24 November 2001
Source: Digital files from Court Reporter Julaine V. Ryen, Western District of Washington, Tacoma, WA. Telephone: (253) 593-6591

This is Day 4 of the testimony.

See other testimony: http://cryptome.org/usa-v-jdb-dt.htm


 
 
                                                                         471
 
 
 
           1                   UNITED STATES DISTRICT COURT
                              WESTERN DISTRICT OF WASHINGTON
           2                            AT TACOMA
 
           3
 
           4  UNITED STATES OF AMERICA,    )  Docket No. CR00-5731JET
                                           )  Court of Appeals No. 01-30303-00
           5              Plaintiff,       )
                                           )
           6          v.                   )
                                           )  Tacoma, Washington
           7  JAMES DALTON BELL,           )  April 6, 2001
                                           )
           8              Defendant.       )
                                           )
           9
 
          10                              VOLUME 4
                                     TRANSCRIPT OF TRIAL
          11                 BEFORE THE HONORABLE JACK E. TANNER
                       SENIOR UNITED STATES DISTRICT JUDGE, and a Jury
          12
 
          13  APPEARANCES:
 
          14  For the Plaintiff:            ROBB LONDON
                                            Assistant United States Attorney
          15                                601 Union Street, Suite 5100
                                            Seattle, Washington  98101
          16
              For the Defendant:            ROBERT M. LEEN
          17                                Attorney At Law
                                            Two Union Square
          18                                601 Union Street, Suite 4610
                                            Seattle, Washington  98101-3903
          19
 
          20
 
          21  Court Reporter:               Julaine V. Ryen
                                            Post Office Box 885
          22                                Tacoma, Washington 98401-0885
                                            (253) 593-6591
          23
 
          24
              Proceedings recorded by mechanical stenography, transcript
          25  produced by Reporter on computer.
 
 
 
 
 
                                                                         472
 
 
 
           1                              I N D E X
 
           2                                                   Page
 
           3  VOLUME 4                                      471 -  649
 
           4
              WITNESSES ON BEHALF OF PLAINTIFF:
           5
                  JEFFREY GORDON
           6           Direct (Continuing)  ..........   474
                       Cross  ........................   504
           7           Redirect  .....................   517
 
           8      JEFFREY GORDON (Recalled)
                       Direct  .......................   520
           9
              Plaintiff Rests  ...............................    522
          10
              WITNESSES ON BEHALF OF DEFENDANT:
          11
                  JAMES D. BELL
          12           Direct  .......................   541
 
          13
              MOTIONS:
          14
              Defendant's Motion for a Verdict of Acquittal
          15  Pursuant to Rule 29 ............................    523
                 As to Count 1  ..............................    524
          16           Denied  ...............................    525/534
                  As to Count 2  .............................    525
          17           Denied  ...............................    525/534
                 As to Count 3  ..............................    525
          18           Denied  ...............................    526/534
                  As to Count 4  .............................    527
          19           Denied  ...............................    534
                 As to Count 5  ..............................    528
          20           Denied  ...............................    534
 
          21  Defendant's Motion For a Mistrial Renewed ......    529
 
          22
 
          23  EXHIBITS             Admitted
 
          24    116                   477
                119                   478
          25    127                   486
 
 
 
 
 
                                                                         473
 
 
 
           1                              I N D E X
 
           2  EXHIBITS             Admitted
 
           3    130                   540
                132                   540
           4    134                   540
                135                   540
           5    140                   478
                151                   479
           6    155                   479
                157                   480
           7    162                   480
                170                   482
           8    184                   485
                235                   494
           9    236                   494
                237                   494
          10
                A-1                   592
          11    A-3                   594
                A-4                   598
          12    A-5                   598
 
          13
 
          14
 
          15
 
          16
 
          17
 
          18
 
          19
 
          20
 
          21
 
          22
 
          23
 
          24
 
          25
 
 
 
 
 
                                                                         474
 
 
 
           1      (Defendant present.)
 
           2                           MORNING SESSION
 
           3      (Jury not present.)
 
           4           THE COURT:  Are we ready?  Anything before the jury?
 
           5           MR. LEEN:  No, sir.
 
           6           MR. LONDON:  Actually, Your Honor, we are prepared now
 
           7  to file the redacted version of Exhibit 51, so I can hand that
 
           8  up.
 
           9           THE CLERK:  Thank you.
 
          10           MR. LEEN:  Your Honor, may I indicate for the record,
 
          11  while I object to the exhibit in its entirety, this is the --
 
          12  the government allowed me to make suggestions of redactions.  We
 
          13  still object to the exhibit, but I think at least this comports
 
          14  with what the government felt was relevant about the exhibit.
 
          15           THE COURT:  All right.
 
          16      Bring the jury.
 
          17      (Jury present; 9:40 a.m.)
 
          18           THE COURT:  Let the record reflect the jury has
 
          19  returned.  Good morning.
 
          20      (Jury responds good morning.)
 
          21           THE COURT:  The witness is on the stand.  The witness
 
          22  is still under oath.  Redirect -- I'm sorry, direct.
 
          23                   DIRECT EXAMINATION (Continuing)
 
          24  BY MR. LONDON:
 
          25  Q.  Agent Gordon, when we were going through your testimony
 
 
 
 
 
                                                                         475
 
 
 
           1  yesterday before the break, I believe we, in terms of the
 
           2  chronology of the timeline things, had gotten up to what you
 
           3  were observing on the Internet and in other respects about Mr.
 
           4  Bell's -- some of Mr. Bell's communications and his conduct,
 
           5  through pretty much, I think, the end of the summer.  I want to
 
           6  turn your attention to Exhibit 116, an email dated September 15,
 
           7  2000, to the Cypherpunks.  Did you observe that on the Internet
 
           8  on or about September 15th?
 
           9  A.  Yes, I did.
 
          10  Q.  All right.  And did you notice something about Agent McNall
 
          11  in that email?
 
          12  A.  Yes, I did.
 
          13  Q.  What did you notice about that email that caught your
 
          14  attention?
 
          15  A.  On the third page, it mentioned that he thought that ATF
 
          16  Agent, or BATF Agent Mike McNall would -- he thought it was
 
          17  Agent Mike McNall who did the deal with Lund to have him
 
          18  assaulted.
 
          19  Q.  What did you make of that?  I mean, did it make any sense to
 
          20  you?
 
          21  A.  Well, I understood what he was at least claiming.  It
 
          22  certainly -- and that he was apparently doing more research.
 
          23  But, no, I mean, it certainly wasn't true, and --
 
          24  Q.  But had you prior to this ever heard Mr. Bell's allegation
 
          25  that he had been beaten up by someone at SeaTac named Ryan Lund
 
 
 
 
 
                                                                         476
 
 
 
           1  and that this had been done at the behest of the government to
 
           2  try to coerce him into taking a plea in 1997?
 
           3  A.  Yeah.  I heard that allegation before.  I think it had come
 
           4  up during his probation violation hearings, and I had seen other
 
           5  information relating to that purporting to be from him on the
 
           6  Internet.  But this was the first time that I had seen the name
 
           7  or even -- ever heard of Mike McNall.
 
           8  Q.  All right.  Now, when you say you saw Exhibit 116 on the
 
           9  Internet, was that on a place on the Internet that is a public
 
          10  site that anyone can access if they simply enter the email
 
          11  address for that website?
 
          12  A.  This was on the Cypherpunks list which is public, and the
 
          13  Cypherpunks list actually can be seen in several -- there's
 
          14  several different ways you can see or get the Cypherpunks list.
 
          15  One way is to have it come and sent to you as email, and in this
 
          16  case, that's what I do.  I set up a separate mailbox, an email
 
          17  address, to receive the Cypherpunks list.  But the Cypherpunks
 
          18  list also gets publicly posted to a web page, which they call
 
          19  the archive, or several web pages that have it so that if you
 
          20  don't want to set it up and have it emailed to you, you can just
 
          21  go to the web page and look at the various emails on that web
 
          22  page.  So there's different places you can see it.  In this
 
          23  case, when I got it initially, I saw it as receiving it as
 
          24  email.
 
          25  Q.  But in any respect or in any manner, were you monitoring any
 
 
 
 
 
                                                                         477
 
 
 
           1  kind of private email between Mr. Bell and anybody else,
 
           2  anything that wasn't -- that he wasn't publicly posting to the
 
           3  email?
 
           4  A.  No.
 
           5           MR. LONDON:  We offer Exhibit 116.
 
           6           MR. LEEN:  No objection.
 
           7           THE COURT:  It's admitted.
 
           8      (Exhibit No. 116 was admitted.)
 
           9  Q.  (By Mr. London)  Now, around about October 10th, did you
 
          10  also observe another email publicly posted on the Internet?
 
          11      Exhibit No. 119, I draw your attention to that.
 
          12  A.  Yes.  I don't remember the exact date that I saw it, but 119
 
          13  is my printout that I make.
 
          14  Q.  And what did you notice about 119 that caught your
 
          15  attention?
 
          16  A.  This is just publicly posted to the Usenet portion of the
 
          17  Internet and so it's publicly available.  It's like a bulletin
 
          18  board that anybody can go see it.  And this is one where he just
 
          19  discuss -- just says, "Please consider my essay, 'Assassination
 
          20  Politics,'" and gives the web page -- one of the web pages where
 
          21  that's located as it is.  And he mentions, "you need to read my
 
          22  idea of a solution to the problem."  So it was just another
 
          23  evidence, to me, anyway, that he was still, as of October 10th,
 
          24  2000, advocating Assassination Politics.
 
          25           MR. LONDON:  I offer 119.
 
 
 
 
 
                                                                         478
 
 
 
           1           MR. LEEN:  No objection.
 
           2           THE COURT:  119 is admitted.
 
           3      (Exhibit No. 119 was admitted.)
 
           4  Q.  (Mr. London)  All right.  Now, that one was dated October
 
           5  10th.  A few days later, on October 24th, did you see a message
 
           6  posted on the Internet with the header, "Say Goodnight to
 
           7  Joshua"?
 
           8  A.  Again, I'm not sure the exact date I saw it, but, yes, I did
 
           9  see a -- that message.
 
          10  Q.  Was that message dated October 24th?  If you will look at
 
          11  Exhibit 140.
 
          12  A.  Yes.  This is my printout that I made.
 
          13  Q.  All right.
 
          14           MR. LONDON:  We offer 140.
 
          15           MR. LEEN:  No objection.
 
          16           THE COURT:  140 is admitted.
 
          17      (Exhibit No. 140 was admitted.)
 
          18  Q.  (By Mr. London)  Now, I believe yesterday you did testify
 
          19  that you had already observed some publicly available Internet
 
          20  correspondence between Mr. Bell and John Young or via the
 
          21  Cypherpunks list about a Mr. Mueller and a CIA Intelink in
 
          22  Oregon.  Specifically, which exhibits did you download that
 
          23  included the references to Mr. Mueller in Oregon?  I will ask
 
          24  you to start with 151.
 
          25  A.  151 is an exhibit that I received and downloaded relating to
 
 
 
 
 
                                                                         479
 
 
 
           1  that.
 
           2  Q.  That was 151?
 
           3           MR. LONDON:  I will offer 151.
 
           4  A.  Yes, that was 151.
 
           5           THE COURT:  Are you offering 151?
 
           6           MR. LONDON:  Yes, Your Honor.
 
           7           MR. LEEN:  No objection.
 
           8           THE COURT:  151 is admitted.
 
           9      (Exhibit No. 151 was admitted.)
 
          10  Q.  (By Mr. London)  Will you turn to 155?
 
          11  A.  Yes.  This is also one of the emails that I downloaded from
 
          12  the Internet.
 
          13  Q.  What does it describe?
 
          14  A.  This is again CIA in Oregon.
 
          15  Q.  Does it mention Mr. Mueller?
 
          16  A.  Yes, it does.
 
          17           MR. LONDON:  We offer 155.
 
          18           MR. LEEN:  No objection.
 
          19           THE COURT:  It is admitted.
 
          20      (Exhibit No. 155 was admitted.)
 
          21  Q.  (By Mr. London)  157. What is 157?
 
          22  A.  157, again, an October 28th email message involving CIA in
 
          23  Oregon that I downloaded from the Internet.
 
          24           MR. LONDON:  We offer 157.
 
          25           MR. LEEN:  No objection.
 
 
 
 
 
                                                                         480
 
 
 
           1           THE COURT:  It's admitted.
 
           2      (Exhibit No. 157 was admitted.)
 
           3  Q.  (By Mr. London)  Please turn to 162.
 
           4  A.  Okay, I have it.
 
           5  Q.  What is 162?
 
           6  A.  This is a message again to the Cypherpunks list that I
 
           7  downloaded from the Internet.
 
           8  Q.  Concerning Mr. Mueller and the CIA?
 
           9  A.  162 is the one that is not -- no.
 
          10  Q.  What is that about?
 
          11  A.  This is the one, or this is a message which he says, in
 
          12  discussing apparently government employees, "Under libertarian
 
          13  principles they are fully guilty of initiating 'force and/or
 
          14  fraud'.  And there are no 'statutes of limitation' on our
 
          15  response to these people regardless of current law.
 
