you have a CEO?
2 A. A CEO?
3 Q. Uh-huh.
4 A. That’s me.
5 Q. Do you have any other positions with Liberty
6 Lobby?
7 A. Well, I'm treasurer.
8 Q. And what are your job duties with Liberty
9 Lobby?
10 A. CEO. I run it.
11 Q. In its entirety, correct?
12 A. Well, no, that’s not correct. We have
13 employees.
14 Q. No. But, sir, you said that you first ran
15 the West Coast section of it. You also run the East
16 Coast division of the --
17 A. Well, yeah. When I'm there I have the
18 authority, yes.
19 Q. Were you one of the incorporators of Liberty
20 Lobby?
21 A. Yes.
22 Q. We had talked about the foundation and
23 Liberty Lobby. What other organizations are maintained
24 within the 300 Independence building?
25 A. There is The Foundation for Defense of the
19

1 First Amendment.
2 Q. Any others?
3 A. I can't think of any others.
4 Q. Foundation for Defense of First Amendment is
5 what type of business entity, is that a corporation?
6 A. Yes.
7 Q. Is that a for-profit corporation?
8 A. No.
9 Q. Is it tax exempt?
10 A. Yes.
11 Q. Do you hold any position with The Foundation
12 for Defense of the First Amendment?
13 A. No.
14 Q. Do you do any jobs for this at all,
15 volunteer work or otherwise?
16 A. Yes.
17 Q. And what do you do for The Foundation for
18 Defense?
19 A. Fund-raise.
20 Q. Does The Foundation for Defense have any of
21 its own employees?
22 A. Its situation is analogous to that of the
23 Government Education Foundation. The clerical and
24 other work that is performed by people are — the
25 compensation is offset on the books. In other words,
20

1 Liberty Lobby does more or less what some employment
2 companies do that literally employ personnel, which are
3 then directed by the client, which means that the
4 client then does not have to keep any records of
5 employment and taxes and deductions, and so on and so
6 forth, and then the client pays to the employment
7 agency a fee based on the amount of work that’s done by
8 the employment agency, which pays for all of the
9 salaries and deductions, plus a fee for the service.
10 Q. So both The Foundation for Defense and The
11 Foundation for Economic Liberty and the Government
12 Education Foundation, none of those have their own
13 employees separate and apart from Liberty Lobby
14 employees; is that correct?
15 A. That’s correct.
16 Q. Do you know whether you were the
17 incorporator of The Foundation for Defense of the First
18 Amendment?
19 A. I was not.
20 Q. Let’s get back to those a little later.
21 Do you drive a car, sir?
22 A. Yes.
23 Q. And what is the year, make and model of that
24 car?
25 A. It is a Chevrolet Monte Carlo, 1995, I
21

1 think.
2 Q. Do you own this car?
3 A. No.
4 Q. Who is the owner of the car?
5 A. The Government Education Foundation.
6 Q. What is your arrangement with them for your
7 use of this car?
8 A. Well, it’s provided as a perk.
9 Q. For the work that you do for them, correct,
10 sir?
11 A. Correct.
12 Q. Do you know if the Government Education
13 Foundation provides a car for any other employee or
14 volunteer?
15 A. Well, I think the car Elisabeth drives is
16 also a GEF vehicle and I believe that the pickup truck
17 in Washington is also owned by the GEF.
18 Q. Who drives the pickup truck in Washington?
19 A. Usually Steve Lombardo.
20 Q. Do you use that truck when you're in town?
21 A. No.
22 Q. Do you drive when you're in Washington D.C.?
23 A. No.
24 Q. So you don't keep a vehicle there, correct?
25 A. Right.
22

1 Q. Do you have to pay any type of rent or lease
2 on this car to the government?
3 A. To the government?
4 Q. Government Education Foundation. I'm sorry.
5 A. That, again, is all taken care of by
6 Mr. Hutzel who handles the books and has done so for
7 over 20 years.
8 Q. Do you have automobile insurance?
9 A. Me?
10 Q. On this car.
11 A. On the vehicle in Washington?
12 Q. No. The Monte Carlo.
13 A. Yes.
14 Q. And who is your carrier?
15 A. I think it’s Farmers.
16 Q. Do you pay for your own insurance?
17 A. Oh, no.
18 Q. That’s also picked up by the Government
19 Education Foundation?
20 A. Certainly. It’s their car.
21 Q. Do they pay for gas?
22 A. Yes.
23 Q. Do they give you an actual credit card to
24 pay for gas?
25 A. No.
23

1 Q. Do they reimburse you for any cash laid out?
2 A. Yes.
3 Q. Do you happen to know what the policy number
4 or annual premium is for the insurance on that car?
5 A. No.
6 Q. That, again, would be a record maintained by
7 Mr. Hutzel?
8 A. Yes.
9 Q. And who pays the insurance on the
10 automobile, is it actually the Government Education
11 Foundation or would it be Liberty Lobby reimbursing
12 them?
13 A. Well, I would suppose it’s GEF --
14 MR. URTNOWSKI: Mr. Carto, she doesn't want your
15 supposition. She wants your knowledge.
16 THE WITNESS: I don't know.
17 BY MS. ARONSON:
18 Q. Let me say, I don't want you guessing;
19 however, if you have a best estimate and you think it's
20 right, but you're just not 100 percent positive, I
21 think I am entitled to that.
22 So do you think that Liberty Lobby pays the
23 Government Education Foundation for the use of this car
24 and its insurance?
25 A. I don't know. But the policy is to — that
24

1 the corporations pay their expenses.
2 Q. You said that the Government Education
3 Foundation also owns the car driven by your wife,
4 correct?
5 A. I believe so.
6 Q. And what type of car is that, sir?
7 A. That’s a Cadillac.
8 Q. Do you know what year that is?
9 A. 1991 with 300,000 miles.
10 Q. Do you have any other vehicles other than
11 those two that we've just mentioned, the Cadillac and
12 the Monte Carlo?
13 A. No.
14 Q. Are there any lienholders, that you know of,
15 on these automobiles?
16 A. No.
17 Q. Do you know how much the Cadillac is worth
18 today?
19 A. It was — I remember it was purchased for
20 $30,000 ten years ago. I have no idea what it’s worth
21 today.
22 Q. And what about the Monte Carlo?
23 A. Same. I mean it was purchased for less, of
24 course, but I don't know what it’s worth. I have no
25 idea.
25

1 Q. You haven't recently tried to sell either of
2 these cars, correct?
3 A. No.
4 Q. So you would have no idea what their present
5 value would be?
6 A. Right.
7 Q. You had said the pickup truck in
8 Washington D.C., that is not a truck that you
9 personally drive?
10 A. Well, if — I can drive it. I have a
11 driver’s license and — but I normally don't — there's
12 no reason for me to drive it.
13 Q. In the past year have you ever driven the
14 vehicle?
15 A. Yes.
16 Q. How many times approximately have you driven
17 the vehicle in the past year?
18 A. Maybe five.
19 Q. Where are the car keys kept for that
20 vehicle?
21 A. In Washington?
22 Q. Uh-huh.
23 A. Well, they are in the building.
24 Q. But do you carry a set on your personal key
25 chain?
26

1 A. Oh, no.
2 Q. I'm trying just to identify whether or not
3 this is a vehicle for your use or for any employees at
4 Liberty Lobby or is it somebody’s main vehicle.
5 A. Well, you have to understand that any
6 business needs a vehicle to pick up things, deliver
7 things around town in Virginia and Maryland.
8 Q. Is there any one person that uses this
9 vehicle as their personal vehicle?
10 A. Oh, no. Absolutely not.
11 Q. And you have no commercial vehicles,
12 correct?
13 A. No. Correct.
14 Q. Other than the property that we spoke of at
15 Quail Ridge — now, I know you don't say you own it and
16 Judge Maino says you did. So we're not going to
17 discuss that property anymore — do you own any other
18 real property in the state of California?
19 A. No.
20 Q. Do you own any other real property anywhere
21 in the world?
22 A. No.
23 Q. And that includes land or condominiums,
24 correct?
25 A. Correct.
27

1 Q. Do you own any purchase options on any real
2 property?
3 A. No.
4 Q. Do you own any time-shares?
5 A. No.
6 Q. Do you own any jewelry valued above the
7 price of $500?
8 A. Well, let me see. Maybe this.
9 Q. And what is this, sir?
10 A. It’s a wrist watch.
11 Q. For the record, I'm looking at an Amstar
12 wrist watch with a broken crystal so everybody knows
13 that I didn't do that, and it appears to have a brown
14 leather wrist band.
15 How old is this watch, sir?
16 A. About ten years old.
17 Q. And where did you purchase it?
18 A. A drug store.
19 Q. What was the purchase price, sir?
20 A. $8.88.
21 Q. Chances are pretty good it’s not worth more
22 than $500 or more?
23 A. Sometimes watches appreciate in value. I'm
24 not an expert, so I wouldn't know.
25 Q. Have you ever had it appraised, sir?
28

1 A. No.
2 Q. Let the record reflect it’s also been placed
3 back in Mr. Carto’s pocket.
4 Do you own any other jewelry, sir?
5 A. Yes.
6 Q. And what would that be?
7 A. I have a ring.
8 Q. And what type of ring is it, sir?
9 A. It’s got a simulated ruby stone.
10 Q. When you say simulated ruby stone, do we
11 mean it’s a piece of glass?
12 A. Yes.
13 Q. Is it set in gold?
14 A. No.
15 Q. Do you know what its setting is?
16 A. I have no idea.
17 Q. And where did you get this ring from, sir?
18 A. I was given it for my birthday about 50
19 years ago from my mother.
20 Q. Do you know what its value is presently?
21 A. No.
22 Q. Do you believe its value to be presently
23 above $500?
24 A. No.
25 Q. Do you believe you have any other jewelry
29

