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PETER F. PAUL, Appeal No. B191066 Plaintiff and Appellant, (Superior Court vs. No. BC 304174)
WILLIAM JEFFERSON CLINTON, (Honorable Aurelio N. Munoz, Judge) Defendant,
HILLARY RODHAM CLINTON, HILLARY RODHAM CLINTON FOR U.S. SENATE COMMITTEE, INC.,
Defendants and Respondents.
DECLARATION OF D. COLETTE WILSON, COUNSEL FOR APPELLANT, IN SUPPORT OF MOTION TO ADMIT NEW DOCUMENTARY EVIDENCE
Gary G. Kreep (SBN 066482) D. Colette Wilson (SBN 123112) UNITED STATES JUSTICE FOUNDATION 932 D St., Suite 3 Ramona, CA 92065 Tel. (760)788-6624 Fax (760) 788-6414
Attorneys for Plaintiff and Appellant I, D. COLETTE WILSON, declare:
1. I am an attorney at law, licensed to practice before all the courts of the State of California, and I am co-counsel for the Plaintiff and Appellant in the within action. I am over the age of 21 years, and I make this declaration in support of Appellant's Motion to Admit New Documentary Evidence.
The following facts are true of my own knowledge and, if called to testify, I could and would competently testify thereto.
2. On November 9, 2006, based on information provided to me by my client, Peter Paul, I telephoned Assistant U.S. Attorney Jonathan "Jed"
Davis, in the United States Attorney's Office for the Eastern District of New
York, located in Brooklyn, New York. Assistant U.S. Attorney Davis is the prosecutor of Mr. Paul in United States v. Paul, et al, Case No. CR 01-636, on one count of violation of 17 C.F.R. § 240.10(b)(5). I informed Mr. Davis that I wished to obtain copies of any videotapes in the government's possession that were delivered by Stan Lee Media, Inc. to the government or that were otherwise obtained by the government in connection with Peter
Paul's criminal prosecution. I explained that these videotapes were relevant to Mr. Paul's civil fraud case against Hillary Clinton and others.
3. I further explained to Mr. Davis that Mr. Paul had advised me that his criminal lawyer, Joseph Conway, had made repeated requests to him for
2 copies of the videotapes that the government had made available to the other defendants, but that Mr. Conway had advised Mr. Paul he had been unsuccessful in obtaining them. Since the tapes at issue were Mr. Paul's property, I asked whether and how it would be possible for Mr. Paul to regain possession of them.
4. In response, Mr. Davis confirmed that the U.S. Attorney's office had in its possession, pursuant to a search warrant, numerous videotapes originally belonging to Peter Paul. He told me that, due to the fact that Mr.
Paul had not yet been sentenced, these videotapes were part of an "ongoing" criminal matter, and the originals could not be returned to Mr. Paul at this time. Mr. Davis assured me that, as long as I could represent to him in a letter that these videotapes had not previously been provided to either
Judicial Watch (Mr. Paul's prior criminal counsel) or Mr. Conway (Mr.
Paul's present criminal counsel), that there would be no problem in his arranging to have the tapes copied at our expense.
5. I faxed and mailed such a letter to Mr. Davis on November 16, 2006, a copy of which is attached hereto as Exhibit 1. In accordance with our
November 9 conversation, I requested that Mr. Davis arrange to have the tapes copied at our expense so that we would obtain them the earliest
3 possible. However, four months went by, and I received no response from
Mr. Davis.
6. I telephoned Mr. Davis' phone number numerous times over the succeeding four months in order to follow up on my request to obtain copies of Mr. Paul's videotapes in the possession of the U.S. Attorney's office.
However, I was never able to reach Mr. Davis directly - only his voicemail.
Despite the fact that I left a voicemail message each time I attempted to reach him, Mr. Davis never returned my calls.
