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Part I-B

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[NOTE: The reporter on this deposition didn't use a spell check.  Some of the spelling errors have been corrected and follow the incorrect word in parentheses.]




State Attorney's Office
Metro Justice Building
1351 N.W. 12th Street
Miami, Fl.
Friday, April 2, 1982
2:15 P.M.



Taken before Mary Jane Grant, Notary Public for the State of Florida at Large, pursuant to Notice of Taking Deposition filed in the above cause.

Assistant State Attorney
on behalf of Plaintiff

on behalf of Plaintiff.

Rivergate Plaza
Suite 700
444 Brickell [BRICKEL] Avenue
Miami, Florida
on behalf of Defendant.



I, Mary  Jane Grant,  hereby certify that counsel for the defendant, requested the following questions be certified:

Page: 22 Line: 11
Q.  Have you filed a tax return for 1979, 1980, or 1981?
A.  I don't have to answer that question to you, sir.
Q.  Are you refusing to answer it?
A.  I am not refusing to answer it.  I am telling you that I don't have to answer it.  I am not  refusing.
MR. WILLIAMS:  Certify it, please.

Page: 26  Line:  6
Q.  How much were you paid?
A.  I'm not going to tell you.  Ask the Marshals.  I might expose some of  their operation,  I  believe. So you better, you know --
MR. WILLIAMS:  Certify it, please.

was called as a witness and, having been duly sworn, was examined and testified as follows:

Q.  We were last talking about the training that you had been getting from the Mossad in Venezuela, while you were a part of DISIP.
What was the period of time during which you were actually living in Venezuela, as your primary residence?
You said you first went down there in 1972 or so?
A.  Yes.
Q.  Did you, upon your arrival in Venezuela, in 1972, in effect, stay there as your primary place of residence until 1976?
A.  No.  I was commuting back and forth.
At one  point, I was holding apartments in both  countries.
Q.  During that period of time, while you were  commuting, was your Miami residence in Biscayne Twenty One Building, as you have previously told us?
A.  No. It was the address in 1976 -- >77.

Q.  Prior to that, where was your Miami office?
A.  The Park East Fountainbleau Boulevard.  I can't recall the exact number of the building.
Q.  In Fountainbleau Park?
A.  Yeah,  Park  East.  It's right on  the corner of Flagler and Eighty Seventh Avenue.  There is a complex -- big complex there.  Park East.
Q.  With whom were you living?
A.  By myself.
Q.  During the luncheon recess, did you have the opportunity to  talk about any of the details of your testimony or the questions that you expected would be asked of you, with Ms. Cohan or Mr. Diaz or Mr. Puig?
A.  I was too busy munching my sandwich.
Q.  I take that to be a no.
Prior to assuming the supervisory positions that  you described with the Venezuela government, what was the nature of your employment in Venezuela?
A.  Would you repeat that question again for me, please, sir?
What do you mean by supervisory  position?
I was trying to pick up on that word supervisory.  Because actually, there was no supervisory position, there.  I mean, you get everything mixed up.  You are trying to mix it up.

Q.  If you do not understand the question, tell me.
A.  That's exactly what I am trying to tell you.
I don=t understand the question with that word supervisory.
Q.  There came a time, you told us earlier, when you were made the chief of commissor or commander or head huncho, whatever you want to call it --
A.  You are the one calling it head huncho.
It's a position.  It's a  rank.  And it's commissor.  That was the ultimate -- the last position that I  hold in the  DISIP.  Commissor.  It's a rank.
Q.  Would you describe that as being a supervisory position?
A.  It's not a supervisory position.
Q.  You did not have  supervision an control over anybody else?
A.  I had supervision and control of the whole division.  Because I was a commissor.
Q.  All right.  Prior to the time that you were appointed to that position of supervision --
A.  It's not the position of supervision.
Q.  Whatever you want to call it.
A.  Whatever you want to call it.
Q.  What did you do before that?

A.  What?
Q.  What did you do before that?
A.  I told you before, I was an inspector.
Q.  Inspecting what?
A.  Inspecting nothing.
It's a rank.  Inspector.  It's like sergeants, corporals, lieutenants, captain.  It's a chain of command.
Q.  I see.
For  whom  or in what were you an inspector?
A.  In the DISIP.
Q.  In that capacity, what was the nature of your job?
A.  Counter-intelligence.
Q.  Did you assume the position of inspector,  upon your first arrival in Venezuela or, did you  have some --
A.  No.  No.
Q.  Let me finish the question.
Or, did you have some civilian work outside the government in Venezuela, before  you were  hired by DISIP?
A.  No.
Q.  No, to  which?
A.  I was not a civilian, there.  I was a government employee.

Q.  From the moment you arrived?
A.  In '72?
Q.  Yes.
A.  No.   Not in '72.
In '74.
Q.  What did you do before 1972 and 1974?
A.  In Venezuela?
Q.  Yes.
A.  Oh, that's different.  That's a lot different.
What did I do there?
Q.  Yes.
A.  Established an information net.
Q.  Working on your own, I take it, or, working for yourself, as opposed for anybody else?
A.  What do you mean working by my own?
Q.  Were you in anybody's employe [EMPLOYEE]?
A.  At the time?
Q.  When you said it.
A.  When I said nothing.  What time?  What  year? '72? '73 and '74?
I was a paid  informant for the Bureau of Investigation.
Q.  While you were in Venezuela?
A.  Yeah.

Q.  And, was it during that same period of time that you were also establishing an information net?
A.  Of course.
Because I knew that I was going to wind up with the job in the government.
Q.  At the time that you went to Venezuela, in 1972, were you already, as you put it, a paid informant for the F.B.I.?
A.  Yes.  As a matter of public record.
Q.  It does not much matter, I suppose.
A.  It is a matter of public record.
Q.  Let's see if we can make this proceeding more  tolerable for both of us.
A.  For you.  I'm very  pleased, you know.
Q.  Your job is here to answer questions.   I will ask them.
A.  No.  I don't have a job here.  I have a duty.
Q.  However  you want to  say it.
When I ask you a question --
A. Don't put words in my mouth or try to  situate me in a capacity which, you know, is not the way it is.
Q. If I do not ask you a question, then there is no need for you to say anything.  You only need to tell me what is necessary.
A. Don't tell me --