          16      "Now would be an excellent time for anyone to go to their
 
          17  county voter's registration office, and order a copy of the
 
          18  voter's registration database for current and future use."
 
          19           MR. LONDON:  We would offer 162.
 
          20           MR. LEEN:  No objection.
 
          21           THE COURT:  162 is admitted.
 
          22      (Exhibit No. 162 was admitted.)
 
          23  Q.  (By Mr. London)  What is the date of that email?
 
          24  A.  October 30th.
 
          25  Q.  Would you turn to Exhibit 170 now.  And as you look at that
 
 
 
 
 
                                                                         481
 
 
 
           1  exhibit, perhaps you can describe where you were on October
 
           2  31st, at approximately 10:35 in the morning.
 
           3  A.  I was in my office, the Treasury Inspector General Office,
 
           4  in Portland, Oregon.
 
           5  Q.  And what happened?
 
           6  A.  The fax machine started making the normal fax machine noises
 
           7  when a fax comes in, and this is the exact document -- I've got
 
           8  my initials and the date on the back -- that came in through the
 
           9  fax machine.
 
          10  Q.  Now, about this time, had you been involved in discussions
 
          11  with Mr. Bell or with Mr. Bell's attorney, Mr. Solovy, to
 
          12  arrange the return of the guns that we heard testimony about
 
          13  yesterday?
 
          14  A.  Yes.  Actually --
 
          15  Q.  And his other property.
 
          16  A.  By this point, by October 31st, I had just simply shipped
 
          17  all the property that -- all the other property back to Mr.
 
          18  Bell's residence.  Since we were at an impasse, we couldn't get
 
          19  any instructions, so we shipped it to him directly, so we didn't
 
          20  have that, but I couldn't do that with the guns.  I needed
 
          21  somebody to come and pick them up, so we had -- even after this
 
          22  July 31st deadline had past, we had given another deadline to
 
          23  his attorney to -- and that deadline, I believe, was either
 
          24  October 31st or November 1st.  I think it was November 1st, to
 
          25  either have somebody pick up the guns or we were going to
 
 
 
 
 
                                                                         482
 
 
 
           1  destroy them.  And that was what was going on at that point.  We
 
           2  had a fixed deadline of November 1st.
 
           3  Q.  So this fax came in, and what did it say?
 
           4  A.  Well, most of the fax was my original fax from July 31st.
 
           5  That's the typed portion.  But written on it was the, "How about
 
           6  if I drop by your house tomorrow night with my designee to pick
 
           7  up the four items?  Or maybe you'd prefer at the address above?
 
           8  Jim B."
 
           9  Q.  And what was the address above?
 
          10  A.  The address above is the U.S. Treasury Inspector General, my
 
          11  office address, at 1220 Southwest Third in Portland, and it has
 
          12  my phone number and my fax number on it.
 
          13           MR. LONDON:  All right.  We offer 170.
 
          14           MR. LEEN:  No objection.
 
          15           THE COURT:  170 is admitted.
 
          16      (Exhibit No. 170 was admitted.)
 
          17           MR. LONDON:  And we would ask that that be published to
 
          18  the jury.
 
          19  Q.  (Mr. London)  The four items, is that a reference to the
 
          20  four weapons?
 
          21  A.  I presume so, yes.
 
          22           MR. LEEN:  Objection, Your Honor.  Move to strike.
 
          23  Conclusion.
 
          24  Q.  (By Mr. London)  Well, how many items remained for you --
 
          25           THE COURT:  Why don't you read it to the jury because
 
 
 
 
 
                                                                         483
 
 
 
           1  it looks very difficult to see.
 
           2  A.  It says, "How about if I drop by your house tomorrow night
 
           3  with my designee to pick up the four items?  Or maybe you'd
 
           4  prefer at the address above?  Jim B."
 
           5  Q.  (By Mr. London)  Now, the original version of this with the
 
           6  blue ink handwriting, that was recovered during the search at
 
           7  Mr. Bell's house, correct?
 
           8  A.  Yes, that's what we have marked as Exhibit 171.
 
           9  Q.  So it's your understanding that what happened here is Mr.
 
          10  Bell took a fax cover sheet, a fax that you had sent to him and
 
          11  to Mr. Solovy, and simply wrote in hand that message, and then
 
          12  faxed it back to you on October 31st?
 
          13  A.  That's correct.
 
          14  Q.  How is a facsimile transmitted from one person's computer or
 
          15  fax machine to another person's?
 
          16  A.  Through the phone lines.
 
          17  Q.  And --
 
          18           MR. LEEN:  Objection, Your Honor.  That's conclusory.
 
          19           THE COURT:  You can cross-examine him on it.  It will
 
          20  stand.
 
          21      Go ahead.
 
          22  Q.  (By Mr. London)  I'm sorry, can you repeat your answer?
 
          23  A.  Normally all the fax machines, generally speaking, that I'm
 
          24  familiar with, are hooked to telephone lines.  You plug them
 
          25  into your telephone or to a telephone line.  I know the one in
 
 
 
 
 
                                                                         484
 
 
 
           1  our office that receives -- the only way we receive faxes is
 
           2  through the phone line.  Our fax has a phone number, (503)
 
           3  326-2246.  That's our fax line, and it's plugged into the
 
           4  telephone and you call into it, dial into it, and it answers and
 
           5  receives the fax.
 
           6  Q.  All right.  Are fax machines and telephone lines used
 
           7  regularly as instruments in interstate commerce?
 
           8  A.  Yes.
 
           9           MR. LEEN:  Objection.  Calls for a legal conclusion.
 
          10           THE COURT:  As to what he does?
 
          11           MR. LEEN:  No.  He's asking about how -- about
 
          12  telephone lines and interstate commerce and such.  I'm saying
 
          13  that's a legal conclusion.
 
          14           THE COURT:  As he uses them?  Is that the objection?
 
          15           MR. LEEN:  No.  As to whether or not this constitutes
 
          16  interstate commerce, Your Honor.  That's my objection.  That's a
 
          17  conclusion.
 
          18           THE COURT:  Well, he may answer.
 
          19  A.  Yes.  In my experience, and certainly all the time we use
 
          20  our fax, this particular fax machine, all the time to send faxes
 
          21  to other offices and witnesses and all sorts of people across
 
          22  state lines.
 
          23  Q.  (By Mr. London)  Now, on November 4th -- please turn your
 
          24  attention to Exhibits 184 and 185 -- did you see anything more
 
          25  on the Internet indicating that Mr. Bell, perhaps, now had found
 
 
 
 
 
                                                                         485
 
 
 
           1  the home of Scott Mueller, this supposed CIA agent?
 
           2  A.  Yes.  184 is the original that I downloaded off the Internet
 
           3  of, again, another CIA in Oregon email message.  In this one, he
 
           4  specifically -- it indicates that he's been out there, or
 
           5  somebody's been out there because it gives specific information
 
           6  about the residence.  He says, "This address is a house in a
 
           7  rather new subdivision," and he also says, "Two vehicles," and
 
           8  he gives the license plates, "are in the driveway."
 
           9  Q.  All right.
 
          10           MR. LONDON:  We offer 184.
 
          11           MR. LEEN:  No objection.
 
          12           THE COURT:  184 is admitted.
 
          13      (Exhibit No. 184 was admitted.)
 
          14  Q.  (By Mr. London)  Now, that was dated November 4th.  Two days
 
          15  later the search warrant was executed at Mr. Bell's residence at
 
          16  7214 Corregidor, correct?
 
          17  A.  Yes.
 
          18  Q.  All right.  We've already talked about a lot of the items
 
          19  that were recovered from the search.  Are you familiar with all
 
          20  of the CD-ROMs and phone disks and Department of Motor Vehicle
 
          21  printouts and the spiral notebook with all the information
 
          22  showing where he had been?  Have you looked at all of that
 
          23  evidence?
 
          24  A.  Yes, I have.
 
          25  Q.  Are you also familiar with the tax assessor printout?
 
 
 
 
 
                                                                         486
 
 
 
           1  A.  Yes, I am.
 
           2  Q.  Turn to Exhibit 127, which I don't think anyone has talked
 
           3  about yet.
 
           4  A.  Yes, I have it.
 
           5  Q.  What is 127?
 
           6  A.  This is a receipt that I found in Mr. Bell's bedroom during
 
           7  the search.
 
           8  Q.  A receipt for what, issued by whom?
 
           9  A.  This was issued by Clark County and it's got an address in
 
          10  Vancouver, Washington.  It says it's received from Bell, is
 
          11  handwritten in, and says "For 10 Assr," assessor, "prints."
 
          12  Q.  So what does that appear to be to you?
 
          13  A.  This appears to be the receipt, because it's dated
 
          14  October 11, 2000, for the purchase of what I believe is
 
          15  Exhibits 125 and 126.  Those are also dated the same day,
 
          16  October 11, 2000.  The real property records for Jeffrey
 
          17  Gordon are two different Jeffrey Gordons, apparently.
 
          18           MR. LONDON:  We offer 127.
 
          19           MR. LEEN:  No objection.
 
          20           THE COURT:  127 is admitted.
 
          21      (Exhibit No. 127 was admitted.)
 
          22  Q.  (By Mr. London)  Now, you had been to the Bell residence on
 
          23  a prior search warrant in 1997, correct?
 
          24  A.  Yes.
 
          25  Q.  You were familiar with the layout of the house, correct?
 
 
 
 
 
                                                                         487
 
 
 
           1  A.  Yes.
 
           2  Q.  What evidence was there when you went in October -- excuse
 
           3  me -- November with the search warrant, when Mr. Bell was
 
           4  actually living at that residence?
 
           5  A.  Well, Mr. Bell was present and actually asleep when we
 
           6  arrived in the bedroom in the basement in the residence.  His,
 
           7  what appeared to be his, personal possessions were there and his
 
           8  clothes.  The documents all in the basement area all seemed to
 
           9  be related to him.
 
          10  Q.  Is that where he had his computers?
 
          11  A.  There were two -- as I understand it, two computers in the
 
          12  basement and an additional computer upstairs.
 
          13  Q.  Did Mr. Bell say anything at all to suggest that this was
 
          14  not where he was actually living?
 
          15  A.  No.
 
          16  Q.  All right.  Several days after the search warrant was
 
          17  executed -- we are now on November 9th -- did you see an article
 
          18  in the Columbian newspaper about Mr. Bell?
 
          19  A.  I don't recall the exact date, but I know I have seen
 
          20  articles in the Columbian about him.
 
          21  Q.  Could you look at Exhibit 214, please.
 
          22  A.  Yes.  This is an article that I cut out of the Columbian
 
          23  myself.  I've got my initials up in the corner.
 
          24  Q.  And what does it say about Mr. Bell, or what did you notice
 
          25  in this article that might have caused you to be particularly
 
 
 
 
 
                                                                         488
 
 
 
           1  interested in it?
 
           2  A.  Well, he made what I consider admissions that he has been
 
           3  using motor vehicle records and that specifically he had gone to
 
           4  the homes of agents' houses and taken pictures.  And, you know,
 
           5  he reiterated, I guess, his feelings that we're absolutely
 
           6  crooked, things like that.  That was a concern.
 
           7  Q.  Now, the tracking device in his car, that had already been
 
           8  installed several days earlier during the execution of the
 
           9  search warrant, correct?
 
          10  A.  Yes.  That was done on November 6th.
 
          11  Q.  Now, were you concerned enough about your safety that you
 
          12  wanted to be able to have a way of monitoring the tracking
 
          13  device yourself at home at night?
 
          14  A.  Yes.
 
          15  Q.  And what did you do to make sure that you could find out if
 
          16  that tracking device was getting anywhere near you?
 
          17  A.  What I did is -- the system was kind of designed for this.
 
          18  We set it up -- we told the system that if Mr. Bell left a
 
          19  certain defined area, basically a couple miles square around his
 
          20  house, so that it wouldn't notify us, for example, if he just
 
          21  went to the store close by or went to get a drink, but if, you
 
          22  know, he left that area, that it would alert my pager, and then
 
          23  I would know to go and check the system so that we could see
 
          24  where he was going.  And I kept a list of as many targets as I
 
          25  was aware of, or potential targets for him, of the various
 
 
 
 
 
                                                                         489
 
 
 
           1  people that I knew he was gathering information on so that I
 
           2  could hopefully, if I saw him going somewhere, identify who he
 
           3  was trying to go after and notify them or take whatever steps we
 
           4  needed to do for their safety.
 
           5  Q.  And were you at home around 12:15, early in the morning of
 
           6  November 10th?
 
           7  A.  Yes.
 
           8  Q.  And were you monitoring the device, or what were you doing
 
           9  around that time?
 
          10  A.  Sleeping.
 
          11  Q.  And what happened?
 
          12  A.  The pager went off and alerted me.  I went to the computer
 
          13  and checked where Mr. Bell -- or where the device, the tracker
 
          14  was.
 