7. Eventually, on March 29, 2007,1 received a call from Meredith
Weill, a woman identifying herself as a paralegal in the U.S. Attorney's
Office, who said she was calling at Mr. Davis' direction. She told me she had just received several boxes from storage containing the Peter Paul materials, including a substantial number of videotapes.
8. A few days later, on April 2, Ms. Weill emailed me a detailed inventory list of 82 tapes, a copy of which is attached hereto as Exhibit 2. I reviewed the list and told her I was interested in obtaining copies of all of the tapes on the list. Ms. Weill explained that she would arrange to have the videotapes sent to a vendor, "Dupe Coop," and that I would be able to make my own arrangements with John Palermo at Dupe Coop to pay for and obtain copies of the videotapes.
4 9. I immediately began making those arrangements with Dupe Coop, but several days went by, and John Palermo advised that no authorization letter had yet been provided from the U.S. Attorney's office permitting Dupe
Coop to release copies of the tapes to us.
10. I therefore called Ms. Weill on April 9 to find out what the delay was. Ms. Weill informed me that there was a "problem" releasing the tapes to us, that someone "higher up" in her office had stopped her from authorizing it. Based on my conversation with Ms. Weill on April 10,1 faxed and mailed Mr. Davis a letter reciting the history of my efforts to obtain copies of Mr. Paul's tapes and asking for an explanation of what could possibly be the reason for not authorizing us to obtain a copy of Mr.
Paul's own tapes. A copy of my April 10, 2007, letter to Mr. Davis is attached as Exhibit 3.
11. The following morning, Mr. Davis called me at my office. Without ever explaining what the problem had been, Mr. Davis informed me that the tapes were already at Dupe Coop and that an authorization letter had now been emailed to them, allowing us to obtain whatever copies we desired.
12. I was able to arrange with Dupe Coop that same day, April 11, to make DVD copies of all 82 of the tapes listed on the inventory and to then ship the DVD copies directly to Peter Paul so that he could review them.
5 13. In reviewing the copy of the videotape listed as No. 78 in Exhibit 2,
Mr. Paul came across footage of a conference call between himself, Stan
Lee, and Aaron Tonken on the one hand (all on speakerphone), and Hillary
Clinton, on the other. As set forth in the concurrently filed declaration of
Peter Paul, the conference call on the videotape was a conversation he himself filmed on or about July 17, 2000.
14. Mr. Paul sent me an email containing a link to this footage, which I reviewed. The taped footage is approximately five minutes long and begins after the conference call with Mrs. Clinton is already under way. I arranged to have a written transcript prepared of the call, which I edited for accuracy.
Attached hereto as Exhibit 4 is a true and correct written transcript of the entire call with Mrs. Clinton as captured on the videotape.
15. Mr. Paul sent the DVD copy of videotape No. 78, as prepared by
Dupe Coop, to a film-editing technician, Stephen Petty. I arranged with Mr.
Petty for him to copy onto another DVD just the excerpt of the five-minute footage of the conference call with Mrs. Clinton. Mr. Petty did so, and he then sent me the DVD I had asked him to prepare.
16. I reviewed the DVD that Mr. Petty sent me, and I confirmed that it contained all of the footage of the conference call as reflected in the transcript attached as Exhibit 4.
6 17. I then arranged with a film copying and editing vendor in
Escondido, "Sentimental Memories," to make duplicate DVD copies of the
DVD I had received from Mr. Petty.
18. I have personally checked each of the DVD copies prepared by
Sentimental Memories to verify that it contains the entire five-minute footage of the conference call as reflected in the transcript attached as
Exhibit 4 and to ensure that the DVD plays correctly. All of the copies have been labeled "July 2000 Conference Call - Hillary Clinton & Peter Paul,
Stan Lee & Aaron Tonken."
19. Each and every one of the copies, labeled "July 2000 Conference
Call - Hillary Clinton & Peter Paul, Stan Lee & Aaron Tonken," that is being submitted to the Court and served on the interested parties to this appeal is a true and correct copy of the entire video footage of the conference call between Hillary Clinton and Peter Paul, Stan Lee and Aaron
Tonken contained on Video No. 78 obtained from the U.S. Attorney's Office for the Eastern District of New York, as set forth above.