Q.  You only need answer what is necessary to answer the question.  You do not have to tell me any more of that.
MS. COHAN:  Objection.  The witness will answer questions as he sees fit.
MR. WILLIAMS:  Well, I am afraid that is not quite the case.
Q.  Prior to going to Venezuela in 1972, where were you residing?
A.  Here, in Miami.
Q.  Where?
A.  I have two apartments at different areas -- in the area of Seventh Street, N.W., and Forty Fifth Avenue and Fifty  Second Avenue, whichever came first.
Q.  With whom were you living?
A.  By myself.
Q.  Which one of those two apartments was your primary  place of residence?
A.  Oh, before that?
I was married.  That was my second marriage.  I was living with the second wife and the kids.
Q.  This is 1972, before going to  Venezuela?
A.  No.
Well, that's around when I, you know, started

the war sound proceedings in 1972.
Q.  What was the name of your former wife, please?
A.  Iramina (phonetically).
Q.  This is your second wife?
A.  That is my second wife. Ex-wife.
Q.  By what name is she known today?
A. I do believe that she still uses the last  name of Morales.
Q.  Where does she resides?
A.  In Miami.
Q.  Where, please, sir?
A.  Huh?
Q.  Where,  please?
A.  Hialeah.
Q.  Do you know her address?
A.  No.
Q.  Do you know her phone number?
A.  No.
She works at the Miami Herald.
Q.  In what capacity?
A. I believe that  she is one of the top superiors, there. Whatever.
If you call there, they can tell you.
Q.  While your were living with your second wife, where was your residence?

A.  Oh, we moved to at least four or five -- six different addresses.
Q.  All in the greater Miami area?
A.  Yes.  All in Miami.
Q.  What was your first wife's name?
A.   Magda.
Q.  Is  she still living?
A.  I believe so.
Q.  By what surname is she presently known?
A.  I don't know.  Because she remarried.  On at least two more occasions.  And really, I don't know.
Q.  Where is she living?
A.  In Miami, too.  As far as I know.
Q.  What is the name of the man to  whom you most recently knew her to be married ?
A.   Last name was Machin. M-A-C-H-I-N.
Q.  First name?
A.  I don't know.
I know it was Machin.  Because she changed from Morales to Machin.  But she divorced that guy, and then married again.  And I believe that she got another divorce, and then married again.  She's a very lucky woman.
Q.  Your testimony is, that you do not know any surname that she used, subsequent to Machin?

A.  No.  That's definitely --
Q.  Did  you have children with her?
A.  Three.
Q.  Are they all over the age of eighteen?
A.  Only  two.
Q.  Where do they live?
A.  Who?
Q.  Your children?
A.  The first one?
Q.  All of them.
A.  The other one is in the U.S. Marine Corps.
Q.  What is his name?
A.  Raul.
Q.  What are the other two names?
A.  Ricky --
MS. COHAN:  What is the name of the one in the Marines?
Q.  Where does he live?
A.  He lives with the mother, I believe.
Q.  Have you ever  known him to have an occupational profession?

A.  Yes.
MS. COHAN:  Objection.   Asked and answered.
THE WITNESS:  I already answered to that question, at the beginning.  In the hotels, down in Miami.  In the tour capacity.
Q.  What is your immigration and naturalization  status with the United States?
A. I don't know.
Q.  Are you a citizen?
A.  No.
Q.  Have you ever applied for  citizenship?
A.  No.
Q.  Are you a permanent resident?
A.  No.
Q.  Have  you ever applied for permanent residency?
A.  Never.
Q.  When did you  first come to the United States, from wherever it is you came from?
A.  From the Republic of Cuba, my birth place.
From the country that I was born.  That's a name.  Republic of Cuba.  November 29th, 1960.
Q.  Were you admitted under refugee status, when you came into this country?
A.  No. Political refugee.

Q.  May I assume that your point of entry, into this country, was Miami?
A.  That's correct.
Q.  Did you enter by yourself or, were you admitted with other  persons traveling in your group?
A.  We -- I was at the Embassy in Havana, Cuba.  And, the whole load -- there were about six of u who had American visas.  So we  traveled directly to the United States, instead of going down to Brazil.  I was a political refugee at the time.
Q.  What kind of visa was issued to you by the United States, in Havana?
A.  Tours.
Q.  Have you ever had any conversations with any officers or employees of the Immigration and Naturalization Service, about  your   status as a resident in the United States or, your status by virtue of your presence in the United States?
A.  Of course.
Q.  On how many occasions?
A.  As I recall, when I  applied for my alien number in Newark --
Q.  When was that?
A.  New Jersey.
Oh, that was in the late sixties, or  early

Q.  When else?
A. Oh, when I was arrested after a raid in Cuba.  Returning from a raid in Cuba.
Q.  When was that?
A.  Summer of either '62 or '63.
Q.  Were you arrested, then?
A.  Yeah.  The whole group was arrested.
Q.  What was the nature of  your communication with Immigration in the early sixties, at the time you returned from Cuba,  pertaining to your status in this country?
A.  No.  In 1961.
I just went down to the INS  office, and I applied for a political refugee status, which was given to me.
And, after we returned from the raid, INS just debriefed everyone from the group, about what we did down there, and why we did it, you know -- and where we landed and what happened.  And, now we got away and things like that.
Q.  When was the last time that  you have had any specific conversation with anybody from INS, expressly about your status in this country?
A.  The last time I ever talked to INS people, was

after the raid.
Q.   1962 or A63?
A.  Right.
Q.  And, so far as you know, you are still here in the status of a political refugee?
A.  I cannot make a statement about that.
Q.  Well --
A.  Because, I don't know.
Q.  Do you have any knowledge that indicates that your status with INS has changed since you were first  given refugee status?
A.  Well, I filed and signed INS  papers with the Marshal service and the determination of that application, I don't know.
Q.  What kind of papers did you fill out?
A.  Well, I signed the forms that was presented to me.  And they were supposed to -- they were supposed to file the forms for me, based upon my former status down here.
Q.  For what purpose did you file the form?
A.  As a continued resident in the United States.
Q.  And, that was just when you  were  with the United States Marshal Service in protective custody?
A.  That's right.
Q.  What status were you seeking by the applica-

tion that you filed?
A.  I listed the same one that I got before.
Q.  Political refugee?
A.  That's right.  Or, whatever they want to come up with, you know.
Q.  Have you heard from any source  or anything, since 1962 or '63, that has  either indicated to you indirectly or directly, that your Immigration status in this country has changed from that of a political refugee?
A.  Of course.
Q.  Tell me what you heard.
A.  When I applied for the visa in the Embassy, in Venezuela --
Q.  What did you learn, then?
A.  Nothing.  They gave me a multiply entry --
Q.  That would have been on the occasion of your return from Venezuela, in 1976?
A.  Mr. Williams, when I  arrived there in Venezuela, you know, there was a question that I have to be a Venezuelan  citizen, just to  hold a higher  position inside the government.
So I was made a Venezulian [VENEZUELAN] citizen by President Carlos Andres Perez -- by the former President.
So right away, I went down to the American

