DEPOSITION OF
RICARDO MORALES
NAVARETTE
PART I-A
IN THE CIRCUIT COURT OF THE
ELEVENTH JUDICIAL CIRCUIT IN
AND FOR DADE COUNTY, FLORIDA
CRIMINAL DIVISION
CASE NO. 81-17247
STATE OF FLORIDA
Plaintiff
vs
ALFREDO ARIAS, et al,
Defendants
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PART I-A
State Attorney's Office
9th Floor
Metropolitan Justice Building
1351 Northwest 12th Street
Miami, Florida
Friday, April 2, 1982
10:20 o'clock a.m.
DEPOSITION OF RICARDO MORALES NAVARETTE
Taken before Joycee Wax, Notary Public in and for the State
of Florida at
Large, pursuant to Notice of Taking Deposition filed in the
above cause.
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PAGE 2
APPEARANCES:
JANET RENO
State Attorney
By: RINA COHAN and
IRA LOEWY
Assistant State Attorneys
1351 Northwest 12th Street
Miami, Florida
on behalf of the Plaintiff.
DOUGLAS L. WILLIAMS, ESQ.
NATHAN, WILLIAMS & Reichenthal
444 Brickell Avenue
Miami, Florida
on behalf of Alfredo Arias, Defendant.
EDWARD R. CARHART, ESQ.
717 Ponce de Leon Boulevard
Coral Gables, Florida
on behalf of Rafael Villaverde.
BENEDICT KUEHNE, ESQ.
200 Southeast First Street
Miami, Florida
on behalf of Carlos Luis.
WILLIAM P. CAGNEY, ESQ.
200 Southeast 1st Street.
Miami, Florida on behalf of Raul Villaverde
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Thereupon: RICARDO MORALES NAVARETTE called as a witness on
behalf of the
Defendants having been first duly sworn was examined and
testified on his
oath as follows:
DIRECT EXAMINATION
BY MR. WILLIAMS:
Q. Tell me your full name and --
MS. COHAN: Prior to proceeding, we are here for the
deposition of Ricardo
Morales Navarette.
Mr. Morales, I want to inform you that you have been
immunized by the State
of Florida for both use and transactional immunity; such
immunity having
been given to you on December 16th of 1980 extending
specifically to the
sworn testimony you gave on that date to myself concerning
the Quesada Organization
and any of the narcotics related transactions in which it
engages between
1979 and 1980.
Your subpoena for defense deposition today confers no
immunity on you for
any other crimes which you may be admitting, and pursuit to
any admissions,
you do have the right to have your own counsel present and
confer with your
own counsel present and confer with your own counsel as you
so desire.
Do you understand?
THE WITNESS: Yes, I understand, by my
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PAGE 4
involvement with Quesada started in 1978 at the end of --
yes, mid 1978.
MS COHAN: You are covered for that. Anything we
discussed during your
sworn testimony on December 16th, you are immunized for.
THE WITNESS: Okay.
MS. COHAN: Okay, Mr. Williams. Sorry.
BY MR. WILLIAMS:
Q. Tell me your full name and your date of birth
and where you
were born, please?
A. Ricardo Morales Navarette. My D.O.B. is
June the 14th,
1939, and I was born in Havana, Republic of Cuba.
Q. Where are you presently residing?
A. Residing?
Q. Yes.
A. Right now?
MS. COHAN: Objection to a specific address.
You may answer in terms of where in the United States.
BY MR. WILLIAMS:
Q. No, I want to know your resident address. Mr.
Morales??
MS. COHAN: Objection.
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Mr. Morales, do you have any fear for your own safety and
well-being or that
of your family should you disclose your address?
MR. WILLIAMS: Wait, wait, wait. Hold it.
Is Ms. Cohan here your lawyer? Is the prosecuting
attorney your lawyer
representing you?
THE WITNESS: She is a prosecutor, and you know that.
BY MR. WILLIAMS:
Q. Is she representing you?
A. How is she going to represent me?
She is the prosecutor.
Q. As long as you are aware of the fact that she is
not here representing
you, you are not privileged to rely upon any advice that she
gives you or
turn to her for any assistance at all in the conduct of the
deposition.
A. No, I am residing right now in Miami.
Q. Where, please, sir?
A. Nope.
Q. I'm sorry?
A. Nope
Q. Nope what?
A. I'm not going to give you the address where I am
staying.
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Q. You are refusing to answer that question?
A. I am not refusing to answer that question. I
am refusing to
give you the address where I am staying in Miami.
MR. CAGNEY: Is that your permanent residence?
MR. WILLIAMS: Certify that, please, sir.
BY MR. WILLIAMS:
Q. How long have you been staying at the place in Miami
where you are now
staying?
A. Since mid-November.
Q. Is it a place that you current regard as your
residence?
A. Nope.
Q. Where is your residence? When you say
"mid-November." by the
way, I assume you mean November of 1981; is that correct?
A. What?
Q. Do you mean November of 1981?
A. November, 1981.
Q. If that is not the place that you regard as your
residence, where
is the place that you regard as your residence?
A. I don't have a residence.
Q. I am entitled to know the place of your
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residence.
A. I don't have a residence.
MS. COHAN: Objection, Mr. Williams, to your --
MR. WILLIAMS: Just wait.
I'm entitled to know the place of your residence in order to
conduct what
additional pretrial investigation is pertinent in order for
me to be able
to examine you appropriately.
MS. COHAN: Objection to testimony by Mr. Williams.
BY MR. WILLIAMS:
Q. If you are refusing to tell me where you are living
now, then, we
will recess the deposition long enough to appear before the
Circuit Judge,
and let him rule upon it.
A. That is your problem.
I am not going to give you the address where I am staying.
Q. Tell me the reason for your refusal to give me the
address?
A. Security.
Q. Security?
A. Yes, security , Mr. Williams. Security.
Q. Explain that to me.
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A. Security.
Q. I don't understand what you mean when you say
"security."
A. Security for my life, Mr. Williams.
Q. Is it your testimony, Mr. Morales, that you feel
that if you tell
me your address presently, the place at which you are
staying --
A. It is going to be a matter of public record.
You know that.
Q. You think, therefore, that your life will be
endangered by
your telling me the address?
A. Oh, yes.
Q. Is there anybody in particular who causes you to
harbor a fear for
your well-being in the event that you tell me your
address? Is there
some specific person whom you think to be a threat to you
presently?
A. All the defendants in this case.
Q. Have you had contact from any of the defendants in
this case in
the past six months?
A. No.
Q. Has anybody expressly told you that he or she
intends to attempt
to harm you or to take your life if they can find out who
is, in any way,
connected with this case?
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A. Repeat that question, again?
Q. Is there anybody who is, in any way, connected with
this case, either
as a defendant or a relative or a defendant, expressly told
you that if he
or she is able to determine your whereabouts, that he or she
intends to cause
you any harm?
A. No.
Q. As I understand it, you have no specific or
particular reason --
A. I have my experience, Mr. Williams.
Q. Let me ask you the question, Mr. Morales.
A. I have my experience.
Q. You don't know the answer to the question yes,
because I haven't
posed the question, so will you let me finish the question
before you intend
to answer it; okay?
A. Uh huh.
Q. The question to you is, whether it is the case,
then, that you have
no specific or particular reason to be able to articulate as
the source of
any fear for your well-being, but rather, as the harbor a
general ongoing
feeling that it would be harmful to you if you give me an
address; is that
correct?
A. I am not stupid, Mr. Williams. I am not stupid.
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Q. Is that correct? Answer the question.
A. You know, I am not stupid.
Q. Answer the question.
A. So, if I give the address to you, you know, I really do
believe that my
life is going to be in danger.
