The Science of Entrapment at its most pernicious  

Pages 5121 - 5150 of the Who's Who Worldwide Registry trial transcript contain sixteen examples of how cleverly Watstein, highly-paid government informant who was told that the cost of 'no prison' was maneuvering one WWW Registry employee after another into lies and fraud, failed in his attempt to use his multimillion-dollar con man skills, dangling, pushing, distorting and lying.   All to stay out of prison.

The tapes reveal consistently honest and excellent business practices at Who's Who Worldwide, represented by Annette Haley and others with enthusiastic honesty and cutting-edge business integrity, (Does YOUR organization operate with such commitment to excellence?)   And still, the jury said "Guilty".

Hard to blame them, between efforts to taint the jury and exposing them to such a weighted amount of evidence against one man, with little or none indicating lack of integrity, let alone a crime, regarding the sales defendants.

This organization earned its rank as #1 in the industry. It led the way with a CD-ROM so advanced that the device, in the year 2001, still ranked in the top percentile of all cd-roms for pure utility, ease, and effectiveness.   The postally-infected jury still said "guilty."

Despite the unprecedented package of financial, networking, publicity and other benefits available to members, such as Tribute Magazine, filled to bursting each issue with profiles of and articles by America's seniormost business leaders, each and every one of them a one-or-more-time member of Who's Who Worldwide Executive Club! -- the literally crying jurors voted 'guilty,' tearfully apologizing to defense counsel and defendants before departing the courthouse.

Including but not limited to hearing how he changed the words of each person he was focused upon, each review of tape or transcript reveals deception on the part of the desperate Steven Watstein a/k/a Steven West and so many other names.

Here in this small piece of the transcript from  Feb 20th, separate examples of the taped evidence indicated a scrupulously honest woman doing her job in a conscientious, ethical manner, in accordance with law and good custom, no matter that he's repeatedly dangling a fat juicy sale in front of her, and offering information completely different from what had just been taped, without her knowledge. The way he addresses the Court so arrogantly says much of Watstein's hubris, undermining his own credibility.


1 S T E V E N W A T S T E I N,
2 called as a witness, having been previously
3 duly sworn, was examined and testified as
4 follows:
6 the COURT: You are previously sworn and you are
7 still under oath, Mr. Watstein.
9 THE COURT: Mr. Geduldig, were you still
10 cross-examining?
11 MR. GEDULDIG: I think I was, Judge.
12 THE COURT: You are going to move along, right?
13 MR. GEDULDIG: I am.
16 BY MR. GEDULDIG: 17 Q Mr. Watstein, I think we had given you a copy of the
18 transcript we were looking at the other day?
19 A Yes.
20 Q I have handed up to you 1325, which is the transcript
21 of the conversation you had with Annette Haley on November
22 11th, 1994. If memory serves me correctly, where we
23 finished off yesterday, we were going through whether or
24 not a delicatessen owner was sufficiently prestigious to
24 be in the registry.


1 Do you remember that?
2 A Yes, sir.
3 Q What I would like to do now is turn to page 9 of the
4 transcript.
5 I stand corrected, turn to page -- did we speak
6 about -- did you have a conversation with Ms. Haley on
7 this occasion concerning the benefits you would get as a
8 prosp ective member?
9 A Yes, sir.
10 Q And we read that attribution at the very bottom of
11 page 6, where Annette tells you about the discounts on
12 long distance and international phone calls and such?
13 A I believe so.
14 Q Now, turn to page 7, a quarter of the way down, right
15 after you say, yeah, where there is an attribution to
16 Annette, where she says to you: But let me tell you, for 17 a five-year membership, it's $350 now.
18 Watstein, right.
19 Annette, and $99 in December of 1995 when the
20 registry is released.
21 You see that?
22 A Yes, sir.
23 Q This conversation is November of 1994; is that
24 correct?
24 A Yes.