I declare under penalty of perjury that the foregoing is true and correct.
Executed this of June, 2007, at Ramona, California.
D. Colette Wilson
7 Exhibit"!" November 16, 2006
BY FAX TO (718) 254-7499 AND THEN BY MAIL TO: QOPY
Jonathan E. Davis, Esq. Assistant U.S. Attorney Eastern District New York 147PierpontSt. Brooklyn, NY 11201
Re: Paul v. Clinton, et al. LASC Case No. BC 304174
Dear Jed:
We spoke on November 9, when I asked you about obtaining copies of certain videotapes. I explained that I am one of the attorneys representing Peter Paul in his civil case against the Clintons and other parties and that we need copies of these tapes to use as evidence. You told me you were willing to provide copies of the tapes in question without a subpoena, but you asked me to first verify that neither Judicial Watch nor Joe Conway previously received them. You said that a lot of materials were given to Judicial Watch and that Joe Conway also got copies of numerous items.
I spoke to Mr. Conway today, and he assures me that he never received the tapes in question. I have previously spoken to someone at Judicial Watch (it was Paul Orfanedes, I believe), who told me emphatically that Judicial Watch had turned over everything they had to Mr. Paul. Among the large volume of items Mr. Paul received from Judicial Watch, there were no videotapes.
Just so we're clear, what I would like to obtain are copies of all tapes that were delivered by Stan Lee Media to the government or otherwise obtained by the government in connection with Mr. Paul's cases brought in the Eastern District of New York and the Central District of California, including all videotapes that Mr. Paul or Stan Lee Media created and all videotapes pertaining to either Mr. Paul, Stan Lee Media or the Clintons. My understanding is that there were twelve tapes that were produced by the government to all of the criminal defendants excepting Mr. Paul. We would like to receive copies of those as soon as possible, as well as any others not delivered as part of that discovery. Please arrange to have the tapes copied, at our expense, so that we may obtain them at the earliest feasible time. If you need anything further from me, please call me at: (760) 788-6624 or email me at: colettefglusjf.net. Thank you for your assistance.
Sincerely,
UNITED STATES JUSTICE FOUNDATION
D. Colette Wilson cc: Peter Paul Exhibit "2" U.S. v.Peter Paul
Index of Video Cassettes
SLM = Stan Lee Media Company
Tape Number and Description
1. SLM meetings with potential business partners/investors in P. Paul's office.
2. BLANK
3. Interviews with SLM artists
4. Video of Backstreet Boys action figures
5. Home video of Peter Paul's wife and infant child in P. Paul's home
6. Meeting with George Hamilton in P. Paul's office
7. Meetings with potential business partners/investors; Stan Lee speaking about comic book characters
8 Meeting with George Hamilton in P. Paul's office
9 Meeting with Stan Lee and SLM executives discussing comic book characters and comic stories
10 SLM executive staff meeting in SLM office discussing operations and potential partnerships
11 Stan Lee's birthday party at P. Paul's house PART 1
12 Stan Lee's birthday party at P. Paul's house PART 2
13 SLM staff party in SLM office; Stan Lee speaking with artists about comic book figures
14 Meetings with Stan Lee and SLM artists
15 Video of P. Paul's child at school spelling contest; P. Paul's wife and child out for dinner
16 Interview with potential artist; Meeting among SLM executives discussing financial accounts
17 Journalist interviewing Stan Lee 18 Interview with Backstreet Boys concerning Backstreet cartoon
19 BLANK
20 Meeting with Stan Lee, P. Paul and other SLM execs at brunch
21 Journalist's interview with Stan Lee; Meeting among SLM execs
22 Interview with Stan Lee discussing 7th Portal comic
23 BLANK
24 BLANK
25 BLANK
26 Video of SLM artists working
27 Video of SLM artists working