Q. Here's my question to you once again, Mr. Morales,
and listen.
If you don't understand the question that I put to you at
any time, feel
free to tell me that, and I will rephrase it for you as
often as it takes
for it to be understandable by you.
A. Of course.
Q. If you understand my question, then, answer
it. If your answer
needs an explanation, then, you can explain it.
A. Uh huh.
Q. The question for you, sir, is whether you have any
specific reason that
you can articulate as being the source of any present fear
that you have
for your well-being in connection with any of the defendants
in this case,
or whether the fear that you have expressed is a general
ongoing concern
of your well-being -- which of the two?
A. It is a general ongoing concern of my well-being
since this is a
drug related case, and
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there are so many people being killed because of drug
related matters.
You know, you don't have to be a wise up guy just to
understand that.
Q. Has Ms. Cohan or Officer Diaz given you any
suggestions or any advices
concerning questions that you should or should not answer or
questions that
you may refuse to answer in the course of this deposition?
A. That's her problem. Not mine.
Q. Answer my question, Mr. Morales.
A. That is her problem. Not mine. If that is
what she is here
for --
Q. Here's my question to you: Has Ms. Cohan —
A. Nope.
Q. (Continuing) -- given you any specific advise
--
A. Nope.
Q. (Continuing) -- with regard to what questions you
may or may not
answer?
A. Nope.
Q. Has Officer Diaz given you any such advice?
A. No.
Q. Are you thoroughly fluent in the English language?
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A. Yes.
Q. Do you foresee any possibility for needing or
having the assistance
of an interpreter at any point in the course of this
deposition?
A. No.
MR. WILLIAMS: All right. I will recess the deposition
long enough to
see if I can get the Circuit Judge to make himself available
to rule on this
preliminary question, because my feeling is that if we don't
do it now, then,
you will just take, to yourself, the prerogative of deciding
what questions
you are or are not going to answer, and that is not how it
works.
MR. CAGNEY: Doug, before we recess, let me just take a quick
second with
you.
(Whereupon, an off the record discussion was had between Mr.
Williams and
Mr. Cagney.)
MR. WILLIAMS: Your presence is cordially requested.
MS. COHAN: I will be right along.
MR. WILLIAMS: We don't need him down there.
MR. LOEWY: You may very well need him there to testify.
MR. WILLIAMS: That's fine with me. Always happy to
have Mr. Morales.
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(Whereupon, a short recess was taken after which the
following proceedings
were had in Courtroom 2-5 before the Honorable Gerald
Kogan:)
MR. WILLIAMS: We have just begun the deposition of Mr.
Morales, the State
informant, and we had asked Mr. Morales to tell us where he
is presently
residing, and Mr. Morales has taken it upon himself to
refuse to tell us
that, claiming that he harbors some general free floating
fear for his well-being.
I asked Mr. Morales, whether, at any point in the recent
past, just arbitrarily
using six months, whether he received any communication of
any sort from
the defendants or any of their relatives which he
specifically regarded as
any kind of a threat upon his life, and he said it was just
a general feeling
that he had that since this was a drug case, that if he told
me where he
was living, that it would cause him some harm.
Of course, we have the right always to put a witness, any
witness in context,
by putting ourselves, acquainting ourselves, with his
present living circumstances,
and perhaps, in the course of Discovery, interviewing
neighbors or making
such inquiries as might bear upon his present status as a
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witness, and aside from that, Judge, I've always had the
feeling that it
just doesn't lie with a witness to unilaterally decide which
questions he
is or is not going to answer.
MS. COHAN: Your honor, there was an objection by the State.
THE COURT: Wait, wait, wait.
Everybody, I want to get one thing perfectly clear. I
realize that
you are all attorneys, and these are adversary proceedings,
but there is
one thing that I insist upon. Let everybody say their
peace, and everybody
else will get a chance to say theirs.
All right, Mr. Williams, continue.
MR. WILLIAMS: Thank you, sir.
We, of course, asked Mr. Morales whether he felt himself
privileged to rely
upon the advises of Ms. Cohan, as the prosecutor, and he was
candid enough
to agree with us that she was not his attorney.
I can't see the legal sense of an objection that the State
would impose unless
the State is prepared to make an affirmative factual showing
of some particular
reason why to give a fellow's address would dispose some
harm.
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Of course, in Mr. Morales' case, it may just be a case of
paying the piper
for the tunes and some problems that he feels might exist as
one of his own
making, I would think over the past fifteen or twenty years.
We'd like to be able to conduct some discrete inquiries
concerning his present
living circumstances to determine whether it bears either
directly or indirectly
upon his competence as a witness.
THE COURT: Ms. Cohan?
MS. COHAN: Your honor, there is an objection by the State to
Mr. Morales
disclosing his residence address.
In the past six months or since the inception of this
investigation, three
of the subjects of the investigation have been killed.
There has specifically been a report to --
THE COURT: The only one that I know of was Wilfredo Gil.
Who are the others?
MS. COHAN: An individual by the name to Alfonso who was
killed in the King
Crossing Six, in Kendall Six. He was one of our
subjects.
Additionally, another subject was killed
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before he could even be arrested in this case.
There was a report to Detective Diaz of a contract in the
amount of $250,000
for Ricardo Morales, Detective Diaz, and Sergeant Martinez
concerning Tick-Talks.
Obviously, it is more than a general fear for his
well-being, which Mr. Morales
is relying upon not to disclose his address.
THE COURT: Brief rebuttal, Mr. Williams, and then, I will
rule.
MR. WILLIAMS: Your Honor, I haven't heard anything from the
prosecutor that
addresses itself to anything articulable or specific, and I
have the feeling
that if Mr. Morales wanted to badly enough, he could reach
back into his
colorful past and probably summon some kind of justification
for harboring
a fear of any and every creature that walks on the face of
the western hemisphere,
any maybe some in the eastern was well.
As a right of the defendants, and especially the one I
represent, under the
5th and 14th Amendments of the Constitution of the United
States, Declaration
of the State of Florida, and Florida Rules of Criminal
Procedure to have
the same discovery rights with respect to Mr. Morales that
we have with
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regard to police officers, civilian witnesses, ships'
captains and shepherds,
I want to be able to have my investigator obtain some
information.
Now. If your Honor thinks that it's necessary to instruct us
not to disclose
the information to anybody not directly connected with the
case or not to
disclose it to any of the individual defendants, I have no
problem with that,
because my client doesn't need to know where this man lives
or any of the
other individuals.
I'd like an investigator to know --
THE COURT: Mr. Cagney?
MR. CAGNEY: I'd like to add, in the record, may have been
said in my absence
by Mr. Williams, that I think that Smith versus Illinois and
U.S. versus
Alford have put up certain minimum standards that the Court
may consider
before it makes a determination to deny cross examination to
a defendant,
and I suggest to the Court it's not enough for the State to
come in and make
generalized allegations of threats.
I think there is a requirement on behalf of the Court to
make the State articulize
the threats and allow the defense to show that they are, in
fact, spurious,
fallacious, or used solely for the very issue to keep from
the defendants
a legitimate need
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to know the address of where Mr. Morales currently is and
where he permanently
resides.
I have absolutely every right, as Mr. Williams says, to go
into the community
and bring forth his neighbors and the people that he has
associated with
and show that this man is unworthy of belief under oath, and
I can only do
that, Judge, if I know where he has resides and is residing.
To cut that avenue off from me is to cut off the legs of my
defendant in
attempting to impeach the very accuser in this case, and as
your Honor knows
from Discovery so far, that we have an awful lot of
interpretations about
alleged meetings to conversations that, on their face, are
apparently innocuous,
and I want to be able to get to the bottom, which is Mr.
