EXECUTIVE SESSION

COMMITTEE ON GOVERNMENT REFORM AND OVERSIGHT

U.S. HOUSE OF REPRESENTATIVES

WASHINGTON, D.C.

DEPOSITION OF: LARRY WONG

Monday, July 27, 1998

Washington, D.C.

The deposition in the above matter was held in Room 2203, Rayburn House Office Building, commencing at 10:03 a.m.

Staff Present for the Government Reform and Oversight Committee: Barbara Comstock, Chief Investigative Counsel Alicemary O. Leach, Investigative Counsel; John T. Mastranadi, Investigator; Kenneth Ballen, Minority Chief Investigative Counsel; Kristin Amerling, Minority Counsel; and Michael J. Yeager, Minority Counsel.

For LAWRENCE WONG:

DARWIN L.D. CHING, ESQ.

DARREN CHING, ESQ.

Yoshida & Ching

Grosvenor Center

Makai Tower

733 Bishop Street, Suite 1190

Honolulu, Hawaii 96813

Ms. Leach. On behalf of the members of the Committee on Government Reform and Oversight, I would like to thank you for coming here today.

Could you please put the witness under oath.

THEREUPON,

LAWRENCE WONG,

a witness, was called for examination, and after having been first duly sworn, was examined and testified as follows:

Ms. Leach. I am Alicemary Leach. I'm the designated counsel for this deposition. With me today is John Mastranadi of the Majority staff. Representing the Minority is Christine Amerling, Michael Yeager and Ken Ballen.

Pursuant to its authority under House Rules 10 and 11 of the House of Representatives, the committee is engaged in a wide-ranging review of possible political fund-raising improprieties and violations of law. The committee has been granted specific authorization to conduct this deposition pursuant to House Resolution 167, which passed the full House on June 20th, 1997.

Rule 20 of the committee outlines the ground rules for this deposition. If you don't understand a question, please ask me to, and I will repeat it. If you don't -- you can't hear me, please let me know, and I'll repeat the question. You must give verbal, audible answers, because the reporter is making a written record of this proceeding.

Your testimony is being taken under oath as if you were in court, and if you answer a question, it will be assumed that you understand the question and answer -- and the answer was intended to be responsive to it.

Are you here voluntarily or as a result of a subpoena?

The Witness. On the advice of counsel, I respectfully decline to testify and invoke the fifth amendment of the U.S. Constitution on the grounds that my testimony may tend to incriminate me.

Ms. Leach. Okay. I am hereby communicating to you an order issued by the United States District Court for the District of Columbia. The oath -- the order provides in substance that you may not refuse to provide evidence to this committee on the basis of your privilege against self-incrimination. It provides that evidence obtained from you under this order may not be used against you in any criminal proceeding with the exception of prosecutions for perjury, giving a false statement or otherwise failing to comply with this order.

Mr. Ballen. Counsel, if I may just interject. The better procedure for the witness' protection of the constitutional rights is if there's a question on the substance of the case and the witness invokes the fifth amendment at that point. For example, if you ask a witness what is his name, my name is Larry Wong; do you know Gene Lum; then he invokes it, then you convey the order. That's the best way so there's absolutely no doubt that he's answering a compelled question on the subject matter of the inquiry.

Ms. Leach. Do you want to go through this procedure?

Mr. Ballen. Yes, I think it would be best, with counsel's concurrence.

Mr. Darwin Ching. Let the record reflect that Darwin Ching and Darren Ching, attorneys for Lawrence Wong, we concur with Mr. Ballen.

Ms. Leach. So are you here voluntarily or as a result of a subpoena?

The Witness. On the advice of counsel --

Mr. Darwin Ching. Hold on. I think --

Mr. Ballen. Why don't you just ask him his name and then ask him a question and the substance, and then we avoid the question of whether that's a fifth amendment, because that one is right on the gray area.

EXAMINATION

BY MS. LEACH:

Q Will you please state your name for the record?

A My name is Lawrence Wong.

Q Do you know Gene and Nora Lum?

A On the advice of counsel, I respectfully decline to testify and invoke the fifth amendment under the U.S. Constitution on the grounds that my testimony may tend to incriminate me.

Q I am hereby communicating an order issued by the United States District Court for the District of Columbia. The order provides, in substance, that you may not refuse to provide evidence to this committee on the basis of your privilege against self-incrimination. It provides the evidence obtained under the order may not be used against you in any criminal proceeding, except prosecutions for perjury or by giving false statements or otherwise failing to comply with this order.

Mr. Darwin Ching. For the record, this appears to be a Xerox copy of the order. I don't know if we have an actual certified copy. But we'll accept representations of counsel, if concurred by both counsel, that this is a true and accurate copy of the order.

Mr. Ballen. We haven't seen the order yet, so I'm interested to look at this.

BY MS. LEACH:

Q Are you here voluntarily or as a result of a subpoena?

Mr. Ballen. Excuse me.

[Pause.]

Mr. Darwin Ching. Off the record.

[Discussion off the record.]

Mr. Ballen. Yes, this order seems to be a proper copy of the original order. As long as Majority certifies it and that it's accurate, then we have no problem with it.

Ms. Leach. Okay. A copy of this order will be placed in the record.

BY MS. LEACH:

Q Are you here voluntarily or as a result of a subpoena?

A I came voluntarily.

Q Do you understand that the testimony you give today is under oath?

A Yes, I do.

Q Do you understand your oath obliges you to give complete and truthful responses to my questions and that your responses are as if they were being given before a committee of the United States Congress?

A Yes.

Q Do you have any questions?

A The question is, am I a target?

Q No.

A I'm not a target?

Q You're a witness.

A I'm a witness. Thank you. Thank you.

Mr. Ballen. For the record, the Congress of the United States does not prosecute any individual, so you can neither -- you cannot -- any witness before the Congress is not a target. Sometimes committees of the Congress refer to the Department of Justice people, that has happened in the past, that they consider may have committed crimes. But the Congress can never prosecute. That has to be within the executive branch.

BY MS. LEACH:

Q Could you please state your employment history since 1987?

A My employment history?

Q Yes.

A 1987, I was the -- still social science teacher at Norwalk La Mirada Unified School District in the Los Angeles area, in Southern California area. And although I started as a teacher in 1963, I've always been a teacher, for 33 years, and I retired in June of 1996, 2 years this past June. And you're asking me about my history of my teaching career as it were?

Q Just your employment history, if you were a teacher.

A Yes. I've been a teacher since 1963 and retired after 33 years, in June of 1996, during which time I was a social science teacher that have conducted more than 25 various trips to Nation's capitals and helping the kids to raise money, et cetera, et cetera, teaching them the democratic process, expose them to it.

Q Can you list all of your professional organizations and social clubs you belong to?

A Well, I've always been a faithful member of the teachers union called TANLA, Teachers of -- TANLA, T-A-N-L-A, TANLA, this is really the teachers professional organization for which I belong to from the beginning of time when I started teaching. And I have been involved with -- at one point I belonged temporarily to Lion's Club, in which I was, I guess, shanghaied to it because they knew I was a cook. And my whole career, besides being a teacher, I grew up in a Chinese restaurant, and they've always used my cooking talents to help in raising money for the blind.

And I've raised more than 400 scholarships for students with my family and my Hawaiian associates. And I've done -- for example, in the same association, have in September of '92 -- when Hurricane Iniki hit the island of Kauai, following the '92 election, early November or the middle of November, I helped to raise funds, about 1,500 people accompanied, and all $40,000 was sent to the island of Kauai.

So I've been really a cook all my life, and proud to be a professional cook because I grew up in a restaurant, learned firsthand from my family, my dad, but educated in the social science because my mom always told me, you be the best American citizen you can. She was a naturalized citizen.

Q Do you sit on or have you sat on any corporate boards?

A Yes, I have.

Q Which ones?

A Presently I am on the Dynamic Energy Board, and I was invited to join the board at the first board meeting of January of 1994 in Tulsa, Oklahoma.

Q And you're currently a director?

A I'm still currently a director, but I understand, you know, we're still in Chapter 11. So I don't know what status that puts me in.

Q How did you first come to meet Nora Lum?

A I first met Nora Lum, I can't be exact, but it was in 1987 at the Kings Hawaiian Restaurant in Torrance, California, on Sepulveda Boulevard, and that was the first time I met Gene and Nora Lum, who at that moment had known that I was a community-involved worker in southern California. So they asked me to help them in a fund-raiser for a city councilman named Lei Wai Doo, who was a candidate for Congress, L-E-I, I believe Wai, that could be spelled W-A-I. I think it's a Chinese name.

Mr. Darwin Ching. L-E-I-G-H W-A-I, last name D-O-O; is that correct?

The Witness. D-O-O.

That was the first time I met Nora.

BY MS. LEACH:

Q What year was that?

A Around 1987. And I consented to help with raising money for the primary, but that did not materialize because he lost the primary. So that ended that.

Q When was the next time that you met her?

A The next time, I can't be exact, but it was either the latter part of August or September of 1992 at the APAC-VOTE headquarters which was organized in the city of Torrance.

APAC-VOTE was part of the DNC, it was my understanding, which is known as the Asian Pacific Advisory Council, and the theme was to get out the vote, which I was very interested in doing as a young -- well, as a young teacher, but as a teacher, yeah. All my life I was registering kids, you know.

Q What was your relationship with Gene or Nora Lum, or is your relationship?

A I don't understand the question. What do you mean my relationship? Did I associate businesswise; is that what you say?

Q Socially, business. How close were you?

A Basically when I met them --

Mr. Darwin Ching. Excuse me, are we all the way up to the present or back in '92?

Ms. Leach. His entire association with them.

BY MS. LEACH:

Q Were they -- do you consider them close friends?

Ms. Amerling. Counsel, I just want to ask what the relevance would be to probe into the nature of his social interactions with the Lums?

Ms. Leach. It is relevant.

Ms. Amerling. Could you explain the relevance?

Ms. Leach. It goes to the relationship with the Lums.

Ms. Amerling. How does the social interaction with the Lums relate to the investigation into political fund-raising?

Could you just let me finish my statement before responding? I would appreciate that courtesy.

Can you explain the connection to the investigation into political fund-raising improprieties?

Ms. Leach. That will become evident throughout my questioning.

BY MS. LEACH:

Q Please answer the question.

A Now you're asking me about 1992, right, my relationship with them at that time?

Q Right.

A Basically I only met the Lums that one time. I've got to be clear and go back, one more time. In 1954, I was a senior in high school at Iolani Episcopal Prep School in which Gene Lum was 3 years longer than I was. So I don't want to mislead you by saying that I didn't know. I knew of him. He was just a young freshman punk as we say. We're seniors. I didn't mean to defame, what I said; young freshman, okay? So I have to go back.

Mr. Darwin Ching. Maybe we should back that word.

The Witness. I didn't mean punk. As seniors look down at the underclassmen, I'm sorry. I didn't mean to defame a friend.

BY MS. LEACH:

Q I understand.

A He was a young freshman, who I said '87, you know, I've seen him, never became a friend. I was on the varsity football, and he was on the eighth grade team, whatever it was. Just to clarify, that's the first time I met him, I saw him.

Q Thank you.

A I didn't associate with him, okay?

Q So you met them once?

A In '87.

Q In '87?

A Yes.

Q And then you reacquainted with them in 1992?

A Yes.

Q And then how did your relationship with the Lums develop at that point?

A Well, when they asked me to help participate, because APAC-VOTE was set up, and I came in after it was set up. I had nothing to do with the administration of it, and being a cook, they knew my cooking talent. I put on like 25 luaus, annual luaus, for the school district to help the kids come to the United States Capitol. So they asked me to use my talents as a cook.

And that was part of the fund-raising, you know, where we cook for people that came frequently to the place. I don't recall all the people I cooked for, you know. It's been a long time. But I can boast of being as I believe as good a cook as a teacher, and I became a pretty damn good teacher. I became teacher of the year in 1977 in southern California.

Q How would you characterize your relationship with Gene or Nora Lum?

