CUBAN INFORMATION ARCHIVES




DOCUMENT  0049


[ Main Site Menu ] [ Back to  Menu ] [ Back to Morales Menu ]  [ Index to Site Documents ]

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
------------------------------------------------

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.
----------------------------------------------
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
--------------------------------------------
PAGE 3

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
------------------------------------
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.
-------------------------------
PAGE 5

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.
-------------------------------
PAGE 6

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
-------------------------------------
PAGE 7

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.
------------------------------------
PAGE 8

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?
-------------------------------
PAGE 9

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.
-------------------------------
PAGE 10

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
-------------------------------
PAGE 11

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?
-------------------------------
PAGE 12

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.
-------------------------------
PAGE 13

(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
-------------------------------
PAGE 14

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.
-------------------------------
PAGE 15

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
-------------------------------
PAGE 16

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
-------------------------------
PAGE 17

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
-------------------------------
PAGE 18

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
-------------------------------
PAGE 19

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
-------------------------------
PAGE 20

 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
-------------------------------
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
-------------------------------
PAGE 22

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,
-------------------------------
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?
-------------------------------
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.
-------------------------------
PAGE 25

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.
-------------------------------
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
-------------------------------
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?
-------------------------------
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
-------------------------------
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?
-------------------------------
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,
------------------------------------
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
-------------------------------------
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

End of Page

Copyright 1998-2014 Cuban Information Archives. All Rights Reserved.