Morales, an to show
that this man lives a life of prevarications, of
fabrications, and if your
Honor denies me a chance to go into his history in the
community, I will
never be able to show that satisfactorily to the Court at
the time of trial.
THE COURT: All right.
The Court is going to sustain the objection. Mr.
Morales does not have
to testify as to where his present address is.
The Court feels that under the situation
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where we have twenty-four defendants who are charged in this
particular case
where Mr. Morales is alleged to have been the key witness as
to those particular
defendants based upon the State's proffer, the Court has
reason to believe
that Mr. Morales, perhaps, whether rightly or wrongly, he
does have a reason,
perhaps, and in his mind, to fear that he may be in some
danger.
Now, let me say this : Mr. Cagney, you raised a point, Mr.
Williams, you
raised a point, about checking out the background of this
defendant -- of
this witness, rather. I don't know if that's a
Freudian slip or what,
but in any event, this particular witness, I have heard from
the outset of
this particular trial, and I have also read in national
magazines about how
this particular witness, Mr. Morales, is well-known to law
enforcement officials,
well-known to defense attorneys, well- known to court
officials in regards
to his integrity or lack of integrity, his veracity, or lack
of veracity,
and the court feels that there are probably, based upon what
you all have
told me, and when I say, you all," I am referring to defense
attorneys; Mr.
Neal Sonnett in particular, that there are reams and reams
of individuals
who can come forward and
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testify as to the background and the history and the
veracity or the
lack of veracity of Mr. Morales without having your
knowledge increased as
to where he lives.
The Court is going to ball the situation one against the
other. I fell
you have adequate remedy to ascertain information about his
background and
about the type of person that he is without having his exact
location or
address as to where he is living at this time remain known
to you.
Are there any other questions that came up?
MR. WILLIAMS: Not presently.
Your honor, that is a far as we have gotten, but I am sure
we will be back.
THE COURT: I am sure you will.
MR. LOEWY: Judge, before we come back on this, I just want
to say --
THE COURT: I'm not coming back to this issue. This
issue is over with.
MR. LOEWY: He said something about coming back, coming back
again for future
issues:
Mr. Williams said something, which I strongly differ, in
terms of whether
a witness can refuse to answer a certain question. I
think if questions
are asked, if the State has a legitimate
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PAGE 21
objection, we can raise the objection, and the question can
be certified.
There are certain areas that the State has no right to
impose an objection
as we do not represent Mr. Morales. However, Mr.
Morales, whatever
Mr. Williams may think of him, and I certainly think Mr.
William has shown
his feelings concerning Mr. Morales very plainly, Mr.
Morales is entitled
to the same Constitutional rights as his defendants re, and
everyone else
is, so he, Mr. Morales, feeling that he has a Constitutional
right or right
to interpose that he has the right to refuse to answer the
question based
on what he perceives to be his legal privilege, and if he
does so, that question
should be certified.
THE COURT: The Court is aware of all these things.
In the event the witness does not answer a particular
question, the matter
will be brought before the Court. The Court will hear
as to both sides,
and then, the Court will make fun a ruling.
If the Court says the witness does not have to answer the
witness does not
have to answer. If the Court says the witness will
answer, the witness
will go upstairs and the witness will answer. If the
witness will not
answer, then, the Court will take
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appropriate action when the witness is brought down again,
so it is unnecessary
to loiter back and forth.
Let's take him back upstairs, or wherever the deposition is
being held, and
let's take the deposition.
MR. LOEWY: If we are going to enter a procedure where every
time he refuses
to answer a question, that we come back down here
immediately, this deposition
may last forever.
I would suggest that we set up a time each day where they
can come down and
go through all their certified questions, so it may be
done instead
of wasting all the times with elevators and stairwells.
We can do it once a day or when the deposition is over, but
I can't see every
time there is a question, come down to your Honor.
THE COURT: We can do this: Every hour.
MR. CAGNEY: More than reasonable, your Honor.
THE COURT: I don't think you are going to run into that many
problems quite
frankly.
(Whereupon, a short recess was taken after which the
following proceedings
were had:)
BY MR. WILLIAMS:
Q. Mr. Morales, would you tell me, please, sir,
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PAGE 23
whether you are presently married?
A. No, I am not.
Q. Do you have any children over the age of eighteen?
A. Two.
Q. Does either of them live in the South Florid area?
A. Both of them. The one under eighteen;
right?
Q. No, I asked you about over eighteen, mas que over
eighteen?
A. No, you said under eighteen.
MR. COHAN: Let's not argue. Over first.
THE WITNESS: No, no, no. I am fluent in English. Oh,
no, no, no. You
said under eighteen.
BY MR. WILLIAMS:
Q. Is that what you heard me to say?
A. Yes, sir.
There are two under eighteen, and two over eighteen.
Q. Now, let's talk about the two over eighteen.
A. Uh, huh.
Q. Do they live in the South Florid area?
A. One of them.
Q. What part of South Florida?
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PAGE 24
A. Miami.
Q. Is that a male or a female? I don't need to
know that.
A. It's a male.
Q. Does he have some occupation or profession?
A. Oh, yes, I believe that he works.
Q. What does he do?
A. He works in Miami Beach in hotels.
Q. Doing what?
A. Clerical jobs like, you know, desk clerks, or
things like that.
Q. You said you've been in the Miami area since --
A. You don't want to know about the other one; right?
Q. No.
MS. COHAN: Don't volunteer.
THE WITNESS: I'm not volunteering. But just -- you
don't want to know
about the other one; right?
BY MR. WILLIAMS:
Q. No.
You said you've been in the Miami area since November 1981;
is that correct?
A. Mid-November, taking or giving.
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Q. Where were you before that?
A. Where was I when?
Q. Where were you before November of 1981?
A. In the Federal Witness Protection Program.
Q. For how long?
A. Six or seven months. Seven months, maybe.
Eight months --
whatever.
Q. Which agency sought your inclusion in the
Marshall's Program?
A. I.R.S.
Q. Were you then a witness for the United States
Government in a pending
case or in a investigation or both?
A. No, in a trial, for trial.
Q. Which trail?
A. Medaro Alvero-Cruz.
Q. Who is the case agent for the Government in this
case? Was it Raul
DeArmas?
A. Yes.
Q. Was it Mr. DeArmas who specifically requested your
inclusion in
the Marshall's Program?
A. I believe so.
Q. Did you eventually testify on behalf of the United
States Government
in that or any other case while you were in the program.
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PAGE 26
A. Mr. Cruz' defense attorneys -- they stipulate my
testimony.
Q. Your answer is not, then?
A. My answer is that I have never testified because
they stipulate
my testimony.
Q. Those attorneys wouldn't have been Messrs.
Bierman and Sonnett
by any chance, would they?
A. Who?
Q. Those attorneys would not have been Messrs.
Bierman an Sonnett,
would they.
A. I believe that's the law firm who represents Mr. Alvero
Cruz.
Definitely, Mr. Bierman was the counselor for Mr. Alvero
Cruz who would stipulate
to my testimony.
Q. When was that, please, sir?
A. What?
Q. That the stipulation was made between the
government and Mr. Bierman
that obviated the need for you to testify?
A. I don't know.
Q. Do you know when it was that the case eventually
concluded?
A. Nope.
Q. Do you know whether you were maintained in the
Marshall's Program
for any period of time after
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PAGE 27
the case was over?
A. Oh, yes.
Q. For how long?
A. After the case was over?
Q. Yes.
A. I don't know when the case was over, Mr. Williams.
You know, I was in the Witness Protection Program, and they
were bumping
me from one place to another, and coming back to Miami for
testimony until
Mr. Bierman stipulate to my testimony. Said that
everything that I
said was true.
