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IN THE UNITED STATES DISTRICT COURT

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FOR THE DISTRICT OF COLUMBIA


UNITED STATES OF AMERICA,

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Plaintiff,
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vs.
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WILLIAM R. CLEMENS,
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a/k/a "ROGER CLEMENS,"
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Defendant.
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...............................x

Docket No. CR 09-223

Washington, D.C.
Tuesday, April 24, 2012
9:04 A.M.

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TRANSCRIPT OF TRIAL PROCEEDINGS - A.M. SESSION


BEFORE THE HONORABLE JUDGE REGGIE B. WALTON
UNITED STATES DISTRICT JUDGE

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APPEARANCES:

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For the Government:

Steven Durham, AUSA


Daniel Butler, AUSA
Courtney Saleski, Jr., AUSA
Gilberto Guerrero, AUSA
UNITED STATES ATTORNEY'S OFFICE
555 4th Street, N.W.
Washington, D.C. 20530

For the Defendant:

Russell Hardin, Jr., Esquire


Jeremy Monthy, Esquire
RUSTIN, HARDIN & ASSOCIATES
1401 McKinney Street
Suite 2250
Houston, Texas 77010

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Michael Attanasio, Esquire


COOLEY, GODWARD, KRONISH, LLP
4401 Eastgate Mall
San Diego, California 92121.

APPEARANCES (Cont'd):

Also appearing:

William Pittard, Deputy General Counsel


U.S. House of Representatives
Office of the General Counsel
219 Cannon Building
Washington, D.C. 20515

Court Reporter:

Cathryn J. Jones, RPR


Official Court Reporter
Room 6521, U.S. District Court
333 Constitution Avenue, N.W.
Washington, D.C. 20001

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Proceedings recorded by machine shorthand, transcript


produced by computer-aided transcription.

TABLE OF CONTENTS

MISCELLANY

Page No.:

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Opening Statement on behalf of the Defendant ....

P R O C E E D I N G S

E X C E R P T

OPENING STATEMENT ON BEHALF OF THE DEFENDANT

MR. HARDIN:

JURORS IN UNISON:

MR. HARDIN:

Good morning.
Good morning.

That is not the, in the books, for

lawyers as the way to start an opening statement.

obviously when I look around the table here, I didn't get

the memo about clothes and ties either.

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And

So I hope that you

won't hold any of that against Mr. Clemens.


I really appreciate how closely you all paid

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attention to the Government yesterday.

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good lawyer and a very decent man.

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at the finger-pointing and the aggressiveness he took about

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Mr. Clemens as a person.

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Mr. Durham is a very

I was a little surprised

Deceit, dishonesty, betrayal, all of those words

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he threw at Mr. Clemens.

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final argument than an opening statement when we're supposed

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to be discussing the evidence.

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not what this should be about.

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All of those words more like the

He points at him.

This is

This should be about what the evidence is going to

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show as to whether Roger Clemens lied before Congress when

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he testified in two different ways, one in a deposition in

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February of 2008, and the next week before the world at

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large on public TV.

We're here because a man dared to publicly deny

consistently in every forum known to man his innocence of an

allegation in a private report released publicly.

simple as that.

It's as

What this evidence will be designed to do from the

Government, Mr. Durham has already broadcast.

to call Mr. Clemens a liar.

deceitful, and apparently a bunch of other words.

all coming back, always will be because he dared to deny he

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was guilty of a crime.

They're going

They're going say he was


And it is

That's all.

The person who has consistently throughout and

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regularly since December the 13th of 2007 denied he did

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anything wrong and denied that he took HGH or steroids is

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Roger Clemens.

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And what you're going to see from the evidence is,

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is he has done everything possible from the day one these

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allegations were made public to deny his guilt.

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of that, first Congress and now the U.S. Attorney's Office

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here in D.C., has chosen to make that a crime.

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sitting in judgment of whether it is a crime to deny you

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committed a crime.

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Congress that that's what he was going to do.