1 that might be valued above $500?
2 A. No.
3 Q. Do you own any antiques that might be valued
4 above $500?
5 A. No.
6 Q. Do you own any collections that might be
7 valued above $500, that includes stamp collections,
8 baseball card collections, anything of that nature?
9 A. No.
10 Q. Do you own any art in excess of $500?
11 A. No.
12 Q. No paintings, no sculptures?
13 A. I have paintings --
14 Q. Before you answer, again, I'm asking about
15 paintings that would valued above $500.
16 A. No.
17 Q. How about sculptures?
18 A. No.
19 Q. Any other piece of art that might be valued
20 above $500?
21 A. No.
22 Q. Do you have any musical instruments that
23 might be valued above $500?
24 A. No.
25 Q. Have you pawned any personal property within
30

1 the last five years?
2 A. No.
3 Q. Do you have any insurance to cover your
4 personal property such as renters insurance or
5 homeowners insurance?
6 A. I believe that the policy we have covers
7 things like that, homeowners policy, yeah.
8 Q. And who is the homeowners policy with?
9 A. The man’s name is Bob Brown in Escondido.
10 Q. That would be your agent?
11 A. Yes.
12 Q. Do you know if it’s with Farmers or
13 State Farm or --
14 A. No.
15 Q. Where is the policy presently located?
16 A. The policy?
17 Q. Uh-huh.
18 A. Well, it’s in — somewhere at home. I guess
19 probably my wife has it.
20 Q. I believe that was one of the documents that
21 we asked to be produced. Do you know whether that
22 document has been produced?
23 MR. URTNOWSKI: We went over it with Mrs. Carto.
24 MS. ARONSON: That’s what I thought. And that's
25 the same policy we're discussing today, correct?
31

1 MR. URTNOWSKI: I believe so.
2 Any other policy other than the one
3 Mrs. Carto would have had?
4 THE WITNESS: No.
5 BY MS. ARONSON:
6 Q. Do you know whether you scheduled any
7 personal property on this insurance policy?
8 A. I'm sorry?
9 Q. Did you schedule any personal property on
10 this insurance policy such as --
11 A. You mean list?
12 Q. Yes.
13 A. I don't think so.
14 Q. Are you currently purchasing any property on
15 an installment plan?
16 A. No.
17 Q. Do you have a will, sir?
18 A. Yes.
19 Q. Who are your beneficiaries?
20 A. My wife.
21 Q. Who has possession of your will?
22 A. I do.
23 Q. Do you have any interest in any trusts?
24 A. No.
25 Q. Do you have any stock?
32

1 A. No.
2 Q. Do you have any bonds?
3 A. No.
4 Q. Do you have any securities?
5 A. Stocks and bonds are securities, aren't
6 they?
7 Q. Yes, but there’s other forms of securities.
8 A. No, I don't have anything.
9 Q. Have you made any assignments of any assets
10 whatsoever within the last five years?
11 A. No.
12 Q. Do you belong to any clubs, sir?
13 A. Well, I'm a member of the National Rifle
14 Association and I'm a member of the board of policy of
15 Liberty Lobby, and I think that’s it.
16 Q. Do you belong to any country clubs?
17 A. No.
18 Q. Do you own any boats?
19 A. No.
20 Q. Do you own any other form of water vehicle?
21 A. No.
22 Q. Do you own any motorcycles?
23 A. No.
24 Q. Any motorized vehicles of any type?
25 A. No.
33

1 Q. Do you have any interest in any warehouse
2 receipt?
3 A. No.
4 Q. Do you have any storage facility?
5 A. Any storage facility?
6 Q. Correct.
7 A. No.
8 Q. Do you have any interest in any bills of
9 lading?
10 A. No.
11 Q. Do you have any other documents the title of
12 which you own interest?
13 A. No.
14 Q. Do you have any interest in the estate of
15 someone who is deceased?
16 A. No.
17 Q. Are you planning on inheriting any money or
18 other assets within the next five years?
19 A. No. I'll ask the Angel of Death.
20 Q. A lot of times these things get caught up in
21 probate for five years, believe it or not, but as far
22 as you know, there’s no estate in probate right now of
23 which you are a beneficiary, correct?
24 A. Correct.
25 Q. Do you have any interest in any wills?
34

1 A. Any wills?
2 Q. Uh-huh.
3 A. No, I don't think so.
4 Q. Are you the beneficiary of any trust?
5 A. No.
6 Q. Have you made any gifts to any persons
7 within the last five years valued in excess of $2,500?
8 A. No.
9 Q. And, again, when you said that you had given
10 the property at Quail Ridge to I believe --
11 A. Yeah. But you said five years, right?
12 Q. That’s what I'm asking.
13 A. It was before. It was longer than five
14 years ago.
15 Q. Thank you. Do you have any bank accounts,
16 sir?
17 A. Yes.
18 Q. And where are those located?
19 A. The Fidelity Federal Bank in Costa Mesa.
20 Q. Is that a checking account?
21 A. Yes.
22 Q. Do you have a savings account there?
23 A. No.
24 Q. Do you have a savings account anywhere?
25 A. No.
35

1 Q. Is that the only bank account that you have,
2 sir?
3 A. Yes.
4 Q. Do you have any deposit accounts with any
5 financial institutions?
6 A. No.
7 Q. Okay. The account we just discussed at
8 Fidelity, how much money is in that account?
9 A. I believe you have it there at your left --
10 Q. Is this the most recent — let’s just
11 check — this goes up to May 2001. So we're just a
12 month or two behind, and it has here listed a balance
13 of approximately 1,700. Do you know if that's
14 approximately the balance that’s kept in that account
15 at this time?
16 A. I have no idea. I mean I haven't received
17 the latest statement. I'm sure Mr. Lennon has it. Why
18 don't you ask him?
19 Q. Because it’s not his judgment debtor's
20 examination, sir. I have to ask you these questions.
21 As far as you know, is this an approximate
22 amount that you would generally keep in this account?
23 A. Yes.
24 Q. Do you have a safe deposit box, sir?
25 A. No.
36

1 Q. Do you have any letters of credit?
2 A. No.
3 Q. Do you have a line --
4 A. Incidentally, the money in that account is
5 derived wholly and exclusively and solely from my
6 social security and my veteran’s benefits and it cannot
7 be touched lawfully.
8 Q. I didn't say whether we were going to touch
9 it, sir. I'm just asking --
10 A. I want to put that on the record.
11 Q. You're more than welcome to put it on the
12 record. I'm not here today to go in and take your
13 veteran’s pay. That’s not what I'm here for.
14 A. I'm sure you're not.
15 Q. Do you have a line of credit, sir?
16 A. No.
17 Q. Do you have any other bank accounts in the
18 state of California?
19 A. No.
20 Q. Do you have any other bank accounts anywhere
21 in the world including foreign countries?
22 A. No.
23 Q. Do you have any retirement funds, sir?
24 A. No.
25 Q. You don't have an IRA or --
37

1 A. Well, I have — Liberty Lobby has a
2 retirement program. I've been with them long enough to
3 be a beneficiary.
4 Q. Do you know presently how much you have in
5 that IRA?
6 A. I really don't have any idea.
7 Q. Do you get quarterly statements?
8 A. No.
9 Q. Do you get any kind of statements regarding
10 your IRA?
11 A. No.
12 Q. Do you have any other accounts with any
13 other financial institutions that we've not already
14 discussed?
15 A. No.
16 Q. Are you a signatory on any other account
17 anywhere in the world?
18 A. Yes.
19 Q. What accounts would those be, sir?
20 A. Liberty Lobby, I'm treasurer, and I can't
21 think of any other.
22 Q. What about the three foundations we
23 discussed earlier, do they have accounts of their own?
24 A. Yes, of course.
25 Q. Would you be signatory on those accounts.
38

1 A. No. Separate corporations, I have nothing
2 to do with them.
3 Q. But you would not write checks on their
4 behalf, correct?
5 A. No.
6 Q. Liberty Lobby, where do they keep their bank
7 account?
8 A. At the National Capital Bank.
9 Q. Would that be a checking account, sir?
10 A. Yes.
11 Q. Do you know whether it’s only one account?
12 A. Yes.
13 Q. They don't maintain separate accounts for
14 payroll versus checking --
15 A. Yes, they do.
16 Q. So there would be more than one account
17 number?
18 A. Yes.
19 Q. How many accounts do they maintain, sir?
20 A. Well, I'm not sure. There’s the operating
21 account, there’s the payroll account, and then
22 there’s — yeah, there’s a refund account, and there's
23 a Spotlight account, and there’s others. I have no
24 list.
25 Q. And all of those accounts, sir, would be
39

1 kept at the National Capital Bank in Washington D.C.?
2 A. Yes.
3 Q. It would have no accounts outside of the
4 national bank, correct?
5 A. No, that’s not correct. There is another
6 account in Dothan, Alabama.
7 Q. I'm sorry. Where in Alabama?
8 A. Dothan.
9 Q. Would you mind spelling that for the record.
10 A. D-o-t-h-a-n.
11 Q. Do they have an office in Dothan, Alabama,
12 sir?
13 A. Oh, no.
14 Q. What type of account is kept in Dothan,
15 Alabama?
16 A. Checking.
17 Q. And what is the purpose of having an account
18 in Alabama, sir?
19 A. It’s sort of vestigial. We just have had it
20 for many, many years because the owner of that bank at
21 one time was very prominent with Liberty Lobby, and
22 it’s a very modest amount kept there.
23 Q. Do you have any relatives that live in
24 Alabama, sir?
25 A. No.
40