1 Q She is telling you, you pay 350 now and an additional
2 $99 in approximately 13 months; is t hat right?
3 A Yes.
4 Q And it goes on.
5 Watstein, so, 350 and 99 --
6 Annette, you'll be in there until the year 2000.
7 Watstein, that's pretty good.
8 Annette, or if you want to be in there for the
9 rest of the your life, that's $550 now.
10 Watstein, I think five years is sufficient.
11 Annette, and $99 in December.
12 Watstein, gotcha.
13 You used that phrase a lot, gotcha?
14 A Yes, sir.
15 Q Were you sending a little subliminal message to these
16 people on the phone? 17 A No, sir.
18 Q And you go on with some of the benefits right after
19 the gotcha. Annette says: With the lifetime you will
20 have a choice of a second wall plaque or the CD-ROM
21 software package. It comes free with the lifetime.
22 Watstein, oh, I see.
23 Annette, otherwise, it's $99. If you buy it with
24 the five year it would be $99 .
24 Watstein, oh, I see, for $100 more I get the


1 lifetime and --
2 Annette, exactly. And you'll get the CD-ROM with
3 it.
4 Watstein, so, lifetime is $550, plus $99?
5 Annette, $99 in December of 1995.
6 Watstein, gotcha.
7 You see that?
8 A Yes, sir.
9 Q She is telling you about the split billing, right?
10 A Yes.
11 Q You understood she was talking about split billing,
12 right?
13 A Not as it is defined, but, yes, sir.
14 Q There were going to be two payments?
15 A Yes, sir.
16 Q And she was telling you, if you joined and took the 17 five-year membership, the fee would be, I think she said
18 $550, plus 99, plus an additional charge if you wanted the
19 CD-ROM?
20 A That's correct, sir.
21 Q Okay.
22 She was telling you if you took the lifetime you
23 would get the CD-ROM for free, or an additional plaque if
24 you chose?
24 A Yes, sir.


1 Q That was pretty clear?
2 A I think it was crystal clear, yes, sir.
3 Q Then you go on to a conversation about renewal rates
4 on page 8, virtually in the middle of the page, right
5 after Annette's uh-huh; do you see that?
6 A Uh-huh, yes.
7 Q And Annette says -- I lost it -- she says uh-huh.
8 Watstein, what's your renewal rate? How happy
9 are the members?
10 Annette, everybody.
11 Watstein, everybody renews?
12 Annette, everybody, in fact we do give the
13 people, say they take a five year membership.
14 Watstein, right.
15 Annette, within a year or two, we give them the
16 option of upgrading to a lifetime. 17 Watstein, right.
18 Annette, I would say 85 percent do.
19 Watstein, really?
20 Annette, yep?
21 Watstein, so you would say that in terms of the
22 renewal rate, 95 percent, 100 percent.
23 You saw that?
24 A Yes, sir.
24 Q And she said to you the renewal rate was 85 percent,


1 didn't she?
2 A No, sir.
3 Q Well, she said to you, just above that -- go from the
4 bottom where it is you, Watstein, from the bottom up,
5 Watstein, Annette, Watstein, Annette, all right? So it is
6 the fourth attribution from the bottom. You see that?
7 A Yes.
8 Q Annette says, I would say 85 percent do; do you see
9 that?
10 A I believe it modifies --
11 Q I am asking you if you see it?< BR> 12 A Certainly.
13 Q And the next two attributions are just one word.
14 You say really.
15 She says, yep.
16 then you come in, Watstein, so you would say that 17 in terms of the renewal rate, 95 percent to 100 percent.
18 On the next page Annette says 85 percent, right?
19 A Yes, sir.
20 Q And you heard her when you were talking with her on
21 the phone that day, November 11th, 1994, you heard her say
22 85 percent, did you not?
23 A Yes, sir.
24 Q And you responded by saying 95 to 100 percent; is
24 that right?


1 A Yes, sir.
2 Q Were you trying to mislead her?
3 A No.
4 Q Was there a reason that you purposefully misstated
5 the number she gave you?
6 A Yes.
7 Q You were trying to gotcha her?
8 A No, sir.
9 Q And in any event, after you say 95 to 100 percent,
10 she corrects you and says 85 percent.
11 By the way, when you up that percentage, you
12 specifically mentioned renewal. You said, so you would
13 say in terms the renewal rate, 95 to 100 percent; correct?
14 A Yes, sir.
15 Q She corrects you to 85 percent; right?
16 A Yes, sir. 17 Q She doesn't say to you you are talking about
18 something different than I'm talking about, does she?
19 A No, sir.
20 Q She says 85 percent.
21 Watstein says 85 percent?
22 Annette, yeah.
23 Watstein, wow, that's really good.
24 Annette, renew their member -- in other words,
24 not even renew it, they, umm.