Q. When did you enter the Witness Protection Program?
A. February.
Q. Of?
A. 1981. Officially, I mean.
Q. Why do you emphasize the word "officially"?
A. For nothing.
Q. Were you receiving Witness Protection from the
Federal Government
before you actually entered into the program?
A. Nope.
Q. Prior to your entering into the Witness Protection
Program, where
were you living?
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PAGE 28
A. The Ramada Inn.
Q. That was the brief period of time when --
A. That was a long time for me. It was a long
time.
Q. That was the brief period of time when Officer Diaz
had you staying
out there until Agent DeArmas actually physically took
custody of you; is
that correct?
A. Uh huh, that is correct.
Q. We're not talking about more than five or six or
eight days or something
like that; isn't that correct?
A. More or less, I believe so.
Q. Where were you living before that, Mr. Morales?
A. Over a girl friend's house.
Q. That would be Silvia Levine; would it not?
A. That is correct.
Q. What was her address?
A. 2629 South Bayshore Drive.
Q. What apartment number?
A. It was on the 3rd Floor, Mr. Williams. You
know, and it could
have been 35-B or 34-B, you know.
Q. You're not sure?
A. I'm not sure. Either one. It was on the
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PAGE 29
3rd Floor.
Q. At any time since leaving Ms. Levine's apartment
and going into
the Witness Protection Program up until today, have you had
any contact with
Ms. Levine?
A. Yes.
Q. How recently?
A. Two days ago.
Q. As I understand it, Mr. Morales, you were living
with Ms. Levine
on and off during the latter part of 1980 into 1981 when you
--
A. No, no, no 1981. 1980. On and off.
Q. When did you move out?
A. When she left Miami.
Q. When you had contact with her a couple of days ago,
where was she?
A. Huh?
Q. When you had contact with her a couple of days ago,
where was she?
A. In New York.
Q. Where in New York, Please?
A. Where her parents live. She lives with her parents.
Q. What are her parents' names?
A. Jesus. Berga, B-e-r-g-a.
-------------------------------
PAGE 30
Q. Are you saying B as in Boy or V as in Victor?
A. B as in Boy.
Q. What are their first names?
A. Silvia and Jorge.
Q. J-o-r-g-e?
A. Uh huh.
Q. What is her phone number?
A. Whose phone number?
Q. The number at which you reached Ms. Levine?
A. I don't know.
Q. Do you have it written down someplace?
A. I believe so.
Q. When you were in touch with her two days ago, was
she in New York?
A. Yes.
Q. Yes. Who called whom?
A. She.
Q. Where specifically in New York do her parents
live? In which
of the Burrows?
A. Queens
Q. Do you know on what street?
A. I know how to get there.
Q. Do you know what street? Do you know the name
of the street
or the street number?
-------------------------------
PAGE 31
A. No, not offhand.
Q. Where would you have to look among the resources
available to you
to find the telephone number for the woman? Where is
it?
A. I don't know.
Q. I mean, do you have it written down someplace?
A. I believe so.
Q. In an address and telephone book that you keep?
A. No, I never keep telephone books or anything like
that. You should
know that.
Q. The record doesn't know it. Where would it be
written?
In what kind of place or --
A. I don't know Mr. Williams. How I am going to
give you a straight
answer to something that - - you wan me to do some research
for you?
That's what you are asking?
Q. No, sir.
A. Okay.
Q. I am asking you just to tell me.
A. Because I don't have it.
Q. (Continuing) -- where you have the woman's
phone number written.
It is in your personal
-------------------------------
PAGE 32
possession someplace, obviously, and I need to know where,
so that I can
have a proper subpoena issued?
THE WITNESS: Rina, I don't have an answer for that.
MS. COHAN: Okay. If you don't know, you don't know.
BY MR. WILLIAMS:
Q. If you had to go back to wherever it is that you
are living now
and look for it, where would you look?
A. It's not there. Jesus Christ.
Q. What kind of work does she do?
A. When?
Q. Presently?
A. I don't know. I believe that she helps the
family. They
have their own business -- you know, like I believe that
they own a candy
store and a sales route or whatever.
Q. Also, in Queens?
A. Well, not specifically in Queens, you know.
In New York.
Q. They have more than one store?
A. No. They only have one.
Q. When you talk about a sales route, what are you
talking about?
-------------------------------
PAGE 33
A. The whole family and the whole people, all the
people, you know,
from -- because they are all from the same home town in
Cuba, they sell potato
chips, you know.
MS. COHAN: Do they make them?
THE WITNESS: No, somebody else makes them -- Lays or Wise,
or whatever is
the name, you know.
I mean, I don't know about that kind of a business.
I'm a dull guy. Ask me about Intelligence -- things
that I know.
I don't know about selling potatoes.
BY MR. WILLIAMS:
Q. If it were peanuts, you wouldn't know that;
wouldn't you?
A. No, I am the only monkey who never eats peanuts.
Q. Do you know anybody else in the South Florida area
who has had contact
with Silvia Levine in the past month.
A. Nope.
Q. Do you know any more about the woman's whereabouts
or the means
that are available to locate her other that what you have
told me?
-------------------------------
PAGE 34
A. No.
Q. What is her approximate age?
A. Whose age?
Q. Ms. Levine?
A. Early thirties.
Q. Give me a physical description of her, please?
A. Physical description?
Q. Yes.
A. She is 5'4".
Q. What color hair does she have, Monkey?
A. All depends, you know.
Q. Tell us the truth, the real basic truth?
A. All depends, you know. You never know the real -- I
mean, what kind
of a question is that; you know? I don't know the real
color.
Q. Yes.
A. Well, could be brown -- you, something like
that. Brownish.
Once she got it red.
Q. How long ago did you actually see her?
A. Huh?
A. When most recently have you seen her?
Q. What do you mean "see her"?
Q. When most recently have you seen her face to face?
-------------------------------
PAGE 35
A. Oh, face to face?
Q. Uh huh.
A. The summer, the Indian Summer.
Q. In the Fall?
A. No, it's not Fall. It's the Indian Summer.
Q. Where was that, please, Mr. Morales?
A. That was in New York.
Q. What color was her hair then, Mr. Morales?
A. Brown, dark brown.
Q. How did she wear it?
A. Huh?
Q. How did she wear it? Did she wear it long or
short or in the
middle?
A. What do you mean "long or short"?
Q. How does she wear her hair?
A. I can't understand. How she wears her
hair? I'm not
a hairstylist. What you mean -- if she part it or --
MS COHAN: Is it short or long?
BY MR. WILLIAMS:
Q. Did you not understand when I ask you how a woman
wears her hair,
whether she wears it short or long?
A. Oh, short or long (Indicating.)
MS. COHAN: Indicating chin length, for
-------------------------------
PAGE 36
the record.
THE WITNESS: Indicating chin length, for the record.
BY MR. WILLIAMS:
Q. How much does she weigh?
A. I don't know. I don't know how much she weighs.
Q. Is she slim or stocky?
A. No, medium build. No, she has a medium build,
complexion,
and she is 5' 4", medium build complexion. Maybe 125
pounds, or something
like that.
Q. Does she have a car?
A. Oh, yes. The whole family have cars.
Q. When you were living with her, what kind of car did
she have?
A. Oh, she had a Mercedes.
Q. What model?
A. It was a 1978, I believe, or 1979. It was the
proceedings
of her divorce from her previous marriage.
Q. What model was, Monkey? Was it the
two-seater?
MS. COHAN: Objection to referring to the witness as
Monkey.