          15  Q.  The display that the jury saw yesterday of the progression
 
          16  of the tracking device going south across the river to the
 
          17  residence on South Clackamas, were you able to see essentially
 
          18  that same thing as it was happening in live time?
 
          19  A.  Yes.  That's -- it looks very -- exactly like that only in
 
          20  real time, so it's a lot slower because it's not in that fast,
 
          21  fast pace mode.
 
          22  Q.  So you watched it, and what did you see?
 
          23  A.  I think by the time I got on, got on to see it, he was
 
          24  already southbound.  He had already crossed the border and was
 
          25  south on 205.  I wasn't sure -- 205 is a main artery, so I
 
 
 
 
 
                                                                         490
 
 
 
           1  wasn't sure where or what he was doing.  I was concerned about
 
           2  it because it was so late at night.  That's an unusual time to
 
           3  be doing a normal trip, so I continued to watch it to see if I
 
           4  could figure out where he was going.
 
           5  Q.  And at what point did you figure out where he might be
 
           6  headed?
 
           7  A.  At the point he turned on to South Clackamas River Drive, I
 
           8  recognized that as the Groener/Andrews, the street that they
 
           9  lived on.
 
          10  Q.  So what did you do?
 
          11  A.  I contacted -- the first thing I did was contact 911 and ask
 
          12  them to have local units respond to the residence to see if they
 
          13  could get out there as soon as possible to ensure the safety of
 
          14  the residents.
 
          15  Q.  And did you try to call the residents yourself?
 
          16  A.  Yes, I did.  I, I dialed Mr. Groener's phone number.
 
          17  Q.  And what happened?
 
          18  A.  I got put into -- I wasn't sure at the time whether it was a
 
          19  voice mail machine or answering machine, and so I thought maybe
 
          20  it was an answering machine and maybe he just wasn't answering
 
          21  because it was so late at night, so I kind of shouted into it,
 
          22  "Chris, Chris, if you're home, answer the phone.  Answer the
 
          23  phone.  I need to talk to you," and I identified myself.
 
          24  Q.  Were you concerned about Agent McNall as well at this point?
 
          25  A.  No.  I wasn't concerned about Agent McNall because I knew
 
 
 
 
 
                                                                         491
 
 
 
           1  that he no longer lived in that area.  I was concerned about the
 
           2  Andrews, I was concerned about Mr. Groener at the immediate
 
           3  time.  But I did know that -- did contact him because I knew he
 
           4  was -- or I arranged to have him contacted because he was
 
           5  familiar with the property and wasn't that far from it and could
 
           6  respond to the scene.
 
           7  Q.  Did you call anybody else besides 911?  Did you contact your
 
           8  own supervisor?
 
           9  A.  Yes, I did.  I contacted -- I stayed -- I was on line with
 
          10  911.  I contacted my supervisor.  I contacted another treasury
 
          11  agent in our office, had him respond to be with me in case we
 
          12  needed to take some action or response.  I placed him on alert,
 
          13  and actually I had him make the call to ATF and try to get ahold
 
          14  of Agent McNall and to alert ATF.  I paged and tried to get
 
          15  ahold of ATF's case agent to advise them that this was going
 
          16  on.
 
          17  Q.  Now, you were aware that Mr. Bell was stopped by the
 
          18  Clackamas County Sheriff's officers a few miles from the Groener
 
          19  house, correct?
 
          20  A.  Yes.
 
          21  Q.  But that he was also ultimately released that evening,
 
          22  correct?
 
          23  A.  Yes.
 
          24  Q.  The next morning, on November 11th, did you see an article
 
          25  by Declan McCullagh on the Internet on Wired News in which Mr.
 
 
 
 
 
                                                                         492
 
 
 
           1  Bell was quoted talking about picketing your house?
 
           2  A.  I'm not sure of the exact date, but I recall a Wired News
 
           3  article in regard to that.
 
           4  Q.  Would you look at Exhibit 229.
 
           5  A.  Yes.  This is an article that I printed out myself.
 
           6  Q.  All right.  And in that article, was Mr. Bell quoted as
 
           7  saying that he was thinking very strongly of picketing Gordon's
 
           8  house?
 
           9  A.  Yes.
 
          10  Q.  And that he was hopping mad and feeling very hostile and
 
          11  that he was not going to be stopped?
 
          12  A.  Yeah.  He said, "If you think this is going to stop me,
 
          13  baloney."
 
          14  Q.  All right.  So Mr. Bell had been present during the
 
          15  execution of the federal search warrant and you were there,
 
          16  correct?
 
          17  A.  Yes.
 
          18  Q.  He had been stopped now just a few miles from his second
 
          19  visit to the Groener property, correct?
 
          20  A.  Yes.
 
          21  Q.  And he was now telling the reporter that he was not going to
 
          22  be stopped, correct?
 
          23  A.  Yes.
 
          24  Q.  All right.  And an arrest warrant was finally obtained for
 
          25  him and he was arrested on November 17th.  Were you present at
 
 
 
 
 
                                                                         493
 
 
 
           1  the scene?
 
           2  A.  I responded to the scene and arrived shortly after he was
 
           3  detained in the car.
 
           4  Q.  He was stopped in his car?
 
           5  A.  Yes.  In fact, we used the tracking device to help make the
 
           6  arrest so we knew where he was driving and had the Vancouver
 
           7  Police Department make a traffic stop on him, and as soon as
 
           8  they got him pulled over, then I responded to the scene.
 
           9  Q.  All right.  Now, his car was searched incident to the
 
          10  arrest, correct?
 
          11  A.  Yes.
 
          12  Q.  And a number of items were found in there that you believed
 
          13  to be relevant to this.  Can you tell us what they are?  And I
 
          14  will direct your attention to Exhibit 235.
 
          15  A.  Yes.  On the -- 235 is an item that I saw and found in the
 
          16  car, and my initials are on the back of it.  This is a photo
 
          17  processing envelope that was sitting on the passenger seat in
 
          18  the car.
 
          19  Q.  And can you look at 236?
 
          20  A.  Yes.
 
          21  Q.  What is 236?
 
          22  A.  This is the -- one of the pictures that was inside the photo
 
          23  processing envelope that we just spoke of.  It's got my initials
 
          24  again on the back.  One of the pictures we found in the car.
 
          25  Q.  And do you know what that is a picture of?
 
 
 
 
 
                                                                         494
 
 
 
           1  A.  Yes.  That's -- we had some testimony on this earlier, I
 
           2  believe.  This is one of Mr. Mueller's -- I think it's his
 
           3  previous residence.
 
           4           MR. LONDON:  We offer 236.
 
           5           MR. LEEN:  No objection.
 
           6           THE COURT:  236 is admitted.
 
           7      (Exhibit No. 236 was admitted.)
 
           8  Q.  (By Mr. London)  And look at 237.
 
           9  A.  Yes.
 
          10  Q.  What's 237?
 
          11  A.  237, again, is an item that I found in the car and seized.
 
          12  This is a receipt from -- while it's dated November 17th, which
 
          13  is the date of the arrest, at 8:40 p.m., which is just prior --
 
          14  the time just prior to the arrest, and it's for photo/elec,
 
          15  which I assume to be electronics.
 
          16  Q.  Now --
 
          17           MR. LONDON:  We offer 237.
 
          18           MR. LEEN:  No objection.
 
          19           MR. LONDON:  And 235.
 
          20           MR. LEEN:  Let me look.
 
          21           MR. LONDON:  It's the envelope.
 
          22           MR. LEEN:  No objection.
 
          23           THE COURT:  235 and 237 are admitted.
 
          24      (Exhibits Nos. 235 and 237 were admitted.)
 
          25  Q.  (By Mr. London)  Agent Gordon, have you had an opportunity
 
 
 
 
 
                                                                         495
 
 
 
           1  to do what we call a search using a search engine on the
 
           2  Internet for Scott Mueller?
 
           3  A.  Yes, I have.
 
           4  Q.  What is -- describe for those of us who may be less savvy
 
           5  about the Internet what a search engine is and how you run a
 
           6  search for someone over the Internet?
 
           7  A.  Okay.  There's many websites or web pages on the Internet.
 
           8  There's millions and millions of them.  There's lots of
 
           9  information.  And so if you're looking or are interested in a
 
          10  particular subject or particular person, you don't know
 
          11  necessarily what web page to go to, so there are various
 
          12  companies or people out there that have set their computers to
 
          13  go to each different web page and kind of catalog what's on that
 
          14  site and to create an index, kind of like the card catalog at a
 
          15  library.  And so if you go to -- and that's the search engine
 
          16  people.  If you go to that search engine, you can type in what
 
          17  you're looking for and it will go out and search its memory and
 
          18  tell -- and point you or tell you which different web pages you
 
          19  might want to try to find that information.
 
          20  Q.  So, for example, if you were to type in a name with the
 
          21  search engine, essentially search all over the Internet various
 
          22  websites and pull down all of the places where that name
 
          23  appeared.
 
          24  A.  Different search engines use different methods of locating
 
          25  it, but, yes, that's essentially what happens.
 
 
 
 
 
                                                                         496
 
 
 
           1  Q.  All right.  And what happened when you ran the name Scott
 
           2  Mueller?
 
           3  A.  Well, I think I ran the full name -- did it a couple of
 
           4  different ways.  But when I run, for example, Scott Deforest
 
           5  Mueller, those three names, I came back basically with the CIA
 
           6  in Oregon Cypherpunks-type postings.  In other words, the
 
           7  postings that Mr. Bell made giving all his information.
 
           8  Q.  And outing Mr. Mueller as a CIA agent?
 
           9  A.  That's correct.
 
          10  Q.  Did you have a chance to observe or to look through Exhibit
 
          11  137, which I have referred to as the stalking diary?  This is
 
          12  the spiral notebook that was found during the search of Mr.
 
          13  Bell's home.
 
          14  A.  Yes, I have.
 
          15  Q.  And have you had a chance to see that, or whether there are
 
          16  many telephone numbers recorded in that book?
 
          17  A.  Yes, there are.
 
          18  Q.  For various individuals?
 
          19  A.  Yes.
 
          20  Q.  Have you had a chance to compare the telephone numbers
 
          21  recorded in this diary with Mr. Bell's telephone records from
 
          22  the residence at 7214 Corregidor?
 
          23  A.  Yes, I have.
 
          24  Q.  And what does the comparison show?
 
          25  A.  It's not a perfect match.  There are some phone numbers in
 
 
 
 
 
                                                                         497
 
 
 
           1  the diary -- some long distance numbers that are in the stalking
 
           2  diary that aren't on his phone bills, but generally speaking,
 
           3  quite a few of them are and matched up.  In some cases when
 
           4  there were dates in the diary and in some cases they matched
 
           5  up.  But there were some matches.
 
           6  Q.  All right.  So -- but is it your testimony that on days
 
           7  indicated in the diary in which telephone number information was
 
           8  recorded, there's corresponding evidence in the phone records
 
           9  that he was actually calling those numbers from his home, or
 
          10  some of them?
 
          11  A.  Yes.  Except that most of the diary doesn't really have
 
          12  dates, so it's -- it's hard to correlate exact dates to days.  I
 
          13  think we have at least one example of it where it did match up.
 
          14  But in general, yes.  And there were certainly numbers that are
 
          15  written down in the stalking diary that then the phone records
 
          16  show -- where there are phone records available, show that they
 
          17  have been called.
 
          18  Q.  All right.  Did you have a chance to make up an exhibit or
 
          19  kind of a diagram to show this?
 
          20  A.  Yes.  Although the diagram that we have only relates to the
 
          21  phone bills through a Uni-Tel.  There was another phone provider
 
          22  for some of the period of time, and those records, even though
 
          23  the phone calls may be in here, weren't -- that's not included
 
          24  in this chart.
 
          25  Q.  All right.  I would ask you to look at Exhibit 180 and tell
 
 
 
 
 
                                                                         498
 
 
 
           1  us if that's the chart that you prepared showing that Mr. Bell
 
           2  was actually telephoning some of the numbers that were also
 
           3  found in his diary.
 
           4  A.  Yes.  This is the chart that I prepared.
 
           5           MR. LONDON:  I would like to ask that that be
 
           6  published.
 
           7           MR. LEEN:  No objection.
 
           8  Q.  (By Mr. London)  Can you describe the information --
 
           9           MR. LONDON:  The jury needs to see it.
 
          10  Q.  (By Mr. London)  Can you just describe how you prepared this
 
          11  and what it shows?
 
          12  A.  Yes.  On the left side is the --
 
          13           THE COURT:  They can't see.  Members of the jury can't
 
          14  see it.
 
          15           MR. LONDON:  Is that better?  That's about as much as I
 
          16  think we will be able to magnify it.
 