1 Watstein, they pay their dues --
2 THE COURT: You have to slow down, Mr. Geduldig.
3 You have to go much slower than that.
4 First of all, if someone was following you
5 without reading the transcript, as anybody can, they would
6 have a difficult time doing that. Is the reporter
7 certainly is having difficulty.
8 MR. GEDULDIG: I apologize.
9 THE COURT: You have to slow down. You want the
10 jury to hear it and understand it?
11 MR. GEDULDIG: I have been talking to
12 Mr. Trabulus too long. The two of us go, and it is wind.
13 the COURT: When he is asked to, he does slow
14 down.
15 MR. GEDULDIG: And I will try, judgment I
16 apologize. 17 Let me pick it up with Watstein saying wow,
18 that's really good?
19 Annette, renew their number -- I am sorry,
20 member. In other words, not even renew it, they, umm --
21 Watstein, they pay their dues or whatever?
22 Annette, yeah, huh, they upgrade to a life time.
23 Watstein, no kidding.
24 Annette, yeah, we giem the choice to
24 upgrade to a lifetime and almost everybody does.


1 Watstein, 85 percent?
2 Annette, I would say at least.
3 Watstein, so maybe I should go for a lifetime up
4 front here, I guess.
5 Annette, well, it's up to you.
6 Do you see that?
7 A Yes, sir.
8 Q So, she is not even encouraging you to take the
9 lifetime. She is saying to you, do whatever you want to
10 do, it is your choice, right?
11 A That was the tactic, sir, yes.
12 Q She wasn't putting any high pressure on you?
13 A A tactic, yes.
14 Q She didn't say, a great idea, buy the lifetime, soak
15 some more money into this operation, did she?
16 A No, sir. 17 Q She said your choice, w hatever you decide, you do,
18 right?
19 A Her tactic, sir.
20 Q Tactic.
21 Did you ever hear mention from the government or
22 anybody else about a man named Tinny, gray haired man
23 working for Grossman -- I am sorry, Swinney,
24 S W I N N E Y.
24 A There was a gentleman in the witness room with me


1 yesterday, might have been the same gentleman, with gray
2 hair.
3 Q Did he tell you he upgraded?
4 A No, sir.
5 Q He wasn't forced to, he did it on his own?
6 A I have no knowledge of it.
7 Q Upgrading is what she is talking about here, people
8 upgrade?
9 A She is discussing two concepts at the same time, sir.
10 Q Then we go on on the same page in the middle, you are
11 talking, and you say as follows: Yeah, I see.
12 And what does this plaque look like?
13 Before we go on there, had you seen the plaque
14 before you made the phone calls?
15 A I am not sure.
16 Q You can't recall now if you have seen the plaque? 17 A I can't recall.
18 Q You saw the plaque, you just can't recall when you
19 saw it?
20 A That's correct.
21 Q In any event, you go on to say, yeah, I see, and what
22 does this plaque look like? We had a terrible experience
23 here.
24 Annette, the plaque is beautiful. The plaque is
24 really beautiful. It's a marble laminate. It has our


1 seal on it, it would be engaged. It would say, awarded to
2 Chuck C. Sampson, distinguished member of Who's Who
3 Worldwide.
4 Watstein, right.
5 Annette, the member named above is included in
6 the Who's Who Registry.
7 Watstein, right.
8 Annette, and at the bottom of the wall plaque it
9 says: Memberships are limited to those individuals who
10 have demonstrated outstanding leadership and achievement
11 in their occupation, industry or profession. We get
12 letters on it.
13 Watstein, so it's made -- Annette, the wall
14 plaque is beautiful.
15 Watstein, it's made out of marble?
16 Do you see that? 17 A Yes, sir.
18 Q If you go up to where she starts talking about the
19 plaque, about a third of the way up from the bottom, she
20 says the plaque is beautiful, it's really beautiful, it's
21 a marble laminate. You heard her say that?
22 A I don't believe so. There was a pause in the tape at
23 that time.
24 Q It doesn't say pause in the tape?
24 A In the sound.