28 Video of Stan Lee filming commercial for SLM web site
29 Video of Stan Lee, P. Paul and Steven Spielberg at Universal Studios theme park
30 Video of phone interview of Stan Lee discussing SLM web site
31 Backstreet Boys voice-over for Backstreet cartoons filmed in sound studio
32 Video of phone interview with Stan Lee
33 Backstreet Boys press conference
34 Interview of Stan Lee in SLM offices
35 SLM May 2000 Picnic
36 Mary J. Blige concert
37 Meeting with Stan Lee and SLM execs discussing SLM website; Macromedia conference with Stan Lee
38 Video of Stan Lee making commercial for 7th Portal
39 Video of Stan Lee website 40 Stan Lee meeting with director Kevin Smith
41 SLM meeting with new CEO Ken Williams
42 Meeting with Stan Lee discussing comic book character development; Stan Lee on CNNfh
43 Interview with SLM artists
44 Stan Lee meeting with director Kevin Smith
45 BLANK
46 Video of Flashfilm Festival 2000 featuring SLM artist
47 Interviews with SLM artists
48 Video of X-Men character Sabertooth in SLM office
49 Meeting with Fred Prince Jr, Stan Lee and P. Paul; meeting with Michael Jackson and P. Paul; meeting with P. Paul and Showtime execs; meeting with P. Paul and George Hamilton
50 Video of SLM artists
51 Stan Lee and P. Paul meeting with Francis Ford Coppola
52 Video of Stan Lee filming 7th Portal commercial
53 Video of voice-overs for cartoons in sound studio
54 Costume party at SLM office
55 Backstreet Boys viewing Backstreet cartoons
56 BLANK
57 Meeting with SLM execs discussing cartoon plots
58 Meeting with P. Paul and George Hamilton
59 Video of Stan Lee commercial takes; P. Paul explaining global webcast
60 Video of Stan Lee with friends; Stan Lee signing autographs at comic convention 61 Stan Lee meeting with fans
62 Home video of P. Paul's wife and infant child
63 Backstreet Boys pres conference
64 Video of voice-overs for SLM cartoons
65 Interview with SLM music composer Derek Perkins
66 Video of Digital Coast awards featuring 7th Portal and Stan Lee
67 Promotional interview with Stan Lee for SLM
68 Meeting with Stan Lee and journalist
69 Press conference with Backstreet Boys
70 Backstreet Boys doing voice-overs for cartoons in sound studio
71 Meeting with SLM staff and Stan Lee regarding cartoon characters; meeting with Backstreet Boys
72 Video of Stan Lee being interviewed
73 Video of SLM offices
74 SLM launch party at restaurant
75 SLM staff road race
76 Stan Lee meets with Globetrotters basketball players
77 Video of Stan Lee being interviewed at SLM office
78 SLM staff meeting re: Hollywood tribute; SLM meeting with Chinese executives; conference call with Hillary Clinton re: Hollywood salute to Bill Clinton; meeting between Stan Lee and professional wrestler; meeting with George Hamilton
79 May 13, 2000 Cartoon Art Museum exhibition with Stan Lee; meeting with George Hamilton
80 Reception for Hillary Clinton featuring Dionne Warwick
81 Meeting with Larry King, Stan Lee and P. Paul at SLM offices
82 Reception for Bill Clinton and Governor Davis Exhibit "3" April 10,2007
BY FAX TO (718) 254-7499 AND THEN BY MAIL TO:
Jonathan E. Davis, Esq. Assistant U.S. Attorney Eastern District New York 147 Pierpont St. Brooklyn, NY 11201
Re: Paul v. Clinton, et al. LASC Case No. BC 304174
Dear Jed:
When I received a call from Meredith Weill on March 29, letting me know that she had received the boxes from storage containing the Peter Paul materials - including numerous videotapes originally belonging to him — and that you had instructed her to work with me in seeing that we got copies of what we needed, I was excited and happy. Finally, after two years of effort on Mr. Paul's behalf to obtain copies of some of those videotapes, first through his criminal counsel, Joe Conway, who was unsuccessful from 2005-2006, and then through me, it looked like we were making some progress. I myself have been asking for copies of videotapes since I first called you last November.