          17  A.  Okay.  On the left side I tried --
 
          18           THE COURT:  Why don't you -- have you got a pointer?
 
          19           MR. LONDON:  You've got a pointer.
 
          20           THE COURT:  That might help.
 
          21           MR. LONDON:  Why don't you use that.
 
          22  Q.  (Mr. London)  Okay.
 
          23  A.  Okay.  So on the left side I have tried to put what the
 
          24  stalking notebook, Exhibit 137, what it says and the page number
 
          25  in parens, so for the first entry it's Larry Olstad with a phone
 
 
 
 
 
                                                                         499
 
 
 
           1  number 849-4635.  That would be Exhibit 137, page 1.  And then
 
           2  on the other side, the right side after the line, I have put the
 
           3  -- again, the phone number that was found on the Uni-Tel phone
 
           4  bill and the dates that that number was called, the phone
 
           5  records show it was called.
 
           6  Q.  All right.  But you're not suggesting that these are phone
 
           7  numbers of people who are actually being stalked, are you, these
 
           8  are more -- how would you describe these numbers?
 
           9  A.  These are just numbers that are listed, and you can see, for
 
          10  example, there's the assessor's office, or just various people.
 
          11  They are not necessarily victims in the case.  It just shows
 
          12  that -- relates the stalking notebook to actual activity.
 
          13  Q.  All right.  But there are -- do you see the third entry, the
 
          14  Benton County, Washington, Assessor's Office?
 
          15  A.  Yes.
 
          16  Q.  Is the county assessor's office someplace where you can get
 
          17  property records if you are looking for someone's address?
 
          18  A.  Yes.
 
          19  Q.  And the last, the King County Assessor, is that -- the same
 
          20  question there?
 
          21  A.  Yes.
 
          22  Q.  And the second one, assessor/treasurer.  What does that mean
 
          23  to you?
 
          24  A.  The same thing, it's some sort of, most likely a county
 
          25  office or something.
 
 
 
 
 
                                                                         500
 
 
 
           1  Q.  It's got a 253 area code.
 
           2  A.  I think that's up in this area, the Pierce County area.
 
           3  Q.  You're a law enforcement agent, isn't that correct?
 
           4  A.  Yes.
 
           5  Q.  You carry a gun as part of your everyday responsibilities,
 
           6  correct?
 
           7  A.  Yes.
 
           8  Q.  What would your answer be if someone were to say to you, why
 
           9  are you afraid of this guy, or what reason, what cause do you
 
          10  have to be afraid of this guy?  You're the guy who's carrying
 
          11  the gun.  He's the guy who had to give up his guns.
 
          12  A.  Well, there's a lot of answers to that.  One is that he's
 
          13  clearly targeting me at my residence, at my home where my family
 
          14  lives, so it's not just me, it's my family.  It's not just when
 
          15  I'm on duty or working as a law enforcement officer, where I
 
          16  would normally be carrying my gun in antici- -- you know, have
 
          17  it ready, but it could be while I'm sleeping at night or when
 
          18  I'm not there.
 
          19      There were -- but he's a person who's strongly advocated the
 
          20  assassination of government officials, and specifically tax
 
          21  officials.
 
          22      He -- there's the whole chemical weapon issue, the fact that
 
          23  he's at least stated that he's made Sarin gas, a highly
 
          24  dangerous nerve agent.  We found precursor-type chemicals for
 
          25  that in his residence.  He's got a degree in chemistry from MIT,
 
 
 
 
 
                                                                         501
 
 
 
           1  so he clearly has the ability to make those.
 
           2      He's dumped chemicals in an IRS office in retaliation for
 
           3  rela- -- comparatively minor, I guess, in retaliation for the
 
           4  seizure of his vehicle.  So what's he going to do because we put
 
           5  him in jail?
 
           6      And he's -- the time he spent in jail had no effect on him.
 
           7  It -- or it certainly didn't deter him from this activity; it
 
           8  increased it.  He did -- or similar activity was coming after
 
           9  agents in '97, and we put him in jail on supervised release, and
 
          10  instead of learning from that, now he's even more aggresive and
 
          11  escalating.
 
          12  Q.  In fact, in '97 he was never accused of actually showing up
 
          13  at anybody's house, is that fair?
 
          14  A.  Correct.
 
          15  Q.  What steps have you taken, if any, to try to increase your
 
          16  security because of this?
 
          17  A.  I've purchased additional firearms for the family and the
 
          18  house.  I've installed the first part of the security system in
 
          19  my residence and gotten an additional one.  I've obtained an
 
          20  anti-stalking order from the State of Oregon.
 
          21      My -- I had to, you know, talk to my family about what steps
 
          22  to take while Mr. Bell was still on the loose or before he was
 
          23  in custody.  I had to, you know, sit down with my wife and talk
 
          24  about the situation, and she had, you know, started carrying
 
          25  around a large firearm with her, you know.  So.
 
 
 
 
 
                                                                         502
 
 
 
           1      I mean, every morning when I wake up, the first thing I do
 
           2  is look out the window, or especially when he was -- look out
 
           3  the window.  When I walked out to my car, I check up and down
 
           4  the street.  When I come home I take evasive routes and check
 
           5  the neighborhood, and if there's a car that gets off the freeway
 
           6  behind me at the same time as I do, I turn a couple different
 
           7  directions to go a different way to see if they are actually
 
           8  following me or not.
 
           9  Q.  What would you say to the accusation, if it were to be made,
 
          10  that you are just as obsessed with him as he is with you?
 
          11  A.  Well, from a -- maybe just from a defensive posture.  I
 
          12  would have been very happy had he gotten out of jail and just
 
          13  completely left us alone or left me alone.  I really took no
 
          14  steps upon him being released from custody in April.  I didn't
 
          15  do -- go near him or do anything other than monitor public
 
          16  information on the Internet, receive some phone calls when
 
          17  people called me about him, and that's basically it.  I didn't
 
          18  try to arrange -- continue, which I had been for at least a year
 
          19  prior, continue to try to arrange the return of his property
 
          20  back to him.
 
          21  Q.  There's been some suggestion, I guess by counsel, that Mr.
 
          22  Bell's accessing or his use of the Department of Motor Vehicles
 
          23  database is perfectly legal.  Is that your understanding?
 
          24  A.  No, it's not.
 
          25  Q.  What laws govern the use of the Department of Motor Vehicle
 
 
 
 
 
                                                                         503
 
 
 
           1  materials, such as the material that he has on CD-ROMs and has
 
           2  been using to search for your address and the addresses of
 
           3  others?
 
           4  A.  There's both state and federal laws restricting the use of
 
           5  DMV data, especially the more recent stuff.  In response to some
 
           6  of these stalking and harassment problems that there have been,
 
           7  the government passed, I think it's 2712 -- I don't remember
 
           8  exactly what statute it was -- that restricts what you can use
 
           9  and how -- who can obtain the DMV data and what you can use it
 
          10  for.
 
          11  Q.  In fact, doesn't it restrict its lawful use to those who are
 
          12  going to use it for commercial purposes?
 
          13  A.  Yes.  There's several uses.  For example, law enforcement
 
          14  can use it or various -- but essentially that's one of the uses,
 
          15  is for those who are using it for commercial or marketing
 
          16  purposes.
 
          17  Q.  All right.  Are you aware that agents who work with you have
 
          18  tried to obtain a sample of Mr. Bell's handwriting pursuant to
 
          19  an order of this court?
 
          20  A.  Yes.
 
          21  Q.  Did Mr. Bell comply?
 
          22  A.  No, he did not.
 
          23  Q.  Does that explain why there's no handwriting comparison in
 
          24  this case comparing his handwriting to the handwriting in the
 
          25  notebooks?
 
 
 
 
 
                                                                         504
 
 
 
           1  A.  That's correct.  We were unable to -- we obtained the order
 
           2  from the court to have Mr. Bell give us exact handwriting
 
           3  samples.  The examiners need the same handwriting that appears,
 
           4  the same words, and they need it multiple times in order to make
 
           5  a scientific comparison to see if it's that individual's
 
           6  handwriting.  And when the agents on -- after having coordinated
 
           7  with Mr. Bell's attorney prior to going out to the prison, went
 
           8  there twice to give him the opportunity to obey the court order,
 
           9  and both times he refused to even meet with them.
 
          10           MR. LONDON:  Nothing further.
 
          11           THE COURT:  Cross-examination.
 
          12                        CROSS-EXAMINATION
 
          13  BY MR. LEEN:
 
          14  Q.  Good morning, Agent Gordon.
 
          15  A.  Good morning, Mr. Leen.
 
          16  Q.  In the course of investigating Mr. Bell, you used the
 
          17  Internet.
 
          18  A.  Yes.
 
          19  Q.  And did searches on the Internet.
 
          20  A.  Yes.
 
          21  Q.  Much the way Mr. Bell did searches on the Internet.
 
          22  A.  Presumably.
 
          23  Q.  You did cross-references of telephone directories.
 
          24  A.  On occasion.
 
          25  Q.  Much the way Mr. Bell did cross-references of telephone
 
 
 
 
 
                                                                         505
 
 
 
           1  directories.
 
           2  A.  I didn't use it exactly the same, but there -- the way he
 
           3  did it, but similar.
 
           4  Q.  When did you first open a file on Mr. Bell?
 
           5  A.  October '96.
 
           6  Q.  When was Mr. Bell's vehicle seized?
 
           7  A.  February '97.
 
           8  Q.  Were you aware that it was going to be seized?
 
           9  A.  Yes.
 
          10  Q.  Were you involved at all in the decision to seize his
 
          11  vehicle?
 
          12  A.  I was in -- the final decision wasn't mine, but I certainly
 
          13  had a lot of involvement in the process.
 
          14  Q.  When the vehicle was seized, was there a copy of
 
          15  Assassination Politics, that is a hard copy, in the vehicle?
 
          16  A.  Yes.
 
          17  Q.  Was that the first time you had become aware of that
 
          18  article?
 
          19  A.  No.
 
          20  Q.  You had become aware of it through an Internet search or --
 
          21  A.  Yes.
 
          22  Q.  -- somehow or another were directed to it on line?
 
          23  A.  Yes.
 
          24  Q.  Did you pull up tax records from databases regarding Mr.
 
          25  Bell?
 
 
 
 
 
                                                                         506
 
 
 
           1  A.  Yes.
 
           2  Q.  Did you monitor on the Internet Cypherpunk list any email
 
           3  Mr. Bell may have written or email that was written to Mr. Bell?
 
           4  A.  At what time period?
 
           5  Q.  Well, after -- any time after you opened the file.
 
           6  A.  Later on, yes.
 
           7  Q.  Were you aware that there was a Special Agent Walsh using
 
           8  the name Steve Wilson sent to infiltrate the Multnomah County
 
           9  Common Law Court?
 
          10  A.  I wouldn't describe it like that.
 
          11  Q.  How would you describe it?
 
          12  A.  Well, he -- I was certainly aware of Agent Walsh and the
 
          13  undercover operation that we had going.  His -- his mission was
 
          14  not to infiltrate the common law court, though.
 
          15  Q.  Was his mission to monitor Mr. Bell?
 
          16  A.  His mission was essentially to determine what Operation
 
          17  Locate IRS was and to determine if Mr. Bell or anybody else
 
          18  planned to harm any Internal Revenue Service agents.
 
          19  Q.  Were you aware that Mr. Wilson, under the name Steve Wilson,
 
          20  Agent Walsh was communicating email to Mr. Bell?
 
          21  A.  Certainly, yes.
 
          22  Q.  Were you aware that some of that email indicated that Steve
 
          23  Wilson thought that the government was acting out of control and
 
          24  were a bunch of crooks and much of the same type of rhetoric
 
          25  that Mr. Bell had been himself writing in emails?
 
 
 
 
 
                                                                         507
 
 
 
           1  A.  I don't recall those specific words, and I don't think there
 
           2  was a whole lot of that, but certainly he was playing that role.
 
           3  Q.  Were you aware that Agent Walsh asked Mr. Bell to build for
 
           4  him or supply to him an illegal fm transmitter?
 
           5  A.  In fact, I'm specifically aware that that never happened.
 
           6  Q.  Are you aware that Special Agent Walsh contacted Mr. Bell
 
           7  numerous times outside the Multnomah County Common Law Court?
 
           8  A.  I wouldn't describe it as -- well, it depends on your
 
           9  definition, numerous.  On occasion, yes.
 
          10  Q.  And met with him?
 
          11  A.  On one -- I believe one occasion, yes.
 
          12  Q.  Now, you said that Mr. Bell was using Mr. East's house for
 
          13  phone calls and as a mail drop.
 
          14  A.  Yes.
 
          15  Q.  And when did that occur?
 
          16  A.  That was occurring in that same time frame.  I think on his
 
          17  employment application, which was actually around October '96,
 
          18  he had used Mr. East's address and phone number -- I believe
 
          19  phone number.  I know that at one point Agent Walsh received
 
          20  what we believed was a call from Mr. Bell, caller ID, identified
 
          21  it as coming from Robert East's house, and that would probably
 
          22  have been around May of '97.
 
          23  Q.  All right.  Now, you indi- -- when Mr. Bell's vehicle was
 
          24  seized for payment of back taxes, approximately how much money
 
          25  did he owe?
 
 
 
 
 
                                                                         508
 
 
 
           1  A.  You know, I don't recall exactly, and it depends on how you
 
           2  define what you owe, because there was audit things going on.
 