1 Q A pause in the sound?
2 A Yes.
3 Q You remember the conversation clearly enough now to
4 say there is a pause in the sound over the telephone,
5 that's why you didn't hear marble laminate?
6 A In that particular case, yes, sir.
7 Q It wouldn't be that you were trying to mislead
8 Annette to say, yes, it is a marble plaque?
9 A No, sir.
10 Q You wouldn't do that?
11 A No, sir.
12 Q It would be a gotcha, where you hear what they say
13 but misrepresent what they say, encouraging them to leads
14 you on to do things that you wouldn't want to do?
15 A Is that a question, sir?
16 Q Yes. 17 A The answer is no.
18 Q You didn't do that.
19 So, you didn't hear her say marble laminate, and
20 you said it was made out of marble by mistake, because you
21 had not heard wha t Annette told you?
22 A My recollection is it wasn't clear, sir.
23 Q In any event, Annette having heard you say that it's
24 marble, she corrects you at the top of page 10 and says,
24 no, it's a marble laminate.


1 Watstein, oh, I see.
2 Annette, marble would be too heavy to hang.
3 Watstein, I gotcha.
4 Annette, yeah, it's a marble laminate, it's
5 beautiful.
6 Watstein gotcha.
7 You see that?
8 A Yes.
9 Q She went back and corrected you?
10 A Yes.
11 Q And she didn't want to mislead you?
12 A In that instance, yes.
13 Q Going on the same page 10, talking about networking.
14 Watstein, these are all things by the way,
15 networking, plaques, the double-billing or B billing,
16 these are all things on the long ch ecklist that you and 17 Biegelman worked out; is that right?
18 A I can't answer it with a yes or no, sir.
19 Q There was a long list of things we spoke about
20 yesterday, topics you want to bring up in these telephone
21 conversations, you recall that?
22 A Yes.
23 Q And these things we are going through the tape, the
24 transcript now, those things appear in the long list that
24 you and I talked about yesterday?


1 A Partially.
2 Q I think everyone was on that list.
3 In any event, let's go on.
4 Watstein then says about a quarter of the way
5 down the page, starting after your last gotcha.
6 Annette, and every year it's a little different.
7 Watstein, umm, now let me ask you this: In terms
8 of networking, which is really what the reason I called
9 you back --
10 Annette.
11 That computer package is the best. Now, say you
12 want to know every member in Michigan --
13 A place you are familiar with.
14 Watstein, right.
15 Annette, it would come up. Say you want to know
16 all the CFO's. 17 Watstein, right.
18 Annette, or say you may, don't want to go to the
19 CFOs, say you want to know all the directors that are in
20 Michigan.
21 Watstein, right.
22 Annette, okay. They would all come up. Then you
23 want to zero into a certain area. I want to know all the
24 areas in Michigan that are in the plastics industry. I
24 want to know then, the next one, I want to know all the


1 members that are in Michigan, that are in the plastics
2 industry, that make plastic screws, cause --
3 Watstein, really? No kidding.
4 Annette, different items. There could be plastic
5 bread boxes, plastic furniture. You want somebody that
6 makes screws. Then say you want to talk business on the
7 golf course. I want to know all the members that are
8 directors in Michigan that make plastic screws that play
9 golf.
10 Watstein, I see.
11 Annette, so you can zero in by any criteria with
12 that computer package. You know, how a CD-ROM works.
13 Watstein, oh, oh, sure, of course, of course.
14 She is explaining to you the CD-ROM?
15 A Yes.
16 Q And that's the item if you took the five-year 17 membership, you have to pay the $50 for and get free with
18 the five-year membership?
19 A All right.
20 Q Then you go to the other items we talked about the
21 other day, sucker mailing list.
22 You say at the top of page 1 1.
23 Watstein, let me ask you, in terms of the members
24 in general, am I going to end up on some kind of sucker
24 mailing list here?


1 Annette, no. It is not in libraries, and
2 hopefully, you are not going to, but our members do get,
3 and receive a registry.
4 Let me stop for a second.
5 When you ran your Who's Who, you told prospective
6 customers that your book was in libraries, didn't you?
7 A That is correct.
8 Q And this Who's Who was telling people honestly,
9 truthfully and accurately, that their Who's Who was not in
10 libraries; is that right?
11 A I can't answer with a yes or no, sir.
12 Q That's what Annette just told you, didn't she?
13 A That individual person said that, yes.
14 Q You are saying Annette might say it this w ay and
15 someone else might say it a different way?
16 A Yes, sir. 17 Q You go on, you say, well, the members, I don't mind.
18 Annette, every single person, we have Fortune
19 500, million dollar companies here. Everybody has to be
20 interviewed to be in this registry. Not one person. And
21 there are people you read about in the media, names that
22 you know, companies that you know, they weren't in here
23 unless they were interviewed.
24 Watstein, so The famous people get
24 interviewed.