1 Q. Other than your wife, who are your immediate
2 relatives?
3 A. No — what’s the question?
4 Q. Other than your wife Elisabeth, who are your
5 immediate relatives?
6 A. My brother.
7 Q. You have one brother, sir?
8 A. Yes.
9 Q. What is his name?
10 A. David.
11 Q. David Carto?
12 A. Uh-huh, yes.
13 Q. And where does he reside, sir?
14 A. Mansfield, Ohio.
15 Q. What is his profession, sir?
16 A. He is a — the owner of a ski run in
17 Mansfield.
18 Q. There’s ski runs in Mansfield?
19 Is he in the banking profession, sir?
20 A. No.
21 Q. Do you maintain any accounts with your
22 brother, David Carto?
23 A. No.
24 Q. Are you signatory on any accounts of your
25 brothers?
41

1 A. No.
2 Q. Do you have any accounts in Mansfield, Ohio
3 or Ohio?
4 A. No.
5 Q. Other than the account at Liberty Lobby, are
6 you a signatory on any other party’s accounts?
7 A. No.
8 Q. Do you have the power of attorney for any
9 other account?
10 A. No.
11 Q. Do you have the power to sign checks or
12 instruments on any other account?
13 A. Not that I can think of.
14 Q. Do you have any credit lines?
15 A. No.
16 Q. Do you have any credit cards?
17 A. Yes.
18 Q. What credit cards do you have, sir?
19 A. Visa.
20 Q. Do you have that with you today?
21 A. No.
22 Q. Do you have any other credit cards?
23 A. Well, no.
24 Q. Do you have use of any other credit cards,
25 sir?
42

1 A. Yes.
2 Q. And what would that be?
3 A. A Texaco credit card.
4 Q. And would that be the education foundation's
5 card?
6 A. No. I think that’s in the name of Liberty
7 Lobby.
8 Q. And that’s how you put gas in the Monte
9 Carlo automobile we discussed?
10 A. Sometimes.
11 MS. ARONSON: Why don't we go off the record for
12 a second.
13 (Discussion off the record.)
14 BY MS. ARONSON:
15 Q. Are you a shareholder in any corporation?
16 A. No.
17 Q. Do you own any copyrights?
18 A. No.
19 Q. Do you own any trademarks?
20 A. No.
21 Q. Do you own any patent rights?
22 A. No.
23 Q. Who is your accountant?
24 A. Blayne Hutzel, B-l-a-y-n-e.
25 MR. URTNOWSKI: Ms. Aronson, I think you need to
43

1 be more specific with that question as to who the
2 accountant is.
3 MS. ARONSON: I was going to be because I
4 believe Elisabeth has already answered these questions.
5 I'm assuming that they would share the --
6 THE WITNESS: Excuse me. I have no personal
7 accountant.
8 BY MS. ARONSON:
9 Q. Do you prepare taxes, sir?
10 A. No.
11 Q. And how long has it been since you've not
12 prepared taxes?
13 A. Many, many, many years.
14 Q. Would it be over 20?
15 A. Yes.
16 Q. Have you used any personal accountants in
17 the last five years?
18 A. No.
19 Q. Where do you maintain your personal
20 financial records?
21 A. Well, you have them. They are in the other
22 room. You've got them right there.
23 Q. So your answer would be your home in
24 Quail Ridge?
25 A. Yes.
44

1 Q. Do you have any health insurance, sir?
2 A. Yes. Liberty Lobby has health insurance.
3 Q. Do you know what company that’s with?
4 A. I do not.
5 Q. Good for you. That means you don't use it
6 much.
7 A. Right.
8 Q. Do you have any disability insurance?
9 A. Well, just from the government, veterans.
10 MR. URTNOWSKI: Not disability pay. Disability
11 insurance.
12 MS. ARONSON: Correct.
13 MR. URTNOWSKI: Do you understand the
14 distinction?
15 THE WITNESS: Well, I guess it’s included with
16 what we have at Liberty Lobby. I don't pay attention
17 to things like that.
18 BY MS. ARONSON:
19 Q. Do you have any life insurance policy, sir?
20 A. Yes.
21 Q. Would that also be with Liberty Lobby?
22 A. Yes.
23 Q. Please describe the insurance.
24 A. Describe it?
25 Q. Uh-huh.
45

1 A. As I remember, it’s for $10,000. All
2 employees have insurance, life insurance.
3 Q. Does that policy have any cash value, that
4 you know of?
5 A. Not that I'm aware of.
6 Q. Other than homeowners insurance, you have no
7 property insurance, correct?
8 A. Correct.
9 Q. And the homeowners insurance, that would
10 include the fire insurance or anything else against
11 your home, correct?
12 A. Correct.
13 Q. Do you have any loans out against any of
14 your insurance policies?
15 A. At one — no, I don't. No, I don't.
16 Q. You were about to say at one time — did you
17 at one time have a loan against your insurance policy?
18 A. Yes.
19 Q. Which policy would that have been, sir?
20 A. My Government National Service life
21 insurance.
22 Q. Does that have a cash value now presently?
23 A. I believe so.
24 Q. Do you know what that cash value would be,
25 sir?
46

1 A. I have no idea.
2 Q. Have you made any claims on any insurance
3 companies within the last five years?
4 A. I can't remember that I have.
5 Q. As far as you can recall, the answer is no,
6 sir?
7 A. The answer is no, as far as I can recall.
8 Q. And you maintain your insurance policies at
9 your home at Quail Ridge, correct?
10 A. Well, we pay the bill. What do you mean
11 maintain?
12 Q. The records are maintained at the
13 Quail Ridge property?
14 A. Well, yes, of course.
15 Q. Are any of your insurance policies
16 transferable?
17 A. I don't think so.
18 Q. And other than that one that we just
19 discussed, do any of your insurance policies have a
20 cash-out value?
21 A. I don't think so.
22 Q. Now, we've already said you are employed by
23 Liberty Lobby, correct?
24 A. Correct.
25 Q. Do you own this company?
47

1 A. Pardon?
2 Q. Do you own this company?
3 A. No. Liberty Lobby is a nonprofit
4 corporation.
5 Q. What is your job description other than CEO?
6 A. Well, as I said, I'm treasurer, I'm
7 executive publisher of the Spotlight, weekly newspaper.
8 That’s why I'm late.
9 Q. Anything else, sir?
10 A. No.
11 Q. Fund-raiser?
12 A. Well, yes, fund-raiser of course.
13 Q. Do you hold any professional licenses?
14 A. No.
15 Q. And we've already said Liberty Lobby is a
16 corporation, correct?
17 A. Correct.
18 Q. Who are the principals of Liberty Lobby?
19 A. Vince Ryan is chairman, Tom Valentine is
20 secretary. All this is on your records. You have all
21 this.
22 Q. I understand, sir.
23 A. And then vice chairman is — I think Tom is
24 vice chairman as well, and then there’s members of the
25 board.
48

1 Q. Are you a member of the board?
2 A. Of course.
3 Q. And who else would be a member of the board?
4 A. You mean in addition to the ones I just
5 named?
6 Q. Yes.
7 A. It’s all in your records. I'm sure you have
8 a better recollection than I. Carl Hottelet,
9 Kirkpatrick Dilling, Howard Carson, Olive Snead. She's
10 secretary, Olive is secretary. That’s all I can
11 recall.
12 Q. Now, Olive Snead is secretary, you are the
13 treasurer. Who are the other officers of the
14 corporation?
15 A. Well, to repeat myself, Vince Ryan is
16 chairman and Tom Valentine is vice chairman.
17 Q. And is this a public or a private
18 corporation?
19 A. It’s a nonprofit corporation.
20 Q. It actually has exempt status?
21 A. No. You've asked me that. The answer is
22 no.
23 Q. Who is the agent for service of process of
24 the corporation?
25 A. Well, of course any of the directors, I
49

1 suppose.
2 Q. You don't know if one individual has been
3 assigned that duty?
4 A. No.
5 Q. And there are no shareholders?
6 A. Correct.
7 Q. When we say it’s nonprofit, do any of the
8 people we have mentioned as the officers and principals
9 of the corporation accept any money as salary or
10 compensation?
11 A. Yes.
12 Q. And who would that be?
13 A. Vince Ryan, who is also editor — editor --
14 I think editor emeritus of the Spotlight. He works at
15 the office.
16 Q. Do you know how much his salary is, sir?
17 A. Well, not offhand. I think he gets around
18 30,000, something like that.
19 Q. When you say 30,000, a year, correct?
20 A. Yes.
21 Q. Anybody else that you know of a salaried
22 employee?
23 A. Well, myself.
24 Q. Do you receive a salary, sir?
25 A. Yes.
50

1 Q. What is your salary?
2 A. A dollar a year.
3 Q. Do you have any other bonuses, commissions
4 or compensation from Liberty Lobby?
5 A. No.
6 Q. Is there anybody else who is a salaried
7 employee that you know of who would be a director or
8 officer of the corporation?
9 A. No.
10 Q. So everybody else would be a volunteer,
11 correct?
12 A. Yes.
13 Q. What is the primary purpose of Liberty
14 Lobby?
15 A. Precisely as its name implies.
16 Q. Which is?
17 A. It lobbies.
18 Q. Does it actually employ lobbyists in
19 Washington D.C.?
20 A. When — when — except when our money is
21 drained off by parasites and lawyers.
22 Q. Mr. Urtnowski and I will take no offense.
23 MR. URTNOWSKI: At least you distinguished the
24 two.
25 MS. ARONSON: Yes. Most people would classify
51

1 us as parasites and say no more.
2 MR. URTNOWSKI: It would have been redundant,
3 Mr. Carto.
4 BY MS. ARONSON:
5 Q. Does Liberty Lobby do anything other than
6 lobby?
7 A. Yes.
8 Q. What else does it do?
9 A. Publishes the newspaper.
10 Q. And that’s the Spotlight, correct?
11 A. Yes.
12 Q. Does it do anything else?
13 A. No.
14 Q. Does it conduct seminars or --
15 A. Well, yes. Yes. Once in a while we do have
16 seminars around the country or in Washington.
17 Q. Any other purpose that you can think of?
18 A. No.
19 Q. Does Liberty Lobby use any other fictitious
20 name?
21 A. No.
22 Q. Does it have any dba's?
23 A. No, not that I can think of.
24 Q. Would the Spotlight be considered a dba of
25 Liberty Lobby?
52