           3  Q.  The principal amount, as opposed to with interest.
 
           4  A.  I think it was somewhere around 50,000, but it could have
 
           5  been down from that.
 
           6  Q.  Are you aware of how he incurred that tax, what kind of
 
           7  income he had generated prior to that which he had not paid
 
           8  taxes on?
 
           9  A.  Yeah.  There was multiple years of it.  There were stock
 
          10  sales in some years, and then there was a big hundred-thousand-
 
          11  dollar payment of some sort back in the late '80s that he had
 
          12  never -- I don't believe he had ever filed a tax return related
 
          13  to, so they audited him to assess taxes on it.
 
          14  Q.  Were you aware that Mr. Bell actually was -- ran a business
 
          15  at one time?
 
          16  A.  Yes.
 
          17  Q.  And do you know anything about the particulars of that
 
          18  business?
 
          19  A.  I've heard about the business and also some of the IRS side
 
          20  of that, yes.
 
          21  Q.  And what type of business was that?
 
          22  A.  I think it was called Semi-Disk Systems, or something
 
          23  relating to computer components or something like that.
 
          24  Q.  So at one point he was a legitimate businessman.
 
          25  A.  Well, I've heard different stories about that.
 
 
 
 
 
                                                                         509
 
 
 
           1  Q.  Now, Mr. Bell is not being prosecuted for having authored
 
           2  Assassination Politics, is he?
 
           3  A.  No.
 
           4  Q.  And he's not being prosecuted for the chemicals that were
 
           5  recovered from his house in 1997, is he?
 
           6  A.  No.
 
           7  Q.  Did you, when you searched his residence in November of
 
           8  2000, I think it was November 6 of 2000, did you recover any
 
           9  firearms?
 
          10  A.  No.
 
          11  Q.  Did you recover any precursor chemicals to make nerve gas or
 
          12  other dangerous substances?
 
          13  A.  There were dangerous substances there, but we didn't take
 
          14  them.
 
          15  Q.  In particular, what were they?
 
          16  A.  There was a list that haz-mat gave me -- or hazardous
 
          17  material guys gave me.  I know mercury, or -- there were some
 
          18  chemicals there.
 
          19  Q.  Now, you're aware that Mr. Bell is a chemist.
 
          20  A.  Yes.
 
          21  Q.  And you're aware that his -- you've interviewed his parents,
 
          22  or agents that are working with you have interviewed his
 
          23  parents.
 
          24  A.  Agents that are working with me have, yes.
 
          25  Q.  And you're aware that he's been a hobbyist in chemistry
 
 
 
 
 
                                                                         510
 
 
 
           1  since he was a preteen.
 
           2  A.  I've heard that, yes.
 
           3  Q.  And you're aware that he was exceptionally bright, is
 
           4  exceptionally bright.
 
           5  A.  People say that, yes.
 
           6  Q.  And he attended Massachusetts Institute of Technology.
 
           7  A.  Yes, I confirmed that, yes.
 
           8  Q.  And he graduated.
 
           9  A.  I believe so, yes.
 
          10  Q.  And do you know approximately when?
 
          11  A.  Late '70s or '80s, something like that.
 
          12  Q.  You've indicated that you returned the weapons that had been
 
          13  seized in 1997 from Mr. Bell, you returned them to Robert East.
 
          14  A.  Yes.
 
          15  Q.  Why did you return them to Robert East if you felt that he
 
          16  was an associate of Mr. Bell?
 
          17  A.  Because the United States Attorney's Office advised me that
 
          18  I had no legal means to maintain them.  That I was required by
 
          19  law to return them.  They were Mr. Bell's property, and I was
 
          20  required to return them, and so at that point it was his choice
 
          21  to -- or his attorney's choice as to his designee as to who he
 
          22  wanted to have them, and our only requirement was that it was a
 
          23  person who was legally entitled to possess them.  And since Mr.
 
          24  East is legally entitled to possess firearms and Mr. Bell
 
          25  designated him to be his designee, apparently, I returned them
 
 
 
 
 
                                                                         511
 
 
 
           1  to him.
 
           2  Q.  Have you ever seen those weapons again?
 
           3  A.  No.
 
           4  Q.  Now, there was a tracking device placed in Mr. Bell's
 
           5  vehicle at the same time that the search warrant took place on
 
           6  November 6th.
 
           7  A.  Yes.
 
           8  Q.  Were there any tracking devices ever placed in Mr. Bell's
 
           9  residence -- vehicle prior to November 6th, 2000, that you're
 
          10  aware of?
 
          11  A.  No.
 
          12  Q.  Was there any monitoring of Mr. Bell from residents in the
 
          13  neighborhood prior to November 6 -- well, let's start first,
 
          14  prior to November 6th, 2000?
 
          15  A.  No.
 
          16  Q.  Was there any monitoring at all of Mr. Bell's activities
 
          17  other than what we've just discussed and your reading of public
 
          18  emails prior to November 6th, 2000?
 
          19  A.  Well, certainly we did -- when you say monitoring, I mean,
 
          20  we were keeping him -- you know, when he's at the court.  We had
 
          21  Agent Walsh, for example, in contact with him.  But if you're
 
          22  talking about electronic monitoring or surveillance teams, I
 
          23  think, for example, the day of the -- that the IRS seized his
 
          24  vehicle, we had a team out watching for the vehicle that day.
 
          25  But other than that, there was no sustained effort.  There was
 
 
 
 
 
                                                                         512
 
 
 
           1  no wire taps or bugs or electronic microwaves or anything like
 
           2  that.
 
           3  Q.  Was his phone ever listened to?
 
           4  A.  The only electronic monitoring of the phone was when Agent
 
           5  Walsh made phone calls with Mr. Bell or received phone calls
 
           6  from Mr. Bell's, we used one-party consensual monitoring on
 
           7  that, which we are legally entitled to do.  And so we tape
 
           8  recorded, and we consider that electronic monitoring.  We
 
           9  electronically monitored the calls between Agent Walsh and Mr.
 
          10  Bell.
 
          11           MR. LONDON:  I just want to ask for clarification of
 
          12  the time when that happened.
 
          13           THE WITNESS:  That would have been in 1997, prior to
 
          14  Mr. Bell's arrest, when we had the undercover operation going
 
          15  on.
 
          16  Q.  (By Mr. Leen)  Now, Mr. Bell isn't being prosecuted for
 
          17  anything that happened prior to 1997, is he?
 
          18  A.  No.
 
          19  Q.  Or prior to 1998?
 
          20  A.  No.
 
          21  Q.  In fact, he's not being prosecuted for anything other than
 
          22  the specific dates and crimes in the indictment, is that
 
          23  correct?
 
          24  A.  Yes.
 
          25  Q.  Now, when you first saw the email, "Say Good Night to
 
 
 
 
 
                                                                         513
 
 
 
           1  Joshua," did you know who Joshua was?
 
           2  A.  I presumed it was the son of a law enforcement officer, but
 
           3  I did not know who, no.
 
           4  Q.  You don't have a son named Joshua?
 
           5  A.  No.
 
           6  Q.  When did you start monitoring the Cypherpunks mail list?
 
           7  A.  Probably late -- mid to late '97.
 
           8  Q.  So this was a couple of years prior to Mr. -- to these
 
           9  present acts that Mr. Bell is under prosecution for?
 
          10  A.  Yes.
 
          11  Q.  Now, you indicated that you received a facsimile dated
 
          12  10/31/2000 which was a response facsimile to yours.
 
          13  A.  I don't think --
 
          14  Q.  That was a bad question, actually.  Let me rephrase it.
 
          15      You sent a letter or a facsimile to Mr. Solovy, who was the
 
          16  attorney at that time who represented Mr. Bell.
 
          17  A.  In July I had sent a -- that fax with my fax cover sheet to
 
          18  Mr. Solovy, yes.
 
          19  Q.  And that -- that was related to the four firearms?
 
          20  A.  I think at the time it was related to all the property, or
 
          21  the majority of the property, because in July I hadn't returned
 
          22  any of it, or hadn't returned most of it yet.
 
          23  Q.  In fact, you still haven't returned two of the computers
 
          24  that were seized in 1997.
 
          25  A.  Right.  We had one of them in here the other day for the
 
 
 
 
 
                                                                         514
 
 
 
           1  testimony.
 
           2  Q.  Now, then, on October 31st, Mr. Bell sent the facsimile to
 
           3  you which we've seen here with the handwriting on it.
 
           4  A.  Yes.
 
           5  Q.  Is that correct?  Did Mr. Bell ever direct any other
 
           6  facsimile to you, that you're aware of?
 
           7  A.  No.
 
           8  Q.  So that was the only one instance?
 
           9  A.  The only fax.
 
          10  Q.  Now, does -- are you aware that you can send facsimiles by
 
          11  computer?
 
          12  A.  Yes.
 
          13  Q.  You can scan and -- you can scan documents onto a computer
 
          14  and then facsimile it from a computer.
 
          15  A.  Yes.
 
          16  Q.  And you're aware that Mr. Bell's computer had cable access,
 
          17  not telephone access.
 
          18  A.  Right.
 
          19  Q.  You were present at the November 6th search of Mr. Bell's
 
          20  residence.
 
          21  A.  Yes.
 
          22  Q.  Now, you indicated that when the tracking device was put on
 
          23  Mr. Bell's car there was a list of persons that you were
 
          24  concerned that he might injure or harm in some way.
 
          25  A.  Yes.
 
 
 
 
 
                                                                         515
 
 
 
           1  Q.  Your name was on the list.
 
           2  A.  Actually, many Jeff Gordons were on the list.
 
           3  Q.  All right.  And Mike McNall's name was on the list.
 
           4  A.  Yes.
 
           5  Q.  You told us about Mr. Groener and Mr. Andrews.  They live
 
           6  next door to each other.
 
           7  A.  Yes.
 
           8  Q.  Who else was on the list?
 
           9  A.  Peter Avenia was one, Mr. Bell's prior attorney.
 
          10  Q.  Anyone else?
 
          11  A.  Yes.  There was another -- I believe there was another
 
          12  defense attorney that had somehow been involved in his case that
 
          13  he had been looking up his address to.
 
          14  Q.  Anyone else, that you can recall?
 
          15  A.  I believe there were several more, but I can't remember who
 
          16  right now.
 
          17  Q.  Now, you obtained a no-contact order at some point.
 
          18  A.  Yeah.  An anti-stalking order, I believe.
 
          19  Q.  And that was after Mr. Bell was actually in custody and
 
          20  arrested on these charges?
 
          21  A.  Yes.
 
          22  Q.  But not prior to his arrest?
 
          23  A.  No.
 
          24  Q.  Now, you've referred to his -- Mr. Bell's spiral notebook as
 
          25  a stalking diary.
 
 
 
 
 
                                                                         516
 
 
 
           1  A.  Yes.
 
           2  Q.  Does it say "stalking diary" on it?
 
           3  A.  No.
 
           4  Q.  Those are your words, a stalking diary?
 
           5  A.  I usually don't use the word "diary."  I usually refer to it
 
           6  like a stalking notebook.
 
           7  Q.  Does it have information that Mr. Bell has accumulated over
 
           8  -- since his release from custody?
 
           9  A.  Yes.
 
          10  Q.  You have indicated that the DMV records are not available to
 
          11  private citizens unless they meet certain statutory categories,
 
          12  such as businessman for marketing purposes, things like that.
 
          13  A.  Correct.
 
          14  Q.  When did those laws go into effect?
 
          15  A.  A couple of years ago, I think.
 
          16  Q.  Do you know when?
 
          17  A.  Not off hand, no.
 
          18  Q.  Did you speak to the individual who sold Mr. Bell the DMV
 
          19  database CD-ROM?
 
          20  A.  Yes.  Or -- at least one of them, yes.
 
          21  Q.  And when an individual purchases one of those by statute,
 
          22  aren't they supposed to sign a certain form?
 
          23  A.  I don't know whether -- I don't believe the statute
 
          24  specifically requires the form to be signed, but this individual
 
          25  wanted people to sign it, yes.
 
 
 
 
 
                                                                         517
 
 
 
           1  Q.  Was he able to produce it, the form that Mr. Bell signed?
 
           2  A.  No.
 
           3           MR. LEEN:  One second.
 
           4      No further questions.  Thank you.
 
           5           THE COURT:  Redirect.
 
           6           MR. LONDON:  Very briefly,
 
           7                       REDIRECT EXAMINATION
 
           8  BY MR. LONDON:
 
           9  Q.  Agent Gordon, when you send a facsimile using a computer, as
 
          10  opposed to a stand-alone fax machine, you're doing it from the
 
          11  computer that is essentially functioning as a fax machine,
 
          12  correct?
 
          13  A.  Yes.
 
          14  Q.  And, in fact, doesn't a computer that can do that have all
 
          15  of the technology that a stand-alone fax machine has built into
 
          16  it?
 
          17  A.  For sending the fax.  It might not have the same printing
 
          18  capabilities.
 