1 Annette, yeah, everybody.
2 Watstein, really?
3 Annette, everybody.
4 Watstein, let me ask, in terms, so you're not
5 going to rent my name out to someone else?
6 Annette, no, definitely not.
7 Watstein, okay, okay, I just --
8 Annette, our organize -- no.
9 Watstein, we've had some bad experience being
10 telemarketed, people hocking us.
11 You were referring to your own company, I
12 suppose?
13 A No, sir.
14 Q That's the kind of things you did?
15 A We were engaged in telemarketing business in many
16 companies. 17 Q You were engaged in a criminal telemarketing
18 business?
19 A At that point in time, yes.
20 Q Annette goes on.
21 What can I say to you? If we do have a member --
22 Watstein, member, I don't worry about, cause they
23 will have been interviewed.
24 Annette, yeah, but, no, of course not, definitely
24 not, not with people we have, no.


1 Now, when she says what can I say to you if, if
2 we do have a member, and then you cut her o ff.
3 What she was going to tell you is members could
4 conceivably use the names and addresses in the registry
5 and do it as they will, but her company does not sell the
6 names of the members in the registry to outside mailing
7 lists; isn't that right?
8 A Is that a question, sir?
9 Q Yes, is that right?
10 A Was she asking me that, implying that?
11 Q She was about to say that to you when you cut her
12 off?
13 A I don't know what she was about to say.
14 Q You cut her off?
15 A Yes, sir.
16 Q Do you remember that clearly, cutting her off? 17 A Not totally, no, sir.
18 Q You remember the other part about the marble laminate
19 wall?
20 A Yes, sir.
21 Q My question is:
22 When you heard the information coming out of
23 mouth of a telemarketer, like Annette Haley, and knew the
24 conversation was being recorded, and you knew you wouldn't
24 like what they were going to say because it wasn't going


1 to be a gotcha, did you purposefully interrupt the
2 conversation so they would not say the things that you did
3 not want to hear?
4 A No, under any circumstances, sir.
5 Q There was nobody listening to you. Mr. Biegelman was
6 not at your shoulder listening to these conversations when
7 you were having these tape recorded conversations, was he?
8 A No, sir.
9 Q You did it completely on your own?
10 A With the exception of one tape, yes, sir.
11 Q So you sat in a room someplace in Georgia, Florida,
12 or New Jersey, where you happened to be by yourself making
13 these calls?
14 A That's correct, sir.
15 Q And then we go on to seminars, another item on the
16 list. 17 Q This is almost the bottom of the page?
18 A What page?
19 Q Page 11, after the last attribution where Annette
20 said they don't sell the names to outside mailing lists.
21 Watstein, I see.
22 One other question, in terms of getting together
23 with other members -- Annette, yeah, we have business
24 seminars, we had one in December in Vietnam and Hong Kong.
24 Watstein, right.


1 Annette, we, we were having one, I think. I
2 didn't hear anything about it, but I am sure it was a
3 success in South Carolina. We had a golf and tennis
4 tournament combined with some business seminars. So we
5 always have something.
6 Watstein, oh, really?
7 When was the one in South Carolina. That one I
8 would have attended.
9 And that's a subject that you and Biegelman had
10 some discussions about, right?
11 A No, sir.
12 Q In any event, Annette goes on and says, yeah, that
13 was --
14 Watstein, Vietnam is too far for me.
15 Annette, months ago, it was months ago.
16 Watstein, months ago? 17 Annette, no, it was months ago. But I know
18 they're going to be having, you know, when you get that
19 quarterly magazine --
20 You say right.
21 Annette, always read that over. All the
22 information would be in there.
23 Do you see that?
24 A Yes, sir.
24 Q And she is telling you the information regarding


1 seminars and business conferences and golf outings is
2 printed in the publication, Tribute?
3 A Yes, sir.
4 Q And that's where you get your infor mation, and she
5 gets her information?
6 A She didn't say that, sir.
7 Q Didn't she say read over the publication, the
8 magazine? She says, no, it was months ago, but I know
9 they are going to be having, you know, when you get that
10 quarterly magazine? She is talking about the Tribute
11 Magazine, right?
12 A Yes, sir.
13 the COURT: You interrupt and she says always
14 read that over. All that information would be in there.
15 Isn't she referring to the seminars where the
16 company holding information about the seminars being 17 printed in the quarterly magazine?
18 A As far as me obtaining my information, yes, sir.
19 Q You don't know if she got the information from the
20 same place or not?
21 A That is correct, sir.
22 Q The information she gave you about the seminars could
23 well have come from the magazines?
24 A Possibl y.
24 Q You go on talking about famous people.