-------------------------------
PAGE 37
BY MR. WILLIAMS:
Q. Do you mind if I call you Monkey?
A. Yes. Monkey, Monkey, Monkey. Yes, I have a
name.
Q. What would you prefer?
A. Ricky.
Q. What model was it?
A. 450 SLC. The one that you can sit in the back, too.
Q. What color was it?
A. Blue.
Q. What was the tag number?
A. I don't know.
Q. You don't know the tag number of a woman whom you
were living with?
A. (Nodding in the negative.) Why should I?
Q. Your are getting mellow.
A. No, I am not getting mellow. I'm just not in
the habit of
getting tag numbers anymore.
I did when I was in business, but after -- you know what
for.
Q. Were they Florida tags on the car or New York tags?
A. Of course. She sold it down in Miami just to
volunteer
-------------------------------
PAGE 38
a little piece of information. She told it, you know,
before she left.
Q. Why didn't you tell me that when I started asking
about the car?
A. You know, just too --
MS. COHAN: You didn't ask.
THE WITNESS: Just whatever.
BY MR. WILLIAMS:
Q. During the calendar year 1980 besides the time that
you spent living
with Ms. Levine, where else were you living and with whom,
and see if you
can do it chronologically going backward before you lived
with Ms. Levine
and going back in time?
Q. And going back in time?
A. Yes.
Q. You are referring addresses, women, or by myself.
Q. All of the above.
A. All of the above? Ms. Levine, I love in the
Quesada household
for maybe two years. That's where my -- you know, my
address in the
driver's license, you know, and car registration, an things,
you know, and
mail went up to.
Q. Where specifically? What address did you use
when you were
living in the Quesada household?
-------------------------------
PAGE 39
A. 1724 Southwest 16 Street.
We lived over 72nd Avenue and close to 56th Street -- that's
Miller Road
-- in a townhouse there. We lived there for some
months.
Q. In a townhouse?
A. In a townhouse. Carlin and myself together.
Q. Who actually was renting the place?
A. Oh. Carlin was using somebody to show up. I
believe it was
his wife. At the time, was no the wife, but she was
--you know, she
rented under her name.
Q. Are you talking about Maggie?
A. Yes, Maggie, and I live over --
Q. Excuse me, Ricky. What period was involved in
your living
in that Miller Avenue address?
A. We moved over there after the shooting, after
Carlin w as almost
killed -- you know, the shooting was in October, and it was
October, 1979,
until February, 1980, because Judge Friedman, who was a
neighbor, made a
lot of complaints about us, and we have to move out of that
place.
Q. Milton Friedman?
A. Yes, he was living next to us.
Q. Continue to tell me the other places where
-------------------------------
PAGE 40
you were residing?
A. Shipping Avenue.
Q. When were you living on Shipping Avenue, and it
what address?
A. 1980 -- Shipping address.
Q. What street number?
A. The street number, I can't remember, but it was in
Shipping going
west on Shipping.
Let's see -- 72nd Avenue -- must be around 37th and
Shipping. I was
living there in a Three's Company situation with two girl
friends.
Q. What were their names?
A. Molly and Lori.
Q. Molly --
A. And Lori.
Q. What were their last names?
A. Molly and Lori.
Q. Come on, Ricky.
A. Molly and Lori. They used to work at The
Mutiny. Everybody
knows Molly and Lori.
I believe if you talk to, Komorowski, he represents one of
them -- Molly,
in , you know, when her probation came up or whatever, to
expunge her record
and so forth.
She's a nice kid, early twenties -- both
-------------------------------
PAGE 41
of them, you know. They're nice kids.
Q. Lori was the blond; wasn't she?
A. Huh?
Q. Lori was blond; wasn't she?
A. No, beautiful black hair.
Q. She is kind of tall?
A. Yes.
Q. How tall?
A. Close to six.
You don't want to ask no more questions about Lori? By
this time, you
know who Lori is. (Off the record.)
BY MR. WILLIAMS:
Q. Prior to the time that you spent with Lori and
Molly, prior to that,
with whom were you living?
A. Huh?
Q. Before living with Lori and Molly, with whom were
you living?
A. You mean, girl friends?
Q. Yes.
A. Before I moved into the Quesada household, I was
with Pilar Alfonso.
She was my steady for maybe six years, seven years. I
broke with her.
Q. When did you stop seeing her?
-------------------------------
PAGE 42
A. No, I broke. We were living together in the
same household
in 1979, on or about March or April of 1979.
Q. Is that when you stopped living together -- in
March or April of
1979?
A. That is right.
Q. Where does she currently reside; do you know?
A. In Miami.
Q. Do you know where?
A. One of those buildings on South Bayshore Drive at
the entrance of
Crandon Park.
Q. You mean, on Key Biscayne?
A. No.
MS. COHAN: Brickell?
THE WITNESS: No, at the entrance of Crandon park at
Brickell. Brickell
Avenue. You know, the Brickell Bay Club? That's where
we used to live
together, and then, there is another building next to that
one. That
is where she's living now.
BY MR. WILLIAMS:
Q. Is she living by herself or with somebody else?
A. One of the daughters.
Q. What is her daughter's name?
-------------------------------
PAGE 43
A. Adys.
Q. How old is the daughter?
A. Adys -- she must be close to eighteen now.
Q. Does Ms. Alfonso presently have some position that
you know of --
work?
A. I don't dig into her life.
Q. When is the last time you had contact with her?
A. Last week.
Q. Over the phone or in person?
A. Both.
Q. Describe the building for me that she lives in?
A. There is a restaurant there. I believe that
you have been
there. I believe that I have seen you going into that
place.
It is the Brickell Townhouse.
What's the name of that nice restaurant that they have?
MS. COHAN: Courtyard Inn.
BY MR. WILLIAMS:
Q. When you were living with Ms. Alfonso, where was
that?
A. We had several address.
-------------------------------
PAGE 44
Q. Do the best you can for me.
A. Brickell Bay Club.
Q. Were you renting an apartment there?
A. Yes.
Q. Under what name?
A. Her name.
Q. Do you remember the period of time when you were
living there?
A.. At Brickell Bay Club?
Q. Yes.
A. Since maybe November, 1978 -- October -- Let's say
October.
On or about October 1978 until when we parted.
Q. In March or April of 1979?
A. That is right?
Q. Where were you all living prior to that?
A. 2121 North Bayshore Drive. That's Biscayne
Boulevard and 21.
You know the 21 Building.
Q. During what date, dates?
A. Well, exactly, I can't recall when she moved there,
because when
she rented the apartment, I was in Venezuela, so that could
have been sometime
in the beginning of either the end of 1976 or beginning of
1977. That
was after her father died.
Q. Was her child living with her then?
-------------------------------
PAGE 45
A. Two daughters.
Q. What became of the other one?
A. She got married.
Q. At some point in time, Ricky, the woman called
Pilar developed some
kind of relationship or involvement with Manolo
Reboso. When was that?
A. She was Manolo Reboso's steady girl friend at the
end of the 60's
and beginning of the 70's.
They have a steady relationship for maybe five y ears.
Q. At any time in the past five years that you know
of, going back
to 1976-1977, did Pilar maintain any kind of a relationship
with Reboso?
A. Not to my knowledge. She was with me.
Not to my knowledge.
Q. At no time between 1976 and the present?
A. What?
Q. That you know?
A. What?
Q. Did the woman called Pilar maintain any kind of a
relationship with
Mr. Reboso?
A. Not to my knowledge.
Q. I understand, then, that you were living with Ms.
Alfonso from sometime
around 1976 or early
-------------------------------
PAGE 46
1977 up until --
A. No, no, no.
Q. When did you come back from Venezuela?
A. No, no, no. You are completely wrong on that.
We have a love
relationship dating back to 1972.