A Socially we are friends, yes. And politically APAC-VOTE, I participated by being involved. I would come after school. I was a full-time teacher. So maybe on one occasion during the day, when it was a short day maybe, for whatever it was, for my campus, but evenings I would come by and bring food. I brought my portable wok, the warehouse where I did the Iniki luau, and I cooked for everybody, you know. I-N-I-K-I. Kauai, Iniki hurricane, I'm sorry.

Q What have your contacts been with Gene or Nora Lum from 1992 up to the present? Have you remained in constant contact?

A Yeah, we were -- we have remained socially in contact, yes.

Q How frequent have the contacts been?

A I would say socially quite frequently. They would call me, and I would meet them for coffee, you know, having coffee.

Q What time period is this?

A Well, in the last -- I guess you would say in the last 2 or 3 years, yes.

Q Have you ever had any contact with Scott Fujoka at Sanwa Bank in Gardena, California?

A I recall the name. I believe he was one of the branch managers, but I don't know him personally, if that's the same person we're talking about.

Q Yes, it is.

A Yes.

Q Can you explain again how you became involved with APAC? Nora contacted you?

A After having met Nora in '87, and the plan to do the fund-raising for a Democratic candidate did not materialize because he lost the primary. Then in '92, she called upon me to participate, and I would be in the old-timer transplant man from Hawaii from the area. So she asked me to come and help set up, and, you know, basically I cooked a lot for them, yes.

Q Did you come to APAC before their grand opening?

A Did I come to APAC before their grand opening? Are you speaking about grand opening when Ron Brown came?

Q Yes.

A I believe I was there, yes -- yes.

Q Can you remember about when the APAC organization began?

A I can't recall exactly, but I would say to me it was September, you know. I don't know when it was organized, because I had nothing to do with organization or administration or financing or any of that, you know.

Mr. Ballen. For the record, September of what year?

The Witness. '92. '92, that's the second time I met them, yes.

BY MS. LEACH:

Q Have you ever met Melinda Yee?

A Yes, I have.

Q When was the first time you met Melinda Yee?

A I believe the first time I met her when she returned from Arkansas and was helping the Clinton campaign sometime in October either at the reception when Ron Brown was -- I can't recall what day, but I did meet her in that fall.

Q Was she -- did she come to APAC regularly?

A Not when I was there. I met her maybe once there, you know, it could be twice, at a reception when March Fong Eu and others were there.

Q At APAC?

A Yes.

Q In the APAC offices?

A No, when they came back in the fall, because Mark introduced Ron Brown.

Q And which reception was this?

A It was open house, whatever you call it.

Q The October 2nd opening?

A You're talking about at the headquarters, or are you talking the Radisson Hotel now? There was a function where some of us were honored at the Radisson Hotel.

Q Which one was Ron Brown at?

A Ron Brown was at the open house, I believe. I don't even recall it an open house. That's when he came and met everybody to excite us about voter registration.

Q And that open house was before the event at the Radisson?

A I would think so, yes.

Q And March Fong Eu was at the open --

A March Fong Eu was there, too. And she introduced Secretary Brown -- well, at that time national chairman.

Q Yes. Do you remember who else was there at this open house?

A Another was Al Harrington, my good friend who was an MC, the actor of Hawaii 5-0, a classmate.

Q Was there anywhere else there?

A There were a lot of people there, but it would be hard for me to remember names. There were people like Audrey Noda, who was involved at APAC. Whether she was paid or voluntary, I don't know. But Audrey Noda; John Chiang, who is now with State Board of Equalization. Lani Sakoda came at times, Lani Sakoda. David Quan from Houston, an attorney, worked in different times, you know. I don't know their role, except that you're asking me who I saw there.

Q Right.

A Yes. Let's see. There was another David Quan; David Quan, who came voluntarily. I believe he took a leave --

Q David Tseng?

A I'm sorry, David Tseng, David Tseng, it was Quan was the other people, yes. But all three of them were attorneys.

Q Were you introduced to anybody from the DNC or the Clinton/Gore campaign at this open house?

A I met Ron Brown for the first time. I think he's -- yes. I met Ron Brown.

Q Was Melinda Yee at this open house?

A I met Melinda Yee, I don't remember when it was, either when she came down one time or at the open house.

Q Did you ever meet Chris Wada of the Sony Corporation?

A No. I don't even recall the name Chris Wada. It's a familiar name, but not him. Chris Wada? No.

Q What did you do at APAC?

A Well, basically, as I told you, I very much pride in the fact that I have learned from the work to be a cook, and throughout my career I didn't hand out to kids, you know, to run this. I raised money for them by cooking, luaus, taking the wok and everything else. I did that. That was my major role at APAC. I did that as voluntary to help people, and I fed a lot of people that came, you know, in and out, and a lot of times at the request of the Lums I did this. And she said, don't worry, I will reimburse you for this. And I said, I'm just doing this volunteer, I'm not on your payroll.

Q Did you ever do a fund-raiser for APAC?

A The only fund-raiser I believe I participated when I was honored at the Radisson, among with several other community leaders, like Dr. Lal, my good friend, and Lani Sakoda.

Q Did Nora --

Ms. Amerling. Clarify, what you meant by doing fund-raising?

Mr. Ballen. Did you ever actually engage in fund-raising activities?

The Witness. You mean literally bringing money in?

Mr. Ballen. Soliciting money.

The Witness. There were times when I asked -- for example, asked them, can you contribute, you know, X number of dollars? And I don't recall whether -- it could be 25, $50. But if you're asking me if I was an upper echelon of fund-raising, I don't know anything about that.

BY MS. LEACH:

Q Who did you ask to contribute money?

A Well, I asked one. I believe it was with the request of Nora to ask this gentleman named Steve Sakane, who was, you know, my friend at that time. I no longer associate with him.

Q Who is Steve Sakane?

A Steve was originally a professional insurance man who owned collection cars, okay. And I asked him to contribute -- I remember calling and asking him to contribute the amount, but he wrote a thousand dollars to me and, you know, when the -- you see a thousand-dollar check or whatever, it was $25, he's not writing it to me. He wrote it to me, and I signed it over. And I said that's not mine, that goes to the things.

Q Did you intend that money --

Mr. Darwin Ching. I'm sorry, I don't know if he was finished.

The Witness. No, I assumed what -- I mean, it was for the campaign, writing it to APAC. So I just signed it over, because, you know.

Ms. Leach. I have a copy of the check that I'll introduce as Exhibit Number 1.

[Wong Deposition Exhibit No. LW-1

was marked for identification.]

[Wong Deposition Exhibit No. LW-2

was marked for identification.]

BY MS. LEACH:

Q Is this the check --

Mr. Darwin Ching. Is this going to be 1 or 2?

Ms. Leach. That will be 1.

BY MS. LEACH:

Q You endorsed this to the DNC?

A Yes, I endorsed it, because he wrote it to the wrong person, it wasn't to me. I asked him to contribute, and then when he wrote it to me, I saw that, and so perhaps I should have just said, write a new check. But when something that doesn't belong to me, I just wrote the thing and said, this is for the DNC. So I said, pay to them. Whether it was the right thing to do or not, I'm not sure. I should have told him --

Q Who did you give the check to after you endorsed it?

A I believe I gave it to Nora Lum, yes; whoever was in charge of collecting the money, I can't recall, more than likely it was Nora Lum.

Q Who else besides Nora was in charge of collecting the checks at APAC?

A I don't even know, yes. You know, the people that worked there, like I said, I named people, I don't know what their role was, you know. If I gave it to one of them, I would give it to Nora. I don't recall, but I know it went to them.

Q And you intended this money to go to the DNC?

A Yes, yes. It was his money, not my money, you know.

Q Do you know what he meant by -- the check was written on October 26th of 1992, and in the memo block, it has "fee." Do you know what he meant by that?

A No, I don't. No, I don't. I just -- I just recognized that right now, this just came back to me. In fact, for a long time, I even forgot about this, because, you know, 7 years ago is -- for me to trust to memory.

Q Were you aware of other money that he had given to APAC?

A Not that I know of, no.

Q You didn't ask him to donate any other money?

A No, no.

Q Are you aware of --

A Could ask me the question again, because maybe I misled you on this. Ask me the first -- the question you just asked me.

Q Are you aware that he donated other money to APAC?

A I'm not aware of that.

Q Are you aware of his business association with Chris Yamamoto?

A Is this the Chris Yamamoto from Japan?

Q Yes.

A Steve told me that he was one of his business partners. I know that Yamamoto owned a pipe company in Japan,, I mean a smoking pipe, okay? And I met Mr. Yamamoto a couple times. And I don't know, at one time I saw a picture of Steve Sakane in a Japanese magazine with him, and he was -- he said he belonged to a boat company. I don't know. But I don't know what the relationship was.

Q Did Chris Yamamoto visit APAC?

A No, I don't believe he visited APAC.

Q Do you know if Nora knew Chris Yamamoto?

A I believe that Nora met Chris Yamamoto.

Q Do you know how she met him?

A Through Steve Sakane.

Q How did Nora Lum know Steve Sakane?

A When Steve came to APAC, he knew me first.

Q You introduced Nora Lum to Steve Sakane?

A Yes, I just introduced them.

Q Do you know if Steve Sakane gave any money to the DNC?

A No, I don't know.

Mr. Darwin Ching. For the record, DNC, you understand what that means?

The Witness. The Democratic National Committee?

BY MS. LEACH:

Q Yes.

A If you're equating that to APAC, when he wrote this check to me, I wrote -- I endorsed it to APAC -- I'm sorry, I endorsed it to the DNC, because I -- my understanding was that APAC was a part of DNC.

Q Right. Besides this check, are you aware --

A No.

Q -- of his donations?

A I'm sorry, go ahead.

Q Are you aware that he donated any other money to APAC or the DNC?

A Not that I know of.

Mr. Ballen. I'm sorry, if I may? So apart from this particular instance, you did not engage in any fund-raising?

The Witness. Unless --

Mr. Darwin Ching. Did you hear his question?

The Witness. Apart from this?

Mr. Ballen. Apart from this check, sir.

The Witness. Well, I also was asked to write a check to Norm Mineta.

Mr. Ballen. That's not answering my question.

The Witness. Apart from this?

Mr. Ballen. Apart from this particular check, did you solicit funds from other individuals engaged in other fund-raising activities?

Mr. Darwin Ching. Maybe you may need to help us, because the way "fund-raising" is being used is so broad. Come back to his question, did you solicit any other funds from any other individuals?

The Witness. I could have asked, like I told her, individuals contribute or, you know, support the '92 election, but I can't recall.

Mr. Ballen. Would that be in small amounts like $50 or --

The Witness. Yes.

Mr. Ballen. This was the only large --

The Witness. This was the only large amount that I know.

Mr. Ballen. Okay.

BY MS. LEACH:

Q Did you ever go to Sanwa Bank?

A Sanwa Bank in California?

Q The Gardena office?

A Yes, I've been in Sanwa Bank.

Q Did you go at Nora's instructions?

A I believe at one time she asked me to pick up something or deliver a note, I'm not sure when. But I did go to Sanwa Bank.

Q Do you remember if you ever cashed any checks for her at Sanwa Bank?

A No, I don't remember doing that, no.

Q What did Nora ask you to do at APAC aside from doing the cooking?

A Well, the emphasis is, Larry, you know, being a teacher, and you've been involved in government, et cetera, you know, teaching government and social science, please help us in getting out the vote. This is what I did do.

Q How did you do that?

A I did fairly well.

Q How did you do that?

A I thought you said how did I do.

Q How did you do that; how did you get out the vote?

A The counting registration cards. So what I did was I talked to Dr. Lal, who was then Pacific Islander, a principal in Carson High School, and, you know, we distributed cards to Pacific Islanders and others to go out and register voters. And I did that on my campus. And I gave them registration cards. And they said, Mr. Wong, we should all participate in community service. I said, well, take five cards. And I said, this is an assignment, you take it home and you ask your parents if they are registered, and if they're not, shame on you, please register, Mom. Then take to five others and ask them to have five others take to five others. As a result I was able to register over 1,200 people.