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And because

You are

And they knew when they brought him to

Let's go back real quick chronologically as to how

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we got here and then I want to ask you to look at these men

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that are at issue.

And I want you to think as you go

through what the evidence is going to be what you're going

to have to decide from it.

About eight or nine days, the evidence will be,

before December the 13th of 2007, Roger Clemens' agent found

out that Brian McNamee, Roger Clemens's trainer since 1998,

had told the Mitchell Commission that Roger Clemens had used

HGH and steroids.

found out that the Mitchell Commission, when it issued its

report the next week, was going to name names of players the

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They found that out because Brian McNamee

Mitchell Commission contended had used steroids.

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Congress, as you've heard from Mr. Durham, in 2005

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had some much ballyhooed hearings with prominent athletes

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about whether they used steroid and what the problem was of

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steroids in baseball.

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After that, baseball, at some prodding by

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Congress, hired George Mitchell, who by then a former

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senator was in private practice with a law firm called DLA

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Piper.

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firm, millions of dollars to do an investigation that

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culminated in December of 2007 with what was called the

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Mitchell Report.

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And they hired him, and that baseball paid him, the

I think the evidence is going to be that no one

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knew for sure until the day the Mitchell Report came out

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whether the Mitchell Report was actually going to name names

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of players they said did it or whether they were simply

going to describe the problem of steroids in baseball as

they saw it in making recommendations.

When Roger Clemens's agent, and then lawyers, find

out that the report was due to come out that week, they sent

two investigators, as Mr. Durham talked to Brian McNamee.

And they interviewed him.

an argument about whether it was accurate or not, they

taped -- that interview was tape-recorded.

recording was later provided to Congress, and the Government

And because they never wanted to

That tape

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has it.

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of Roger Clemens that he had told the Mitchell Commission

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the day before report comes out.

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And that is what Mr. McNamee told representatives

The evidence will be when the report comes out

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December the 13th, Roger Clemens tried to do what the

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Government and anybody reasonable would say, just deny and

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maybe it will blow over.

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appear publicly on December the 13th to answer those

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responses, he spoke to his lawyer, who said it's not true.

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And so Roger Clemens did not

And Roger Clemens takes his two -- two of his sons

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hunting for a week or so.

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furor was unbelievable in the media.

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to imagine because this man had many -- many called the

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premier pitcher in baseball of all time.

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Comes back, during that week the


It's difficult for you

Before 2001, no baseball pitcher had won the most


coveted award in pitching for baseball, in baseball for

pitching, the Cy Young award.

five.

retires, he has won seven.

boy for the Mitchell Report in terms of the nature of

steroids in baseball as far as the way the publicity was,

and so nobody would stop.

Roger Clemens by then had won

He was the first person who ever won five.

When he

And so this man is the poster

So when he comes back, he issues a denial because

people wanted to hear from him on a You Tube, doesn't take

questions, just says, "I didn't do it."

And announces that

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he's then -- and he's going to submit to an interview with

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"60 Minutes" and that Mike Wallace would do the interview.

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The very thing anybody who was not guilty of the allegations

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would do to try to protect their reputation and their

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career.

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He had by that time been a baseball pitcher for 24

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years.

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and taking the cheap way out was total anathema, totally a

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guess, everything he had ever stood for.

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allegations were telling a forty-five-year-old man he had

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cheated, and you got where you were by not playing straight.

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And the evidence will be Roger Clemens wanted the world to

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know that wasn't true.

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And the allegations and show [sic] of using steroids

And those

He does the "60 Minutes" interview.

Two or three

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days before the "60 Minute" interview, his representatives

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are informed that Congress, the House Oversight Committee,

the same committee that had asked for the Mitchell Report to

be done and had the hearings in 2005 was going to issue an

invitation to come testify.

Then the "60 Minutes" interview runs.

That should

have put it to bed; right?

still criticized for not taking live questions from various

members of the media.

a tape of Mr. McNamee and he having a conversation in which

he's urging Mr. McNamee just to come forward and tell the

The evidence will be he was

He has a press conference.

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truth.

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leaves before it's over.