1 Watstein says, would it list some of the famous
2 people that are members there?
3 Annette, oh, yeah.
4 We have been doing a profile on
24 outstanding
5 members, umm, with their picture, you know, people that
6 maybe have started businesses, that really have
7 outstanding stories. Although we do have the president of
8 Izod -- although we do have the president of Izod, we have
9 the president of Viacom, you know, major, major companies.
10 Watstein, and all those people -- Annette, I'm
11 not supposed to be telling you those names, because it's
12 like marketing, or soliciting.
13 Watstein, no, we don't want you to do that.
14 That was a little tongue and cheek, right? You
15 really did want her to do that?
16 A No, sir. I previously testified to that. 17 Q Annette says, but you will see for yourself.
18 Watstein, but all those people were interviewed
19 by in the same fashion?
20 Annette, yeah.
21 Watstein, no kidding.
22 Annette, everybody had to be interviewed in order
23 to be in the registry.
24 You see that?
24 A Yes, sir.


1 Q And going over to page 13, there is a conversation
2 where she is asking you for some personal information
3 about maybe a fifth, 20 percent, or a quarter of the way
4 down from the top of the page, Annette starts talking and
5 she says, all right, let me just go over a few more things
6 and then you can call me back with the credit number.
7 Watstein, sure.
8 Annette, do you want the lifetime?
9 Watstein, yes, please.
10 Annette, okay, all right. It's Chuck C. Sampson,
11 all right? I'll get the address later, but right now I
12 need the name of a famous business magazine. She coughs.
13 You see how she coughs there, they write it in?
14 A Yes.
15 Q And the parts about the pause you say about the
16 marble plaque, there was no cough there? 17 A I have the voice going down lower, sir.
18 Q Nothing in the transcripts about a malfunction or
19 pause or lowered voice?
20 A My recollection is it was lowered sir.
21 Q Going back to the page, we can look it up.
22 Watstein goes back to the say -- Watstein goes on
23 to say, I guess the Detroit Free Press is the closest I
24 come to.
24 Annette, excuse me?


1 Watstein, Detroit Free Pres s.
2 Annette that's --
3 Watstein, newspaper.
4 Annette.
5 Watstein says Detroit Free Press.
6 Annette, that's --
7 Watstein, a newspaper.
8 Annette, a newspaper.
9 Watstein, newspaper, yes.
10 Annette says, no, I wanted a magazine.
11 Watstein, you know, I really don't read any
12 business magazines. To tell you the truth -- Annette,
13 Success, Incorporated, CEO --
14 Watstein, put down whatever you want. Make it
15 up.
16 You wanted her to do that, didn't you? 17 A It had no importance, sir.
18 Q Of course it does. She puts it down, she is making
19 something up, it is just a shill, meaningless no, merit?
20 A No, sir, it is not a significant issue which magazine
21 a person read.
22 Q Why didn't you just give a magazine?
23 A Unimportant.
24 Q If we are trying to show how meaningless the registry
< BR>
24 is, pointless the interview is, wouldn't it prove your


1 point if she asks for your favorite magazine, if you say
2 make it up, I don't care, and she does it?
3 A I don't think so.
4 Q You don't think so?
5 A No.
6 Q You didn't think to give her any magazine at all?
7 A Not in this case, it was unimportant.
8 Q You were not trying to gotcha, were you?
9 A No.
10 Q In any event, in response to what might be a
11 deceptive act on your part, she says, Fortune.
12 You say put down whatever you want. Make it up.
13 She continues, and says Fortune?
14 You say, you? And Annette says Fortune.
15 Watstein says, sure, make it up, sure.
16 You are insisting she make it up, right? You 17 will not let it go, will you?
18 A Sir, it was ins ignificant, a waste of time.
19 Q Give her a magazine, make it up, Newsweek, the
20 Wharton Business Record or something?
21 A There is no such thing.
22 Q A good reason to give it. That's what you were in
23 the business of, making things up?
24 A No, sir.
24 Q Annette says, sure you can make it up, sure.