And I did not tell them how to vote, how to register. I said, you just tell them to register, and if they asked me, then it's your opinion, it's your prerogative to tell them. It's a Democratic, Republican -- because by the way I was -- it was a Republican territory, so I wasn't going to get involved in the political controversy.

Q Was Trisha Lum at the APAC offices?

A Yes, Trisha was at APAC offices, but part of the year, I know she was at the University of San Francisco. So I don't recall if she was there. She was in and out. And I know she took off time to work in Arkansas, too, in the Clinton campaign, you know.

Q Trisha spent time in Little Rock during the summer?

A Yes, in Little Rock during the summer, that was my understanding -- I think in the summer or maybe the fall. I don't know the details, but I just heard it secondhand.

Q Who told you?

A I believe Nora had mentioned it and maybe other people, yeah.

Q Was Maxine Lum at the APAC offices?

A I didn't meet Maxine there, no. I never met her until, I believe, during the -- no, I didn't meet her there.

Q Was Nickie Lum at the APAC offices?

A I think I've seen her once at the APAC office, but she was also working in Arkansas. She was a senior in high school in Hawaii, so she wasn't working there.

Ms. Leach. I have a letter that I'll mark as Exhibit Number 3.

[Wong Deposition Exhibit No. LW-3

was marked for identification.]

BY MS. LEACH:

Q It is dated July 31st, 1992. It is from Nickie Lum to Chairman Brown. It's the last full paragraph on the first page: "I've been in Little Rock for the past week."

Do you know how long she was in Little Rock during the summer of 1992?

A I really don't. No, I don't. Like I told you, I thought she was there in the fall and in the summer, because she was a high school student. So I would imagine -- I just don't know, but I know -- I was told secondhand that she was in Little Rock.

Q That Nickie and Trisha were both in Little Rock in 1992?

Mr. Ching. Listen to the question. She said Nickie and Trisha both.

The Witness. Nickie and Trisha.

BY MS. LEACH:

Q Did Nora ever go to Little Rock during this period?

A I don't recall if she went during this period. I believe she told me that she did go to Little Rock, but I don't recall when she did go.

Q Did she say what she did when she went to Little Rock?

A No, she never told me that. The Lums to me are very secretive. I never ask, you know.

Q Did they ever discuss meeting Governor Clinton?

A I believe they told me that they did meet Clinton at some type of a fund-raiser, because I remember the reason why I say that is because, I can't remember all the details, but I think when Gene walked by, I think Hillary said something to Gene which she related to me. I forget what it was. It was kind of a joke, I guess. But I don't know when, you know. But they did tell me they met the Clintons, yes.

Q Did they say how often they had met the Clintons?

A No.

Mr. Darwin Ching. We're talking about what time period now, in the summer?

Ms. Leach. Any time period.

The Witness. Any time period? Any time at all during the campaign or whatever?

Mr. Darwin Ching. Even up to the present?

Ms. Leach. To the present.

The Witness. To the present, no, no, they never told me how long. That's what you asked me.

BY MS. LEACH:

Q Yes, how many times?

A How many times they've met the Clintons?

Q Yes.

A No.

Q Can you describe the awards dinner at the Radisson Hotel?

A The awards dinner was, I believe, to honor some of the community leaders and political leaders. And we were honored there. And I remember walking up to the stage when Congressman Matsui gave me, you know, an award. Congressman Matsui, your present Congressman of Sacramento was there. He was the speaker there also.

Q Did the hotel cater the event?

Mr. Darwin Ching. Don't guess if you don't know.

The Witness. I don't know who catered the event, yes.

BY MS. LEACH:

Q Do you know if the food was brought in? Did someone prepare the food?

A I don't know.

Q You don't know?

A I don't know.

Q You produced the program of the event?

A Yes.

Ms. Leach. I'll mark it as Exhibit Number 4.

[Wong Deposition Exhibit No. LW-4

was marked for identification.]

BY MS. LEACH:

Q Were you involved in the preparation of this program at all?

A No, I wasn't, except they told me I was going to be honored. If that means participation, yes; the planning and the strategy and all that.

Q Going to the printer or gathering the photographs?

A No, not that I know of, no.

Q Do you know why Maria Haley and Caroline Hee were given special thanks? It's on the last page, your Bates number 12?

A Maria Haley?

Q Maeley Tom, I'm sorry. Maeley Tom and Caroline Hee were given special thanks.

A Well --

Mr. Darwin Ching. Do you personally know?

BY MS. LEACH:

Q Do you know?

A I know Caroline Hee that came --

Mr. Darwin Ching. I'm sorry. Listen to her question, okay?

The Witness. Why were they honored?

BY MS. LEACH:

Q Do you know why Caroline Hee was given special thanks?

A Well, when she came, she helped to do the decorations, like you know how --

Q She decorated the room?

A The flower arrangement and that kind of stuff, that's my understanding, because she does all of my decorations for my luaus, too.

Q How do you know Caroline Hee?

A I met her when she came to help APAC for a few days, and then she flew back to Hawaii.

Q Did she know Nora Lum?

A Yes, she knew Nora Lum.

Q Did Nora explain how she met Caroline Hee?

A No, I don't recall, no.

Q She just came for --

A I was introduced to her through Nora Lum, yes.

Q She came to this event from Hawaii and went back to Hawaii after the event?

A Um-hum, yes.

Q Was Maeley Tom at any APAC events during 1992?

A I believe I saw her at the -- she may have come to APAC headquarters in Torrance, but I saw her also at the inauguration at the Asian Pacific gatherings, one of the hotels. I don't recall which hotel, but there were hundreds of people there.

Q In California?

A No, no. I'm jumping ahead, I guess. That was in inauguration of '93, yes. But she could have been there at APAC sometime, but I don't recall that I really saw her there.

Q Did Nora ever speak of Maeley Tom?

A She had mentioned that Maeley Tom is, I believe, one of the Democratic trustees or in some function of the Democratic Party. I don't remember the details.

Q Did she ever mention to you that Maeley Tom was involved in organizing APAC?

A I don't recall that. If she did, I don't recall.

Q Okay. Do you know who was on the APAC -- was there an APAC staff?

A If there was an APAC staff, I don't know who was on it officially. I can name some names to you that there were there, but I don't know what their official position was, if there were.

Q Do you know if they were all volunteers or if any of them were paid?

A I don't know that either. I do know that they were there, because my position, as you know, was food preparation.

Q Did Nora ever ask you to sign a time card at APAC, or did anyone else ask you to sign a time card?

A No.

[Wong Deposition Exhibit No. LW-5

was marked for identification.]

BY MS. LEACH:

Q I will give you what I'm marking as Exhibit Number 5. It's an FBI document. The interview was taken on October 21st of 1993, and I'll direct you to the last paragraph, the last full paragraph on the first page.

A The last paragraph.

Q During June '92 through December '92, when Nora T. Lum and her husband Eugene Lum were working at APAC, Nora Lum would present time cards to each volunteer to sign. These cards were for payment from APAC, but all of the workers were volunteers and not being paid. A confidential source obtained this information from Charles Chidiac who worked at APAC during October and November of 1992. A confidential source stated that Chidiac told the confidential source that he, Chidiac, refused to sign the time card in the amount of $1,000, and Nora stated that it was all right, she would take care of it.

Did Nora ever ask you to sign a time card?

Ms. Amerling. Counsel, I think the proper question would be does this document refresh the witness' recollection of this matter. And just so the record is clear, the document that counsel for the Majority is discussing is an FBI investigation write-up of information that an agent received from an unnamed confidential source.

Mr. Darwin Ching. Do you want the question again?

The Witness. Could you restate the question?

BY MS. LEACH:

Q Do you know if Nora asked you or anyone else at APAC to sign a time card?

A No.

Q Do you know whether Chris Yamamoto ever made any contributions to the DNC?

A No, I don't.

Q Did you ever see large amounts of cash at the APAC office?

A No.

Q Did you ever hear anyone discussing that there were large amounts of cash at the APAC office?

A No.

Q Did you know that Nora Lum would travel outside Hawaii and pick up cash to deliver to campaign -- as campaign contributions?

Ms. Amerling. Counsel, are you representing that as a fact?

Ms. Leach. I'm asking if he knows it if she ever did this.

Ms. Amerling. Are you asking whether she did it?

Ms. Leach. Is he aware.

Mr. Darwin Ching. Do you understand the question?

The Witness. Yes. Did she carry large of amounts of cash outside of the country?

Mr. Darwin Ching. To your knowledge.

The Witness. To my knowledge.

BY MS. LEACH:

Q Do you know if she ever went outside of Hawaii to collect cash?

A To my knowledge, I don't know.

Q I'll give you what I'll mark as Exhibit Number 6

[Wong Deposition Exhibit No. LW-6

was marked for identification.]

BY MS. LEACH:

Q You said that you first met Nora Lum when she was doing fund-raising for Leigh Wai Doo's congressional campaign?

A When I first -- restate the question again.

Q When you first met Nora Lum, it was at a fund-raising for Leigh Wai Doo?

A No, that's not what I said. I first met Nora Lum around '87 when she came and asked me if I would help in southern California to raise funds for Leigh Wai Doo's primary, and I said it didn't materialize because he lost the campaign. Whether she was raising funds there or -- I don't know. You know, she asked me to help out.

Q Okay.

A It didn't materialize because he lost the primary. So I never did anything after that, yes.

Q Do you know was she raising money for Leigh Wai Doo?

A Do I know if she was raising money for Leigh Wai Doo? She may have told me, I don't know. She didn't tell me exactly. But she came for Leigh Wai, she must have been raising funds. I don't know.

Q Okay. Exhibit Number 6 is an FBI interview on September 18th of 1990 on Bates number 382. It's in the third paragraph. Large mainland cash donations to Doo were usually picked up by Nora Lum in the following areas: Boston, Minnesota, Seattle and California. In 1988, Nora Lum carried and delivered $80,000 in cash for Doo's congressional race.

Were you aware that she was traveling to these States during this time period or any other time period that you knew Nora Lum; did she ever discuss this?

Ms. Amerling. Counsel, I think here again the appropriate question is does this document, which is an FBI report, refresh this witness' recollection in any way about what he already testified to?

Mr. Darwin Ching. Can you help us out, because your question -- he's not refusing to answer, but the question was compound. In terms of what you phrased, do you know one of the questions, did she travel to these different areas?

BY MS. LEACH:

Q Did you ever hear Nora or know of Nora traveling to these different States?

A No, I haven't. You mean in California? Well, she came to California to talk to me. But whether she was doing traveling to collect money for the Leigh Wai Doo, she never told me that.

Q Did you ever know Nora to travel to these States at any time when you knew her?

Mr. Darwin Ching. Up to the present?

The Witness. Oh, yeah, she traveled to Boston. Her daughter lives there.

BY MS. LEACH:

Q Minnesota or Seattle?

A No, I don't know. But whether it was to pick up money for Mr. Doo, I don't know that.

Mr. Darwin Ching. That's not the question. Answer the question, okay?

The Witness. Okay.

BY MS. LEACH:

Q Did Nora ever discuss traveling to these four States?

A No.

Q Do you know did Nora ever discuss her travel outside the United States?

A Any time since I've known her?

Q Yes.

A Yes, she's mentioned going to Korea, Asia, to -- I guess to do business dealings with her company.

Q Do you know what business dealings?

A At that time I believe it was L.A. Sound, L.A. Sound International.

Q Was Korea the only country that you're aware that she traveled to?

A It could have been to Hong Kong or Japan, I don't recall. You know what -- I know she went to Asia.

Mr. Ballen. What time frame was this, sir?

The Witness. It must have been I say in the last -- probably last 3 years, last 2 or 3 years.

BY MS. LEACH:

Q She is traveling to Hong Kong?

A Yes, because at this time she was moving between Tulsa and California from here. She was already the owner of L.A. Sound, then she purchased it. So that's -- I would assume it's the business dealings, you know. I don't know the specifics, because I was talking generalities here.

Ms. Amerling. Were you speculating about the specific countries that she went to?

The Witness. No. She did mention, she went to Korea, I can remember that. For what reason, I don't know, except for business, you know.