1 A. No. Well, I don't know. That’s a legal
2 question. I can't answer that. Spotlight is owned by
3 Liberty Lobby.
4 Q. In its entirety, correct?
5 A. Correct.
6 Q. Does Liberty Lobby own anything other than
7 the Spotlight?
8 A. Yes.
9 Q. What else does it own?
10 A. Bank accounts.
11 Q. I'm sorry. When I said does it own
12 anything, does it own anything else that would be
13 classified as another business?
14 A. No.
15 Q. It has no subsidiaries, correct?
16 A. Correct.
17 Q. And, again, we've discussed the bank
18 accounts, they are all maintained either in Washington
19 D.C. at National Capital or that one small account that
20 I believe was --
21 A. Dothan, Alabama.
22 Q. There we go. Alabama?
23 A. Nice little town.
24 Q. No other accounts, sir?
25 A. Right. Correct.
53

1 Q. Does Liberty Lobby have a line of credit?
2 A. No.
3 Q. Does it have a KEOGH plan or an IRA plan?
4 A. You mean for the employees?
5 Q. Correct.
6 A. I believe so. You'll have to check with
7 Mr. Hutzel.
8 Q. As bookkeeper and accountant, he would be
9 aware of all the financials of Liberty Lobby?
10 A. Yes.
11 Q. Does Liberty Lobby have any interest in
12 joint ventures?
13 A. No.
14 Q. Does it have any interest in any
15 partnerships?
16 A. No.
17 Q. Does it have any other interest in any other
18 business entity including the three foundations we
19 discussed earlier?
20 A. No.
21 Q. Now, we said its address is 300 Independence
22 Avenue, correct?
23 A. Yes.
24 Q. Does it have any other branch offices?
25 A. Well, yes. You could say the one that's
54

1 been comped by Lennon at P.O. Box 28802, San Diego,
2 92198.
3 Q. That was a post office box you were using as
4 its West Coast branch, correct?
5 A. Yes. West Coast headquarters, yes.
6 Q. Any other addresses, sir?
7 A. No.
8 Q. So it only has the two offices, correct?
9 A. Correct.
10 Q. How many employees are with Liberty Lobby?
11 A. Right now it’s about — just a minute. Let
12 me think. 14.
13 Q. How many of those employees are salaried?
14 A. All of them. I guess it would be 15. Put
15 15, as far as I remember. I suppose I'm off a little
16 bit.
17 Q. I won't hold you to it, sir. It's
18 approximately 15?
19 A. Uh-huh.
20 Q. And you say all of them are salaried. Do
21 the majority of them receive a substantial salary or
22 are they salaried like you for a dollar a year?
23 A. No. They all get living wages except me.
24 Q. Other than these 15 employees, does Liberty
25 Lobby have volunteers?
55

1 A. Oh, sure.
2 Q. And how many, approximately, volunteers work
3 regularly out of Liberty Lobby?
4 A. We don't have any regular volunteers. It's
5 all part time when we need them.
6 Q. And you have regular people you would call
7 upon or is it just any given time different people
8 volunteer?
9 A. Both.
10 Q. Do you know what the monthly payroll is for
11 Liberty Lobby?
12 A. The monthly payroll?
13 Q. Correct.
14 A. I think it’s around 30,000.
15 Q. How many hours do you personally work
16 weekly, sir?
17 A. Well, about 80.
18 Q. Puts us to shame, doesn't it?
19 And other than the dollar that you receive
20 per year, do you receive any other type of financial
21 income from Liberty Lobby?
22 A. No.
23 Q. So no commissions or flat fees per job,
24 correct?
25 A. Right.
56

1 Q. Are you currently an officer of any other
2 business?
3 A. No.
4 Q. Are you currently a director of any other
5 business?
6 A. No.
7 Q. Are you currently a stockholder of any other
8 business?
9 A. No.
10 Q. What are the only sources of your income,
11 sir?
12 A. I sponge off my wife.
13 Q. I was talking more in the form of — you do
14 receive veteran’s pay, don't you?
15 A. Yes, I do get a veterans.
16 Q. How about social security?
17 A. No.
18 Q. Anything other than that and sponging off
19 your wife?
20 A. No.
21 Q. And the monies that you do receive, they all
22 go into this account which you produced at Fidelity
23 Federal Bank, correct?
24 A. Yes.
25 Q. Other than Blayne Hutzel, is there any
57

1 outside bookkeeper or accountant for Liberty Lobby?
2 A. Yes.
3 Q. And who would that be?
4 A. His name is Marlon Olson, M-a-r-l-o-n,
5 O-l-s-o-n, I think.
6 Q. And does he work with a firm?
7 A. Yes.
8 Q. What’s the firm name?
9 A. I think that’s the firm name.
10 Q. And is he located in Washington D.C.?
11 A. No.
12 Q. Where is he located, sir?
13 A. Maryland.
14 Q. Do you know what the town is in Maryland?
15 A. No.
16 Q. Is he a CPA?
17 A. Yes.
18 Q. And does he do their yearly taxes?
19 A. Yes.
20 Q. You wouldn't happen to know his address or
21 telephone number, would you?
22 A. No.
23 Q. Where are Liberty Lobby business records
24 maintained?
25 A. In Washington D.C.
58

1 Q. Do you maintain any at your residence at
2 Quail Ridge?
3 A. No.
4 Q. Do you have any part-time businesses, sir?
5 A. No.
6 Q. Have you ever provided consulting services
7 on a fee basis?
8 A. No.
9 Q. Have you ever owned any business in the past
10 five years?
11 A. Owned any business in the past five years?
12 Q. Correct.
13 A. No.
14 Q. Have you transferred any businesses in the
15 past ten years?
16 A. I can't think of any.
17 Q. Well, perhaps the Herford Corporation, but
18 that wasn't a business, correct?
19 A. The what?
20 Q. Herford Corporation.
21 A. That’s not a business. That was just a
22 holding company — it is just a holding company.
23 Q. And how long have you worked for Liberty
24 Lobby?
25 A. Since 1955.
59

1 Q. Has that been your only occupation since
2 1955?
3 A. No.
4 Q. Who else have you worked for, sir?
5 A. Well, you switched the question. You said
6 is that my only occupation. No, it has not been my
7 only occupation. I've kept myself busy with many
8 things.
9 Q. What were your other occupations, sir? Let
10 me clarify for the record, when I say occupations, I
11 don't mean how you occupied your time. I mean
12 occupations in the sense of places you were employed.
13 A. The answer is no. I've just been employed
14 by Liberty Lobby for that time.
15 Q. Were you employed by anybody else but
16 Liberty Lobby during that time?
17 A. No.
18 Q. And have you ever received a salary other
19 than a dollar a year from Liberty Lobby?
20 A. No.
21 Q. So that’s been your salary since the day you
22 began working there in 1955, sir?
23 A. Yes.
24 Q. Is the actual address 300 Independence
25 Avenue?
60

1 A. Yes.
2 Q. But it’s my understanding there is another
3 address for that same building?
4 A. Yes.
5 Q. What is that address, sir?
6 A. 130 Third Street, Southeast.
7 Q. Now, is that the same building, just a
8 different entrance?
9 A. Yes.
10 Q. And the only person that handles payroll at
11 Liberty Lobby is Blayne Hutzel, correct?
12 A. Yes.
13 Q. Other than the sources of income we've
14 already discussed, do you have any other sources of
15 income?
16 A. No.
17 Q. Does Elisabeth Carto own any businesses?
18 A. No.
19 Q. Where is Elisabeth Carto employed?
20 A. By Liberty Lobby.
21 Q. Is she employed by anybody else other than
22 Liberty Lobby?
23 A. No.
24 Q. And her only income is derived from Liberty
25 Lobby?
61

1 A. Yes.
2 Q. What is her income, sir?
3 A. Well, I don't know. It’s around 30,000 a
4 year. It might be a little more.
5 Q. Do you receive any monies from your nephew?
6 A. No.
7 Q. Do you receive any monies from any other
8 third persons?
9 A. No.
10 Q. Does Elisabeth Carto have any other sources
11 of income not already identified?
12 A. Not that I know of.
13 Q. Does Liberty Lobby lease its building in
14 Washington D.C.?
15 A. Yes.
16 Q. Who does it lease it from?
17 A. The owner and I don't know the name. It's
18 a — these people bought it and then they sold it to
19 somebody else — I mean the man that bought it was
20 Fulton Brylawski — B-r-y-l-a-w-s-k-i — and then he
21 sold it and moved to Florida, and I don't know who the
22 owner is.
23 Q. The owner has no relation to Liberty Lobby
24 or any of its foundations?
25 A. Correct.
62

1 Q. And does each of the foundations and Liberty
2 Lobby pay separate rent to the same owner?
3 A. Yes.
4 Q. Do you know what the rent is that Liberty
5 Lobby pays?
6 A. I think it’s either 12 or 13,000 a month.
7 Q. Okay. Do you know how much the foundations
8 pay per month?
9 A. This is the entire rent. And how it's
10 divide up, I don't know, I don't have that.
11 Q. Does anybody else rent that building at
12 300 Independence Avenue other than the three
13 foundations and Liberty Lobby?
14 A. No.
15 Q. So it’s 12 to 13,000 a month for the entire
16 building, correct, sir?
17 A. Correct.
18 Q. Did Liberty Lobby or any other foundation
19 ever own that building?
20 A. Yes.
21 Q. And when was it sold, sir?
22 A. Well, it was sold about — it was sold ten
23 years ago, nine years ago.
24 Q. So approximately 1992?
25 A. Yes.
63