As you may recall, you told me in November that upon receipt from me of verification that neither Judicial Watch nor Joe Conway ever received copies of the tapes, that you would arrange to have the tapes copied at our expense. I faxed you such a letter on November 16.1 felt confident that, as of November 16, 2006,1 had satisfied every possible concern you had regarding releasing tapes that were possibly important evidence in various legal and administrative proceedings in which Mr. Paul is involved.
Four months went by. Despite my leaving several voicemail messages for you to call and let me know what the status was on our request, I never heard anything from you.
So I really was pleased when Meredith called on March 29. She told me that she now had a load of boxes from storage, and that she would pull out all the videotapes and let me know what was there. When we spoke the following day, she told me there were over 80 tapes and promised to send me an inventory of the tapes, which she did on April 2. She also provided me with contact Jonathan E. Davis, Esq. 04/10/07 Page 2
information on a tape-duplicating vendor who works with your office, DupeCoop, advising that we could make our own arrangements to copy the tapes and pay them directly for their services.
A review of the inventory Meredith emailed me made it clear that all of the tapes had potential, significant, evidentiary value in our pending civil litigation and other administrative, legislative, and judicial filings being prepared on behalf of Mr. Paul. I therefore informed Meredith that we needed copies of all of the 80+ tapes. She confirmed there would be no problem, and she said she would see to it that DupeCoop received all of the tapes.
We have since been working with John Palermo, of DupeCoop, who gave us a price, and we gave him the go-ahead to copy all of the tapes. He advised us that Meredith confirmed by phone that we would be making arrangements to have the tapes duplicated at our expense and that she would shortly send an email authorizing release of the copies.
But now, suddenly, we seem to be right back where we started with your office.
I spoke to Meredith yesterday, and she told me that the authorization letter was ready to send by email, but there was a "problem" in releasing the tapes to us. She told me that someone "higher up" in your office has stopped her from sending the authorization letter to DupeCoop. I asked her what, exactly, the problem is. She told me that she herself did not know, that I would need to talk to you about it. She put me on hold in order to get you on the line, but then she came back and said you were in a meeting and unavailable. She said you would get back to me today to explain what the issue is. However, despite leaving two voicemail messages for each of you, I have not been able to speak to either of you today, nor have either of you apparently attempted to call me.
Just what is going on? What could possibly be the reason for not authorizing us to obtain copies of Mr. Paul's own videos obtained by your office through Stan Lee Media back in 2001? I am completely mystified as to how your office could go from (a) refusing to allow us to have copies because you had supposedly already provided them, to (b) refusing to allow us to have copies because you're simply not going to do so. I would love to find out that this is all just a misunderstanding, but it is difficult not to speculate that other, more sinister forces are at work here. I would appreciate the courtesy of a response. You may reach me at my office (760) 788- 6624 or by email to [email protected].
Sincerely,
UNITED STATES JUSTICE FOUNDATION
D. Colette Wilson cc: Joseph Conway, Esq. Exhibit "4" 1 Transcript of Videoclip taken by Peter Paul in his office at Stan Lee Media, Inc., in 2 Encino, on or about July 17, 2000, depicting a conference call between Hillary 3 Clinton, on the one hand, and Peter Paul, Stan Lee, and Aaron Tonken, on the 4 other. Alana Stewart is also shown on the videotape as being in the room.