BY MS. LEACH:

Q And she -- why did she say that she went to Hong Kong?

A Possibly to Hong Kong. I say in Asia, so it could be Japan. It could be Hong Kong, but I know she told me Korea. She said Asia, you know. And I know she mentioned Korea, because of the company bills, they're L.A. Sound Equipment, you know.

Ms. Amerling. You were speculating when you mentioned other countries' names?

The Witness. Right.

BY MS. LEACH:

Q Do you know whether she traveled to Japan?

A I don't recall her mentioning Japan, unless she went from Korea to Japan, I don't know.

Mr. Darwin Ching. Just answer the question. Don't speculate, okay?

BY MS. LEACH:

Q I am going to show you what we will mark as Exhibit Number 7.

[Wong Deposition Exhibit No. LW-7

was marked for identification.]

BY MS. LEACH:

Q This is an interview that Stuart Price gave to the Department of Commerce Inspector General's Office on August 17th, 1995. On page 5, the last paragraph, "Stuart Price states, Nora Lum told Price that she made a trip to an undisclosed location in Asia, where she picked up two suitcases of money. Nora Lum did not identify the currency in this matter. Nora Lum told Price that she brought two suitcases of money back into the United States, and turned the money over to the DNC."

Are you aware that Nora Lum traveled outside of the country and brought back suitcases of cash to deliver to the DNC?

A No, I don't.

Q She never mentioned this to you?

A No.

Q It also says that Nora Lum also told Price that she traveled overseas on this trip using a United States passport she obtained with a false identification. Did you ever hear -- did Nora ever say or did anyone else ever say that Nora Lum had a fraudulent United States passport?

Mr. Darwin Ching. What section are you referring to?

Ms. Leach. Page 6.

Mr. Darwin Ching. I'm sorry, this is switched.

Ms. Leach. Sorry, the top paragraph.

The Witness. Okay. Are you asking me, am I aware of this?

BY MS. LEACH:

Q Are you aware that she had a passport that she obtained with fraudulent, false identification?

A I'm not aware of that, no.

Mr. Ballen. Of course, Counsel, you're reading from an interview memorandum which purports to say that this person said that. You're not stating as a fact that, in fact, Nora Lum had a false identification or anything else that's in this.

Ms. Leach. I said Stuart Price stated in this interview these facts.

Mr. Ballen. As least as reported in this particular document.

BY MS. LEACH:

Q You can set that aside.

Did Nora Lum ever discuss her fund-raising activities for the DNC?

A Well, as far as I can remember, you know, being the DNC was there to the APAC -- you're referring to APAC, right --

Q APAC or --

A -- or DNC?

Q Or post-APAC up 'til the present.

A Well, she had mentioned --

Ms. Amerling. Just so the question is clear.

BY MS. LEACH:

Q At any time that you've known Nora, has she discussed her fund-raising for the DNC?

A Well, she's mentioned doing fund-raising, I guess, for the Democratic Party or the DNC, but specifics, she never told me that.

Q Was APAC a fund-raising vehicle for the DNC as you understood it?

A My understanding is APAC's main purpose was to get out and vote, and that's what I did, besides being almost a gracious full-time cook to help, you know.

Q Did APAC engage in any fund-raising?

A I would say at the Radisson Hotel, I know that she charged my brother and others $125 to come in, so I guess it's a fund-raiser, but we were honored. So I didn't organize that. I'm a cook, yeah.

Q I just asked if APAC hosted any fund-raising events.

Mr. Ballen. That you know of, sir.

The Witness. Not that I know of.

BY MS. LEACH:

Q Other than the Radisson Hotel?

A The Radisson and the reception, open house, you know.

Q That was a fund-raiser, too?

A I don't think it was a fund-raiser. It was an open house. You asked me about location, APAC, if we did it there, right.

Q Did you attend the dinner in northern California in San Francisco, I think it was, about 5 days after the Radisson event, November 2nd?

A That was in '94?

Q '92.

A I'm sorry in '92, yes.

Ms. Amerling. The dinner. Are you referring to a dinner affiliated with APAC?

Ms. Leach. I don't know whether it was a dinner or not. It was honoring northern California.

The Witness. The question is, did I attend in northern California?

BY MS. LEACH:

Q Yes, in San Francisco.

A No, I didn't.

Q Did Nora ever discuss her pledge of a million dollars to the Clinton campaign in 1992?

Ms. Amerling. Counsel, are you representing as a fact that Nora Lum pledged a million dollars?

Ms. Leach. I'm asking if Nora ever discussed a pledge of a million dollars.

The Witness. Did she tell me?

BY MS. LEACH:

Q Did you ever hear her discuss?

A She never told me that.

Q Did you hear anyone else discussing a pledge of a million dollars in 1992?

A No, I don't.

Q Did you ever meet Charles Chidiac?

A I met Chidiac who was there at --

Q APAC?

A At APAC, in the headquarters on occasion, but, yes, I met him there, yes.

Q Did Nora ever discuss her relationship with Charles Chidiac?

A Well, she had mentioned that she had been a consultant for Chidiac, I don't know what category, but, that's it. Yes.

Q Did she say why she was at APAC?

A I would imagine -- no, she didn't tell me that. But I gathered from my own perception that she was helping with APAC. She was helping with APAC, because she was honored, you know.

Q Was he at APAC often? Did you see him?

A I've seen him, I said, more than one occasion, yes. I can't detail the exact times that he came. 1992, is, you know --

Q Did Nora Lum ever discuss with you what she was going to do after the 1992 election?

A Yes. She had mentioned that they want to go -- they will be going to the Nation's capital to lobby for jobs for Asian and Pacific Islanders. And I believe this happened because I know some people that got jobs.

Q Who were those people?

A Well, there was offered a job in the Department of Education, Dr. Lal, a friend of mine that went to the interview, then he became a White House fellow. I don't know if that's a job, but he became a White House fellow at the White House. And, well, Trisha Lum worked at Commerce, I don't know what capacity. And David Tseng, I believe, went to Labor. I'm not sure exactly. Others were asked -- in L.A. were looking for jobs. Some didn't go. Rose O'Shea, I believe, is now with the Attorney General's Office, with the Justice, okay, and she was very active in California. I'm not sure if the job was their because of Nora, but I know she went from California there that we knew of, you know.

Q Do you know who Nora helped get a job? Did Nora say who she was helping?

A She didn't give me any specifics, no. I don't know any specifics, you know. The people I named you I assumed were because of a the lobbying.

Ms. Amerling. Are you speculating when you say that?

The Witness. I'm speculating.

BY MS. LEACH:

Q When you said "because of lobbying"?

A Requesting jobs. I don't know if lobbying is the right term. I hear the word "lobbying" on the Hill a lot, so --

Q Are you saying Nora Lum was lobbying for these jobs, and you were speculating that she received the jobs based on --

A When she told me they were going to the Capitol to request job offers, you know, for people that were involved in the election, then my conclusion was she was lobbying. I could be wrong, you know. She told me she went, that's it, okay.

Q What were your contacts with David Tseng during APAC?

A Once again, David was there working, I don't know what capacity, being an attorney. I'm sure he was doing some part in the administration. And I always brought food to him. I either cook it at APAC, or I brought it from my home, which was about a mile, a couple miles away. And I kept them fed, that was my job, which I appreciated doing. I did it all my life for 34 years, and teaching.

Q Did you observe anyone who was particularly close to Nora Lum at APAC?

Mr. Darwin Ching. Help us on what terms you mean by "particularly close"?

Ms. Leach. A close personal relationship that developed.

Ms. Amerling. Counsel, could you explain the relevance of asking about personal relationships to the political fund-raising investigation?

Ms. Leach. As I said before, it will become evident throughout the deposition why I'm asking these questions.

Ms. Amerling. I think it's appropriate to explain the relevance when you ask the questions.

Ms. Leach. This is a wide-ranging deposition. Everything is relevant, Counsel. You interrupted me numerous times asking me the relevancy of my questions, and I don't think it's appropriate. These are general questions. I'm trying to get a feel for what the relationships and the interaction is between the individuals.

Ms. Amerling. Counsel, I think you've just made an astounding statement that anything is relevant in this deposition, and I want the record to be clear that the Minority does not concur. What is relevant are questions that relate to the subject matter of the investigation.

The Witness. Could you restate the question again?

BY MS. LEACH:

Q Did you observe anyone who became particularly close to Nora Lum during APAC?

A No, I don't. My observation you're asking, right?

Q Yes.

A In my observation, I didn't observe any. I don't recall that I observed any, you know.

Q Did Nora Lum discuss her relationship with Ron Brown?

Ms. Amerling. Counsel, when you say relationship, are you talking about business relationship or a social relationship?

Ms. Leach. Any relationship.

The Witness. I'm not clear about that, because you know when you say relationship, I'm thinking of an affair and what are you asking me.

BY MS. LEACH:

Q Did she discuss her contacts with Ron Brown?

A Well, I know that she mentioned that, you know, Ron, you know, was a friend of hers. You know, they met, I guess, politically at one time.

Q Did she --

A But she never mentioned details to me.

Q Did she say when she first met Ron Brown?

A No, I can't recall what she said. I would assume -- no, I don't want to assume, because I don't know.

Q During the 1992 time period, did Nora ever mention moving to Oklahoma or buying an oil and gas company in Oklahoma?

A No, she never discussed that with me, whether she was going to buy a gas company in Oklahoma, not in '92.

Q What did she first mention that she was going to do that?

A The first time I heard was in somehow in the winter of '92, when she invited me to come on board as a director.

Q Winter of what year?

A I'm sorry, January of '94, winter of '94. It could have been December. I went to the first board meeting in January of 1994 in Tulsa, Oklahoma.

Q And that was the first time that you knew that Nora had moved to Oklahoma?

A That wasn't the first. She already moved to Oklahoma at that time. She was living there, I believe.

Q Do you know when she moved to Oklahoma?

A I don't know. I don't know exactly what time. But that's when she asked -- that's when I was aware of her purchasing, I call it that, I guess. I don't know the name before that.

Q Did you ever meet Jim Kitchen?

A No, I haven't.

Q Did you ever hear Nora speak of Jim Kitchen?

A I don't remember. I don't recall.

Q Did you ever meet Don Sweatman?

A Yes, I did.

Q Where did you meet Don Sweatman?

A I met him at APAC-VOTE headquarters.

Q Do you know why he was there?

A No, I don't.

Q Do you remember when he was there?

A I don't remember when he was there, but I've seen him several occasions, on several occasions.

Q At APAC?

A Yeah, but I don't know why he was there.

Q Was he there -- do you know who he was there meeting with?

A I was introduced to him by Nora, so I assume that that was the contact.

Q Did Nora ever explain how she first met Don Sweatman or what her association was with Don Sweatman?

A No.

Q Do you know what Nora Lum and Melinda Yee's relationship was?

Mr. Darwin Ching. At what point in time? Any time?

Ms. Leach. Yes.

BY MS. LEACH:

Q Do you know when they first met?

A Well, I only heard Melinda's name during the APAC-VOTE time in the '92. When she met, how she met, I don't know. I never asked.

Q Did Nora Lum ever discuss Melinda Yee with you?

A Well, she mentioned that Melinda was getting out -- was one of the Asian organizers to get out the vote for Bill Clinton.

Q Do you know how much money was raised from any fund-raising events that APAC hosted?

A No, I don't. I think I read it somewhere in the paper that the amount was raised, but I don't even recall the details, because, you know, I like to reemphasize because I'm not involved in the financing. I was, you know, just very involved, you know, with the voter registration and also being the man who supplied the food that she put in their mouth. That's about it.

Q Was your impression that APAC and the DNC were coordinated?

Mr. Darwin Ching. I'm sorry. Can you tell us what that means, "coordinated"?

BY MS. LEACH:

Q Was there any coordination between the DNC and APAC?

Ms. Amerling. Can you define what you mean by "coordination"?

BY MS. LEACH:

Q Was the DNC and APAC affiliated with one another?