1 Q. And what was the sale price of that
2 building, sir?
3 A. I think it was — I think it was 950,000,
4 something like that. I could be wrong. I just don't
5 have a head for figures.
6 Q. All I can ask you for is your best estimate
7 today. So we're not going to hold you to that.
8 A. It was sold and we got the money.
9 Q. And when that building was sold, the
10 $950,000 would have been deposited in the bank account
11 for Liberty Lobby, correct?
12 A. You know, this is sort of — I can't — the
13 building could have been owned by the Government
14 Education Foundation and Liberty Lobby could have been
15 paying rent to them. And if so, then the money would
16 have gone to the GEF, but I can't relate the details of
17 this transaction.
18 Q. Were you personally involved in the
19 transaction?
20 A. Yes.
21 Q. And were you the actual person who went out
22 and obtained the buyer and entered into the sales
23 agreement?
24 A. I don't recall how the buyer was obtained.
25 It was — there was a Realtor involved.
64

1 Q. Would you have been the individual who would
2 have signed the sales contract on behalf of either
3 Liberty Lobby or the foundation?
4 A. I can't say. I can't remember.
5 Q. It’s possible, though?
6 A. I was involved in the negotiations and I
7 signed the papers for Liberty Lobby when necessary.
8 Q. Would you have had any reason to sign on
9 behalf of the foundation?
10 A. I couldn't. I have no authority with the
11 foundation.
12 Q. So if it turns out it belonged to the
13 foundation, you probably didn't sign a sales contract.
14 But if it was Liberty Lobby, you probably did, correct?
15 A. Correct.
16 Q. Who would have had authority for the
17 foundation back then?
18 A. Well, it would have been an officer and I
19 just don't recall.
20 Q. Have you made any loans to anyone, sir?
21 A. Me personally?
22 Q. Yes.
23 A. When?
24 Q. Within the last ten years.
25 A. I'm sure I have.
65

1 Q. Any of a substantial nature, $5,000 or more?
2 A. No.
3 Q. Does anybody presently owe you money?
4 A. Owe me money? I don't think anybody owes me
5 money.
6 Q. Does anybody presently owe your wife any
7 money?
8 A. I don't know.
9 Q. Not that you know of?
10 A. Not that I know of.
11 Q. Do you own any interest in any promissory
12 notes?
13 A. No.
14 Q. Do you own any interest in any bills of
15 exchange?
16 A. No.
17 Q. Do you own any interest in any commercial
18 paper whatsoever?
19 A. No. I think we've gone over that before.
20 Q. I'm sure we have, sir.
21 Do you have any judgments in which you are a
22 judgment creditor?
23 A. No.
24 Q. Do you presently have any pending litigation
25 in which you are a plaintiff?
66

1 A. Me personally?
2 Q. Yes.
3 A. Well, there’s that Texas case, but I guess
4 we had to throw that out.
5 Q. I’m sorry. When you say that Texas case,
6 what are you referring to, sir?
7 A. That was the case of myself and Mrs. Furr as
8 incorporators of the legion against the — against the
9 conspirators who took it over.
10 Q. I don't mean to interrupt you, but why don't
11 we say do you have any litigation in which LSF is not
12 involved, any third-party litigations against somebody
13 separate and apart?
14 A. No. No, I do not.
15 Q. Unfortunately I'm quite aware of the
16 litigations that are occurring in this case.
17 You're not, as far as you know, a plaintiff
18 in any other case suing any other third party?
19 A. No, I can't think of anything.
20 Q. Have you taken any assignments of any
21 judgments?
22 A. No.
23 Q. Have you assigned any judgments to any third
24 parties?
25 A. No.
67

1 Q. Are you acting as the executor of any
2 estate?
3 A. I don't think so.
4 Q. Any income for the last five years would
5 have been $5, correct, sir?
6 A. I suppose. I don't fill out income tax so I
7 don't know.
8 Q. But other than the $5 and the veterans and
9 the social security, you don't earn any other income in
10 the past five years, correct?
11 A. I can't think of anything I do. I did have
12 some stock, but I think that’s been long gone.
13 Q. Do you know who your wife’s accountant is,
14 sir?
15 A. No.
16 Q. And you personally don't have a CPA,
17 correct?
18 A. Correct.
19 Q. Have you applied for any loans in the past
20 two years?
21 A. No.
22 Q. Have you filled out any financial
23 applications in the past five years?
24 A. No.
25 Q. Do you have any financial statements on your
68

1 assets that were prepared within the last five years?
2 A. No.
3 Q. Are you a defendant in any pending lawsuit
4 other than those involved with LSF?
5 A. I don't think so.
6 Q. Do you have a key chain with you, sir?
7 A. Yeah.
8 Q. Would you mind putting it out on the table.
9 On it are three keys, two of which appear to be a car
10 and one would be the key — this key, what would that
11 be the key to?
12 A. What’s the question?
13 Q. What would this key open?
14 A. That’s the house, front door.
15 Q. When we say the house, it’s Quail Ridge?
16 A. Yes.
17 Q. And this key, sir?
18 A. It’s the ignition key to the Monte Carlo.
19 Q. And that last GM key?
20 A. That’s to open the door.
21 Q. Do you have any other keys in your
22 possession, sir?
23 A. No.
24 Q. Would you mind taking out your wallet,
25 please. May I please take a look at it, sir. Sorry.
69

1 Let the record reflect he has $7 in his wallet, which I
2 am not taking --
3 A. Thank you.
4 MR. URTNOWSKI: Thanks, Liz. I'll get that.
5 MS. ARONSON: One of us parasites will.
6 And he has no credit cards other than a
7 calling card in his wallet.
8 Q. Thank you very much, sir.
9 Do you have any tax liens filed against you?
10 A. No.
11 Q. And you have no payments such as a mortgage,
12 rent or car payment, correct?
13 A. Correct.
14 Q. What is your monthly electric and gas
15 payment?
16 A. It’s about — it’s about $60. Now, the gas
17 is propane and we get that filled up once a year.
18 Q. And is that a large tank?
19 A. Well, it’s large enough.
20 Q. What would it cost to fill that per year?
21 A. Well, they put 100 gallons in and I think
22 it’s up to around $2 now, something like that.
23 Q. So about $200 per year?
24 A. Uh-huh.
25 Q. What is your monthly water payment, sir?
70

1 A. I think it’s around 50, $60.
2 Q. Per month?
3 A. Yes.
4 Q. What are your taxes per year?
5 A. The real estate taxes are about $4,000.
6 Q. So other than the propane, electric, water
7 payment and taxes per year, do you pay any other monies
8 towards the Quail Ridge property per year?
9 A. Well, yeah. We have to keep it clean. Once
10 in a while we have to hire somebody to do the work,
11 sweep the grass — leaves, stuff like that.
12 Q. But as far as you know, there’s no other
13 monthly expenditures, correct?
14 A. Well, electricity, gas, telephone, but
15 that’s different. Yeah.
16 Q. Have you made any assignment for the benefit
17 of your creditors?
18 A. No.
19 Q. Are you the co-banker on any loan?
20 A. The who?
21 Q. Co-banker on any loan?
22 A. No.
23 Q. Are you the guarantor on any loan?
24 A. No.
25 Q. Are you an endorser on any loan?
71

1 A. No.
2 Q. Do you have any other judgment creditors
3 other than LSF?
4 A. No.
5 Q. And you're not making payments to any other
6 creditors, sir?
7 A. That’s what I said.
8 Q. Now, I know that you just recently filed
9 bankruptcy, but do you plan on filing bankruptcy in the
10 near future?
11 A. If I can.
12 Q. So the answer would be yes?
13 A. Yes.
14 Q. Have you transferred any assets and payments
15 of debts within the last five years?
16 A. No.
17 Q. And the only obligations to other creditors
18 would be to us, correct?
19 A. Right.
20 Q. Do you have any other assets which we've not
21 already discussed?
22 A. No.
23 Q. How do you plan on paying the judgment
24 creditors in this action?
25 A. How do I plan on paying the judgment
72

1 creditors in this action?
2 Q. Uh-huh.
3 A. I can't say I do.
4 MS. ARONSON: Why don't you give me five minutes
5 to talk with Rick, who’s been reviewing those
6 documents. You guys take a break and we'll meet back
7 here in five, ten minutes.
8 (Recess.)
9 BY MS. ARONSON:
10 Q. Do you have any relationship with the
11 Liberty Trust Mint, sir?
12 A. With what?
13 Q. The Liberty Trust Mint?
14 A. Liberty Trust Mint?
15 Q. Yes.
16 A. Liberty Trust Mint is the name we give to
17 the producer of silver medallions.
18 Now give it back. I want all witnesses --
19 Q. Let the record reflect that Mr. Carto just
20 brought out what’s called a Liberty Lobby Silver Coin,
21 it seems to be dated 1999.
22 A. 1993.
23 Q. 1973?
24 A. 1973.
25 Q. Although it was actually minted in 1999.
73

1 A. No.
2 Q. Why does it say 999 on it?
3 MR. URTNOWSKI: That would be the fineness of
4 the silver.
5 THE WITNESS: 999 is the pureness of the silver.
6 BY MS. ARONSON:
7 Q. Pure silver. What do you think this thing
8 is worth?
9 MR. URTNOWSKI: Eight bucks.
10 THE WITNESS: Yeah. We're selling it. I think
11 the price is eight bucks.
12 MS. ARONSON: Let the record reflect I'm
13 returning the coin to Mr. Carto.
14 Q. And what is your relationship with the mint
15 that mints those coins, sir?
16 A. Okay. It’s a name. There is no mint.
17 Q. Is it a dba of Liberty Lobby?
18 A. I believe that’s how it would be described,
19 I suppose, yeah.
20 Q. I think I've asked you this already, but you
21 had answered no. Can you think of any other dba’s of
22 Liberty Lobby?
23 A. No.
24 Q. Are there any other type of businesses that
25 are outside of Liberty Lobby that do other things such
74