          19  Q.  All right.  But if Mr. Leen asked you if it was possible or
 
          20  suggested that it was possible that Mr. Bell might have scanned
 
          21  your cover sheet into his computer with his handwritten notes on
 
          22  it and then sent it via his computer as opposed to a stand-alone
 
          23  separate fax machine and it was that way that the note had been
 
          24  sent.
 
          25  A.  Well, it couldn't have been sent over a cable modem because
 
 
 
 
 
                                                                         518
 
 
 
           1  at some point it had to go through the phone lines because my
 
           2  fax machine is not hooked to the Internet.  It's only hooked to
 
           3  the phone line.  So there's no way that that fax can be sent to
 
           4  my fax machine without using the phone lines.
 
           5  Q.  In the 1997 undercover work by Mr. Walsh of the Multnomah
 
           6  County, so-called, Common Law Court, was there any political
 
           7  motivation ever discussed, that you're aware of, for the
 
           8  infiltration, as it's been termed, of that group?
 
           9  A.  No.  And, in fact, the decision to have him go to the court
 
          10  was made only because that was the only way we could think of to
 
          11  get him in contact with Mr. Bell to find out what was going on.
 
          12  Q.  Did the decision to investigate Mr. Bell or try to find out
 
          13  more about him in '97 depend on Assassination Politics or upon
 
          14  Operation Locate IRS?
 
          15  A.  It was probably a combination of both.  The fact that he was
 
          16  on the one hand proposing, or at least discussing the
 
          17  assassination of the government officials, and in particular tax
 
          18  agents, as a, you know, a philosophy, and at the same time what
 
          19  was apparent to us, imple- -- taking steps towards that by
 
          20  actually gathering up the names and home addresses which was, if
 
          21  you were going to be implementing or if you were going to try to
 
          22  get a jump start by killing off some agents to start the
 
          23  assassination process, that would be the first step.
 
          24  Q.  I guess another way to ask the question is, if you hadn't
 
          25  known about Operation Locate IRS but you had known that you had
 
 
 
 
 
                                                                         519
 
 
 
           1  simply the author here of an essay entitled "Assassination
 
           2  Politics," that's all you had known, would you have decided to
 
           3  open an investigation as a matter of internal security for the
 
           4  Internal Revenue Service?
 
           5  A.  No.  I -- you know, in just reading the Internet as a casual
 
           6  user, even, I come across inflammatory anti-government rhetoric
 
           7  all the time.  It doesn't make me happy and sometimes it's, you
 
           8  know, upsetting, but we don't investigate that.  It was the acts
 
           9  in particular of gathering up the names and home addresses of
 
          10  this operation that was apparently going on with the common law
 
          11  court on top of the assassination plan or discussion that made
 
          12  it -- got it to the point that we needed to investigate.
 
          13  Q.  As a law enforcement officer, are you legally permitted to
 
          14  access various databases as a legitimate investigative tool?
 
          15  A.  Yes.
 
          16           MR. LONDON:  Nothing further.
 
          17           THE COURT:  Recross.
 
          18           MR. LEEN:  No further questions, Your Honor.
 
          19           THE COURT:  The witness may step down.
 
          20      We will take a 15 minute recess.
 
          21      Jury is cautioned, please do not discuss the case among
 
          22  yourself or with anyone.
 
          23      Please go to the jury room.
 
          24      (Jury excused at 10:50 a.m.)
 
          25           THE COURT:  Anything to take up, either party?
 
 
 
 
 
                                                                         520
 
 
 
           1           MR. LEEN:  No, Your Honor.
 
           2           THE COURT:  All right.
 
           3      (Recessed at 10:50 a.m.)
 
           4      (Jury not present; 11:15 a.m.)
 
           5           THE COURT:  Where are we?
 
           6           MR. LONDON:  Your Honor, I am almost ready to rest.  I
 
           7  just wanted do briefly recall Agent Gordon to the stand for two
 
           8  or three short questions.
 
           9           THE COURT:  Then what's going to happen?
 
          10           MR. LONDON:  Then we're going to rest.  And then I
 
          11  understand Mr. Leen has some motions to be taken up outside the
 
          12  presence of the jury.
 
          13           THE COURT:  Bring the jury.
 
          14      (Jury present; 11:16 a.m.)
 
          15           THE COURT:  Jury's returned.
 
          16      Government.
 
          17           MR. LONDON:  Yes.  Just a few final questions of Agent
 
          18  Gordon.
 
          19           THE COURT:  Are you recalling the witness?
 
          20           MR. LONDON:  We're recalling Agent Gordon.
 
          21           THE COURT:  All right.
 
          22            JEFFREY GORDON, PLAINTIFF'S WITNESS, RECALLED
 
          23                         DIRECT EXAMINATION
 
          24  BY MR. LONDON:
 
          25  Q.   Agent, just a reminder, you are still under oath.  I just
 
 
 
 
 
                                                                         521
 
 
 
           1  want to ask you one or two questions.
 
           2      When you were present at the search warrant at Mr. Bell's
 
           3  residence on November 6th, did you observe a fax machine next to
 
           4  his computer?
 
           5  A.  Yes, I did.
 
           6  Q.  Where in the house was this?
 
           7  A.  I noticed one in the upstairs next to the computer
 
           8  between -- there's like a bar between the kitchen and the dining
 
           9  room area.
 
          10  Q.  All right.  Now, the fax message that you received at your
 
          11  office for which there's a telephone record showing it as a
 
          12  telephone transmission from Mr. Bell's residence, could that be
 
          13  shown on the telephone record, if that fax had been sent from a
 
          14  computer other than through a phone line?
 
          15  A.  Well, no.  I mean, it clearly shows on the Exhibit 178 on
 
          16  the phone bill that the phone -- the phone call that we received
 
          17  that generated the fax came to my fax machine, (503) 326-2246
 
          18  from Mr. Bell's residence, so it couldn't have come through a
 
          19  cable modem.  It has to be coming through the phone lines at the
 
          20  residence.
 
          21  Q.  All right.  You had a chance to observe the satellite
 
          22  display, the tracking display for the tracking device for
 
          23  November 10th when it moved from the vicinity of Mr. Bell's home
 
          24  on Corregidor in Vancouver and went to the McNall residence on
 
          25  South Clackamas River Drive, correct?
 
 
 
 
 
                                                                         522
 
 
 
           1  A.  Yes.
 
           2  Q.  And it appeared at all relevant times to be traveling on
 
           3  roads or the road systems, correct?
 
           4  A.  Yes.
 
           5  Q.  Federal and state.
 
           6  A.  Yes.
 
           7  Q.  Based on your knowledge and experience, are the roads of the
 
           8  United States and the states used for the purpose of conducting
 
           9  interstate commerce?
 
          10  A.  Yes, they are.
 
          11           MR. LONDON:  Nothing further.
 
          12           THE COURT:  Cross-examination.
 
          13           MR. LEEN:  No questions.
 
          14           THE COURT:  The witness may step down.
 
          15      (Witness excused.)
 
          16           THE COURT:  Next witness.
 
          17           MR. LONDON:  The United States rests.
 
          18           THE COURT:  Okay.
 
          19           MR. LEEN:  Your Honor, the defense would like to make
 
          20  some motions outside the jury's presence.
 
          21           THE COURT:  How long do you think it's going to take?
 
          22           MR. LEEN:  Ten minutes.
 
          23           THE COURT:  Please go back to the jury room.  Still do
 
          24  not discuss the case among yourselves or with anyone else.
 
          25      (Jury excused; 11:20 a.m.)
 
 
 
 
 
                                                                         523
 
 
 
           1           THE COURT:  Mr. Leen.
 
           2           MR. LEEN:  Yes.
 
           3           THE COURT:  Before, the court wishes to put something
 
           4  on the record.
 
           5           MR. LEEN:  Yes, sir.
 
           6           THE COURT:  The court -- the record should reflect the
 
           7  court has observed the defendant and defendant's counsel, Mr.
 
           8  Leen, discuss the testimony of each and every witness called by
 
           9  the government in this case.  The conversations and the
 
          10  exchanges between the defendant and his counsel always appeared
 
          11  to be congenial to the court, and the court considers that the
 
          12  defendant has cooperated and participated with his attorney in
 
          13  his defense.
 
          14      What have you got to say?  What are your motions, Mr. Leen?
 
          15           MR. LEEN:  Yes, Your Honor.  I would just like to
 
          16  respond to the court's comment.
 
          17           THE COURT:  It doesn't call for a response.
 
          18           MR. LEEN:  Yes, sir.
 
          19      Rule 20 -- the defense makes a Rule 29 motion for verdict of
 
          20  acquittal.
 
          21           THE COURT:  You had better go to the podium.
 
          22           MR. LEEN:  Oh, yes, sir.
 
          23      Thank you, Your Honor.
 
          24      We are now at the end of the state's case in chief.  The
 
          25  defense would move for a verdict of acquittal pursuant to Rule
 
 
 
 
 
                                                                         524
 
 
 
           1  29.  As to each and every count of the indictment -- of the
 
           2  superseding indictment the defense would submit that there is
 
           3  insufficient evidence as a matter of law to make a prima facie
 
           4  case.
 
           5      As it relates to count one -- we would also -- well, I will
 
           6  just start with the sufficiency.
 
           7      There was insufficient evidence that Mike McNall was in
 
           8  reasonable fear of death or serious bodily injury to himself or
 
           9  to his immediate family based on the evidence that was adduced
 
          10  during his examination.
 
          11           THE COURT:  Wait a minute.  Why don't we go through
 
          12  each count so I can keep track of your argument.
 
          13           MR. LEEN:  Okay.
 
          14           THE COURT:  Under the superseding indictment.
 
          15           MR. LEEN:  Yes, sir. And I will start with count one.
 
          16           THE COURT:  All right.
 
          17           MR. LEEN:  As to count one, we have two reasons why we
 
          18  believe it should be dismissed.  One has to do with sufficiency,
 
          19  the other has to do with constitutionality.
 
          20      As it relates to sufficiency, Mr. McNall, I believe,
 
          21  testified that Mr. Bell's behavior caused him to have concerns.
 
          22  I don't believe that that's sufficient from which a jury could
 
          23  conclude or from which the court could conclude that there has
 
          24  been a prima facie showing that he was in reasonable fear of
 
          25  death or serious bodily injury to himself and to his immediate
 
 
 
 
 
                                                                         525
 
 
 
           1  family.
 
           2      Also, as it relates to count one, we -- we would submit that
 
           3  count one is an unconstitutional exercise of the commerce power
 
           4  and therefore should be dismissed as an unconstitutional charge.
 
           5           THE COURT:  That motion will be denied.
 
           6           MR. LEEN:  As to count two, we would submit that as a
 
           7  matter of law there is insufficient evidence to establish that
 
           8  Mr. Bell traveled across the state line with the intent to
 
           9  injure or harass Jeff Gordon, and also that there was -- as a
 
          10  matter of constitutional law, that count two, which is the same
 
          11  statute as count one, but we will adopt that same argument, was
 
          12  an unconstitutional exercise of the commerce clause.
 
          13           THE COURT:  Well, if the question of constitutionality
 
          14  to the first count applies to count one, doesn't it apply to all
 
          15  the counts?
 
          16           MR. LEEN:  I would think so.  But I would raise it
 
          17  anyway.
 
          18           THE COURT:  Same ruling.
 
          19           MR. LEEN:  Yes, sir.
 
          20           THE COURT:  On the constitutionality.
 
          21      Next?
 
          22           MR. LEEN:  As to count three, Your Honor, there are a
 
          23  couple of arguments.  First, count three requires that the
 
          24  defendant use a facility in interstate commerce, and I think
 
          25  that a telephone line would qualify for that, to engage in a
 
 
 
 
 
                                                                         526
 
 
 
           1  course of conduct.  There has been testimony of one specific
 
           2  isolated instance where a facsimile line was used and a
 
           3  telephone line was used.  We would submit that that does not --
 
           4  a single isolated instance does not constitute a course of
 
           5  conduct.
 
           6      We would also argue that the statute, which is a different
 
           7  statute than the one in count one and count two, is an
 
           8  unconstitutional exercise of the commerce clause.
 
           9           THE COURT:  Same ruling as to constitution.  I will
 
          10  deny that.
 
          11      Let me ask that question.  Is there some law out there that
 
          12  shows the number that must be made, telephone calls, to
 
          13  constitute a pattern or course of conduct?
 
          14           MR. LEEN:  Well, pattern in other criminal statutes
 
          15  requires two or more.  Some require three.  But a course of
 
          16  conduct, we would submit as a matter of law, is more than a
 
          17  single instance.  If the congress wanted to say --
 
          18           THE COURT:  I can't threaten you, as a matter of law,
 
          19  by one phone call?
 
          20           MR. LEEN:  You can, but that doesn't constitute a
 
          21  course of conduct.  It would be a different statute you would
 
          22  have to use.
 
          23           THE COURT:  Isn't that a question of fact for the jury
 
          24  instead of law?
 
          25           MR. LEEN:  I think it's a question -- there has to be
 
 
 
 
 
                                                                         527
 
 
 
           1  two or more to constitute a course of conduct.
 