A It was my understanding that the -- my understanding the -- as I joined voluntarily, became involved voluntarily, that APAC, Asian Pacific Advisory Council, was an arm, extension of DNC, extending to get out the votes and involved in Asian and Pacific Islanders. So that's my understanding, it was -- there was a relationship.

Q How did you come to have that understanding?

A Because they tell me, Asian Pacific Advisory Council, you know. And we're told that we would get out -- to help encourage, get out the vote for Asian Pacific, which I did, yes.

Mr. Ballen. How did you come to understand that it was related to the DNC, if at all?

The Witness. When I saw Ron Brown come to the reception, I assumed that he encouraged us to get involved, these Asian Americans. And I've got to emphasize Asian American, I'm not a foreigner. I was born in this country, so I got involved with Asian American.

Mr. Ballen. Did anyone, sir, tell you of the relationship or coordination between the DNC and the APAC? Did you ever have a discussion with anyone that laid that out?

The Witness. Not that I can recall.

BY MS. LEACH:

Q When Don Sweatman visited APAC, did you have any conversations with him?

A The only conversation -- let me say, you know, where you're from, he said, Dallas. I said, oh, great, the Cowboys, the Mustangs, I'm a Horned Frog. I attended TCU. And we talked to him. We've got -- you know, I'm Hawaiian. And we talked to me about Texas, you know, general conversation.

Q Was he there to work at APAC, or was he there for other purposes, if you know?

A I don't know what his capacity was. I can't identify that.

Q But you saw him at APAC?

A I saw him, there.

Q Several times?

A Yes, several times, yes.

Q Did Nora ever ask you to contribute to APAC or the DNC, the DNC through APAC?

A I don't remember if I even contributed at that time, except to, you know -- you know, to be involved in the preparation and sometimes running errands and doing things to bring things into -- supplies, you know, paper supplies, whatever was needed, office supplies, whatever, to pick up stuff, just errands. I assisted them, you know. But I don't remember writing any checks to APAC.

I may have written one that says 125 to the reception. That was where I was honored. I don't know if I did even do that, but I know my brothers and nephews did.

Q Did your brothers intend that money to go to the DNC?

A Well, my brother wrote it because he came to celebrate the honoring of myself. What was in his mind, I don't know.

Q Would you be surprised to learn that most of the money contributed at that fund-raising was transferred to Lum's personal bank accounts?

A I would be surprised.

Q I show you what I will mark as Exhibit Number 8.

Ms. Amerling. Counsel, is this a good stopping point for you, because we've gone an hour in the deposition at this point, and I have some questions I would like to ask, if this is a good spot for you.

Ms. Leach. Do you want to pick up with that?

Mr. Mastranadi. We can get back into this after you.

Ms. Amerling. If that's fine with you, then I would like to start my round.

Ms. Leach. Okay.

Ms. Amerling. Thank you. Could we go off the record for two a 2-minute break?

[Recess.]

EXAMINATION

BY MS. AMERLING:

Q Mr. Wong, I want to start by thanking you for coming in today. I know that you traveled a long way to get here, and we appreciate your taking the time to come and talk with the committee.

A You're welcome.

Q I understand that this is not your first time in D.C. Haven't you been bringing groups of young people to D.C. for many years on field trips from California?

A Yes, I have, at least 35 times in the Nation's capital since 1974, and I'm still bringing since my retirement the last 2 years.

Q And you mentioned that you were a social sciences teacher?

A Yes, uh-huh.

Q Did you teach young people about our Nation's history and how the democratic process works?

A I taught government for most of my career and U.S. history and world culture.

Q And did you bring students to Washington, D.C., to help educate them about our Nation's history and how the democratic system works?

A Yes, I call that my extended classroom, beyond the four walls of classroom.

Q Now, when you volunteered at APAC, you had two functions, one as a cook, and the second you were involved in getting out the vote; is that right?

A Getting out the vote, that's right.

Q Those were your two functions at APAC?

A Yes.

Q Your volunteer duties did not include bookkeeping for APAC, did they?

A No.

Q You were not involved with the financings of APAC, were you?

A No.

Q You weren't involved with setting up APAC's bank account, were you?

A No.

Q Do you have any firsthand knowledge of whether a DNC official was involved with setting up APAC's bank account?

A No, I don't.

Q You weren't involved with the financings of the Democratic National Committee, were you?

A No.

Q Apart from anything you may have heard secondhand from other people or the newspapers, do you have any firsthand knowledge of whether the DNC provided funds to APAC?

A No.

Q Do you have any firsthand knowledge of whether DNC officials asked anyone working at APAC to pay for vendors used at events organized or supervised by the DNC?

A No.

Q Do you have any firsthand knowledge of whether DNC officials received contributions from APAC and knowingly failed to report them to the Federal Election Commission?

A Could you restate that again? I don't understand your question.

Q Do you know if DNC officials received contributions from APAC and knowingly failed to report those contributions to the Federal Election Commission?

A No, I don't.

Q Do you know whether the DNC received any contributions from APAC?

A No, I don't.

Q Do you have firsthand knowledge of whether APAC made any conduit contributions to the DNC?

A If APAC made any conduit contributions to the DNC?

Q Yes.

A No, I don't.

Ms. Leach. Do you know what "conduit" means?

The Witness. I finally found out, but it was after the Kennedy campaign.

Ms. Leach. And what is your understanding of what "conduit" means?

The Witness. Well, I imagine that conduit, now I can look at it as an electrical wire going through, that money was given, for example, through my counsel here, you know, with his name on it, but financed by someone else.

Ms. Leach. This is a hypothetical?

Mr. Darwin Ching. I hope so.

The Witness. For example, hypothetical, yes. I didn't know the term. Who am I answering now?

Mr. Ballen. Both of them.

The Witness. Until all this happened, I didn't understand the term "conduit," except I know that it used to be electrical wire. The wire goes through it. He's not a conduit, I know that. He's my counsel.

Mr. Ballen. He's not an electrical wire, but that's off the record.

The Witness. Off the record.

BY MS. AMERLING:

Q Do you know whether anyone at APAC asked for contributions from a foreign person?

A No, I don't.

Q Do you know whether anyone at APAC received contributions from a foreign person?

Mr. Darwin Ching. Foreign; you mean noncitizen?

Ms. Amerling. Yes.

The Witness. No, I don't.

BY MS. AMERLING:

Q Do you know whether anyone affiliated with APAC asked for political contributions from a foreign government?

A No, I don't.

Q Do you know whether anyone affiliated with APAC received political contributions from a foreign government?

A No, I don't.

Q Do you know whether anyone at APAC asked for or received political contributions from anyone who is acting as a conduit for a foreign person or a foreign government?

A No, I don't.

Q Do you know whether any individuals made contributions that originated from foreign persons or foreign governments to the Clinton/Gore 1992/1993 Inaugural Committee?

A No, I don't.

Q I'm going to turn to a few questions on Dynamic Energy Resources. You mentioned that you were -- that you were on the board of directors?

A Yes.

Q And didn't you own a few shares in Dynamic as well?

A I have five shares in Dynamic.

Q You haven't been involved in the day-to-day operations of Dynamic, have you?

A No.

Q Do you have any firsthand knowledge of whether any Clinton administration or Democratic Party officials were involved in Dynamic?

Mr. Darwin Ching. Involved in what sense? On the board? Is that what you're talking about?

Ms. Amerling. On the board we'll start with, on the board.

The Witness. In the Democratic Party you're saying?

BY MS. AMERLING:

Q Democratic Party officials or Clinton administration officials.

A You mean elected officials; is that what you're saying? I'm not -- I'm not sure about the question you're asking me, so --

Q Okay. Democratic Party officials, meaning people who are employed by the Democratic National Committee or another Democratic National Party organization.

A I'm not aware of that. I have no idea.

Q Do you have any firsthand knowledge of whether any Democratic Party official or administration official received money from Dynamic?

A No, I don't. You said firsthand, right?

Q Yes.

Now, have you personally made any conduit contributions?

A Yes, I have.

Q Could you describe the circumstances surrounding those?

A In May of '94, I was asked if I would contribute to the Kennedy campaign, and I wrote a check of my own money, okay? And in September of '94, Nora Lum asked me if I would contribute another thousand. And I consented to do that, and she told me that she would reimburse me for the thousand. And I asked my wife -- being a Kennedy supporter all my life, I asked my wife if she would contribute $2,000, and she did. And she did of her own money, okay?

Q And that was the extent of the conduit contributions?

A Well, I guess I have to find out what a conduit was. I went back to Steve Sakane when he wrote it, and I sent it in. I don't know if you consider that a conduit, because I didn't know the term, you know. And then Nora asked me, I recall in September, to write a check for $2,000 to the Mineta campaign. She wrote me a check first and asked me to write a check to Mineta campaign, which I did.

Q In September of what year?

A Well, I think it was around October of '92. And it was never cashed.

Mr. Ballen. I'm sorry, I didn't hear what you said.

The Witness. It was never cashed.

BY MS. AMERLING:

Q Nora's check to you was never cashed?

A No, Nora's check -- no, my check to the Mineta campaign was never cashed.

Ms. Leach. How did you send that check to the Mineta campaign?

The Witness. I think the campaign -- if I recall, I gave it to Nora, you know. I didn't send it by mail or whatever, because I didn't know where his location was. Then I gave -- I asked my wife to give $2,000, okay, and she wrote a check for 2,000. But I never told her that I would reimburse her. She wrote it -- you know, she had to cash it in the bank. She wrote a check for 2,000.

Q And that was to the Kennedy campaign?

A To the Kennedy campaign, yes. And I'm not saying that it was a conduit. I'm just saying that I asked her, and she did it. And I never told her that it should be reimbursed.

Q And, sir, have you described now the extent of any conduit contributions in which you were involved?

A Yes. Steven Sakane, the check that I endorsed and turned over to the DNC and to Mr. Mineta. I also told the Justice Department that, you know, my wife wrote a check for $2,000, and you know, she was not coerced to write it. She just did it because I asked her to contribute, like Nora asked me on the first check, which I contributed out of my own money in May of '94. Now, you asked me if I ever became a conduit. That is when I found out what a conduit is by counsel, by the Justice Department, that I was a conduit, when I wrote that thousand dollars.

Q I'm not certain that the Sakane check that you mentioned would constitute --

A I just endorsed it, like he was writing it to the campaign. So I just endorsed, and maybe I should have said write it over, but it didn't come to my mind. I didn't know it was improper. I've done that before on other things.

Also, I might explain on the Kennedy campaign, I was reimbursed. They said, thank you for the contribution, and I have notes here. And they returned the money to me, okay? You know, I received the refund on the conduit check a thousand dollars, but also I was identified. I was asked by the Justice in the grand jury, by Mr. Houser or Mr. Baren, to identify these money orders, you know, that was written, that is that my signature, you know? And that's the first time I saw it, that wasn't my signature. Those two money orders wasn't mine. I don't know if it was two. I know I looked at a signature. It could have been one or two money orders. You know, I looked at the signatures, whether it was one or two, that's a long time ago you think, but I know it wasn't my signature. I did not sign that.

RPTS DOTZLER

DCMN WASSERMAN

Ms. Amerling. I don't have further questions at this time. Thank you very much.

Ms. Leach. I will pick up with the questions on the Kennedy campaign. I will go back. First I am going to show you some checks from the APAC bank account that were written to you. I will mark the first check as Exhibit 8.

[Wong Deposition Exhibit No. LW-8

was marked for identification.]

BY MS. LEACH:

Q This is a check written on the Democratic Asian Pacific Advisory Council account at Sanwa Bank. It is check 1008 written on November 2, 1992. It is payable to Larry Wong in the amount of $2,010. It is endorsed on the back. Is that your endorsement? Is that your signature?

A That looks like my signature, but --

Q You said that Nora -- you just mentioned that Nora had asked you to make a $2,000 contribution to the Mineta campaign and she would reimburse you.

A No, no. That was October. What date is this?

Q November 1992. If you look on the back of the check, the bank markings on here are 1992.

A Okay. She wrote me a check.

Q Do you know what this check was -- why she wrote you this check?

Ms. Amerling. I would like to note on this document it appears in the memo section, reimbursed, R-E-I-M, for printing and car rental.