Embassy, and filled out an application for a tour visa, which was, you know, a stamped in my  Venezulian [VENEZUELAN] passport.  And that's how I  keep commuting back and forth to the United States from wherever I was.
Q.  Then presently, you hold Venezulian citizenship and travel on a --
A.  That's technicality.  And yes and no.
Q.  In your mind, do you have Venezulian [VENEZUELAN]  citizenship?
A.  No. No. No.
I am  a Cuban.  I was born a Cuban.  I am a Cuban.  And I will die a Cuban.
That has been -- the matter has been taken care of by  attorneys over there.  And things  like that.  So yes an no.  That's correct answer for that.
Q.  Tell me what your understanding of the technicality is?
A.  You are the one that has to understand the technicality.
Q.  I just asked you a  question.
What understanding do you have of whatever the technicality is, that bears upon your citizenship?
A.  What citizenship?
Q.  Any?
What is the technicality that you  believe to

A.  It's like, you know, in Cuba, according to the constitution, I am not a Cuban no more.  Even though I was born there.
Q.  What is the technicality?
A.  The  technicality there is, that how they can deny that I am a Cuban, since I was born there.  Just because they took over and said, whoever is not with us, is not a Cuban any more.
Q.  You have a Venezulan [VENEZUELAN]  passport; don't you?
A.  It expired.
Q.  Do you have any passport?
A.  No.  I don't have any passports.
Q.  Your understanding then, is that the present government in Cuba, by some decree, has restricken you --
A.  Not by a decree.
The government constitution, that they enacted in 1973 or 1975, just that word had been engaged in covert actions,, to overthrow the El Castro -- so I was considered not a Cuban any more.  There are some many chapters concerning that.
Q.  Have you renounced your Venezuelan citizenship.
A.  I am in that process.
Q.  Have you at this time, signed  any documents

renouncing your Venezulan [VENEZUELAN]  citizenship?
A.  The papers are on the way.
Q.  Is that a no, sir, that you  have not signed any?
A.  You see, the legal procedure down there in Venezuela is quite different.
Q.  Mr. Morales, have you signed any papers  renouncing your citizenship or not?
A.  I already signed the paper.  I already announced the authority to start the proceedings on that.
It's like a power of attorney.  But it=s being called there, different.
Q.  Have you ever filed a tax return with the Internal Revenue Service?
A.  Oh, yes.  And, it was audited by them.
Q.  When most recently, did you file a tax return?
A.  Oh, up to 1978.
Q.  Does that include the calendar year, 1978?
A.  What?
Q.  Does that include the calendar year, 1978?
A.  I believe so.
Q.  For  how long had you been filing tax returns?
How many years before that, did you file tax returns?
A.  Before, when?

Q.  '78?
A.  '78  -- never.
Q.  So 1978 is the only year in which you filed a tax return?
A.  No.  No. No.
They covered '74, '75, '76, '77 and '78, I believe, too.  The whole investigation, it was brought upon me was from starting in 1974, I believe.
Q. Is that to say that you were at one point, the subject of an Internal Revenue Service investigation?
A.  No.  I was --there was a civil matter brought against me. It was a civil matter, not a criminal investigation.
Q.  Is it the case that you have not filed a tax return for 1979, 1980, or 1981?
A.  I don't believe that I have to answer that question to you.
Q.  On what grounds?
A.  On the grounds of privacy.  On the grounds that  whatever you want to certify, we can go down there.
Q.  No.
The one legitimate claim that you can make is, that you think to answer the  question might expose yourself to some criminal penalty, self-incrimination, the Fifth Amendment.

You can use that as well as anybody else.
A.  Oh, come on, Mr. Williams.
Q.  Is that the grounds upon which you do not want to answer?
A.  There is no Fifth Amendment or  incrimination   or anything like that, involving that.  So I don't have to tell you my private life about all tax matters and things like that.
Q.  Sure you do.
A.  Oh, yeah?  How?
Q.  Have you filed a tax return for 1979, 1980 or 1981?
A.  I don't have to answer that question to you, sir.
Q.  Are you refusing to answer it?
A.  I am not refusing to answer it.  I am telling you that I don't have to answer it.  I am not   refusing.
MR. WILLIAMS:  Certify it, please.
Q.  Are you declining to answer that question on the grounds that to answer it might expose yourself to self-incrimination or --
A.  No.
Q.  --criminal penalties?
A.  No. No.

It's just that, it's none of your business.  That's what I'm saying.
Q.  Sure it is.
A.  No, it's not.  It's not o your business.
MS. COHAN:  Objection.  Bickering should stop.
THE WITNESS:  That's the only reason why I am not answering you that question.  I am not refusing to answer.  I am not answering to you, because it's none of  your business.
Q.  Now, when is the last time that you have been in the employee of any third person by which, I mean, an individual, corporation, government, governmental agency, or anything or other person, which whom you communicate, who might employ you?
A.  1978, January.
Q.  By whom were you employed?
A. By the Venezuelan government.
Q.  Is it the case then, that between January '78 and the present, you  have not been in the employee of any other person?
A.  I have not been in the payroll of anybody.
Q.  Between 1978 and the present, tell me, please, sir, any and every source through which you realized any

kind of income?
A.  Say that again?
MR. WILLIAMS:  Please read back the question.  (Thereupon, the question was read back by the court reporter.)
THE WITNESS:  The witness protection program, the Marshals gave me money.  The State of Florida gave me money.  And the drug business gave me money, too.
This is between 1978 and the present?
A.  No, Mr. Williams.  I have not been engaged in any kind of narcotics activities since 1980.
Q.  All right.  Here is my question to you, Mr. Morales.
You  have mentioned three sources of --
A.  Right.
So I am pinpointing.  Because I am out of that business.
Q.  Here is my  question to you.
You mentioned three sources of income --
A.  Right.  In a broad --
Q.  The witness protection program, the marshal service, and the drug business.
My question to you is, whether between 1978 and today, there has been any other source of income that

you have realized, besides those three?
A.  No.
MS. COHAN:  The book?
MR. WILLIAMS:  Rina, I will not have this   man helped.  He does not need any help.
THE WITNESS:  But I want to hear what she said.
MS. COHAN:  Then, you will go on inaccurate answers.
MR. WILLIAMS:  That is his problem, until it becomes the State's problem.
THE WITNESS:  What did you say, Rina?
MS. COHAN:  I  will get you on cross.
Q.  During what periods of time or at what period of time, were you receiving money from the United States Marshal Service?
A.  Since they took care of me.
Q.  When was that?
A.  Either January or February, 1981.
Q.  Until when?
A.  Until I left them, the department.
Q.  In November of last year?
A.  No.
Q.  When did you  leave them?