Q. In other words, you were involved with her prior to
the time that
you went to Venezuela?
A. Well, yes.
Q. Then, when you came back from Venezuela, your
relationship either
resumed or was still ongoing?
A. And she was visiting me in Venezuela.
We resumed nothing. We have a steady love relationship
since the end
of 1972, sometime around the end of 1972, until March or
April, 1979.
Q. When did you go to Venezuela ?
A. She was my girl friend, my lady love.
Q. When did you go to Venezuela.
A. The first time, the last time?
Q. Let's go back in time.
A. Let's go back in time?
Q. Working back?
A. 1972 was the first time that I was down there.
Q. When most recently have you been in
-------------------------------
PAGE 47
Venezuela other than on a temporary visit?
MS. COHAN: Objection to the vague terminology.
BY MR. WILLIAMS:
Q. You understand what I mean, Ricky?
A. No, repeat the question. Rephrase it.
Q. I want to know when most recently you have been in
Venezuela on
a regular ongoing basis as opposed to when you might have
stopped there for
a day or a week? When most recently have you been
there on a regular
basis?
A. I left that country one day, and I have never
returned to that country.
Q. I don't blame you.
When did you leave.
A. January, 1978.
Q. 1978?
A. That is right.
Q. Had you been in Venezuela continuously from 1972
until 1978?
A. Not on a daily basis.
Q. No, sir, but had that been your regular place of
residence between
1972 and 1978?
A. Both -- the United States and Venezuela.
Don't get confused on that issue about dates
-------------------------------
PAGE 48
and things like that; okay?
Q. I'm not confused about anything.
A. Because there is a lot of people that are confused
about that issue.
I am trying to straighten the record many times from the
firs time that I
was there until the last day that I was there.
Q. You know, those clocks that the chest players use
when they move
an they hit the clock to start time? I'm going to work
out some kind
of an understanding here, after Mr. Morales has answered my
question, I'll
make some signal, and anything else that he says after that,
the court reporter
will bill to him, so that we can keep my expenses in this to
a minimum.
MS. COHAN: Well, you continue to make gratuitous
comments like you
just did, and you will pad the record nicely.
THE WITNESS: It works both ways.
BY MR. WILLIAMS:
Q. During the period of time that you were in
Venezuela, what were
t he dates during which that was your primary place of
residence?
A. 1974. Yes, between 1974 and January,
1978. Will you
ask me that question again, please?
Q. During what period of time was the
-------------------------------
PAGE 49
country Venezuela your primary place of residence?
A. I already answered.
Q. 1974 to 1978?
A. I already answered.
Q. Is that your answer -- 1974?
A. Go back to the record. It's there. I
already answered.
Q. Ricky --
A. Yes?
Q. I'm trying to keep a clear record.
A. Trying to keep clear the record.
Q. Are you telling me that --
A. That I was correct the answer I gave you.
Q. You held some position in either a law enforcement
or security with
the Venezuela military; didn't you?
MS. COHAN: Objection as to the solitary nature of the
question.
BY MR. WILLIAMS:
Q. Did you hold such a position?
A. What position?
Q. Did you hold any position while you where residing
primarily in
Venezuela in law enforcement?
A. Yes.
Q. Or in some way related to official security?
-------------------------------
PAGE 50
A. Yes.
Q. What was the position, please?
A. I hold three positions there.
Volunteering information for you.
Q. Tell me what positions you held?
A. One, the Foreign Ministry, and two positions, in
the Interior Ministry.
Mr. Carhart?
MR. CARHART: Mr. Morales?
THE WITNESS: We have never been introduced officially
before, but I know
who you are, and you know who I am.
MR. CARHART: I think I have heard about you.
THE WITNESS: And I have heard about you, too.
(Off the record.)
BY MR. WILLIAMS:
Q. What was the formal title that you held in the
Venezuelan Foreign
Ministry?
A. In the Venezuelan Foreign Ministry, I was
coordinator or Counterintelligence
in the Caribbean Bays.
Q. Was that your formal title or --
A. No, that was the formal title.
-------------------------------
PAGE 51
Q. Or is that the way you describe it?
A. No, that is the formal title.
Q. What were the two positions that you held in the
Interior Ministry,
formal titles?
A. By formal title?
Q. Yes.
A. Commissar.
Q. Commissar of what?
A. Of a serious division. Division 54 --
Counterintelligence.
Q. You were the commissar of Division 54?
A. I was the commissar, head chief -- whatever you
want to call it.
I was the boss in the Division.
Q. Division 54, and that's Counterintelligence?
A. D.I.S.I.P.
Q. What does the acronym stand for?
A. That's the raffling in English.
Q. No, give it to me first in Spanish?
A. In Spanish? Direccion de los Servicios
Inteligencia e Proteccion.
At the Foreign Ministry, the place that I work was the
Direccion Nacional
de Fronteras.
Q. That was within the Division 54?
A. No, it was the Foreign Ministry. That was the
foreign Ministry.
-------------------------------
PAGE 52
Q. What was the other position that you held in the
Interior Ministry?
A. Liaison with the General's Office.
Q. Which general?
A. Generals.
Q. Oh, generals plural?
A. Yes, there were about ten of them.
Q. In Venezuela, everybody is a general or corporal?
A. No, not everybody is a general in Venezuela.
Venezuela is
-not????- a little banana republic.
Q. Tell me, as briefly as you can, what was the nature
of your position
or your duties as coordinator for counterintelligence?
A. Where?
Q. We're talking about the position that you held in
the Foreign Ministry
of Venezuela?
A. In the Foreign Ministry in Venezuela?
Q. That's what we're talking about.
A. Just collecting what the opposition was doing
against you.
Q. You were the person in charge?
A. No, there were other people there.
Q. I'm asking you whether --
A. I have the chain of command.
-------------------------------
PAGE 53
Q. Were you the boss of the person in charge of that
division?
A. No, I was the chain of command.
Q. Who was the person in charge?
A. Orlando Garcia-Vasquez. He was my immediate
superior.
Q. Is he still in government there?
A. Not to my knowledge.
Q. Is he still alive?
A. I believe so.
Q. Do you have any specific knowledge that he isn't?
A. I don't have any specific knowledge that he is
alive or he is dead.
Q. What was his title?
A. Where?
Q. As your superior in the Foreign Ministry position
as coordinator
for counterintelligence in the Caribbean Bays?
A. He was the director of the O.I.P.A. That is
the Oficina de
Investigacion Procesion e Analisis.
Q. Who were your superiors in the Interior Ministry
while you were
with Division 54?
A. No Division 54. I was the head, the boss.
Q. To whom did you answer?
-------------------------------
PAGE 54
A. To the deputy director.
Q. Of --
A. D.I.S.I.P.
Q. What was that person's name?
A. Rafael Rivas-Vasquez.
Q. I assume that these governmental folks whom you
have described when
you last had knowledge of them were living in Caracas?
A. Uh huh, that is correct.
Q. To your knowledge, is Mr. Rivas still with us, or
has he also gone
to the great --
A. I have no idea. He may be dying from a heart
attack right
now. I don't know.
Q. Oh, let's hope not. My goodness. Keep
him around for
a while.
MS. COHAN: Why?
MR. WILLIAMS: Huh?
MS. COHAN: Why?
MR. WILLIAMS: We need all the help we can get.
BY MR. WILLIAMS:
Q. What was the nature of your duties as the head of
Division 54?
A. To know what the opposition was doing against us.
-------------------------------
PAGE 55
Q. You said that you also were the liaison with the
General's Office
as part of your position in the Interior Ministry.
What did that involve?