BY MS. LEACH:

Q I had previously asked if you had been involved in the printing of the program.

A No, I had not been involved in the printing of the program.

Q Did you pay for any printing at APAC?

A I don't recall if I did to pay a bill. I did assist them in doing some errands, but I can't recall right now if I specifically went to a print shop. I wasn't involved in the printing, except they asked me for a picture and a little background originally of my profession.

Q This was written on the date of the Mineta fund-raiser in San Francisco. Do you recall what this check --

Ms. Amerling. What is the question?

BY MS. LEACH:

Q Do you recall why she wrote this check to you?

A No, I don't.

Ms. Leach. I am going to refer now to the Kennedy checks. You produced check number -- and I will mark this as Exhibit No. 9.

[Wong Deposition Exhibit No. LW-9

was marked for identification.]

BY MS. LEACH:

Q It is a Dynamic Energy Resources check on State Bank, No. 1781, dated September 19, 1994, to Larry Wong in the amount of $3,000, and in the memo line it says "Reimbursement." Do you know what reimbursement, what she meant by "reimbursement" here?

A This is written September 19 --

Q 1994.

A -- 1994. I know she told me that she would reimburse me for different and food and hosting -- you know, parties and all that. But my understanding when I saw this check, I wrote a check in which I became a conduit in September, around 16th, I believe, of 1994. But when she asked me to write a check, let me reiterate -- she asked me to contribute $1,000 and I said I would. She said that she would reimburse me. I assume that $1,000 was for reimbursing me.

Q We have the checks that you produced to us. We will mark those.

A The check that I wrote for a $1,000?

Q You wrote two checks for $1,000 and your wife wrote one $2,000 check.

A My wife wrote a check. I didn't tell her that I would reimburse her. She wrote it out of her own -- I don't consider it a conduit for that.

Ms. Leach. I will just mark your checks to the Kennedy campaign.

[Wong Deposition Exhibit No. LW-10

was marked for identification.]

The Witness. Yes, I wrote these two checks.

BY MS. LEACH:

Q I have marked those as No. 10.

A This was September 16. I don't know when she called me, but she asked me if I would contribute another $1,000 under my signature but of her money. And I consented to do that, but I had an understanding that she would reimburse me for that $1,000. The other $2,000 I would imagine was for my assisting her.

Ms. Leach. You produced a check written by your wife and we will mark that as Exhibit 11.

[Wong Deposition Exhibit No. LW-11

was marked for identification.]

Ms. Leach. This check was No. 421 dated September 16, 1994, payable to Kennedy for Senate from the account of Betty Wong in the amount of $2,000, and you produced your two checks, No. 1592 from the joint account of Larry and Betty Wong dated May 6, 1994 for $1,000 and check No. 5303 from the joint account of Larry and Betty Wong dated September 16, 1994 to Kennedy for Senate for $1,000.

And you also produced a reimbursement check from the Kennedy for Senate 2000 in the amount of $2,000, dated May 15, 1997, payable to Larry Wong. I will mark that as Exhibit No. 12.

[Wong Deposition Exhibit No. LW-12

was marked for identification.]

Ms. Leach. I am also going to show you your Federal Election Commission contribution history. There are three different pages, and we will mark them all as Exhibit No. 13.

[Wong Deposition Exhibit No. LW-13

was marked for identification.]

BY MS. LEACH:

Q On the page it lists the dates May 25, 1994 and September 23, 1994. It lists a $1,000 contribution from Larry Wong to Kennedy for Senate.

Mr. Darwin Ching. I'm sorry, where are you looking at?

BY MS. LEACH:

Q These contributions, the May 25th and the September 23rd, I am assuming these are the reports for these two checks, your May 6th check and your September 16th contribution to Kennedy for Senate?

A I really don't know. You are referring to these two checks that I wrote?

Q Yes. They were reported, as closely as I can tell, on May 25, 1994 and September 23, 1994.

Ms. Amerling. Are you asking him to testify regarding that record?

Ms. Leach. No, I am not.

The Witness. I --

Mr. Darwin Ching. There is no question pending.

BY MS. LEACH:

Q I am trying to match up the contributions to the FEC.

Mr. Ballen. There is no basis in the record for that.

Ms. Leach. I am not asking that.

BY MS. LEACH:

Q On the next page there are two contributions reported, both on April 4, 1995, in the amount of $1,000 for Kennedy for Senate 2000.

A '95?

Q And there are no corresponding checks for these two contributions.

A Yes.

Ms. Amerling. There are no corresponding checks in what?

BY MS. LEACH:

Q In what you have produced. Do you know why there are not checks? Why you do not have checks for these contributions?

A I recall that the Justice Department, Mr. Hulser or Mr. Biran, I forgot, asked me -- showed me, as I say, one or two, maybe three: Is this your signature? Those were not my signature. They may be referring to this, okay. That was done in Oklahoma. I never was in Oklahoma at that time.

Q The money orders were from Oklahoma?

A That is what they showed me, as I recall. I didn't write those money orders. I did not write any money orders.

Q What else do you recall from those money orders?

A All they asked me: Is this your signature? Did you write this? I said no. That is all.

Q They were from Oklahoma. Did you see the bank?

A No. Either they told me, "Were you in Oklahoma at this time?" I don't recall. I can't trust my memory, but that wasn't my signature. One or two of them wasn't my signature, and that explains why I don't have a return check for that because I didn't do it.

Ms. Amerling. Counsel, I think your questions here are probing into events that occurred in grand jury testimony and I don't know that is appropriate.

Ms. Leach. The witness can testify to his own testimony.

Mr. Ballen. That does not mean that we should be asking him to violate that. If the witness volunteers something as he did before, that is fine. But questions of what occurred before the grand jury, it is my understanding this committee does not inquire what occurred in the grand jury.

Ms. Leach. I asked him if he could explain why he did not produce checks for these two contributions dated April 4, 1995.

Mr. Ballen. The record will speak for itself. You asked him a series of questions covering what was said in grand jury. That is not my understanding of the way we were supposed to be conducting our deposition.

Mr. Darwin Ching. For the record, I will clarify. The questions regarding those money orders were asked in a briefing session before the grand jury had been convened, and so to that extent part of what he was testifying to is not just in the grand jury.

BY MS. LEACH:

Q Your FEC history shows that there was three $1,000 refunds of contributions, two May of 1997 and one June 30 of 1997. Have you received a refund for the fourth $1,000 contribution?

Ms. Amerling. I am unclear when you ask about the fourth.

BY MS. LEACH:

Q The FEC has reported that Mr. Wong made four $1,000 contributions to the Kennedy for Senate campaign and Kennedy for Senate 2000, and I am showing that there has been $3,000 returned. I am asking if the other $1,000 has been returned.

A Yes, it has been returned.

Q They returned --

A Whether the Kennedy campaign returned it to me is your question?

Q We have documents showing that they returned $3,000. Did they return another $1,000?

A Yeah.

Q What is the total?

A Returned to me was -- I would say --

Mr. Darwin Ching. Can we have agreement to go off the record in order to refresh his recollection?

Ms. Leach. Sure. Off the record.

[Recess.]

Ms. Leach. Back on the record.

The Witness. Yes, the $1,000 was returned. There is a record to me, $2,000.

BY MS. LEACH:

Q What is the date?

A 5-15-97. There was one for $1,000 returned on 6-30-97 to me.

Q So for a total of $3,000?

A Yes.

Q The FEC has reported that you made four $1,000 contributions, so the total of campaign contributions returned to you by the Kennedy campaign is $3,000?

Mr. Darwin Ching. Perhaps you can help us. He got $4,000?

Ms. Leach. No, he got back $3,000.

BY MS. LEACH:

Q The FEC has reported $4,000 in contributions. The FEC has reported that you made four $1,000 contributions, and the Kennedy campaigns have returned to you $3,000; is that right? I am asking if you have gotten another --

A You mean four single $1,000 --

Mr. Ballen. What was the total contribution that you made?

The Witness. Let me explain what I did. I wrote a check in May of 1994 for $1,000. Out of my own money I contributed, okay? I wasn't asked -- I did it on my own, okay? In September of 1994, September 16 or whatever date it was -- September 16, I wrote a check for $1,000 after Nora asked me to contribute another $1,000, okay? And I wrote this check and she said she would reimburse me for the $1,000. But I asked my wife to contribute $2,000 and she did out of her own money. I did not force her. I asked her like a good husband and like a good wife. The rest were not my signatures, I think I told you that, on the money orders.

BY MS. LEACH:

Q Right. I am going by what the FEC has reported, and they have reported that you made four $1,000 contributions and the Kennedy campaigns have returned three.

Mr. Ballen. He can only testify as to what he did.

Ms. Leach. I am asking if --

Mr. Ballen. He told you what he gave.

The Witness. I received the $3,000.

BY MS. LEACH:

Q That is all that you have received in refunds?

A Correct.

Q Can you describe how Nora asked you to make this conduit contribution in September of 1994?

A I don't recall exactly how she did, but she either called me or she talked to me in person. I think she called me, and she asked me, "Would you contribute another $1,000 to the Kennedy campaign?" And I said I would. And she said, "I will reimburse you for the $1,000." And I agreed that I would write the check and she said she would reimburse me for $1,000, okay? That's all.

But I asked my wife to write a check for $2,000, and she did, not coerced, just agreed. Being a Kennedy supporter like I am since the sixties, she did.

Q Are you aware in the factual basis for Nora and Gene Lum's plea agreement that they identified check No. 1781 as a reimbursement to you and your wife for conduit contributions made to the Kennedy campaign?

Ms. Amerling. Excuse me, does the document that you are referring to refer to Mr. Wong by name?

Ms. Leach. It refers to a Dynamic shareholder and director and his spouse, and identifies check 1781 made out to that shareholder and director for the purpose of making conduit contributions to the Kennedy campaign.

Ms. Amerling. Thank you for clarifying.

The Witness. You are asking me if I was aware?

BY MS. LEACH:

Q Were you aware that check was for the reimbursement for those contributions?

Ms. Amerling. Excuse me, I am not clear on the question when you say "those contributions."

Ms. Leach. The contributions to the Kennedy campaign.

Ms. Amerling. Which contributions are you talking about?

Ms. Leach. The contributions that he made. I don't know. I am asking him to explain the reimbursement from Nora.

BY MS. LEACH:

Q You said that she stated she would reimburse you for the contributions?

A For the $1,000 that I wrote in September.

Q And she identified that check as the reimbursement for the contributions?

A I don't know where the other $3,000 came from, and I only found out about that proffer when you handed it to me this morning. My understanding, she told me she would reimburse me for that $1,000. I asked my wife, and I don't consider it conduit because she did it with her own money.

Mr. Ballen. Just so we are clear, your understanding is that Nora Lum was going to reimburse you for $1,000?

The Witness. $1,000.

Mr. Ballen. She gave you this check but you asked your wife independently to write a $2,000 check?

The Witness. Right. But my wife got it refunded back to her, and I began to question that because my wife testified --

Mr. Darwin Ching. Let's not go into the grand jury.

The Witness. I asked her like you would ask your husband to contribute. I asked her and she did. But it had nothing to do with that reimbursement of the $3,000. That $3,000 came for whatever reasons, favors that I have done for her. Reimbursement can be many other things, $1,000, $2,000.

BY MS. LEACH:

Q I was asking you for your understanding.

A My understanding is $1,000.

Q Based on the plea agreement?

A No, no.

Ms. Amerling. Are you asking if the plea agreement refreshes his recollection?

BY MS. LEACH:

Q I am asking for your explanation.

A This is not correct, okay.

Ms. Amerling. When you say "this"?

The Witness. The proffer that I read this morning. The factual basis for the plea saying my wife was a conduit. My wife was never a conduit. I asked her for it. I don't want a divorce after 41 years.

Mr. Ballen. So if the Lums made this statement, it would be wrong?

The Witness. I don't agree with it. That is false. I gave $1,000, and was told that I would be reimbursed. I was wrong, and I am sorry I did that.

BY MS. LEACH:

Q Thank you. I wanted that clarified. Did Nora discuss with you any other individuals that she asked to make conduit contributions?