A.  September I believe.  On or about September, 1981.
Q.  At what intervals were you paid, while you were in the Marshal Service?
A. Oh, they  have a monthly allocation.
Q.  How much were you paid?
A.  I'm not going to tell you.  Ask the Marshals.  I might expose some of their operation, I believe.  So you better, you  know --
MR. WILLIAMS:  Certify it, please.
Q.  Between September of 1981 and today, have you  had any source of income at all?
A.  The State was so kind and gentle, that they helped me out, to get out of the witness protection program.  And , when they provide funds for me to do so.
Q.  The State of Florida?
A.  Yeah, the State.  City of Miami Police Department.  The State Attorneys.  Whatever is the State of Florida.
Q.  Who actually made those arrangements for  you?
A.  What?
Q.  Who made those arrangements for you?
A.  (Indicating).  You have it right there.

MR. WILLIAMS:  Indicating for the record, the prosecutor, Ms. Cohan.
Q.  At what intervals have you been paid by the State, if more than once, by the State of Florida?
A.  I received one installment to get out of the witness --you know -- to get away from the Marshals.
And, I received my witness fee, the other day.
And prior to that, before I  got into the witness protection program, they paid for the Ramada Inn.  And, you know, my daily --
Q.  We will go back to that  later on.
When you left the Marshall --
A.  Why do you have to cut me when I am answering you?
Q.  Because I did not ask that.
A.  Let me finish my answer.  Don't shout at me,  Williams.  Let me finish my answer.
You asked me a question.  Let me finish it.  Okay?
Q.  No.
A.  Yes.
Then don't ask no more questions to me.  If I'm not going to finish.
Q.  Then leave.  If you want to leave, get up and take your people and go.
MR. COHAN:  Objection.
He is here in response to your subpoena for deposition.  We have every intention of continuing this deposition in a civil fashion.
Q.  Now, listen to the question, Mr. Morales.
If you do not understand the question, Mr. Morales.
If you do not  understand the question --
A.  But let me finish my answer.  That's the only thing that I am complaining, now.
Q.  Stop  yelling.  Do not get excited, now.
A.  What about when you get excited?
Q.  I do not get excited.  Now listen to the  question.
A.  Okay.  It works both ways.
Q.  The question is, between September of 1981 and the present, do you have that?
A.  Yes.
Q.  What frequency were you  paid money by the State of Florida?
Now, you told me --
A.  I already answered that question.
Q.  What was the amount of the one installment payment that was paid to you when  you  left the Marshal?

A.  Six thousand.
Q.  This was in September of 1981?
A.  On or about September.
They can give you the  papers, and the garbage and whatever, the receipts.
Q.  How was that amount determined, Mr. Morales?
A.  What?
Q.  How was that amount  settled upon; six thousand dollars?
A.  I settled it.
Q.  It was your choice, your figure?
A.  It was my choice.

(Thereupon, a brief discussion was held off the record.)

THE WITNESS:  How did I arrive at the amount?

Q.  How did you select the amount of six thousand dollars?
A.  Oh, very simple.  I acknowledge that I -- did I make a breakdown for that?
Q.  No.  They cannot help you.
A.  Well, I did make a breakdown for that.  And that's the amount that I arrived to keep me going on for the next  four  months.
Q.  In other words, you determined what you thought

your  predictable living expenses would be a monthly basis?
A.  Right.  Instead of having, you know --
Q.  Monthly installments?
A.  Right.
Q.  With  whom did you have discussions about the amount that you were going to be  paid?
A.  Discussions about the money that I was going to be paid?
Q.  Yes.
With whom, on behalf of the State and or police department?
A.  Oh, I talked about it with Rina.  And I talked about it with -- what is the name of the Major -- Oboz.
Q.  When did those conversations take place?
A.  And Martinez.
Q.  Which Martinez?
A.  Raul.
Q.  When did those conversations take place?
A.  In the summer o 1980.
Q.  Did you simply tell them how much money you wanted or, there  conversation about  it among all of you?
A.  No.

I told them that I have, you know, arrived to the conclusion that that's the money that I need to get the hell out of the Marshal's custody.  And the money that I need to move from one place to another, and to keep me going on for the next four months.  That's exactly --
Q.  Was there any objection raised to the amount by anybody?
A.  No. No. No.
Q.  Was it agreed to as soon as you stated it?
A.  Yes.
      It's not to my knowledge if there was any between them.
Q.  Of course.  I am only asking you what you know or what you heard.
A.  What I heard, no.
Q.  And this was shortly before you left the Marshal's program?
A.  Since.
Q.  No.  That is not the question, Ricky.  Here is the question.
That discussion you  had was shortly before you left the Marshal's program.
A.  Otherwise, I would have never been able to leave the Marshal's  program.
Q.  Is that a yes, sir?
A.  Otherwise, I will never have been able to leave the Marshal's program, which I wanted to leave.  And, thanks to them, I  was able to get the hell out of there.
Q.  It sounds like they did you quite a favor.  What was so bad about it?
A.  What?
Q.  The Marshal's  program?
A.  Oh, the place that they relocate me --
Q.  So you were glad to get out?
A.  I have to.  It was a security risk for me.  It was a nightmare.
Q.  You're almost making it sound like those folks saved your skin.
A.  Actually, you can tell that.  That's the way I feel.
Q.  When did you get your witness fee payment?
A.  The first date of the month..
Q.  The first  of March?
A.  The first date of the month.
Q.  Just yesterday, April first?
A.  Which  one are you referring to; the Marshals or --
Q.  The witness fee payment.

