DOJ-OGR-00013193.pdf

Case 1:20-cr-00330-PAE Document 753 Filed 08/10/22 Page 180 of 264 1618 LC7Cmax6 Carolyn - cross 1 A. Yes. 2 Q. And you also had a lawyer in 2008 named Richard Willits. 3 Do you remember Mr. Willits? 4 A. Yes, I do. 5 Q. The lawsuits that were filed in 2008 were after your first 6 discussion with the FBI in 2007; correct? 7 A. I'm not sure. 8 Q. Well, you met with the FBI in 2007 and then there was a 9 lawsuit in 2008; right? 10 A. Correct. 11 Q. And before the lawsuits were filed, you had lawyers; right? 12 A. Correct. 13 Q. And you had meetings with lawyers about the lawsuits? 14 A. Yes. 15 Q. And based on those meetings, you filed not one, but two 16 civil complaints. Do you recall that? 17 A. I -- yeah. 18 Q. I want to talk about the second civil complaint first. 19 First, you read that complaint before it was filed. 20 Do you recall that? 21 A. I don't recall. 22 MR. PAGLIUCA: If we can direct the witness to 23 3505-043, page 41, deposition page 157, lines 18 through 25. 24 If we can blow that up for the witness and the Court, please. 25 THE COURT: Okay. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00013193