5 6 [conversation already under way when videoclip begins] 7 8 HILLARY CLINTON: No. I- 9 10 STAN LEE: [cutting in] Don't ask, just accept the thanks! 11 12 PETER PAUL: [laughing] 13 14 HILLARY CLINTON: No, no. I think that, uh -- whatever it is you're doing, I- 15 Is it okay that I thank you? [laughs] 16 17 PETER PAUL: I think it's tremendous. No - well, you know what? 18 We're having a good time trying to help out. 19 20 HILLARY CLINTON: Well, I'm— I'm very appreciative. And it sounds 21 fabulous. I got a full report from Kelly, uh, today when 22 she got back and told me everything that, uh, you're 23 doing, and it just sounds like it's gonna be a great event. 24 25 PETER PAUL I— I~ I think this is worthy of the kind of, uh, title that 26 we're giving it, as The Hollywood Gala Salute to 27 President William Jefferson Clinton- 28 Transcript of Paul's Conference Call with HRC - Page 1 1 2 HILLARY CLINTON: Oh, that's wonderful- 3 4 PETER PAUL: [continuing] —and I think that the community that, that, 5 uh, shows up will be a tremendous accolade to the kind 6 of, uh, impact that he's had on Hollywood during your 7 collective administration. 8 9 HILLARY CLINTON: Well, I thank you for that. You know, I think that, uh, 10 you know, so— so many positive things have happened, 11 and, uh, we just have to, you know, keep working to 12 extend and expand it, and I'm, you know, I'm just very 13 much looking forward to it. 'Cause I think it's not only 14 going to be successful, I think it's going to be fun.
15 16 PETER PAUL: Well, I— We certainly hope so. And Aaron and all of us 17 are working diligently to make sure that it's gonna be a 18 lot of fun, and you're gonna enjoy it. 19 20 HILLARY CLINTON: Now, I understood that you were going to be parachuting 21 in, Peter. Is that wrong? 22 23 STAN LEE: [laughing] 24 25 PETER PAUL: Uh, yes! And I'm going to carry these—these, uh, flares 26 with me — the red, white and blue ~ on a parasail- 27
28
Transcript of Paul's Conference Call with HRC - Page 2 1 HILLARY CLINTON: [laughing] And I heard that- 2 3 PETERPAUL: [continuing] — but you have to catch me!
4 5 HILLARY CLINTON: And I heard Stan was being shot out of a cannon. 6 7 PETER PAUL: [laughing] 8 9 STAN LEE: [laughing] And towards Europe! 10 11 PETER PAUL & 12 HILLARY CLINTON: [both laughing] 13 14 STAN LEE: It's the only way they'll ever get rid of me. 15 16 P. PAUL, STAN LEE & 17 HILLARY CLINTON: [all laughing] 18 19 AARON TONKEN: Mrs. Clinton? 20 21 HILLARY CLINTON: Yes, Aaron. 22 23 AARON TONKEN: You wouldn't believe — I've saved some of the messages 24 from people that are coming, like Jimmy Smits, Rosie 25 O'Donnell, the Judds. They leave messages that go for 26 five minutes on the machine. The only reason why 27 they're doing it, is because of you, they only care about 28
Transcript of Paul's Conference Call with HRC - Page 3 1 jyow, that it means more to them than anything, like the 2 Steenburgen-Dansons are calling from back East - they 3 want to sell tickets— It's like, the most unbelievable 4 response on your behalf. 5 6 HILLARY CLINTON: Oh, Aaron. Thank you. I- 7 8 STAN LEE: [cutting in] Isn't that great? I thought, myself, it was 9 because we're offering everybody a free comic book, but 10 I guess I was wrong, [laughs] 11 12 HILLARY CLINTON Oh, I think that's a big draw, myself- 13 14 PETER PAUL: [laughing] Have you two had- 15 16 HILLARY CLINTON: [continuing] —certainly, it's the reason I'm coming. 17 18 STAN LEE: Ha! Ha! Bless your heart! 19 20 PETER PAUL: [trying to interject] Have you— Have you- 21 22 HILLARY CLINTON: [continuing on] And, you know, Aaron, I'm so grateful 23 because I know how hard you've worked on it, and it's 24 your, you know, constant effort, and your outreach to all 25 of these people that really gets them excited about doing 26 this. Because I know I've talked with Cher and, uh, you 27 know, she was just great, just said, you know, she really 28