A.  Oh, the witness fee payment?
Q.  Yes.
A.  It was the day before yesterday.
Q. How much was that?
A.  Six hundred.
Q.  Was that  given to you by check?
A.  That's right.
Q.  Who gave it to you?
A.  Oh, we went down to the courthouse, and they wrote the check over there.
Q.  Oh, that was the other day, Mr. Kagney rode down to the courthouse, a couple of days ago, and it was authorized by Judge Kogan?
MS. COHAN:  Mr. Kagney?
MR. WILLIAMS:  Yes.  One of your secretaries --
THE WITNESS:  That's what counter-intelligence is all about.
Q.  How was the six hundred dollar figure determined, do you  know?
A.  I don't.
Q.  Do you expect to receive any more money from the State, as you sit here?
A.  As a witness fee?
Q.  From any source, for any reason?

A.  Yes.  As a witness fee.
Q.  How much more?
A.  What?
Q.  How much more?
A.  I don't  know.
Q.  Who is going to determine that?
A.  The State.
Q.  Who, specifically, on behalf of the State?
A.  Janet Reno, Rina Cohan or, I don=t know how the administrative parties run.  I don't know anything about it.
Q.  When will that be determined?
A.  I don't know.
Q.  Do you expect any more money within the next thirty days?
A.  I hope so.
Q.  Is it your understanding with the State, that you are going to be paid on a periodic basis, until this case has been completed?
A.  Yes.
Q.  With whom did you  negotiate those arrangements?
A.  What arrangements?
Q.  For periodic payment, until the case is completed?

A.  I have not --
Q.  I asked you a moment ago, if it was your understanding that you were to be paid on a periodic basis.
A.  Well, any kind of negotiations will be between Rina Cohan and myself, since she is the State representative of --
Q.  Then, to the extend that you have expectations that you are going to be paid periodically, those expectations are based upon conversations that you had with Ms.  Cohan?
A.  Yes.
Q.  What is the frequency with which you expect to be paid  in the future?
A.  I don't know the frequency.
Q.  Has there been any conversation about  that?
A.  About the frequency?
Q.  Yes.
A.  No. Because otherwise, I would give you an answer.
Q.  Do you know the amount?
A.  No.
Q.  Has the amount not been determined?
A.  Not to my knowledge.
Q.  To your  understanding, who is the person  or

who  are the persons, if there are more than one, who will eventually determine the amount of money that you are to be paid?
A.  I don't know.
I believe  it's Rina, the one who might -- if she has got somebody else on top of her, that, I don't know.
Q.  So as far as you are concerned, though, it is not Ms. Cohan?
A.  What?
Q.  As far as you are concerned, it is not Ms. Cohan?
A.  Yes.
Q.  Have you, as of today, sought any kind of employment from anybody, any person, any firm, business, corporation, governmental agency?
A.  No, sir.
Q.  Or, anything else?
A.  No, sir.
Q.  Since leaving the Marshals program?
A.  Yes, sir.
Q.  And, whom did you seek employment, since leaving the Marshals program?
A.  With anybody.  Nobody.
Q.  No. you answered my question in the affirm-

ative, which indicated that you had sought employment someplace since leaving the Marshals program.
A.  Oh, yes.  Yes.  Yes.  Yes.
I applied several places in the State of New York.  And nothing came through.
Q.  Since leaving  the  Marshals  program?
A.   Yes, sir.
Q.  What kind of position did you apply for?
A. Gas station attendant.  I  have no skills except one.
Q.  What is that one?
A.  Intelligence.
Q.  With whom did you make the application for the position as gas station attendant, Mr. Morales?
A.  One of those -- you see, you sit behind the bullet proof office, and they  have those self serve pumps, and then, you --
Q.  Who is the person?
A.  It was not a person.  It was just a place that they had AHelp wanted@.  And, I went down there and talked to the guy.
Q.  Up in New York?
A.  Up in  New York.  It was a very risky position.
Q.  You cannot be too careful these days.

A.  Especially up there.
Q.  Apart from that attempted venture in the petroleum industry, have you applied anyplace else for any kind of employment, since leaving the Marshals program?
A.  No, sir.
Q.  Well, what are you going to do, Mr. Morales?
Are you going to go to work someplace or, are you going to wait and see what happens?
A.  I want to get it over with, your trial.
Q.  You want to get that out of the way, before you do anything?
A.  Of course.  I have to.
Q.  You talk about my trial.
You  mean the case in which Mr. Quesada and the others were charged?
A.  The Tic-Toc [TICK-TALKS] affair.
Q.  For as long as the case is pending, then, you have no intention of doing anything else.  Is that correct?
A.  That's correct.
Q.  How are  you going to live?  What kind of money?
A.  What?
Q.  What kind of money are you going to live on;

what you get from the  State?
A.  I don't understand your question.
Q.  What are you going to do to  provide yourself with food and clothing and shelter?
A.  I  have somebody who is providing me with food and board.
Q.  Do you think that you could go on for an indefinite period of time?
A.  Yes.
Q.  Without having any source of income at all?
A.  Yes.
Q.  So that might be your intention?
A.  That is my intention.  That's what I am doing exactly, right now.  That is what I have been doing for the past time, since I arrived here in Miami.
Q.  Except for what you received from the State?
A.  That's right.
Q.  And so far as you  know, whatever you are going to get from the  State is going to continue until this case is over with?
A.  I believe so.
By the way, I threw away the check that you gave me.
Q.  All right.  Let's go back to the time before

you entered the Marshals program.
Prior to that time, what was your most recent employment?
A.  Venezuela government.
Q.  At the time you left the employee of  the Venezuela government, in 1978, how much were you getting paid by the Venezuela government?
A.  Oh, I was making forty thousand a year.
Q.  American or Venezuelan?
A.  American.
It's conversions. I mean, I was being paid in Venezuelan currency.
Q.  No. But I asked you the equivalents.  That is what I wanted to know.
A.  Yeah.  The equivalence, forty thousand a year.
Plus expenses, and the privilege that went along with my position, there, with regard to my intelligence.
Q.  For who?
A.  And for myself, for the Venezuela government.
(Thereupon, a brief discussion was held off the record.)
THE WITNESS:  If I want to know what is in the record for the last five minutes, can I --

MR. WILLIAMS:  If it pertains to an answer to a question that you gave.
THE WITNESS:  And, it pertains to your interrogatory remarks about the Venezuela government and yourself.
MS. COHEN:  May we avoid all further gratuitous arguments by the parties?
THE WITNESS:  I don't have to take insults from him.
Q.  Would you feel insulted if somebody called you a dope dealer?
A.  Not when I was a dope dealer.  Because I was not a dope dealer at that time.
Q.  Would you feel insulted if somebody called you a killer or a gunman?
A.  Yes.
Q.  Because you never have done that?
A.  Because I'm not a killer or a gunman.
Q.  You certainly have killed people.
A.  Have you ever seen me kill anybody?
Q.  Okay.
A.  Don't insult me.
Q.  Would you  feel insulted if somebody called you a killer?