What were your duties in that regard?
A. It was a liaison, it was the coordination with the
General's --whatever
they need from my agents all over the world, I would provide
them with the
information.
Q. To simplify it in layman's terms, D.I.S.I.P. is a
spy agency; isn't
it?
A. No, it's not a spy agency. That's not the
function.
Q. How would you describe it?
A. Like the Central Intelligence Agency. It's
the counterpart.
MS. COHAN: That's a spy.
BY MR. WILLIAMS:
Q. So, that agency's employees or agents are spread
around the world
ostensibly for the purpose of collecting intelligence
information about what
the agents of other governments are doing to acquire
intelligence?
A. Not other governments, Mr. Williams. The
opposition.
Q. Whoever that might be?
-------------------------------
PAGE 56
A. Whoever that might be.
Q. Well, who are the opposition from the point of view
of the counterintelligence
service of the country of Venezuela?
A. Communists.
Q. Pardon me?
A. The communists, the Russians, the Czechoslovakians,
the Cubans.
There is a democracy there. People go to the polls,
and they vote,
and they elect a president.
Q. And the function of the agent is to --
A. Find out who is trying to disrupt democracy there.
Q. Somebody to find out who is trying to disrupt
democracy?
A. Of course.
Q. In Venezuela?
A. In Venezuela.
Q. Did you acquire all three of those positions at the
same time in
Venezuela?
A. No. The last one was after I went to the Israeli
Counterintelligence
Course. That's when I was promoted from inspector to
counselor.
Q. In Division 54?
A. And then, I was given the command of that
-------------------------------
PAGE 57
division due t o the recommendation of the Israelis, the
Mossad.
Q. Where did you go to be trained by the Mossad?
A. They came over there from Israel.
Q. How many people did they send?
A. I don't have to answer that question to you.
Q. Did they send more than one person, Ricky?
A. I don't have to answer that question to you.
Q. Did they send more than one person, Ricky?
A. I don't have to answer that question to you.
I respect that people so much that I will never disclose any
of their methods,
ways and means of transportation.
There are not that many of them. There are not that
many of them.
Q. Let's not get too sidetracked. I really
doesn't matter.
A. So? So I doesn't matter, so don't go into
them.
Q. The point is, did you receive your training within
the territorial
limits of Venezuela?
A. That is right.
Q. By folks that were sent over there to train you?
-------------------------------
PAGE 58
A. That is right.
Q. How long did it last?
A. I don't have to answer to you that.
Q. Was it a day, Ricky, or was it for some more
extensive period of
time?
A. It was a very extensive period of time.
Q. More than a month?
A. Could be.
Q. Is that a yes or no?
A. Yes.
Q. What was the basic nature of the training that you
received?
I don't want to ruffle your little feathers about anything
sensitive.
A. Counterintelligence.
Q. Be more specific, please, and tell me --
A. Counterintelligence.
Q. See, I'm just an amateur, and I don't know what
that means.
When you get training in counter intelligence, what are the
specific skills
that you are taught -- that's what I need to know?
A. Counterintelligence.
Q. Are you able to tell me that specific skills
involved in being taught
counterintelligence?
MR. CARHART: For example, did you receive firearms training?
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PAGE 59
THE WITNESS: Not in counterintelligence.
MR. CARHART: Did you receive training in electronic
surveillance techniques?
THE WITNESS: Not in counterintelligence.
BY MR. WILLIAMS:
Q. What were you taught by the Israeli
counterintelligence instructors?
A. I'm not going to tell you.
MR. WILLIAMS: Certify that, please.
BY MR. WILLIAMS:
Q. Here's what I need to know, and I'm going to tell
you why I need
to know it, so that when we next appear before the Circuit
Judge, you
will have a fuller understanding of the sense of the
question: One
of the things that I want to be able to test by taking your
deposition like
this before?
A. I have testified in several trials.
Q. Yes. Has anybody ever taken your deposition
in a criminal
proceeding in the State of Florida or any other State?
A. This
is the first time that I am going to be a witness for
the State.
In Federal Court, we don't have --
Q. Yes, I am aware of that.
-----------------------------------
PAGE 60
My question is whether anybody has ever taken your
deposition before
in a criminal proceeding in the courts of this state?
A. No.
Q. How about in a civil proceeding -- has
anybody ever
taken your deposition?
A. No, no, no.
Q. I want to be able to, and I have the right to test
your ability
to observe, perceive, remember, recognize people, and the
ability that you
have to store or retain information; okay? Those are
all the things
that are very important, so I should like you to tell me
specifically the
nature of the training that you have?
A. I'm going to try to make it easy for you, I
believe, as a layman.
Counterintelligence is the graft -- you know, where you
find out what
the intelligence services of the opposition are doing; right
-- either to
penetrate your own service, to penetrate destructors of your
government,
your nation; right, and the graft of counterintelligence is
to detect them
in their efforts, their agents, and things like that;
okay? It's a
whole spectrum on that.
There is nothing involved in to -- you know,
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PAGE 61
waiting for somebody, you know, around the corner, and
stabbing him to death
or cyanide bullets, and things like that.
Q. That's what I need to know.
What are the skills that you are taught to become effective
at counterintelligence?
That is what I want you to tell me, and specifically, what
skills were you
taught in the mid 70's by whoever it was that came to
Venezuela to teach
you?
MS. COHAN: To obviate any further problems, can
I see you?
(Whereupon, an off the record discussion was had between MS.
Cohan and the
witness.)
THE WITNESS: Williams --
MS. COHAN: There is no question pending.
BY MR. WILLIAMS:
Q. Call me Douglas, Ricky.
A. Douglas.
MS. COHAN: Is there a question pending?
MR. WILLIAMS: Yes.
THE WITNESS: Can you read my --
BY MR. WILLIAMS:
Q. Let me give it to you again.
A. Let me give it to you.
Q. Do you want to hear the question, or do you
------------------------------------
PAGE 62
know the question?
A. Yes, go ahead.
Q. Here's the question: If it's too tough,
tell me.
Watch my lips.
What skills were you taught --
MS. COHAN: Objection. Argumentative.
BY MR. WILLIAMS:
Q. (Continuing) -- by the Israeli Mossad
trainers who came
to Venezuela to school you in the methods of
counterintelligence?
A. How to detect a clandestine operation being run by
the intelligence
service of an opposition -- you know, different government,
the opposition,
whatever it was. It's so simple.
Q. Yes, sir, you have told me now the object or the
purpose.
Now, I should like you to tell me, if you can, and if you
are unable to,
then, we will just pass on to something else, and we will
just let it stand
as that you either don't remember --
A. No, I remember.
Q. (Continuing -- or that you don't know how to
describe it.
A. No, I remember.
Q. What I want you to tell me is what
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PAGE 63
specific skills were you taught in the course of this
training program?
A. How to control a situation. I was appointed
head of a division.
I have hundreds of people under my command there.
Q. Do you understand the use of the word "skills"?
A. Of course.
Q. Can you answer the question as I put it to you,
sir, or are you
unable to?
A. I am able to answer the question to you.
Q. Please do so.
A. It is just how to detect the opposition.
MR. WILLIAMS: Certify the answer.
MS. COHAN: You can't certify the answer.
MR. WILLIAMS: Of course. Certification is
something --
CONTINUED DIRECT EXAMINATION
BY MR. CARHART:
Q. What techniques were you trained in order to enable
you to perform
the duty of detecting? For example, do they teach you
to climb telephone
poles and tap lines.
A. No, you don't have to do that.
Q. Did they teach you accounting procedures?
-------------------------------
PAGE 64
A. Counterprocedures like you detect something,
and then, you
double the guy -- you know, and you make the guy start
working for
you inside his own intelligence service.