A No. No.

Q Did she say --

A Discuss with me, no.

Q Did she name other individuals who were making conduit contributions at her request?

A No.

Q Did other individuals discuss with you making conduit contributions at Nora's request?

A No.

Q For the Kennedy campaign or the Mineta campaign or any other campaign?

A Not for any other campaign.

Q Did Nora Lum ever ask you if your name could be used on a conduit contribution?

A No.

Mr. Darwin Ching. Other than what he just testified?

The Witness. Other than I explain to you on the Mineta and --

BY MS. LEACH:

Q The Mineta campaign and the Kennedy campaign?

A Yes.

Ms. Leach. We were about to introduce Exhibit No. 14 of the APAC checks.

[Wong Deposition Exhibit No. 14

was marked for identification.]

BY MS. LEACH:

Q These were diverted to Lum-owned corporations. The bank records are for -- from the Democratic National Committee, Asian Pacific Advisory Council, Sanwa Bank. They show a number of checks written to CPI Corporation and Akahi Joint Venture, one on October 21, 1992 for $20,000 written to CPI Corporation, signed by Nora Lum.

A What check is that, now?

Q The first one.

A $20,000?

Q Yes.

A Okay.

Q The second check is No. 1007 written on November 2, 1992 from Democratic National Committee, Asian Pacific Advisory Council account, in the amount of $9,303, payable to CPI, signed by Nora Lum.

November 2 there is another check for $14,385 to CPI Corporation, signed by Nora Lum.

November 10, there is a check to CPI -- payable to CPI Corporation in the amount of $12,500, signed by Nora Lum.

November 16, payable to CPI Corporation in the amount of $14,000, signed by Nora Lum.

December 12, 1992, payable to CPI Corporation in the amount of $15,000, this time signed by Gene Lum.

A check on December 15 to CPI Corporation in the amount of $3,100, signed by Nora Lum.

On December 25, it looks like, there is a check written out to Nora Lum in the amount of $1,500, signed by Gene Lum.

January 14, 1993, to Akahi Joint Venture in the amount of $30,000, signed by Nora Lum.

On January 26, 1993, there is a debit of $30,000 transferred to CPI Corporation.

Finally, on February 10, 1993, there is a debit transfer of the final $202.21 of the Democratic National Committee, Asian Pacific Advisory Council account transferred to CPI Corporation.

I asked you if you were surprised to learn that the money deposited into the APAC bank account, raised at some of the APAC events, was transferred to the Lum-owned and controlled bank accounts when the checks that were deposited into this APAC check account were all made payable to the DNC?

Mr. Ballen. I object. Let me ask the witness, have you ever seen the checks?

The Witness. No. What is CPI?

Mr. Ballen. Do you know anything about these checks?

The Witness. No, I don't.

Ms. Leach. CPI is a Lum corporation.

BY MS. LEACH:

Q What was your last contact with Gene and/or Nora Lum?

A Last contact when I first -- I saw them last Friday before I left because Marie Callender, we met for coffee. It was a social get-together.

Q Did they know that you were coming here?

A Yes. They knew that I had a deposition, and I just told them I would be going to a deposition.

Q Did you discuss what you would talk about here with them?

A No. Just in general that I would be answering questions relative to the APAC -- whatever. You know. But nothing specific.

Q Did they ask you to say anything?

A All they told me was to speak the truth, and I am.

Q Have you ever met Michael Brown?

A Yes.

Q When did you meet Michael Brown?

A The first time was at the January 1994 board meeting in Tulsa, Oklahoma when I came on board, uh-huh.

Q What were your contacts with Michael Brown since that meeting?

A I have seen him maybe once or twice in Los Angeles when he came to visit, you know, the Lums, and another time at kind of a wedding -- what do you call it? Not a bachelor's party, but when Trisha was getting married there was a little dinner, and I met him there with Michael's sister.

Q Where was that?

A That was somewhere in West L.A.. I don't recall the restaurant where we ate.

Q Do you know what business Michael Brown had at L.A. Sound?

A At the first board meeting we -- the board voted to --

Mr. Darwin Ching. L.A. Sound?

The Witness. I'm sorry, Dynamic Energy.

BY MS. LEACH:

Q You said Michael Brant. You meant Michael Brown --

A I'm sorry, I thought you asked me when I first met him. Will you ask the question again?

Q When Michael Brown came to L.A., and you said that you met him at L.A. Sound offices?

A When he came to visit, I saw him there. He was visiting. I happened to be coming in or I was cooking at that time. Also I prepared food there, too, in the warehouse. Why was he there?

Q Why was he at L.A. Sound?

A I don't know. Socially, I guess, to visit. Visit a friend.

Q Did you ever come to learn that the Lums were being investigated by the FBI as part of a political corruption case in Hawaii?

A Did I ever come to learn? Not that I recall. When was this investigation?

Q It began in 1992.

A No.

Q The Lums never discussed this with you?

A No. 1992 there was an APAC vote.

Q Yes.

A No, I don't recall them mentioning it to me.

Q It continued into 1994.

Ms. Amerling. Is that a question, counsel?

Mr. Ballen. Do you recall anything about that, sir?

The Witness. No, I don't recall. My memory is -- I don't recall. I may have read something in the paper, but every day this thing is in the paper with the media.

BY MS. LEACH:

Q They never discussed the investigation with you?

A No, I don't recall that they did.

Q Did Nora ever discuss meeting James Riady?

A James who?

Q Riady.

A I thought you mentioned two names.

Q James Riady.

A No.

Q Did Nora discuss what her activities were on the 1994 Kennedy campaign? Did she discuss working on the campaign?

A The 1994 campaign, yes, she mentioned to me that she went to Boston or she was going to Boston to get out the Asian votes supporting Kennedy.

Q Did she say who went with her?

A No.

Q Do you know how many times she was there?

A No. I don't -- I don't recall if she even told me how many times she was there, but she told me that she was going to go and she did go.

Q Do you know whether Trisha went?

A I am not aware of it if she went.

Q Do you know anything about a charter plane in June of 1994 that Nora Lum paid for?

A No.

Q At that board meeting on January 15, 1994, that was the first Dynamic board meeting? Was that the first board meeting?

A In January -- I don't recall a date, but in January 1994, that was my first attendance at the board meeting. That was the first board to organize. Is that what you are asking me?

Q Right.

A Yes. We were called to attend that board meeting.

Q You said Michael Brown attended that meeting?

A Yes. He was at that meeting.

Q Was Helen Yee at that meeting?

A I don't recall if Helen Yee was there. I think she was there, but I don't remember. I don't trust my memory, I would need to check.

Q I have the minutes from --

A Let me look at it.

Ms. Leach. We will mark that as Exhibit 15.

[Wong Deposition Exhibit No. 15

was marked for identification.]

BY MS. LEACH:

Q It is a minutes of the shareholder and directors meeting of Dynamic Energy on January 15, 1994 at 502 South Main Mall in Tulsa, Oklahoma.

A My recollection, I wasn't clear, but according to this -- I knew some of the others that came -- but from this minutes it says Melinda Yee on behalf of Helen Yee. So if this is true, I can't even trust to memory if she was there.

Q Do you remember Melinda Yee being there?

A I believe I do now.

Ms. Leach. I want to recognize Barbara Comstock with the majority counsel just came into the room.

BY MS. LEACH:

Q Did Nora Lum discuss with you why she appointed Michael Brown as an officer of Dynamic Energy?

A No.

Q Did Nora Lum ever explain to you why Dynamic opened a Washington, D.C. office?

A No, she hasn't. No, she didn't.

Q Did she explain why Gil Colon was hired to work at Dynamic in the Washington office?

A No.

Q Did you know that Gil Colon was hired to work in the Washington office?

A Yes, I knew that he was hired, but I didn't know why.

Q You produced the minutes of the August 1, 1994 board of directors meeting in Hawaii?

A Yes.

Ms. Leach. I would like to ask you some questions. That will be marked as Exhibit Number 16.

[Wong Deposition Exhibit No. LW-16

was marked for identification.]

BY MS. LEACH:

Q This is the minutes of the meeting with shareholders and directors of Dynamic Energy on August 4, 1994 at 4375 Royal Place in Honolulu, Hawaii. On the first page in the last paragraph Nora says, "In exchange for the stocks held by the Prices, Dynamic Energy Resources will contribute $150,000 to Stuart Price's campaign."

Can you explain why $150,000 was donated to Stuart Price's campaign in exchange for the stock?

Ms. Amerling. Counsel, let's be clear about your question. The document you reference says Nora Lum stated Dynamic will donate $150,000, and your question is, "Do you know why that was contributed?"

BY MS. LEACH:

Q Why there was an offer to contribute $150,000 in exchange for stock?

Ms. Amerling. Why don't we start by asking what the witness does know.

BY MS. LEACH:

Q Do you know that this offer was made to donate $150,000 to Stuart Price's campaign?

A Yes, uh-huh.

Q Do you know why Nora Lum offered to contribute $150,000?

A From my understanding, because he was going to run for Congress, you know. He wanted his shares of stock out. So I understood he wanted his money out. I objected to that down the road in the part of the meeting when I said it is not time for distribution, why should we give him his shares now? We needed him because he was an expert on natural gas.

Ms. Amerling. When you said that you objected down the road, did you mean at the meeting?

The Witness. Yes. I objected at the meeting. If you look at the second page in the paragraph, myself and Ron Higa strongly objected to giving Stuart any more money for the stocks because they thought that the distribution should not have been made until the end of the year. It was not time for the distribution. I was rather concerned because if we have a man that is supposed to be the expert in gas leaving us, and said he is not a candidate and he was not going to run and he became president of the company, and we depended on his expertise. Nora Lum was not an expert on this company, and so I objected to it, to giving him his distribution at this time.

BY MS. LEACH:

Q Do you know what Ron Higa meant by his suggestion to pay Stuart Price as an attorney and consultant to avoid Federal election regulations?

Ms. Amerling. Counsel, are you referring to something that is written up in this document?

Ms. Leach. In the second full paragraph on the second page, right under the sentence where he strongly objected to making the distribution.

Ms. Amerling. And you are asking the witness what the witness thought somebody else meant?

Ms. Leach. I am asking if he understood what Ron Higa meant, if there was other discussion at the time.

The Witness. No, I did not know why Ron asked that question. I could not explain that.

BY MS. LEACH:

Q Do you know why Nora placed him on the board?

A No, I don't.

Q Did she ever --

A Placed Ron Higa?

Q Yes.

A No, I don't.

Q Do you know why she placed Wally Lean on the board?

A No.

Q Do you know why she placed Ted Kimura on the board?

A No.

Q Do you know why she placed Richard Choi Bertsch on the board?

A No, I don't. Richard Choi Bertsch is one person you are referring to?

Q Yes. Do you remember what Nora responded to Ron Higa's suggestion that they pay him as an attorney and consultant?

A I don't recall. Unless it is written in the minutes -- I haven't seen the minutes for a long time. No. No, I don't remember her response.

Q On the third page, on the third paragraph that begins, "The Board in recognition of the services provided by Nora Lum as Chairman, CEO and now President hereby authorize the payment of $300,000 as a bonus. Nora Lum requested that she be allowed to use the bonus freely. The Board unanimously agreed. The Board also authorized Nora and Gene Lum be given an expense account of $30,000 per month but not to exceed $200,000 for the period of July through December, 1994."

Do you recall any discussion as to why these payments were being made?

Ms. Amerling. Can we start by asking whether he recalls the discussion?

Ms. Leach. I did.

The Witness. I recall this proposal here, yes. And we resolved this.

BY MS. LEACH:

Q Do you recall the discussion as to why they were being paid $30,000 a month in expenses?

A For expense account. I took it as expense account.

Q Do you know what the discussion was?

A No, I don't. I don't recall the discussion or the details at that time. But I remember this proposal.

Q On the fourth page, the paragraph that reads, "The meeting continued with the discussion of DERI's payment to Timson Oil & Gas Company in the amount of $30,000. Chairman Nora Lum informed the Board that the payment was to enable Robert Price, (Stuart's brother) to be a full time campaign manager."