Transcript of Paul's Conference Call with HRC - Page 4 1 was excited. And I hadn't talked to her, so I thought you 2 had to have really done a good job selling it to her. 3 4 STAN LEE: Well, he tells me it's because it was promised to him that 5 he'll be the next Secretary of State. 6 7 STAN LEE 8 & AARON TONKEN: [both laughing] 9 10 HILLARY CLINTON: Oh, you weren't supposed to tell anybody that, Aaron. 11 12 STAN LEE: Oh, oh, I thought it was our secret. 13 14 AARON TONKEN: It's amazing-
15 16 HILLARY CLINTON: [continuing on] But, you know, Stan, what we haven't 17 told you is that you're gonna be the next Secretary of 18 Defense, because— 19
20 STAN LEE: [cutting in] Well, I expected that! 21 22 HILLARY CLINTON: You know, the super heroes are going to be a lot cheaper 23 than the missile defense system! 24 25 PETER PAUL: [laughing] 26 27 STAN LEE: [laughing] Hillary, you're wonderful! 28
Transcript of Paul's Conference Call with HRC - Page 5 1 2 AARON TONKEN: We've got, um, people — like Cher — and others, that 3 have really never done anything, that are like, coming out 4 in full force, knowing this is, uh, um, for your Senate 5 race. It's unbelievable! 6 7 HILLARY CLINTON: Well, I-- I'm just thrilled. And, you know, I will check 8 in with you from time to time because, um, I know that 9 putting something like this together is, uh, challenging - 10 even when people are enthusiastic and looking forward to 11 doing it. It's still ~ there's so much work that's 12 involved, and, uh~
13 14 STAN LEE: [cutting in] But in your case, it's very gratifying. You 15 know, my wife wants us to move to New York so that we 16 can vote for you. [laughs] 17 18 HILLARY CLINTON: This is a very good plan! 19 20 PETER PAUL & 21 STAN LEE: [both laughing] 22 23 HILLARY CLINTON: Maybe we could get, you know, a great migration, a 24 country caravan of, you know, literally tens of thousands 25 of people. And I think that sounds like our next big 26 project! 27
28 Transcript of Paul's Conference Call with HRC - Page 6 STAN LEE: I don't want to say it's happening, but if you tried to hire a moving van right now in L.A., you couldn't get one. [laughs]
HILLARY CLINTON: [laughing]
PETER PAUL: Well, we did lobby for the X-Men votes, and all of the X- Men have agreed to, because they're all New York residents, you know-
HILLARY CLINTON: Well, this is ~ that's great.
PETER PAUL: So, all the X-Men are going to be voting for you.
STAN LEE: Oh yeah, you've got the mutant vote, right around the world, [laughing]
PETER PAUL & STAN LEE: [both laughing]
HILLARY CLINTON: Well, yeah, some people think I'm the mutant candidate, so I should have some—
PETER PAUL & STAN LEE: [both laughing]
Transcript of Paul's Conference Call with HRC - Page 7 1 AARON TONKEN: One other thing, I wanted to tell you. A couple of people 2 confirmed today that, like ~ I've never in all my events 3 been able to get, no matter what I give ~ like Brad Pitt 4 and Nicolas Cage are some of the people that are coming 5 to give tribute. 6 7 HILLARY CLINTON: Oh, wow, that's fabulous! Oh, Aaron, this is going to be 8 so terrific! Well, you just let me know if there's anything 9 that I need to do. And I know you and Kelly talk all the 10 time, so she'll be the person to convey whatever I need.
11 But I just wanted to call and personally thank all of you. 12 I'm glad you were all together, so that I could tell you 13 how much this means to me, and it's gonna mean a lot to 14 the President, too.