1 She says I also need the name of a favorite
2 vacation place.
3 You respond, Iron Ridge in Oak, Michigan, is that
4 right?
5 A Yes.
6 Q And she takes some more information from you.
7 This is a conversation you were recording for
8 Mr. Biegelman?
9 A Yes, sir.
10 Q You were going to write a critique or summary of the
11 circumstances surrounding this tape recorded conversation
12 and send it along with the tape to Mr. B iegelman?
13 A Not necessarily, sir.
14 Q Did you do it in this case?
15 A I have no recollection.
16 Q In any event, you hit virtually all the subjects that 17 you and I discussed, and you said were subject that you
18 were particularly interested in, right?
19 A You said that, sir.
20 Q Well, if I am wrong, say I am wrong.
21 We talked the other day about a list of subjects
22 that you like to bring up in these recorded conversations;
23 is that right?
24 A Part of the subjects, yes, sir.
24 Q And the subjects we mentioned were the percentage


1 accepted; is that right?
2 A Yes, sir.
3 Q And that was discussed here?
4 A I don't recall that.
5 Q The 85 percent, the five percent of the people who
6 were accepted, something l ike that?
7 A Yes, sir.
8 Q And 85 percent renewal rate? We talked about that in
9 this conversation?
10 A Not on that list, sir.
11 Q Let's go down the list. We only hit one so far?
12 A Yes, sir.
13 Q And we talked how people are nominated?
14 A Yes, sir.
15 Q How people are in business?
16 A I don't believe we discussed that. 17 Q Is Who's Who Worldwide Financial stable, not
18 discussed in this tape?
19 A Right.
20 Q Was everybody interviewed was discussed?
21 A Yes, sir.
22 Q The plaque made of marble, was discussed?
23 A Yes, sir.
24 Q Benefits received was discussed?
24 A Yes.


1 Q Is it prestigious, was discussed?
2 A I am not sure it was.
3 Q Remember, deli owners don't belong in the regis ter?
4 A I don't know if we discussed it was prestigious.
5 Q Is that what you said, I am not going to find my name
6 here with a deli owner?
7 A I didn't phrase it that way.
8 Q Wasn't that conversation in this tape recording?
9 A Deli owner and prestige are two different words, sir.
10 Q I know that, you can't shine a light on it. You have
11 to be a little clever about it? You can't say to Annette
12 during the course of the tape recorded conversation,
13 listen, I am recording the conversation, I would like to
14 talk about how prestigious the list is, you did it in a
15 more subtle way?
16 A Not so, but one can think that. 17 Q When you said, I will not find my name among a bunch
18 of deli owners, what did you imply?
19 A Other causes of prestige, useless reference value,
20 for example.
21 Q I will let you explain useless reference value when< BR> 22 Mr. White asks you questions.
23 You discussed split billing with Annette?
24 A Yes, sir. Is that on my list?
24 Q I am reading the list to you, I can assure you.


1 We talked about networking, that's in the
2 conversation?
3 A Yes.
4 Q We talked about seminars, and that's in here?
5 A Yes, sir.
6 Q And what we have here is Annette saying that five
7 percent of the people had an -- that apply become members?
8 A Yes, sir.
9 Q And we have Annette saying that there were seminars
10 held in Vietnam, Hong Kong and Hilton Head, and you should
11 read the magazine for the information on those seminars?
12 A Future seminars she said.
13 Q I don't think future. She said read the magazines
14 for the information on the seminars.

1 5 In any event, the transcript is what it is, but
16 there was that conversation as well; is that right? 17 A Yes, sir.
18 Q And for those otherwise, all the information she gave
19 you was pretty accurate on the money; am I right?
20 A No.
21 Q You don't think so.
22 In any event --
23 A Not at all, sir.
24 Q In any event, because of the five percent, and
24 because telling you about seminars that appear in the


1 magazine, you are sitting here now today and you are
2 convinced that Annette Haley should be tried and convicted
3 of the crimes that you committed; is that correct?
4 MR. WHITE: Objection.
5 the COURT: Can I hear that again, Mr. Reporter,
6 please.
7 (Whereupon, the court reporter reads the
8 requested material.)
9 THE COURT: Objection sustained.

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