Was that payment ever made?

A I don't recall if it was ever paid.

Q Do you recall a discussion surrounding the payment of $30,000 to Robert Price?

A I recall the discussion, but I don't remember all of the details. It has been quite a long time ago.

Q What do you recall of the discussion?

A Well, now -- I can't trust my memory, and like I asked her, I wanted to know whether this $30,000 was part of the $150,000 we owed Stuart's campaign.

Q What was the answer to that?

A As stated here, "No, this is a favor for Stuart."

Q Do you know what Nora Lum meant by "this is a favor for Stuart"?

A No, I don't.

Q And you don't recall whether the $30,000 was ever paid?

A No, I don't recall that.

Q Do you --

A I am not involved in the administration of it. I just attended the board meeting at that time.

Q But as a director, you have some responsibility over the corporate spending?

A Right.

Q Do you know whether Dynamic invested $50,000 in a joint venture with Timson Oil and Gas for the drilling of two wells?

A I believe they did, yes.

Q It was invested?

A I believe it was invested, yes.

Q Do you know what was the result of that joint venture?

A I don't know the results. I do know that Nora had mentioned that drilling has not been successful. I don't know when she mentioned it.

Ms. Leach. You produced notes Bates stamped 39 and 40. This was at the January -- they are dated January 25, 1994 marked as Exhibit 17.

[Wong Deposition Exhibit No. LW-17

was marked for identification.]

BY MS. LEACH:

Q Do you remember under what circumstances these notes were taken?

A Well, I was sitting in the board meeting and I took a few notes. Some of them were sketchy, and I didn't pick up everything that was said, but I wrote what I -- what I heard, you know.

Q This says January 25 and the board meeting was on the 15th.

A If I wrote this on the 25th --

Q Is this your handwriting?

A Yes, this is my handwriting. I question about the date of it. The board meeting -- I don't think that it was January 15 because I recall -- right after the board meeting that Sunday I flew in to the Northridge earthquake. That was at the end of the month. I was stuck in Utah somewhere. So -- I wrote -- I know that I wrote this at the board meeting. I took notes. But the date -- I can't recall what exact date. I know that it was January of 1994. You said the 15th.

Q The date on the minutes of the shareholders is January 15.

A That could be a mistake.

Q And then your notes are the 25th. Unless the "2" is a "1."

Do you know why you made a notation regarding John Tisdale, attorney representing Dynamic?

A Well, I saw John Tisdale sitting down, and he was a Little Rock attorney.

Q He was at the board meeting?

A Yes. I put here "attended, represented Dynamic Energy." That is what I was told, he would represent Dynamic Energy Resources.

Q Why is his name not listed here if he attended the meeting?

A I don't know.

Q On Exhibit 15.

Ms. Amerling. Did you write the minutes?

The Witness. I wrote this.

Ms. Amerling. Did you write the notes reflected in Exhibit 15? The minutes of the January 1994 board meeting?

The Witness. No, I didn't write this. This here is what I wrote.

BY MS. LEACH:

Q But you did attend the January 1994 board meeting?

A I believe he did. That is when I first met him and the only time I met him.

Q Did Nora Lum explain why John Tisdale was selected to represent Dynamic Energy?

A No. It was just mentioned that he represented Dynamic Energy. That was my understanding.

Q In what capacity was he representing Dynamic Energy, did she say?

A I believe --

Mr. Darwin Ching. Don't guess.

BY MS. LEACH:

Q Did Nora say in what capacity he was representing Dynamic Energy?

A I guess counsel.

Q Did she explain where he was from?

A I wrote it down here that he represented Dynamic Energy. Maybe as an attorney or adviser, whatever.

Q Did Nora Lum say where John Tisdale was from?

A Yes, she did, and I told you from Little Rock just a little while ago.

Q Did she explain why she chose an attorney from Little Rock to represent a company from Oklahoma?

A No.

Q On the next page of your notes under the heading of agenda, under letter 4(e) you have written "$2.5 million debt." Do you remember why you made that notation?

A I looked at that this past weekend and I don't recall why I wrote that, under what circumstances. I did say $2.5 million debt. Unless -- I can't understand why I wrote it. I can't recall why I wrote it. It was a short note.

Q The letter (f) underneath that, "gauge," is that "proposed $1.5 million debt"?

A I believe I said proposed, but presiding was Stuart Price, and so I just took notes of what he said. Having very little knowledge of gas production, that's what I -- that's what I heard, "proposed $1.5 million debt." I can't recall why the proposal was at this time.

Q You don't know --

A I don't recall.

Q You don't know what the $1.5 million debt was referring to?

A No, I don't.

Q What events did you attend in Washington, D.C. with the Lums at any point?

A I went -- I attended the inauguration of President Clinton in 1993. I attended -- in May of 1993 I went to the East Room of the White House, where I was one of -- I understood one of a hundred Asian Americans honored for community service, et cetera. On both occasions the Lums were there with us.

I am trying to remember. At one time I was -- I wasn't with them, but I flew in to a Kennedy campaign fund-raiser, I can't recall the exact time, but it was cancelled because Jackie Kennedy had passed away that evening on a Thursday and it was for a Friday. I was invited by the Lums to join them.

Q Do you know where that fund-raiser was held?

A I believe it was in Kennedy's home in -- out in Virginia somewhere. I don't know where his home is. Near the FBI or the CIA headquarters. What is the name of that?

Q Langley? McLean?

A McLean, I believe. I am not sure because it was cancelled. I ended up in a hotel and took my toothbrush and went home after that.

Q Was ever rescheduled?

A It was rescheduled I believe for the summer, but I didn't attend. I believe it was rescheduled.

Q Did you contribute any money to attend that fund-raiser?

A No. Not at that time. I contributed the other times. I don't recall contributing at that time. But I did contribute, as you can see here.

Q Did Nora discuss with you how she came to be invited to that fund-raiser?

A No, she did not.

Q Did Nora invite you to attend that?

A Yes. They invited me. That is why I went. I believe they must have bought a table and they asked me to join them. I was thrilled because I never met -- I'm sorry, I met Kennedy in '82 when he was campaigning in California.

Q Were you involved in another Lum entity called Asian Pacific American Educational Council or a name similar to that?

A Yes. Several years ago we -- she told me that she would like to get me involved, being an educator, on the student exchange program, I believe, with people from Taiwan or Nationalist China, China proper, Republic of China, to work with the student program because of my experience in education. And I said yes, I would like to give it a shot. It never materialized. It was deceased. It never got off the ground, let me put it that way.

Q Were you familiar with another organization called Young Americans Together for Change?

A YATC. Yes, I was familiar with it because during the 1992 campaign, Young Americans Together for Change during the 1992 campaign and I went out to some section of Los Angeles, Watts, and we were out there getting out the votes and encouraging people to support and register and pushing them to get them involved in the political process.

Ms. Leach. In a letter that you produced over the weekend, it was a letter to Darwin Ching from Raymond Hulser at the Justice Department dated April 25, 1997 -- I don't have other copies of this -- you discussed a proffer agreement. I will mark this as Exhibit 18.

[Wong Deposition Exhibit No. 18

was marked for identification.]

BY MS. LEACH:

Q Can you discuss that proffer?

Ms. Amerling. Could you give me a second to look this over before you ask that question?

Ms. Leach. Off the record.

[Recess.]

Ms. Leach. Back on the record.

BY MS. LEACH:

Q Did Nora Lum explain to you why she chose you to put on the board of Dynamic?

A When she asked me to join the board, she told me that Dynamic would be doing other things such as getting involved with student scholarships, and she knew that I had raised more than 400 scholarships as a teacher, voluntarily, without being paid.

She wanted to get involved with students in Langston University, Oklahoma who wanted to form minority company, Asians, multi-cultural, which I agreed, Anglos, white, yellows, et cetera, so I would fit into it. And I said I hope I can contribute in that way. And she said it would be helping youth and educating kids, which I have done all of my life. I said I would love to get involved in that.

Q Is there anyone else that you are aware of that Gene and/or Nora Lum gave money to for the purpose of making political contributions?

A I am not aware of any. They didn't tell me.

Q Did anyone else discuss with you money that Gene and/or Nora Lum gave them for the purpose of making political contributions?

A As conduits, you mean?

Q Yes.

A No.

Q Did Nora ever discuss with you her contacts at the Democratic National Committee?

A Before the 1992 election or after?

Q At any time.

A She had mentioned at times that she did visit the Democratic National Committee and talked with people, but I don't know in particular who.

Q No names?

A I can't recall any names she told me, but she did tell me she did visit DNC headquarters on Capitol -- wherever it is.

Q Do you know how often she visited the Democratic National Committee?

A No, I don't.

Q How often did she tell you she was --

A She might have told me once or twice. I am not for certain.

Ms. Amerling. Counsel, it has been over an hour and 15 minutes since you started this most recent round, and it is the minority's turn. Before you would proceed to that, I would like to ask if you can give an estimate how much longer.

Ms. Leach. I have a few more questions.

Ms. Amerling. Just a few more questions on that line?

Ms. Leach. Yes.

Ms. Amerling. Say 5, 10 minutes?

Ms. Leach. Yes, and that is all it would be.

Ms. Amerling. Okay.

Ms. Leach. Continue?

Ms. Amerling. That's fine.

BY MS. LEACH:

Q Did Nora Lum mention any contacts she had at the Department of Commerce after the 1992 election?

A She mentioned her daughter worked at Commerce, and I understood that John Huang was employed at Commerce. Shan Thever was employed at Commerce. I could have read this in the paper, too. She could have told me. And naturally the Secretary of Commerce, the head of the Commerce Department everyone knows was appointed.

Q Did Nora Lum say that she met with John Huang and Shan Thever and Ron Brown at the Commerce Department?

A No.

Q Did she ever mention meeting or speaking with Melinda Yee at the Commerce Department?

A Not that I recall.

Q Do you know who Nora Lum's contacts were at the White House?

A No, I don't. You mean somebody employed at the White House?

Q Yes.

A No, I don't.

Q Did she ever discuss who invited her to these events that she attended at the White House?

Ms. Amerling. Which events are you referring to?

Ms. Leach. There were a number of events.

BY MS. LEACH:

Q There was an Asian Pacific American celebration in May.

A Of 1993?

Q Yes.

A No, she didn't tell me.

Q You attended that?

A I attended, yeah.

Q She didn't discuss how she --

A No.

Q -- how she was chosen to get that invitation?

A No.

Q Do you know how you were chosen to get that invitation?

A Nora told me that I was invited to it. I don't know how I got it. It was through Nora.

Ms. Leach. That's all.

Ms. Amerling. That completes your questioning?

Ms. Leach. Yes.

Ms. Amerling. I don't have any further questions. I want to thank you for your cooperation.

Mr. Darwin Ching. Thank you very much. It is my understanding that the transcript will be sent to us for review?

Ms. Leach. Yes.

Mr. Darwin Ching. And we will have 5 days to respond to any technical or typographical, and if there are any such changes we will respond back on the signature page?

Ms. Leach. That is correct. Off the record.

[Whereupon, at 1:02 p.m., the deposition was concluded.]

CONTENTS

EXHIBITS: PAGE

Wong Deposition Exhibit No. LW-1

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Wong Deposition Exhibit No. LW-2

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Wong Deposition Exhibit No. LW-3

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Wong Deposition Exhibit No. LW-4

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Wong Deposition Exhibit No. LW-5

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Wong Deposition Exhibit No. LW-6

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Wong Deposition Exhibit No. LW-7

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Wong Deposition Exhibit No. LW-8

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Wong Deposition Exhibit No. LW-9

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Wong Deposition Exhibit No. LW-10

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Wong Deposition Exhibit No. LW-11

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Wong Deposition Exhibit No. LW-12

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Wong Deposition Exhibit No. LW-13

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Wong Deposition Exhibit No. LW-14

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Wong Deposition Exhibit No. LW-15

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Wong Deposition Exhibit No. LW-16

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Wong Deposition Exhibit No. LW-17

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Wong Deposition Exhibit No. LW-18

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