           2           THE COURT:  Go ahead.
 
           3           MR. LEEN:  As to count three, this was an amendment to
 
           4  what is charged in count one and count two, and our argument --
 
           5  and I filed a memorandum on the point.  I feel that it's -- the
 
           6  statute, the indictment in count four fails to comply with the
 
           7  requirement of Rule 7(a), I believe it is -- I will just double
 
           8  check.  I don't have it here, but the indictment requires that
 
           9  it track the statute and allege each and every material element
 
          10  of the offense.  While count four tracks the 1996 statute, it
 
          11  does not track the 199 -- the 2000 statute.  The 2000 statute
 
          12  does not say --
 
          13           THE COURT:  Mr. Leen, let's do this.
 
          14           MR. LEEN:  Yes.
 
          15           THE COURT:  Are you going to present any evidence?
 
          16           MR. LEEN:  We will present a case, yes.
 
          17           THE COURT:  You will.  Let's do this.  Let's dismiss
 
          18  the jury and have them come back at one o'clock.  Instead of
 
          19  having them sitting there.
 
          20           MR. LEEN:  Sure.
 
          21           THE COURT:   Bring them back for two minutes.
 
          22      Tell them to go to jury -- go to lunch, do not discuss the
 
          23  case among themselves or anyone else.  Be back in the jury room
 
          24  at one o'clock.
 
          25      (Mr. Leever excused the jury.)
 
 
 
 
 
                                                                         528
 
 
 
           1           THE COURT:  Go ahead.
 
           2           MR. LEEN:  It does not track the statute, Your Honor.
 
           3  It requires that Mr. Bell did travel in interstate commerce, and
 
           4  the indictment alleges that he merely traveled from a state line
 
           5  -- across a state line from one state to another.
 
           6      Now, the prosecutor has argued to the court, and the court
 
           7  has pointed out, that the -- that courts in this circuit and
 
           8  other circuits have said crossing from one state to another
 
           9  constitutes the same thing as interstate commerce, but the
 
          10  statute -- excuse me -- but the indictment does not allege
 
          11  that.  And so while it's a question of fact from which the jury
 
          12  could find that, it doesn't allege the element of interstate
 
          13  commerce.
 
          14      Also, Mr. Mueller was completely unaware of the fact of the
 
          15  travel, completely unaware of whatever Mr. Bell's intent for
 
          16  doing the traveling, until he was notified, I think several
 
          17  days, if not weeks, later.  And so as far as -- as far as Mr.
 
          18  Mueller was concerned, there was no crime, that he had a
 
          19  reasonable fear to be of death or serious bodily injury to
 
          20  himself or his family, until such time as he was notified by
 
          21  Agent Gordon that he should be in reasonable fear because of
 
          22  what Mr. Bell's activities were.
 
          23      And I would just adopt that argument again as it relates to
 
          24  Mike McNall in count one.  He was completely unaware of any of
 
          25  Mr. Bell's activities until notified days, if not weeks, later
 
 
 
 
 
                                                                         529
 
 
 
           1  by Agent Gordon.
 
           2      Finally, as to count five, we just -- the same arguments
 
           3  apply as to the 2000 statute.  It doesn't -- the indictment,
 
           4  which is based on the 2000 statute.  It does not allege travel
 
           5  in interstate commerce.  It merely alleges in the charging
 
           6  language in count five that he traveled from one state to
 
           7  another, and that Agent McNall did not testify to facts
 
           8  sufficient from which it could be concluded that he was in
 
           9  reasonable fear of death or serious bodily injury to himself or
 
          10  his immediate family.  Also, he was unaware of Mr. Bell's
 
          11  activities until notified by Jeff Gordon days, if not weeks,
 
          12  later.
 
          13           THE COURT:  Okay.  Government.
 
          14           MR. LEEN:  May I also make my motion for mistrial?
 
          15      I renew my motion for mistrial that I have made during the
 
          16  course of the trial, renew it again at this time.
 
          17           THE COURT:  All right.
 
          18           MR. LEEN:  Thank you.
 
          19           MR. LONDON:  Your Honor, with regard to the
 
          20  awareness --
 
          21           THE COURT:  Go to the podium.
 
          22      Go to the podium, counsel.
 
          23           MR. LONDON:  With regard to the awareness of the
 
          24  victims, there's nothing --
 
          25           THE COURT:  Let's take them as they come.  Count one.
 
 
 
 
 
                                                                         530
 
 
 
           1           MR. LONDON:  I won't address the constitutionality or
 
           2  commerce clause issue in view of the fact that the court appears
 
           3  to have decided on that.
 
           4           THE COURT:  Um-hmm.
 
           5           MR. LONDON:  The allegation is there's insufficient
 
           6  evidence of fear by Mr. McNall.  That was the first basis of an
 
           7  alleged deficiency in proof.
 
           8      Mr. McNall not only testified that he was concerned, but he
 
           9  testified as to a number of steps that he took in reaction to
 
          10  learning that Mr. Bell had drawn a beat on him, was trying to
 
          11  find his house, and had actually found the last residence that
 
          12  he had lived at before moving to his current residence.  He
 
          13  testified about discussing added security measures with his
 
          14  agency, ATF.  He changed the travel plans to be able to stick
 
          15  around.  He testified about at least one work-related trip that
 
          16  he decided to forgo so that he could be there to protect his
 
          17  family.
 
          18      I think that you can certainly interpolate from those steps
 
          19  the fact that he was extremely concerned and fearful about this
 
          20  gentleman's intentions towards him.
 
          21      With regard to whether he ever would have learned about Mr.
 
          22  Bell's stalking of him without being notified by Chris Groener
 
          23  that he had shown up at the house, or without being notified by
 
          24  Jeff Gordon that there were emails up there on the Internet
 
          25  talking about him and Ryan Lund, that's irrelevant.  There's
 
 
 
 
 
                                                                         531
 
 
 
           1  nothing in the statute that requires that the victim learn of
 
           2  this until, unfortunately, it's too late, when the guy shows up
 
           3  on his doorstep.  The critical thing is, if it's reasonable for
 
           4  the victim to have found out in the way he did, then
 
           5  unfortunately, Mr. Bell has to take his victim's awareness in
 
           6  the way that he finds them.
 
           7      Mr. Bell was posting things publicly to the Internet.  He
 
           8  knew from his prior prosecution and from the investigation that
 
           9  law enforcement was watching what he was doing on the Internet.
 
          10  You can't -- you can't go out there and do this stuff and think
 
          11  that there's no chance that your victims are going to find out
 
          12  until it's too late.
 
          13           THE COURT:  Are you saying that there's nothing in the
 
          14  statute that says that -- under the stalking statute that says
 
          15  that somebody gets the first bite?
 
          16           MR. LONDON:  What I'm saying is that there's nothing
 
          17  that says under the stalking statute that the victim can't learn
 
          18  about the stalking --
 
          19           THE COURT:  Well, what I'm asking --
 
          20           MR. LONDON:  -- by being notified by law enforcement.
 
          21           THE COURT:  What I'm saying is, when I say the first
 
          22  bite, the alleged stalker, surely under the statute, doesn't get
 
          23  a chance to physically do something to the person, are they?
 
          24           MR. LONDON:  That is exactly my point.
 
          25           THE COURT:  That's what I mean by the first bite.
 
 
 
 
 
                                                                         532
 
 
 
           1           MR. LONDON:  Right.  The first bite.  The rest is --
 
           2           THE COURT:  So what you're saying, it doesn't make any
 
           3  difference how the target of the alleged stalker finds out about
 
           4  it.  The fact he does find out about it is sufficient under the
 
           5  statute.
 
           6           MR. LONDON:  Yes, Your Honor.
 
           7           THE COURT:  Okay.
 
           8           MR. LONDON:  So that goes not only for Mr. McNall, who
 
           9  learned in two different ways, one when Chris Groener called him
 
          10  up and said Mr. Bell had been at in his back yard, but also when
 
          11  Agent Gordon notified him that his name, McNall's name, was
 
          12  showing up in emails posted to the Internet by the defendant.
 
          13      With regard to Mr. Mueller, the gentleman in Bend who Mr.
 
          14  Bell outed as a CIA agent, true enough, he never knew about Mr.
 
          15  Bell's activities until he was notified by law enforcement, but
 
          16  once again, Mr. Bell has to take his victims as he finds them,
 
          17  and it's a legitimate thing for law enforcement to notify
 
          18  somebody before it's too late that he is the subject of an
 
          19  excessive campaign by an individual to intimidate or harass him
 
          20  by outing him as a CIA agent and posting that on the Internet
 
          21  for all the world to see.
 
          22      It's a curious argument that is made because if Mr. Bell --
 
          23  if law enforcement waited, if we were aware of what this
 
          24  gentleman was doing and we did not notify potential victims of
 
          25  what he was doing and then someone got hurt, can there be any
 
 
 
 
 
                                                                         533
 
 
 
           1  doubt that the victims' families would be suing us for
 
           2  malfeasance of duty?
 
           3           THE COURT:  Let me ask a question.  So the government's
 
           4  position on all five counts -- let me ask you this.  Has the
 
           5  writing -- what's the name of it, that's been circulated over
 
           6  the Internet?
 
           7           MR. LONDON:  His essay originally?
 
           8           THE COURT:  Uh-huh.
 
           9           MR. LONDON:  It's Assassination Politics.  It's out
 
          10  there on the Internet.
 
          11           THE COURT:  In the government's opinion, is that
 
          12  sufficient to put people on the alert?
 
          13           MR. LONDON:  Absolute ---it's sufficient to put people
 
          14  on the alert.  I wouldn't say that if that's all that he had
 
          15  done that it would be sufficient for us to charge him with
 
          16  anything, unless he coupled it with a reference to a particular
 
          17  individual.
 
          18           THE COURT:  So there was some sort of overt act, no
 
          19  matter how subtle, to connect somebody with it?
 
          20           MR. LONDON:  That -- the continuing availability of
 
          21  Assassination Politics on the Internet and his continuing
 
          22  reference in emails to people to go look it up on the Internet
 
          23  is certainly an overt act in furtherance of this kind of
 
          24  stalking, I think, but we don't rely on that for our proof in
 
          25  this case.  We rely on much more immediate overt acts of his
 
 
 
 
 
                                                                         534
 
 
 
           1  showing up at people's homes and his running reams of database
 
           2  searches and printouts for them.
 
           3           THE COURT:  Well, that's a direct overt act that you're
 
           4  talking about.
 
           5           MR. LONDON:  Yes.
 
           6           THE COURT:  Can't there be subtle acts?
 
           7           MR. LONDON:  Yes.
 
           8           THE COURT:  That this jury can consider.  They can
 
           9  consider both direct -- for the purpose of the defendant's
 
          10  arguments to dismiss, there's insufficient evidence on which a
 
          11  reasonable juror could disagree, is that correct?
 
          12           MR. LEEN:  I say -- that's what we have said, Your
 
          13  Honor, yes.
 
          14           THE COURT:  The defendant's motions to dismiss on
 
          15  counts one, two, three, four, five will be dismissed.
 
          16      Now where are we?
 
          17           MR. LEEN:  We're at the beginning of the defendant's
 
          18  case, Your Honor.
 
          19           THE COURT:  All right.  Does the defendant wish to
 
          20  testify?
 
          21           MR. LEEN:  Yes.
 
          22           THE COURT:  Okay.  How does he wish to testify?  It's
 
          23  my understanding that you might want to use demonstrative
 
          24  evidence.
 
          25           MR. LEEN:  He's indicated he would like to --
 
 
 
 
 
                                                                         535
 
 
 
           1           THE COURT:  Which means he will be off that witness
 
           2  stand.
 
           3           MR. LEEN:  Yes, sir.
 
           4           THE COURT:  With a United States marshal right next to
 
           5  him.
 
           6           MR. LEEN:  That's understood.
 
           7           THE COURT:  So how are we going to work it?
 
           8           MR. LEEN:  If he uses the blackboard somewhat near
 
           9  where it actually is right now, the marshal could be seated in
 
          10  the chair back there and be seated there.
 
          11           THE COURT:  Without -- without asking what he's going
 
          12  to put on there --
 
          13           MR. LEEN:  Yes, sir.
 
          14           THE COURT:  What we're going to do, we're going to use
 
          15  butcher paper on one of those easels.
 
          16           MR. LEEN:  All right.
 
          17           THE COURT:  And whatever he tends to put on, he's going
 
          18  to put it on out of the presence of the jury.  We will provide a
 
          19  pointer.
 
          20           MR. LEEN:  Yes, sir.
 
          21           THE COURT:  Because I want him on the witness stand.
 
          22           MR. LEEN:  Is it possible that he could have a pad
 
          23  to --
 
          24           THE COURT:  I just do not trust him because of his past
 
          25  practices as to the security of everyone in this courtroom.  I'm
 
 
 
 
 
                                                                         536
 
 
 
           1  not saying he can't do it.  But I want the marshals there at
 
           2  every instance, close by.
 