1 as produce counts or --
2 A. No. I can think of nothing else.
3 Q. And if the Liberty Trust Mint is just a dba
4 of Liberty Lobby, that would make you also the person
5 in control or who heads that company, correct?
6 A. That is correct.
7 Q. What is your relationship with Olive Snead?
8 A. Well, she is the secretary of the board of
9 directors.
10 Q. And have you had a personal relationship
11 with Ms. Snead, and I don't mean in any offensive
12 manner, sir?
13 A. I've known her for about 20 years.
14 Q. Did you know her outside of Liberty Lobby
15 prior to her becoming the secretary?
16 A. No.
17 Q. What is your relationship with Henry Fisher?
18 A. Well, I — nothing really. I haven't seen
19 or heard from him in months.
20 Q. When was the last time you heard from Henry
21 Fisher?
22 A. Could be as much as a year.
23 Q. Do you know where he presently resides?
24 A. I don't think anyone does.
25 Q. Do you have any way of contacting him, sir?
75

1 A. None whatsoever.
2 Q. What aliases does Henry Fisher use, that you
3 know of?
4 A. Burns, Dr. Burns.
5 Q. Is that the last name?
6 A. Dr. Burns, yeah.
7 Q. Does he use a first name with that?
8 A. I don't know.
9 Q. Do you know of any other aliases he might go
10 by?
11 A. No.
12 Q. And the last time you spoke with Henry
13 Fisher, did he get in contact with you?
14 A. He always gets in contact with me. He has
15 no telephone number.
16 Q. Was he in the United States?
17 A. I don't know.
18 Q. When he contacted you then, it was by phone?
19 A. Yes.
20 Q. When was the last time you actually
21 physically saw Mr. Fisher?
22 A. It must have been a couple years ago.
23 Q. During the course of the litigation in this
24 case?
25 A. Well, yes. The litigation was ongoing.
76

1 Q. Do you know where Mr. Fisher stayed when he
2 stayed in the United States?
3 A. Well, I know one place he stayed.
4 Q. And what was that, sir?
5 A. The house on — in San Marcos at --
6 Q. Do you know what the address of that house
7 is?
8 A. It’s Pine Heights Way, but I don't know the
9 address.
10 Q. Do you know if that address was owned by
11 Mr. Fisher?
12 A. If that address was — you mean the house?
13 Q. Yes, sir.
14 A. I don't know — I think it was in the name
15 of his mother-in-law.
16 Q. Do you know what his mother-in-law’s name
17 was?
18 A. Yes.
19 Q. And what is that, sir?
20 A. Magree — M-a-g-r-e-e — Dinnon --
21 D-i-n-n-o-n — Magree.
22 Q. Thank you. Do you know if she’s a
23 United States citizen?
24 A. I don't think so.
25 Q. Do you know what country she’s from?
77

1 A. Australia.
2 Q. Do you know if Mr. Fisher has a residence in
3 Australia?
4 A. I don't know.
5 Q. Have you been in any financial dealings with
6 Mr. Fisher since 1993?
7 A. Well, yes.
8 Q. Would you mind describing those, sir.
9 A. Well, he — he procured some microfilm from
10 a — from Moscow of documents that were taken by the
11 Red Army out of Berlin in the final days of the war,
12 and he sold it to me — or not to me, but he sold them
13 to another company and I arranged for the payment.
14 Q. How much was the payment, sir?
15 A. I'm not sure, but I think — I believe it
16 was — I believe it was $20,000.
17 Q. And how did you pay him?
18 A. Well, it was paid by — it was paid, I
19 think — the actual transaction, the money was from
20 Liberty Lobby, I believe.
21 Q. My question more is going towards whether
22 you paid him in cash, by wire transfer?
23 A. Wire transfer.
24 Q. And do you have the information as to where
25 you wired that money to?
78

1 A. No.
2 Q. Would that be part of Liberty Lobby's
3 records?
4 A. Yes.
5 Q. And when did that transaction take place,
6 sir?
7 A. About four or five years ago.
8 Q. Who controls The Foundation to Defend the
9 First Amendment?
10 A. Well, the chairman is James P. Tucker, and
11 the board of directors is — he’s a reporter — and the
12 board of directors is composed of other journalists.
13 Q. Do you have any relationship with it, sir?
14 A. No.
15 Q. How about who owns or controls The
16 Foundation for Economic Liberty?
17 A. I believe — I believe that Mr. Hutzel is
18 one of the directors and I don't know who the other
19 ones may be.
20 Q. Do you have any relationship with The
21 Foundation for Economic Liberty?
22 A. Well, in a sense I — they publish a
23 magazine and I'm listed as the publisher.
24 Q. Did we ever discuss that magazine, was that
25 The Barnes Review?
79

1 A. That is it.
2 Q. Who controls the Government Education
3 Foundation?
4 A. I believe I mentioned — I mentioned George
5 Kadar, didn't I? K-a-d-a-r.
6 Q. You may have. And he would be the CEO?
7 A. Sorry?
8 Q. He would be its chairman or CEO?
9 A. Yes.
10 Q. And what is your relationship with the
11 Government Education Foundation, if any?
12 A. I have none.
13 Q. Who controls or owns The Friends of Liberty
14 Lobby?
15 A. That is the — the chairman, the chairwoman
16 is — was Kathryn Dall — with a K — D-a-l-l — until
17 she passed away, and it is now Mrs. Joan Kahl, J-o-a-n,
18 K-a-h-l.
19 Q. Is that a corporation?
20 A. I'm not — I don't think that it is
21 incorporated in its own name.
22 Q. What would it be incorporated under?
23 A. Under another corporation that — and I
24 don't know the name of the other corporation.
25 Q. Were you one of the incorporators, sir?
80

1 A. No, I was not.
2 Q. Do you have any relationship with The
3 Friends of Liberty Lobby?
4 A. Well, I'm in touch with Mrs. Kahl, but I'm
5 not on the board of anything, no.
6 Q. Does it actually have its own board of
7 directors?
8 A. Yes.
9 Q. You said it was incorporated under another
10 corporation. Would it be one of the corporations we've
11 already mentioned such as one of the foundations?
12 A. No.
13 Q. It would be a separate corporation
14 altogether that was newly created, correct?
15 A. Correct.
16 Q. Who controls The Committee to Defend Liberty
17 Lobby?
18 A. The Committee to Defend Liberty Lobby, I
19 don't think, is extant anymore. I think the charter
20 expired and I don't know if The Committee to Defend
21 Liberty Lobby is active.
22 Q. So you think it’s out of existence?
23 A. Yes.
24 Q. Was it a corporation?
25 A. Yes.
81

1 Q. Who was in charge of it, as far as you know,
2 when it was still operating?
3 A. I was not on the board of directors.
4 Q. Were you involved in it in any way?
5 A. Yes. I raised money for it.
6 Q. Were you an officer or director or have any
7 other relationship --
8 A. No.
9 Q. Who owns or controls The Liberty Lifeline?
10 A. Liberty Lifeline Fund, that’s — that's
11 Elisabeth, my wife.
12 Q. And when you say she owns or controls it,
13 does that mean she’s the chairperson?
14 A. I frankly don't know. I suppose you asked
15 her these questions.
16 Q. What is Liberty Lifeline’s business purpose?
17 A. I have nothing to do with it.
18 Q. So you don't know its stated business
19 purpose?
20 A. No.
21 Q. Who owns or controls VIBET?
22 A. VIBET, V-I-B-E-T?
23 Q. Correct.
24 A. Well, that would be the — I suppose — I
25 don't even think it exists anymore, but it would have
82

1 been Mr. Foetisch, Patrick — F-o-e-t-i-s-c-h --
2 attorney in Switzerland.
3 Q. What was your relationship with VIBET?
4 A. Nothing.
5 Q. Was that corporation formed solely to get
6 the money from the Jean Farrell estate?
7 A. Yes.
8 Q. Did it have any other business purpose, as
9 far as you know?
10 A. As far as I know, that’s all. But I had no
11 control over it.
12 Q. Were you the initial incorporator of the
13 Herford Corporation?
14 A. The Herford Corporation is incorporated in
15 Panama.
16 Q. I understand that. Were you one of the
17 original incorporators of it?
18 A. No.
19 Q. It would have been incorporated by a
20 Panamanian business entity that would have been on your
21 behalf, though?
22 A. That’s correct. A firm of lawyers in Panama
23 City.
24 Q. Who owns or controls The Center for
25 Historical Review?
83

1 A. That’s a dba trade name for The Barnes
2 Review.
3 Q. So the answer would be the government
4 foundation, correct --
5 A. No.
6 Q. — the Government Education Foundation,
7 correct?
8 A. No. The Foundation for Economic Liberty.
9 Q. I'm sorry. You're right. I confuse these.
10 And it’s The Foundation of Economic Liberty
11 that owns and controls The Barnes Review?
12 A. That’s correct.
13 Q. Who controls The International Legion for
14 the Survival of Freedom?
15 A. Well, I don't think that’s extant.
16 Q. When it was in existence, who controlled the
17 International Legion for the Survival of Freedom?
18 A. It was controlled by the board of
19 directors — the legitimate board of directors for The
20 Legion for the Survival of Freedom.
21 Q. Would that be you, your wife, Lavonne Furr
22 and Louis Furr?
23 A. It would have been the Furrs and the rest of
24 the board of directors at that time.
25 Q. And your relationship to it?
84