A.  Yes. Because I'm not a killer.
Q.  So to be called a drug dealer, would not insult you, because --
A.  Because I admit that I was a drug dealer.
Q.  While you were in the employ of the Venezuela government, was your salary always forty thousand dollars?
A.  No.
Q.  Or, did it increase gradually?
A.  It was increasing, you  know, the way I started there.  I started between -- let's see.  Seventeen, eighteen thousand, you know.  And finally, made it up to forty thousand.
Q.  While you were in the employ of the Venezuela government, Mr. Morales, did you  maintain any kind of a bank account, either in Venezuela in the United States, a savings account?
A.  No.
Q.  Did you save any money?
A.  I spent it.
Q.  What was the nature of the incident or situation, that gave rise to your departure from Venezuela in 1978?
A.  Oh, I have an incident with one of my  immediate superiors.  It was a commisor general.

Tell me about it.
A.  Orlando Garcia Vasquez.
Q.  Tell  us about it.
A.  He was a commissor general.  And, we have a very nasty argument one  night.  And, he was completely drunk.  And he was aggressive and he was -- he tried to  pull his pistol out of his belt.  And he was so drunk,  you know, he crashed against the floor.
And I said, AWell, this guy, you know, is real dangerous.  You know.  He's my superior officer.  And, we have been friends.  And he  has come to the point where, you know, he is doing to me what he used to do to everybody there.
And, so I decided that that was the end of  it.
Q.  What did you  have the argument over?  What was the argument about?
A.  Oh, the argument was about so many things concerning the DISIP, concerning himself, concerning his mistresses, concerning his wife, concerning his livelihood.  And, the fact that I was still a commissor, but I have no -- I have been taken off of my command of the division.
Q.  Why did that  happen?
A.  What?

Q.  Why did that  happen?
A.  Because I was exposed to the press over there, in such a way that they decided to  give me some vacation.  And when I returned, I just happened that they had named somebody else there.
And, I was being kept in an advisory situation, with a G.I., which I did.  And out of the blue sky, they just start denying my presence there.
And, everytime that the newspapers were coming up with my name, and they will push me out of the country.  And he  was leaving  the joke that I was the man that never was.
Q.  What were the newspapers saying about you?
A.  That I was a CIA agent.
Q.  And, that is the kind of exposure you were talking about?
A.  Oh, yes.
There  were spreads in the paper about me being a CIA agent, FBI, or whatever.  You know.  And for American intelligence and all kinds of things.  Venezuela is a very confusing country with regard to the  press.
Q.  In other words, the press, in effect, accused you of being a spy for the American government?
A.  Yes.  Among other things.

Q.  What else did they say about you?
I mean, they could not say anything worse; could they?
A.  That was the extend of it.
Q.  Did they accuse you of anything else?
A.  Well, afterward, they accused me of being a drug dealer, when I was arrested in April, 1976 -- in '78, I mean.  Excuse me.
Q.  Well, that was after you came back here, though?
A.  Right.
But that was three months after I left Venezuela.
Q.  Were you?
A.  When?
Q.  While you were in Venezuela.
A.  What?
Q.  A spy or an agent for the CIA or any other branch of the American government?
A.  That's propaganda.  That is propaganda.  This is innuendos, characterization, and yellow press.  And, you know, things that were not something shaded.
Q.  Were you performing any kind of service at all, of an information gathering sort for any agency of the United States, while you were in Venezuela?

A.  Oh, we have what we called cooperation among friendly services.  So there was information exchanged.
Q.  Here's my question to you, Mr. Morales.
A.  That's my answer to you, Mr. Williams.  Let me finish for Christ sake.
Q.  Now, please, Ricky.
A.  Please, do. What excitement. At least let me finish. Okay?
Q.  Go ahead.
A.  Go ahead.
Q.  Were you finished?
A.  Yes. I am finished.
Q.  Good.
The question is, whether while you were in the employ of the government of Venezuela you were at the same time, specifically performing any information gathering function for any agency of the government of the United States; yes or no?
A.  I cannot answer that question in a yes or no manner.
Because it is what I mentioned to you before -- the cooperation among friendly services.  That we provide information, and we receive information from the friendly services, that were in friendly terms with our

work on service.
Q.  Were you giving any information to the government of the United States or any other government that --
A.  Yes.
Q.  --that you were not specifically authorized or instructed to give?
A.  No.
Q.  By the Venezuela government?
A.  No. NO. Nothing specific.
I have to clear up first -- I have the chain of command, there.
Q.  Well, we certainly would not want to violate that; would we?
I mean, somethings are secret after all.
A.  Of course.  You never violate the chain of command.
Q.  So you had a falling out with your superior officer?
A.  One of my superior officers.  One lf my commanding officers.
Q.  Of the things that were written about you in the press.  Is that essentially what it comes down to.
A.  That's part of the -- in general.
Q.  But were there any other complaints that he

made or accusations that he made against you?
A.  No.  It was personal things between him and myself.
Q.  Give us a general idea, so we will know whether we need inquiry or not.
What kind of personal things?
A.  The association with the FBI representative and the Cuban Embassy.
Q.  I gather that what you are saying is, that he had such associations and you disapproved of them?
A.  I came up to the point that I realized that he was doubling with them.
Q.  Well, that probably would be a violation of the laws of the Republic of Venezuela, wouldn't it?
A.  Yes.
Q.  Did he have them arrested?
A.  I don't know.
Q.  Did you have them arrested?
A.  What?
Q.  Did you have them arrested?
A.  How come?  He pulled a gun on me.  And I confronted with certain things about it.
Q.  This was during that night when he was drunk?
A.  Yes.
I never wait until, you know, for the hangover.