Q. What techniques were you asked or advised to employ
to do that --
bribery?
A. No, bribery is not a dependable way to --
specifically, you have
to have -- there are five kinds of motivations.
Ideological motivation is the best one to work out.
Bribery is not
advisable. I mean, in fact, once you bribe somebody,
you know, they
can be bribed by the other guys, and then, people become
double agents, and
things like that.
Q. So, you were taught how to persuade people?
A. How to detect the ideological approachable
individual.
CONTINUED DIRECT EXAMINATION
BY MR. WILLIAMS:
Q. All right. Now --
A. You have to understand something. We have a
weapon.
It's democracy; right, and there are so many confused
people in this
world.
Q. I understand all that, but let's see if we can stay
with the more
objective things because --
---------------------------------
PAGE 65
A. You are deluding yourself.
Q. It is going to take long enough as it is, and we
both have
all the civics that we need.
Now, Ricky, what I am asking is this: Are you able to
describe to
us in specific terms the techniques or the sills or the
methods that you
were taught while you were receiving this training in
Venezuela? Can
you tell us specifically? Mr. Carhart began to give
you some examples.
He asked you if you were taught how to perform electronic
eavesdropping techniques?
A. Nope, I never --
Q. Were you taught specific kinds of psychology to be
applied in the
course of your dealing with persons whom you taught
conceivably could be
persuaded to do your bidding? Is that one of the
things you were taught?
A. What do you mean by "bidding"? We never bid
into nothing.
MR. CARHART: Bidding. Desires. Your bidding is what
you desire somebody
to do.
BY MR. WILLIAMS:
Q. Were you taught psychological techniques to
persuade people to do
what you wanted them to do?
A. For interrogation.
-----------------------------
PAGE 66
Q. So, techniques for interrogation would be another
one; huh?
A. Uh huh.
Q. Can you list for me another skill or technique that
you were taught
in the course of this training period?
A. Well. surveillances.
Q. Now, we're getting someplace. That is
what we are looking
for.
What else?
A. Administration.
Q. Administration of a bureaucracy or a governmental agency?
A. Yes, bureaucracy took so many hours at
bureaucracy.
Q. You are talking about the techniques or
administration of a governmental
bureaucracy or agency that exists for the purpose of
counterintelligence?
A. That is right.
Q. What else?
A. How to instruct people into what I have been
learning.
Q. Were you taught any other skills by the Israelis or
techniques?
A. Negative intelligence and positive
--------------------------------
PAGE 67
intelligence.
Q. What do those things mean?
A. Negative intelligence and positive
intelligence -- that's
what they mean.
Q. Are you able to explain or define them for Mr.
Carhart and me?
A. I am not teaching you anything.
Q. My question to you, sir, is whether you are able to
do so?
A. Oh, yes, I am.
Q. Go ahead, please, and tell me what those terms are?
A. Well, negative intelligence is the basic of
intelligence, and positive
intelligence is when I try to get more than the basic of
intelligence.
Let's say that I want to know what you do, what you eat, who
is with you
if you got a wife, you know, if your wife has --
you know, somebody
else, or whatever, you know. That is positive
intelligence.
Negative intelligence is who are you, where you live,
you know -- open
-- the phone book, and things like that.
More or less, you know I am trying to make it easy for you
to understand
it.
Q. Were you taught any other skills or
----------------------------
PAGE 68
techniques by the Israelis?
A. How to detect the techniques that the opposition
were employing,
and how to detect your counterpart, because, you know,
intelligence and counterintelligence
is a game, and usually, it's being played by the same
players, and even though
you never see who your counterpart is, you can detect, find
out this operation
being run in such and such a place -- you know, has the same
procedures and
techniques and things, you know, that apply to so and so
individual, so do
you understand what I am saying?
Q. Yes, I do.
Can you describe for us any other skills or techniques or
specific areas
in which you were taught aside from the ones that you
have already
listed?
A. How to protect the government's secrets.
Q. Go ahead, sir, if there are others?
A. How to protect our embassies, how to protect our
liaisons with the
so-called friendly services.
Q. Meaning, other intelligence services?
A. That is right, friendly services.
Q. Anything else?
A. That's it.
-----------------------------------
PAGE 69
Q. Are those skills or techniques that you were taught
things which
can only be used by you for so long and you are in the
service of a government,
or are they skills or techniques that kind of carry over
into your day to
day life?
A. No. What do you mean "your daily life"?
Q. Yes, I mean, are the things that you were
taught effective
only for so long as you occupy some governmental position
agency behind you
to implement them?
A. Of course.
Q. In other words, you could not apply the
knowledge that you
received during the course of this extensive training on a
regular day to
day basis separately and apart from your connection with the
Venezuelan government;
isn't that correct?
A. If you don't have the resources, you cannot do it,
and to implement
the counterintelligence information, you need the resources,
and the one
who can provide resources is the government.
CONTINUED DIRECT EXAMINATION
BY MR. CARHART:
Q. For example, suppose you left the Venezuelan
government and went
to work for General
---------------------------
PAGE 70
Motors. Would you have learned skills in this course
that would have
been useful, for example, in doing some service for General
Motors?
A. You are talking, Mr. Carhart, about commercial
espionage?
Oh, yes, there is a field there where my skills can be --
you know, put up
to work.
CONTINUED DIRECT EXAMINATION
BY MR. WILLIAMS:
Q. As you sit here today, if you were not in the
service of any government
or any private employer, could you still, for example, put
to work the knowledge
that you have or that you acquired in order to
determine whether somebody
else was trying to get information about you?
Could you still
do that based upon that training that you've had?
A. Unless my life is endangered, yes.
Q. So, the basic knowledge that you acquired in the
course of that
training is knowledge that stays with you and
that has application
any time you want it to; would that be accurate?
A. For a while, you still think like an agent, you
know, and after
that, you know, you get -- you know, you get it over
with.
Q. Is it accurate to say, Mr. Morales, that to the
extent that you
have an ability to recall that
------------------------------
PAGE 71
which you were originally taught --
A. By everyone.
Q. That to the extent that you have the ability,
the skills and
techniques that you were taught in Venezuela by the Israelis
during the middle
1970's are skills and techniques that you can use at
your leisure or
at your choice in the ordinary course of your day to day
life? Can
you do that?
A. No.
Q. In other words, you couldn't go out, say, into the
Latin community
now and find out if somebody were making inquiries about you
trying to gather
information? You wouldn't be able to do that now?
A. I don't have the sources.
Q. Is that a no -- you wouldn't be able to do it?
A. I don't have the sources.
Q. I'll take that as a no.
MR. WILLIAMS: I think we will all take a lunch break
now.
2:00 o'clock.
(Whereupon, the deposition was recessed.)
------------------------------
PAGE 72
CERTIFICATE
STATE OF FLORIDA:
SS
COUNTY OF DADE:
I, JOYCEE WAX, Shorthand Reporter and Notary Public in and
for the State
of Florida at Large, do hereby certify that the
foregoing deposition
of RICARDO MORALES NAVARETTE, by me duly sworn, was taken at
the time and
place herein set forth; that the deposition was recorded
stenographically
by me and reduced to typewritten form under my personal
supervision; that
the foregoing is a true and correct record of the
deposition, and that
I am in no way interested in the event of the cause.
IN WITNESS WHEREOF, I have hereunto set my hand and
affixed my official
seal in the City of Miami, County of Dade, State of Florida,
This __ day
of April, 19982.
____________________________
JOYCEE WAX
Notary Public in and for the
State of Florida at Large.
My Commission expires;
March 2, 1985
Go to part 1B of deposition
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