1 A. I was — I was a business agent.
2 Q. As far as you know, that is no longer
3 operating, correct?
4 A. What?
5 Q. The International Legion for Survival of
6 Freedom is --
7 A. That’s correct.
8 Q. Is the NECA Corporation still in existence?
9 A. N-E-C-A?
10 Q. Correct.
11 A. No, not that I know of. I'm sure it’s not.
12 Q. And that corporation, again, was created by
13 Jean Farrell so she could bequeath money to The Legion
14 for Survival of Freedom, correct?
15 A. That is correct.
16 Q. And that was the only purpose that you knew
17 of that corporation?
18 A. Yes.
19 Q. Did you have any business relationship with
20 it?
21 A. No.
22 Q. You were not considered a director or an
23 officer or anything of that nature, correct?
24 A. As far as I know it’s defunct.
25 Q. Do you know who owns or controls Hill Top
85

1 Partners?
2 A. No.
3 Q. Have you ever heard of Hill Top Partners?
4 A. I don't think so.
5 Q. Do you know who owns or controls Resistance
6 Records?
7 A. Yes.
8 Q. And who is that, sir?
9 A. William Pierce.
10 Q. Do you have any relationship to Resistance
11 Records?
12 A. No.
13 Q. What is the business purpose of Resistance
14 Records?
15 A. I don't know. You have to ask Mr. Pierce.
16 He’s in West Virginia.
17 Q. How are you familiar with it?
18 A. Because there was a newspaper story about it
19 that might — that Ann Cronin told me about this
20 morning.
21 Q. And that’s your only understanding of this
22 corporation, as far as you know?
23 A. Well, at one time I had an interest in it or
24 I think it was liberty — I don't think I did
25 personally, but I think it was Liberty Lobby.
86

1 Q. What kind --
2 A. It was acquired by Dr. Pierce.
3 Q. And when you say at one time Liberty Lobby
4 had an interest in it, did at one time Liberty Lobby
5 own it?
6 A. That incident was a number of years ago and
7 it was — it was a deal that was put together by a guy
8 named Blodget, who is a thief and a crook, and he is
9 the one that arranged the thing, and he got me involved
10 in it because I was going to be able to use the mailing
11 list of the buyers.
12 Q. At one time in October of 1993 you had
13 written to Jean Farrell that you had clout with three
14 separate banks, one of these banks was in Washington
15 D.C., one was in Zurich, Switzerland, and one was in
16 Ohio. What bank in Washington D.C. would you have had
17 clout with?
18 A. Well, that was the National Capital Bank.
19 Q. And that would be through your accounts with
20 Liberty Lobby, correct?
21 A. Correct.
22 Q. What about in Zurich, Switzerland?
23 A. Well, that would have been the bank
24 Cantrede, C-a-n-t-r-e-d-e.
25 Q. And what kind of clout did you have with
87

1 that bank?
2 A. That’s where the funds were deposited from
3 the Farrell estate. You say I wrote to who?
4 Q. To Jean Farrell.
5 A. To Jean Farrell. Yeah, the funds were
6 deposited there.
7 Q. Did you have a connection with that bank
8 prior to the Jean Farrell funds being deposited there?
9 A. No.
10 Q. What about a bank in Ohio?
11 A. That was my — I think that was a bank that
12 my brother at the time was on the board of directors.
13 Q. So your brother was in the banking business
14 at least at one time?
15 A. No, he was not in the banking business.
16 Q. He was on the board of directors of a bank?
17 A. At one time he was on the board of directors
18 of a bank, yes.
19 Q. What bank would that have been, sir?
20 A. I don't even remember the name.
21 Q. Would it have been in Mansfield, Ohio?
22 A. Yes.
23 Q. What happened to the money that you invested
24 in gold stocks?
25 A. I have invested in gold stocks years and
88

1 years ago when I was under the impression that gold was
2 depressed in price, and I was what you might be able to
3 call a gold bug and I did have gold shares, American,
4 South African, and a couple of others, Home Stake, I
5 believe, and — but you may not know it, but gold is
6 dead. I'm no longer a gold bug. I sold those stocks
7 years ago — many years ago.
8 Q. When you sold them, how much were they
9 valued at?
10 A. I don't remember. I don't remember.
11 Q. Would it be above or below $10,000?
12 A. It would have been — it would have been in
13 that neighborhood, yeah. Probably above, but I don't
14 remember. I have no idea whether — whether — the
15 file has been destroyed.
16 Q. Do you recall what you did with the money,
17 the $10,000 or so that you received from the sale of
18 this?
19 A. Well, no. But I can tell you that I have no
20 compensating investments for that money. What happened
21 to it --
22 Q. Do you believe it’s been spent in the years
23 succeeding that?
24 A. Pardon?
25 Q. Has that money been spent in the years
89

1 succeeding it?
2 A. Yeah. That was quite a long time ago. That
3 was long before I knew Jean Farrell.
4 Q. You have a website www.williscarto.com,
5 correct?
6 A. Yes, I do.
7 Q. Do you have any other web sites?
8 A. Not me personally, no.
9 Q. I'm speaking of just you personally.
10 A. No.
11 Q. What is the log-in name and password to
12 www.williscarto.com?
13 A. Say it again.
14 Q. The log-in name?
15 A. I don't know.
16 Q. Do you personally retrieve e-mails and --
17 A. No. No.
18 Q. Who would have that information?
19 A. Well, my wife is involved in it. She would
20 have it.
21 Q. Have you ever filed a TDF90-22.1 form with
22 the Department of the Treasury?
23 A. What is it? I don't think so.
24 Q. That’s a report of a foreign bank and
25 financial account.
90

1 A. I don't remember.
2 Q. To your knowledge, is the answer no?
3 A. Yes.
4 Q. Have you given or caused to be given any
5 money to Louis and/or Lavonne Furr since 1993?
6 A. Yes. Yes. I had — I reimbursed him for a
7 check that was stolen by Mr. Lennon from them by the
8 United States mail.
9 Q. How much was that, sir?
10 A. It was a couple hundred bucks. And then
11 also I've paid for their legal expenses necessitated by
12 the vicious attack upon them, that sort of thing.
13 Q. Have you ever used the name Samuel Foner?
14 A. No.
15 Q. Have you ever used the name John Henry?
16 A. I don't think so.
17 Q. Have you ever used the name Sanford
18 Griffith?
19 A. No.
20 Q. Do you know anybody by the name of Sanford
21 Griffith?
22 A. Sanford Griffith is a — was an agent — an
23 operating agent for the Anti-Defamation League for many
24 years in New York, but he passed on to where people
25 like him usually go. As Ken Goth would say, he went to
91

1 the place the Lord hath prepared for him.
2 Q. Okay. We'll leave it at that.
3 Do you know whether or not Liberty Lobby
4 employees have ever been paid from The Friends of the
5 Liberty Lobby account?
6 A. No.
7 Q. As far as you know, the answer to that
8 question is no, correct?
9 A. Correct.
10 Q. Have you ever participated in discussions of
11 how to remove assets from Liberty Lobby so that LSF
12 would not be able to seize them?
13 A. I can't remember such a discussion.
14 Q. Have you ever used the name Laughton --
15 Verlin Laughton or Laughton Verlin?
16 A. No.
17 Q. Do you know anybody by that name?
18 A. No.
19 Q. Recently the receiver has intercepted mail
20 from TWA, which is a passenger receipt and itinerary
21 confirmation, and it’s in your name, however, the
22 passenger name is Mr. Verlin Laughton. Do you recall
23 purchasing a ticket for him on TWA?
24 A. Oh, yes. Yes. Yes. Yes. From Oklahoma
25 City.
92

1 Q. Sure. What would that have been for, sir?
2 A. That was for the conference that was held
3 last week. Mr. Laughton is a survivor of the Oklahoma
4 City bombing. He was in the building when it was
5 bombed by the federal government.
6 Q. And you personally paid for his plane
7 ticket?
8 A. Well, The Barns of Youth did. I put it on
9 my credit card and I'll be reimbursed for that.
10 Q. What credit card is that, sir, your Visa?
11 A. Yes.
12 Q. Okay. Just a few more questions. We're
13 almost out of here. I promise.
14 A. As a matter of fact, he’s written up
15 extensively in this issue of Spotlight that’s going to
16 press in two hours.
17 Q. The passport that you had turned in today
18 that we made copies of and returned to you, how old is
19 that passport?
20 A. Gosh, it ought to say.
21 Q. It says date of issuance was 1995. Is that
22 correct?
23 A. I guess so.
24 Q. And you haven't traveled out of the country
25 since 1995?
93

1 A. No.
2 Q. You're shaking your head. I need --
3 A. I said no three times.
4 Q. I'm sorry. I wanted to make sure it was
5 clear on the record.
6 One of the documents you produced was for a
7 checking account statement in your name in Mansfield,
8 Ohio. Do you recall having a bank account in
9 Mansfield, Ohio?
10 A. Many, many years.
11 Q. And that account is no longer in existence,
12 sir?
13 A. Right.
14 Q. Is this the bank that your brother was on
15 the board of directors of?
16 A. No. I think he was on the other bank.
17 Q. What made you have an account in Mansfield,
18 Ohio?
19 A. Because I lived there, for crying out loud.
20 Q. What years did you live there?
21 A. Pardon?
22 Q. What years did you live there?
23 A. From nineteen — well, actually that was my
24 residence when I was in the Army and in college, and
25 all that kind of stuff.
94

1 Q. For the last 20 years, have you lived
2 anywhere other than Mansfield, Ohio and San Diego — I
3 should say Escondido?
4 A. Yes.
5 Q. Where else?
6 A. San Francisco.
7 Q. Anywhere else?
8 A. No.
9 Q. When did you live in San Francisco, sir?
10 A. I don't know. It was about 1954 — no,
11 after that — until about 1960, something like that.
12 Q. Do you still maintain any accounts up in
13 San Francisco?
14 A. No.
15 Q. Do you have any property in San Francisco?
16 A. No.
17 Q. Did you live in San Francisco and then move
18 to Ohio or is it vice versa?
19 A. No.
20 Q. You lived in Ohio and then moved to
21 San Francisco?
22 A. As I say, Mansfield, Ohio has been my
23 residence. I was born and raised in Ft. Wayne,
24 Indiana; as I told you, I moved to Ohio and then I was
25 drafted into the United States Army. So I didn't live
95