           3           MR. LEEN:  It's understood, Your Honor.
 
           4           THE COURT:  So if he has something he wants to put on
 
           5  there, have him draw it up, without the presence of the jury,
 
           6  have him put it on there, and then he can refer to it.
 
           7           MR. LEEN:  Okay.  Just a suggestion, is it possible
 
           8  that he could be brought back about 15 minutes before we start
 
           9  so that he could, with the marshal there, have him put it on
 
          10  there?
 
          11           THE COURT:  Just have him here at one o'clock.
 
          12           MR. LEEN:  The defendant would also --
 
          13           THE COURT:  Can he take the butcher pad to the lockup
 
          14  room?
 
          15           DEPUTY MARSHAL:  Yes, Your Honor.
 
          16           MR. LEEN:  Would he be allowed to have access to both a
 
          17  marker and a pen so that he could write some notes and also --
 
          18           THE COURT:  This is up to the marshals.  They are in
 
          19  charge of his security.
 
          20           MR. LEEN:  I think it requires authorization from the
 
          21  court.  Otherwise they will not allow him to have a writing
 
          22  instrument.
 
          23           THE COURT:  What will the marshals permit?
 
          24           DEPUTY MARSHAL:  We can provide what he needs, both pen
 
          25  and marker, Your Honor.
 
 
 
 
 
                                                                         537
 
 
 
           1           THE COURT:  All right.
 
           2           MR. LEEN:  That would be fine.
 
           3      Your Honor, the defendant indicates that he needs his notes
 
           4  from SeaTac before he can testify.
 
           5           THE COURT:  What?
 
           6           MR. LEEN:  The defendant indicates that he has his
 
           7  notes, which are in a counselor's office pursuant to a prior
 
           8  court order, all notes that he took when he was doing discovery
 
           9  would remain in the counselor's office.  He doesn't have them
 
          10  and he needs them.
 
          11           THE COURT:  And you're just now bringing that up?
 
          12           MR. LEEN:  I just now have been advised that that's
 
          13  what the defendant wants.
 
          14           THE COURT:  When we reconvene at one o'clock, the court
 
          15  is going to ask the defendant, is he prepared to proceed.  And
 
          16  the answer is going to be yes or no.
 
          17           MR. LEEN:  I understand.
 
          18           THE COURT:  Anything else?
 
          19           MR. LEEN:  Not from the defense, Your Honor.
 
          20           MR. LONDON:  No, Your Honor.
 
          21           THE COURT:  All right.  They've got marking pens.  Give
 
          22  the paper to the marshals so they can inspect it, do whatever
 
          23  they have to do.
 
          24      All right, court's in recess.  One o'clock.
 
          25      (Recessed at 11:40)
 
 
 
 
 
                                                                         538
 
 
 
           1                          AFTERNOON SESSION
 
           2      (Jury not present; 1:09 p.m.)
 
           3           THE COURT:  Be seated, please.
 
           4      Where are we?  Jury?
 
           5           MR. LONDON:  Your Honor, before the defendant takes the
 
           6  stand, I would like to advise the court that over the lunch hour
 
           7  the court clerk and the case agent did a review of the exhibits
 
           8  that were offered, and apparently I neglected to actually offer
 
           9  four exhibits for which foundation is laid.  I understand from
 
          10  Mr. Leen that he's not objecting to my offering those at this
 
          11  time.
 
          12           MR. LEEN:  That's correct, Your Honor.
 
          13           MR. LONDON:  We would offer Exhibits 130, 132, 134, and
 
          14  135.
 
          15           MR. LEEN:  I have no objection.  If the court wants to
 
          16  do it outside the jury's presence, that's fine with me.
 
          17           THE COURT:  No.  Do it in front of the jury.
 
          18           MR. LONDON:  All right, Your Honor.
 
          19           THE COURT:  Mr. Leen.
 
          20           MR. LEEN:  Yes, Your Honor.
 
          21           THE COURT:  Does the defendant intend to take the
 
          22  stand?
 
          23           MR. LEEN:  He does, Your Honor.
 
          24           THE COURT:  You're going to question.
 
          25           MR. LEEN:  I am.
 
 
 
 
 
                                                                         539
 
 
 
           1           THE COURT:  He's to stand to the right, right in front
 
           2  of the marshal.
 
           3           MR. LEEN:  Yes, sir.
 
           4           THE COURT:  With the pointer.
 
           5           MR. LEEN:  Okay.
 
           6           THE COURT:  Why don't you turn it around a little so --
 
           7  juror number six and one are going to have a problem.
 
           8      Turn it more.
 
           9           MR. LEEVER:  I'm going to, Your Honor.  I just turned
 
          10  it so that you could see it.
 
          11           THE COURT:  Yeah.  Okay.  That's fine.
 
          12           DEPUTY MARSHAL MOGAN:  Is that okay?
 
          13           THE COURT:  Are you all right?
 
          14           DEPUTY MARSHAL MOGAN:  Yes, Your Honor.
 
          15           THE COURT:  All right.
 
          16      Okay?
 
          17           MR. LEEN:  Yes, Your Honor.
 
          18           THE COURT:  Are you ready for the jury now?
 
          19           MR. LEEN:  Would you like the defendant to take the
 
          20  stand first?
 
          21           THE COURT:  No.
 
          22      Bring the jury.
 
          23           MR. LEEN:  Debby, what numbers do I use?  Do I use --
 
          24           THE CLERK:  You start with A-1.
 
          25           MR. LEEN:  A-1.
 
 
 
 
 
                                                                         540
 
 
 
           1           THE CLERK:  Right.
 
           2      (Jury present; 1:10 p.m.)
 
           3           THE COURT:  The record should reflect all members of
 
           4  the jury are present.
 
           5      Government.
 
           6           MR. LONDON:  Yes, Your Honor.  Before we proceed to the
 
           7  next matter, I would like to move to reopen for the limited
 
           8  purpose of offering four exhibits I neglected to offer into
 
           9  evidence.
 
          10           THE COURT:  All right.  What are they?
 
          11           MR. LONDON:  They would be 130, 132, 134, and 135.
 
          12           MR. LEEN:  I have no objection.
 
          13           THE COURT:  They are admitted.
 
          14      (Exhibits Nos. 130, 132, 134, and 135 were admitted.)
 
          15           THE COURT:  Government rests?
 
          16           MR. LONDON:  Yes, the government rests.
 
          17           THE COURT:  Defendant, first witness.
 
          18           MR. LEEN:  Thank you, Your Honor.
 
          19      We would call the defendant, James Bell.
 
          20           THE COURT:  Okay.
 
          21           THE CLERK:  Raise your right hand.
 
          22                 JAMES DALTON BELL, DEFENDANT, SWORN
 
          23           THE CLERK:  Please state your full name and spell your
 
          24  last name.
 
          25           THE WITNESS:  My name is James Dalton Bell, spelled
 
 
 
 
 
                                                                         541
 
 
 
           1  B-e-l-l.
 
           2                        DIRECT EXAMINATION
 
           3  BY MR. LEEN:
 
           4  Q.  Good afternoon, Mr. Bell.
 
           5      Would you please tell the jury how old you are?
 
           6  A.  Well, as of today, I'm exactly 43 years old.
 
           7  Q.  Mr. Bell, I would like to ask you to tell the jury a little
 
           8  bit about your background.  Where were you born?
 
           9  A.  I was born in Ohio, 1958.  The city was Akron.  Well,
 
          10  actually, it was a suburb called Cuyahoga Falls.  And my father
 
          11  worked at, I believe it was, Goodyear, I think, or a rubber -- a
 
          12  tire company.  Needless to say, I don't remember very much about
 
          13  that time.  But I guess it was a nice place to live.  I drove
 
          14  back by there on the way back from one year in college and drove
 
          15  by the place my parents lived before I was born.
 
          16  Q.  Mr. Bell, where did you go to high school?
 
          17  A.  Shawnee Mission North High School in Kansas.  It's in the
 
          18  northeastern portion of Kansas.  Shawnee Mission is sort of like
 
          19  a general term for a large number of little towns that have
 
          20  eventually run together.  So it's -- I guess it's sort of like
 
          21  the Seattle area where all these little, these -- you know
 
          22  Redmond and Bel-  -- I'm not local, by the way.  I'm from
 
          23  Vancouver, so I don't know the local area.  But the whole place
 
          24  basically ran together years ago, and Shawnee Mission is the
 
          25  general term for a rather large area in the southwest of Kansas.
 
 
 
 
 
                                                                         542
 
 
 
           1  Q.  Where did you go to college, sir?
 
           2  A.  Massachusetts Institute of Technology.  It's a fairly
 
           3  well-known technical college in Cambridge, Massachusetts, which
 
           4  is right across the Charles River from Boston.  MIT has been
 
           5  around for well over a hundred years, and it teaches science and
 
           6  technology.  Its motto is mens et manus; mens meaning science,
 
           7  and manus meaning engineering.  I went there in 1976 to get a
 
           8  degree, and the degree I eventually received from there is
 
           9  chemistry, but I've also taken, from MIT, in addition to all the
 
          10  regular chemistry courses that were required, plus many more
 
          11  that weren't required, I have taken courses in electronics,
 
          12  material science, silicon for semiconductors, and so forth.
 
          13  Physics, many courses in physics.  Computer software, computer
 
          14  hardware.  Optics.  Acoustics.  Various other technical areas.
 
          15  I pretty much took a lot of courses.  Some people focus on a
 
          16  particular area.  I took courses in virtually every area that I
 
          17  could spare the time for.
 
          18      MIT was a great place.  The reason it was such a great
 
          19  place, frankly, is because when I got there, virtually everybody
 
          20  there, in a sense, was like me.  I could have an intelligent
 
          21  conversation with virtually anybody there on virtually any
 
          22  technical subject that I could think of.  Everybody there had a
 
          23  substantial amount to add because of the amount of reading they
 
          24  did.
 
          25  Q.  After you graduated from MIT, where did you go?
 
 
 
 
 
                                                                         543
 
 
 
           1  A.  Well, toward the end of my college career, of course, I --
 
           2  there was a week where they had career day, and, of course, all
 
           3  the company -- you know, companies had sent representatives and
 
           4  agencies, and so forth, to interview various budding graduates,
 
           5  and I, of course, went to the career day, and I wanted to find
 
           6  out where I could find a job.  So I went to the career day and
 
           7  I, I interviewed with a number of people, a number of
 
           8  companies.
 
           9      I interviewed with General Electric, in fact, and talked to
 
          10  them and explained my electronics background.  My very extensive
 
          11  electronics background.  Building computer hardware, electronic
 
          12  circuitry, things called op-amps and SCRs, triacs, transistors,
 
          13  FETS, that kind of thing.  And they were interested in me for
 
          14  the electronics background, but they were also interested in me
 
          15  primarily because I had the chemistry degree, and the
 
          16  combination of being -- having an extreme amount of knowledge in
 
          17  electronics and an extreme amount of knowledge in chemistry is
 
          18  rather rare.  People don't usually have multiple areas where
 
          19  they have large degree experience.
 
          20      In any case --
 
          21  Q.  Did you take a job with someone?
 
          22  A.  Yes, I did.  One of the other organizations I interviewed
 
          23  with was a company called Intel -- I'm sure you've heard of it.
 
          24  They are a big company now, but at the time they were rather
 
          25  small and they were primarily, of course, in Silicon Valley,
 
 
 
 
 
                                                                         544
 
 
 
           1  California, Santa Clara.  They had a facility in Phoenix, I
 
           2  think, but one of their facilities, or sets of facilities, was
 
           3  in Beaverton, Oregon.
 
           4      Well, I interviewed with them, and one of the interviewers,
 
           5  after having heard what my background is in both chemistry and
 
           6  electronics, because Intel does both chemistry and electronics
 
           7  because they build chips, they were very interested to find out
 
           8  that I knew all this material about chemistry and electronics.
 
           9  So the guy asked me, "Well, if you were to work for Intel, where
 
          10  would you want to work?  We have three facilities," he said,
 
          11  "Phoenix, California, and Beaverton, Oregon."  And I said,
 
          12  "Well, frankly, I would rather not go to California."  And the
 
          13  guy looked at me, and he laughed a bit, and he said, "Yeah, I
 
          14  know what you mean."  He says, "Well, how about Oregon?"  I
 
          15  said, "Yeah."  I know a friend, I have an MIT friend who has
 
          16  inadvertently lured me to Oregon by all the wonderful stories
 
          17  I've heard about it.  And I said, "Yeah, I would love to see
 
          18  Oregon."
 
          19      Well, he scheduled a trip where I visited -- I visited
 
          20  Oregon, and I -- a few weeks later, so that -- before I had
 
          21  made -- or actually, after I had made the trip, I believe, an
 
          22  odd thing happened.  Mount St. Helen's blew.  And I sheepishly
 
          23  called the guy back, he was back in Oregon at the time, and I
 
          24  said, "Do I still have a job?"  And he said, "Yeah, our place
 
          25  missed most of the ash."
 
 
 
 
 
                                                                         545
 
 
 
           1      So, yeah, I worked for Intel.  I went --
 
           2  Q.  How long did you work for Intel, sir?