15 16 STAN LEE: Well, that is so nice, and, believe me, your call means a 17 lot to us. 18 19 PETER PAUL: It does. 20 21 HILLARY CLINTON: Well, thank you, my friend, and, uh, onward with the 22 mutant vote! 23 24 PETER PAUL: [laughing] 25 26 STAN LEE: Ha! Ha! Excelsior! 27
28
Transcript of Paul's Conference Call with HRC - Page 8 PETER PAUL: Okay, good luck in New York!
HILLARY CLINTON: Take care. Bye bye!
PETER PAUL: Okay, thanks. Bye!
STAN LEE: Bye!
[End of videoclip]
Transcript of Paul's Conference Call with HRC - Page 9 Second Appellate District, 300 S. Spring St., Rm. 2217 For Court Use Only Los Angeles, California 90013
Attorney(s) Name and Address Telephone: Gary G. Kreep, Esq. (066482) (760) 741-8086 UNITED STATES JUSTICE FOUNDATION 932 "D" Street, Suite 3 Ramona, CA 92065 Attorney for: Plaintiff
Title of Case Abbreviated: Paul v. Clinton
Hearing Date: Hearing Time: Dept: LASC Case Number: BC304174 Appellate No: B191066
I, D. Colette Wilson, declare, that: I am over the age of eighteen years and not a party to the action; I am employed in the County of San Diego, California, in which county and within-mentioned mailing occurred; my business address is 932 "D" Street, Suite 3, Ramona, California 92065. I am familiar with the practice for collection and processing of correspondence for mailing of this office pursuant to which practice all correspondence will be deposited with the United States Postal Service the same day in the ordinary course of business. On June 20, 2007, I caused to be served the following document(s): DECLARATION OF D. COLETTE WILSOK COUNSEL FOR APPELLANT, IN SUPPORT 6F MOTION TO ADMIT NEW DOCUMENTARY EVIDENCE XX BY MAIL: I placed a true copy thereof in a separate envelope for each addressee as indicated on the attached sheet on June 20, 2007. It was deposited with the U.S. Postal Service on that same day and addressed to the below- listed parties;
BY FACSIMILE SERVICE: By facsimile transmission, pursuant to California Rules of Court 2008, from fax number (760) 788-6414, on June 20, 2007,1 caused to be transmitted a true and correct copy thereof. The facsimile machine I used complied with CRC 2008 and no error was reported by the machine. Pursuant to CRC 2008,1 caused the machine to print a transmission record of each the transmissions, copies of which are attached to this declaration.
SEE ATTACHED LIST
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on June 20, 2007, at Ramona, California.
D. COLETTE WILSON
1 PROOF OF SERVICE (Code Civ. Proc. 1013 subd. a(3) and 2015.5 subd. (b); CRC 2008) SERVICE LIST Peter F. Paul v. William Jefferson Clinton, et al. Case No. BC 304174 Court of Appeal Case No. B191066
Counsel for Defendants William Jefferson Co-Counsel for Defendants William Clinton and Hillary Rodham Clinton: Jefferson Clinton, Hillary Rodham David E. Kendall, Esq. Clinton, and Defendant Hillary Rodham Suzanne H. Woods, Esq. Clinton for U.S. Senate Committee, Inc. Christian A. Weideman, Esq. Jan B. Norman, Esq. Williams & Connolly, 1000 Wilshire Blvd., Suite 600 725 12thSt.,N.W. Los Angeles, CA 90017 Washington, D.C. 20005
Counsel for Defendants William Jefferson The Honorable Aurelio N. Munoz Clinton and Hillary Rodham Clinton: Los Angeles Superior Court, Dept. 47 Carolyn Utrecht, Esq. 111 N. Hill St. Ryan, Phillips, Utrecht & MacKinnon Los Angeles, CA 90012-3117 1133 Connecticut Avenue N.W., Suite 300 Washington, D.C. 20036 California Supreme Court (4 copies) 350 McAllister St. San Francisco, CA 94102