1 in Mansfield, Ohio nor did I ever live there except for
2 just short periods of time between college, and that
3 sort of thing. So that was my residence address and so
4 I opened up a bank account there, perfectly normal.
5 Q. I wasn't implying it wasn't normal, sir.
6 I'm just trying to understand.
7 Was anybody else living in Mansfield, Ohio
8 other than your brother?
9 A. Well, yes.
10 Q. Was it your family’s residence, sir?
11 A. Yes.
12 Q. That’s all I'm trying to get on the record,
13 sir.
14 A. Okay.
15 Q. Do you ever pay monies to your brother David
16 Carto?
17 A. Yes.
18 Q. And what are those monies for, sir?
19 A. To pay him back for a loan.
20 Q. Okay. We'd asked you that earlier. Are you
21 still paying him back for a loan?
22 A. No.
23 Q. When did those payments stop, sir?
24 A. After I paid him off.
25 Q. When would that have been, approximately?
96

1 A. Six months ago.
2 Q. And how much would that loan have been for,
3 sir?
4 A. It was from my father, who was in the
5 hospital and had very expensive treatment, and of
6 course I was obligated to pay half of it. I didn't
7 have the money, my brother paid it, and so I had to
8 repay him about $20,000.
9 Q. And when did that loan first incur?
10 A. Before my father died.
11 Q. I'm sorry, sir. I don't know when your
12 father died.
13 A. Well, he died about a year and a half ago.
14 Q. The payments to David L. Carto appear to
15 have began in 1993, sir. Do you recall why you would
16 have been paying your brother since --
17 A. Dad was sick for a while.
18 Q. So the loan was actually incurred in 1993 --
19 A. See, it was payments. He was ill and
20 somebody — and he had doctors and hospital, and it
21 went on and on and on until finally he died.
22 Q. When did the first loan occur between your
23 brother and yourself?
24 A. You say it must have been 1993.
25 Q. And this would have only had to do with your
97

1 father’s illness, correct?
2 A. Correct.
3 Q. Does your brother currently keep any monies
4 for you, sir?
5 A. No.
6 Q. In April of 1999 you paid to the State of
7 Nevada, the Secretary of State, for a filing fee. Do
8 you recall what that filing fee was for, sir?
9 A. April of 1999, how much?
10 Q. It would have been for $100, which is the
11 normal filing fee for a corporation.
12 A. I think that was for — yeah, that was for a
13 corporation named Scholars Education Archives.
14 Q. Scholar Education Archives, is that a
15 corporation that is still in existence?
16 A. No.
17 Q. And what was the purpose of beginning that
18 corporation, sir?
19 A. To purchase these microfilms from Fisher.
20 Q. Have you started any other corporations
21 within the last five years?
22 A. I can't think of any.
23 Q. And was that its only purpose, sir, to
24 purchase this microfilm?
25 A. That’s correct.
98

1 Q. So would that refresh your memory to say
2 that the monies that were paid to Fisher didn't come
3 from Liberty Lobby, they perhaps came from this new
4 corporation?
5 A. That — yeah. I'm grateful to you for
6 pointing — I'd forgotten about that. So it was --
7 that’s correct. Liberty Lobby was not involved in that
8 thing.
9 Q. Would they have had its own bank account?
10 A. Scholar Education Fund?
11 Q. Yes, sir.
12 A. No, it didn't.
13 Q. Whose bank account would it have been wire
14 transferred from, the money?
15 A. The — the money was transferred from the
16 National Capital Bank by wire. That much I remember.
17 And the funds were — I think they were my funds. I
18 don't know where else it would have come from.
19 Q. Where would you have $20,000 in cash from,
20 sir, did you personally own $20,000 in cash in 1999?
21 A. I would have to research that. I don't
22 remember. I could go back and find out — have
23 Mr. Hutzel find the actual papers on that wire transfer
24 and I could trace it.
25 Q. Do you believe they came from your personal
99

1 funds?
2 A. I think so, yeah.
3 Q. Do you presently have $20,000 in personal
4 funds anywhere?
5 A. No.
6 Q. Do you have assets valued at $20,000
7 anywhere in the world?
8 A. No.
9 Q. Do you know who Laughlin & Associates are?
10 A. That is a firm in Reno or Carson City that
11 sets up corporations and they set up the Scholars
12 Educational Archives.
13 Q. Would any mail, then, for the Scholars been
14 addressed to the Laughlin & Associates, would they have
15 been their mail forwarding service?
16 A. They were the registered agents of the
17 corporation.
18 Q. Okay. Thank you. I think that might do us.
19 Just a few more questions.
20 Do you recall Sun Radio, sir?
21 A. I certainly do.
22 Q. And who owned Sun Radio?
23 A. No one.
24 Q. Was it its own corporation?
25 A. Sorry?
100

1 Q. Was it its own corporation?
2 A. Did you say who owns or who owned?
3 Q. Owned?
4 A. Owned.
5 Q. Yes. Past tense, sir.
6 A. It was — Sun Radio Corporation was a stock
7 corporation and it was owned by Liberty Lobby.
8 Q. Did Liberty Lobby own all of the shares to
9 Sun Corporation?
10 A. No. There were some shares that were owned
11 by — as I remember, by a fellow by the name of Larry
12 Wyman, W-y-m-a-n.
13 Q. Does he have any relationship to Liberty
14 Lobby?
15 A. No.
16 Q. Did you own any shares, sir?
17 A. No — I don't remember. I don't think so.
18 Q. Do you know whether or not Sun Radio was
19 sold to Sound Communications?
20 A. Yes.
21 Q. And who owned or controlled Sound
22 Communications?
23 A. No one.
24 Q. In the past tense, owned.
25 A. Basically the same people that owned Sun.
101

1 Q. So they would have been subsidiaries, both
2 of them, of Liberty Lobby?
3 A. Well, Liberty Lobby controlled it actually
4 through the money that was lent to it by Liberty Lobby.
5 Q. What was the purpose — business purpose of
6 selling Sun Radio to Sound Communications if they were
7 both corporations controlled by the same Liberty Lobby?
8 A. I don't remember why. There was a good
9 reason. Kayla, Incorporated — K-a-y-l-a — was the
10 initial owner of Sun and then Sun was incorporated as a
11 separate corporation. Then it was — then Sound
12 Communications was incorporated and Sun became Sound.
13 And just why that was done, I don't know why — I don't
14 remember why, but there was a good reason for it.
15 Q. Did you own any shares of Sound
16 Communications?
17 A. No, I don't think so.
18 Q. The money that came from the Jean Farrell
19 estate, how was that disbursed, sir?
20 A. It went to Sun — Sound.
21 Q. Did all of the money that you received from
22 the Switzerland accounts go to Sun or Sound?
23 A. 100 percent of it and a lot more besides.
24 Q. Where would the documents be that would
25 evidence that, sir?
102

1 A. I just gave you a huge box of stuff.
2 Q. Would all of those documents — just for the
3 record, an LSF representative has reviewed those
4 records and we've been unable to find any documentation
5 regarding transfers of monies, and that’s what we're
6 basically looking for.
7 A. Well, the transfers of money of course are
8 in Washington. The money was transmitted from the bank
9 Cantrede to Liberty Lobby and then from Liberty Lobby
10 it all went to Sun. That’s where the money went.
11 Q. Liberty Lobby’s financial records and
12 banking records would reflect that all the monies from
13 the Jean Farrell estate went from Liberty Lobby to Sun
14 or Sound, correct?
15 A. Precisely. I'm glad you finally asked that
16 question. Because these turkeys have been hounding me
17 about that for six or seven years and not having the
18 intelligence enough to ask that question.
19 Q. Well, that’s why they pay us the big bucks,
20 Mr. Carto.
21 I have no further questions. Is there
22 anything you want to state for the record?
23 MR. URTNOWSKI: Just that we delivered documents
24 today pursuant to the request. They have been reviewed
25 by Mr. Greg Raven — let’s go off the record for a
103

1 second.
2 (Discussion off the record.)
3 MR. URTNOWSKI: Back on the record. We just had
4 an off-the-record discussion that the documents that we
5 produced today are going to be left in the custody of
6 Sampson & Associates. They will send them out for
7 copying and have the documents delivered to my office.
8 And with respect to the documents of
9 Mrs. Carto, my office has had those copied. They are
10 supposed to be done around the noon hour today. I've
11 arranged for them to be transmitted here along with an
12 invoice.
13 MS. ARONSON: I appreciate that. Also one more
14 thing for the record. What about your documents under
15 your subpoena?
16 MR. URTNOWSKI: My documents are being
17 collected. They will be produced as soon as we have
18 them.
19 MS. ARONSON: We appreciate that very much.
20 Yes, Mr. Carto?
21 MR. URTNOWSKI: I don't want you to say
22 anything. I don't want you to volunteer anything
23 without speaking with me.
24 MS. ARONSON: Why don't we go off the record and
25 why don't you tell anything that you were about to
104

1 raise your hand and say to your attorney, and that way
2 he can okay it before it goes on the record. How's
3 that?
4 (Mr. Urtnowski and the witness leave the
5 deposition.)
6 MS. ARONSON: The originals come to us because
7 it’s a debtor’s examination.
8 (Mr. Urtnowski and the witness return to the
9 deposition.)
10 MR. URTNOWSKI: We have nothing further.
11 MS. ARONSON: I was, for the record, relieving
12 the court reporter of her statutory duties and stating
13 that the originals come to us because it’s a debtor's
14 examination. There’s no need for it to go to you for
15 signing or anything of that nature because it’s a
16 debtor’s exam.
17 MR. URTNOWSKI: And the last time I ordered a
18 copy, I will this time, too.
19 (The deposition was concluded at 12:30 p.m.)
105