Q.  Did you have arrest authority, while you were --
A.  Of course I have arrest powers.
Q.  While you were working for the government of Venezuela?
A.  Yes.
Q.  But I understand it, you did not arrest him and charge him with any kind of espionage or activities against the interest of the country of Venezuela did you?
A.  No.
Q.  To your knowledge, has the fellow since then, been charged with anything?
A.  I know that he is being investigated.  But no charged.
Q.  Well, you and I both know that being investigated by something does not mean anything.
I mean, if anybody in the world knows that, you do; right?
A.  Right.
Q.  While you were in the employ of Republic of Venezuela, did you at any time have any income of any

sort, from any other source, whether it was legal or illegal?
A.  I don't understand the question.
Q.  Tell me what I is you do not understand, and I will try to work it out.
A.  What source?  What do you mean by a source?
Independent source?
Q.  Any?
A.  Independent source?
Q.  I said, any source.
A.  What do you mean by any source?
Q.  From any place?
A.  From any place, besides the Venezuela --
Q.  Besides the government of Venezuela.
A.  There was a time that I was being paid by the Venezuela government and by the FBI at the same time.
Q.  That was shortly after your arrival in Venezuela?
A.  Yes.  It's a matter o public record.
Q.  I have been trying to remember, by the way, Ricky, and I have not been able to, what was the name of the fellow who at the time was an older guy with the Bureau, who was kind of your liaison down here?
A.  It was my case officer.
Q.  What was his name?

A.  George Davis.
Q.  He is not with the Bureau any more; is he?
A.  He's retired.
Q.  During what period of time was it that you were getting paid both, by the Venezuela government and the FBI?
A.  1974 up to -- I was paid by the FBI up to July 31st, 1975.  Is when I resigned my position as a paid informant with them.
Q.  We will go back to that in a minute.
After that time or including that time, for as long as you were in the employ of the government of Venezuela in any capacity, were you receiving or, did you receive any other income from any other source of any kind, whether illegal or legal?
A.  No.
Q.  While you were living in Venezuela was your residence in Caracas?
A.  Yes.
Q.  Was it part of your job to travel?
A.  Yes.
Q.  How frequently did you travel on an average?
A.  All depends on the assignments.
Q.  Did it continue to be a part of your responsibility to travel, after you became  the commissor

or the chief?
A.  Yes.
Q.  Were you still doing case work as the chief or the superior or whatever it is, were you still handling specific cases or investigations?
A.  Oh, yes.
Q.  Did you keep some kind of a log or record of the places to which you traveled?
A.  No. But I know where I went.
Q.  If I asked you to recount the various places to which you traveled while in the employ of the Venezuela, do you think you could touch all?
A.  I can come up with a fair description of the places that I visited.
Q.  Give me your best recollection, if you can.  Do a list.
A.  Because the logs that you mentioned, you know, when I have to return, I have to write up my records an things like that.  Which are the property of the Venezuela government.
Q.  You did not keep any of that stuff; did you?
A.  For myself, I never -- never in my life.  I never get copies for myself.
Q.  Always travel light?
A.  Of course.  Everything is in my memory.

Q.  Absolutely.
Give me as full a list as you can of the traveling that you did while you were working for the Venezuela government.
A.  Ecuador, Guatemala, Colombia, Spain, England, Austria, Germany, Sweden, Mexico, United States, Costa Rica, Panama.
Q.  Is that about it?
A.  Roughly.
Q.  I assume that when you traveled, once you were in a supervisory position, that you at least took some people along with you?
A.   I always have an immediate superior with me.
Q.  Was that true while you were a case worker as an inspector?
A.  Yes.
Q.  What other ranks did you hold?
A.  The three that I mentioned to you before, the coordination, the inspector and the commissor.
Q.  What other ranks in DISIP, did you hold, besides inspector and commissor?
A.  That's it.
Q.  You went from inspector to --
A.  To commissor.

Q.  When you traveled to the European continent, you were traveling on a Venezuela passport?
A.  Of course.
Q.  Did you have diplomatic status?
A.  No.
Q.  How did you come to get the job with the Venezuelans, to begin with?
A.  I had contact with the Belgian Congo.
Q.  Did he recruit you or somebody that you knew personally before that?
A.  Oh, I knew him.
Q.  Tell me how it came to pass that you god the job.
A.  Well, because I recruit for the U.S. intelligence agency.
Q.  So you kind of went to him at one point and said ANow, it's your turn?
A.  No.  He was --
Q.  How did you come to get the position in Venezuela?
A.  He gave it to me.  He's the one who took me down there.  He's the one who introduced me.  He's the one that gave me the opportunity.  He's the one that gave me the opportunity for training in advancement, and to developments my line of job, my profession.

Q.  Was he, at the time, either directly or indirectly providing information or any kind of assistance or service to the CIA or any other United States governmental  agency?
A.  Yes.
Q.  So that I was kind of like in effect, using him to put you in place as cover.  Is that it?
A.  Cover for what?
Q.  Anything.
A.  That's not the word.  That's not the sense.  You are mistaking it completely.
Q.  It would not be the first time.
How had he been, in anyway at all, affiliated with the CIA, when you went to work for him in Venezuela?
A.  He was recruited in 1973.
Q.  Only about a year, when you went back down to Venezuela?
A.  I was traveling back and forth, since 1972.
Q.  No.
When you went down to work.
A.  On an official capacity?
Q.  Yes.
A.  Yes.  And that was in November, 1974.
Q.  Did you have to make any disclosures to anyone in the Venezuela government at all, about any of your

prior tests or any of your background, in order to get the position with DISIP?
A.  That was Orlando Garcia Vasquez's job.
Q.  Very neat.
A.  Very neat.  He was my superior officer.
Q.  Did you in fact, make any disclosures to him?
A.  My whole life.
Q.  Was it necessary?
A.  I'm public person.
Q.  I know.  We all are really.
A.  But I am more than you.
Q.  No question about that.
Did you make disclosures to him about prior associations or affiliations that you had with any intelligence service for any other country?
A.  As specifically, the United States?
Q.  Any?
A.  Of course.
Q.  Tell me what you told him.
A.  That I was working for the FBI.  And, that I have worked for the CIA. And, that I have worked for the DEA.
And, at one point in his life, he was also recruited in the early sixties, for the CIA in the Miami area.

Q.  What else did you tell him about any other work that you did for any other  government or the information gathering of any other government?
A.  Well, I didn't have to tell him, you know, the exact nature of my job.  Because it was prejudiced.
So the only thing we need to know is my association with whatever, intelligence or law enforcement agency I have been associated with -- I have done work for them or been paid by.
Q.  What other governments have you worked for or been paid by, besides the United States and Venezuela?
A.  The Cuban government.
Q.  Go on.
A.  What?
Q.  Go on.
A.  The Cuban government in 1959 and 1960.
Q.  What else?
A.  That's it.
Q.  Is it your testimony, sir, that at no time in the past have you ever worked for or been paid money by any other government , regardless of the level, through which the payment came, which is to say, at the federal level or at some lower level of the government, you have either worked for non been paid money by another government to do anything or not do to anything, except the

United States, Venezuela, and Cuba.  Is that your testimony?
A.  That's correct, sir.
Q.  Well, there was a period of time when you were on the African continent; wasn't there?
A.  That's correct.
Q.  When was that?
A. 1964.
Q.  Specifically, where?
Q.  What were you doing there?
A.  I was on a mission.
Q.  What were you doing there?
A.  Fighting a war.
Q.  What war?
A.  The Congelese [CONGOLESE]  war.  You never heard of it?
Q.  Were you a soldier in the army?
A.  What?
Q.  Were you a soldier in an army?
A.  No. I belonged to Einzadze Gruppen.
Q.  Spell that, please.
A.  That is a special force team.
Q.  Spell it so the reporter can get it.
A.  Special Force team.  That is a German word for >Our team@.
Q.  How do you spell it?

E-I-N-A-D-Z-E G-R-U-P-P-E-N.
Q.  How does that translate?
A.  Special force, hard core, a team.  There are so many names that you can go by it.
Q.  Of what government or army was the Einzadze Gruppen a part?
A.  We were attached to the five mercenary brigade.  The Wild Geese.
Q.  Of what?
I mean, the Belgian Congo or --
A.  The five mercenary brigade.  The Wild geese.
Q.  A private mercenary organization, that did not have any governmental affiliation.  Is that correct?
A.  We were fighting  against the communists on behalf of the Congelese[CONGOLESE]  government, who was being beseiged, and trying to be overthrown by government forces.
Q.  What group?
Q.  The one you just told us you belonged to?
A.  My group?
Q.  Yes.
A.  No.
My group -- we worked CIA.

Q.  At the same time that you were working for the CIA, were you also on the service employed by some other government or, was this group strictly a mercenary group?
A.  What group?
Q.  The group that you were in.
A.  My group?
Q.  Yes
A.  We were contact agents for the CIA.  And, we were attached to the five mercenary brigade.  The Wild Geese.
Q.  Under whose direction or control was the five mercenary brigade?
A.  The five mercenary brigade?
Q.  Yes.
A.  Colonel Mike Horg [HOARE].  It's the truth.
Q.  Was the Colonel Horg [HOARE] under contact with the Congelese[CONGOLESE]  or --
A.  That, I don't know.
Then, the group to which you belonged, so far as you could determine, was strictly a mercenary group, without any official governmental affiliation.  Is that correct?
A.  Which group?
Q.  The one that we have been talking about; the

five mercenary brigade.
A.  No.
That day, they were under the command of the Congelese [CONGOLESE] government.
Q.  They were?
A.  Of course they were.  It was an unorganized force that was fit to --
Q.  Then, you were on the one hand, attached to an organization that was a formal or official arm of the Congelese [CONGOLESE] government.  And at the same time, a contract agent for the CIA.  Is that correct?
A.  Roughly.
Q.  Tell me how it is incorrect.
A.  It is incorrect, because we didn=t belong to the five mercenary brigade.  And we were not part of the Congelese [CONGOLESE] government.
We were an elite unit from the Central Intelligence Agency that were attached to the five mercenary brigade.  And, we used the cover of being mercenaries, because you don=t go around telling me that you belong to the CIA.
Q.  Everybody else does?
A.  The ones that do not belong to the CIA.
Q.  Has there been any other occasion when you have been performing any information gathering or military

or paramilitary service of any sort, in any other country, besides the United States, Venezuela, Cuba, and what was then, the Belgian Congo?
A.  Everytime that I travel to the countries that I mentioned to you before, I was on duty.
Q.  All right.  I will rephrase the question.
Has there been any other occasion when you or appeared to have been ,attached to some arm or agency of some government for the purpose of either information gathering or any military or paramilitary work, aside from Cuba, the United States, Venezuela, and the Belgian Congo?
A.  I never worked for the Belgians.  And I never worked for the Congelese government.
Q.  Listen to my question.
Has there ever been any other occasion when either you were attached or, you appeared to be attached, to any other agency or arm of any other government, aside from those four?
A.  No, sir.
Q.  So those are the only four instances.  Is that correct?
A.  The ones that I already answered to you.
Q.  By the way, while you were in the Belgian Congo, you did not kill anybody then; did you?

A.  I survived that war.  And I never let, you know, the enemy to kill me.
Q.  Is that a yes or a no?
A.  So there was a lot of casualties, there.
Q.  Is this a yes or a no?
Nobody is going to prosecute you for that.
A.  But I disagree with the word kill.  You don't kill.
Q.  No, I do not. Except for an occasional ant or --
A.  I'm not telling you --
Q.  Or some other kind of verment or bug.
A.  That does not apply.
It is when you take -- you remove physically, your enemies.  Your enemy soldiers.
Q.  Well, what word would you like better that kill, Ricky, to describe the process by
which --
A.  They just -- it's a military response.
They suffer casualties.
Q.  Listen to my question.
Tell me what word you would prefer to use to kill, when you describe the process of caution -- the discontinuation of life of a --
A.  Inflicting casualties to the enemy.
Q.  Okay.  Understanding the term, inflicting

casualties to the enemy, to be your choice for a synomon to the word kill, did you inflict any casualties to the enemy in the Belgian Congo?
A.  Of course.  There was a big war going on there.  And a lot of shootings back and forth.
They inflict casualties on us, and we inflict casualties to them.
They inflict casualties on us, and we inflict casualties to them.
The only thing is, our casualties were bigger that theirs, so we won.  Like any other war.
Q.  War is hell; isn't it , Ricky?
A.  I love it.
MR. WILLIAMS: It is about four o'clock on Friday.  I am inclined to recess for the day.

(Thereupon, the deposition was recessed.)

(Thereupon, formalities were not waived.)


PAGE  65



I, MARY JANE GRANT, Shorthand Reporter and Notary Public for the State of Florida at Large, do hereby certify that I was authorized to report the deposition of RICARDO MORALES NAVAREHE [NAVARETTE], a witness herein; that said witness was duly sworn, and that the foregoing pages numbered one through sixty four constitute a true record of the deposition  given by said witness.

Dated at Miami, Dade County, Florida, this 15 day of April, 1982.


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