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No.

He gets upset during the interview and ultimately

Everybody says if somebody didn't do something and

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you get charged with it, I'd sue.

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the eve of the "60 Minutes" show for slander.

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He plays

He sued Mr. McNamee on

In January, his representatives visit with the

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Congressional staff, with Mr. Barnett, who's going to be the

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first Government witness, urging them not to call Roger

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Clemens as a witness.

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Nobody had ever seen a good witness before Congress, if

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Congress is after them, it doesn't work.

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Nothing would be gained by it.

The invitation stood, and the request not to call

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him was denied.

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Clemens refuse to come forward and make him do what they did

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in 2005, which was to subpoena all those players.

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the evidence will be uncontradicted from Mr. Barnett, that

And so then the issue is, does Roger

And then

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if you decline to come testify before Congress, they can

issue a subpoena.

everybody, the evidence will be, knew that's what they would

do.

And the history was they had in 2005, and

And once Congress issues you a subpoena, you have

only two choices.

you'll be in contempt of Congress.

you can avoid not having to testify is do you take the Fifth

and say, "Exercise my Constitutional rights and I'm not

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You have to respond to a subpoena or


And then the only way

going to testify," or you testify under oath.

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So Roger Clemens did not require a subpoena that

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he knew would come if he didn't do it.

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the assumptions of the world is you did it.

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he testifies in two ways before Congress.

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here.

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He'd take the Fifth,


And so he does,
That's how we get

But let it not be ever forgotten, the evidence is

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going to show, he didn't want to.

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world to know he did not know what he'd been -- do what he

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had been accused of.

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He just simply wanted the

So, then we end up with the tale of two men.

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the tale of two men is Roger Clemens and Brian McNamee.

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There is a hearing.

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you'll hear excerpts when he testifies where he may be

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questioned about some things he said.

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And

Mr. McNamee gives his deposition,

Mr. Clemens gives his deposition.

You'll hear the

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Government introduce things from that deposition.

in their first count 15 obstructive acts, they say, that Mr.

Clemens did to obstruct Congress.

obstructive acts occurred during the deposition before the

next week when he appeared publicly.

look and try to match up the evidence with what they contend

were obstructive acts.

They have

My memory is 11 of those

But you'll hear and

It is always going to be about the fact of that

Roger Clemens from day one has dared to say, I did not do

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it, and that's what he's being prosecuted for.

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being prosecuted for using.

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saying he didn't.

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said it with every breath he's had for the last four years.

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He's not

He's being prosecuted for

And he didn't just say it at Congress, he

So who are these guys?

How did we get here and

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their relationship?

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Yankees.

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mother that had five children first, and then another child

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in the second marriage.

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Well, here's Roger and the New York

Here now, he's born in 1982 [sic] in Ohio to a

He basically grows up around women because he

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didn't really have a relationship with his natural father,

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and his stepfather that he loved dearly died when he was

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like ten.

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This guy, I always want to say this in public

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where he can't do anything to me for it, but this guy was a

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pudgy tall kid.

This guy is, the evidence is going to show,

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was an achiever unbelievably, and he made himself that way,

not Brian McNamee.

that happened.

And the evidence will tell in detail how

Next guy, the other guy in these two guys, that's

Brian McNamee.

on your screens in front of you.

in 2010 when he testified before the Grand Jury.

testified before the Grand Jury with that blue tie is

advertising a company's product that he is hawking then and

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Brian McNamee here in this picture, and it's


That's the way he appeared
And he

now.

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He actually knew the cameras, the evidence will

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be, he knew the media was going to be all over it.

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up for the Grand Jury for the media advertising a private

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business of his that -- involvement he had, that nobody

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would have cared about except for the notoriety he

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accomplished by being the man who supposedly brought down

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Roger Clemens.

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What is Roger Clemens's career?

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through this just very quickly.

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testimony first go?

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do this.

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He shows

And I want to go

Where did -- where did this

Before we do the career station, let's

The Government shows you a picture -- the

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Government showed you a picture of him testifying.

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is the atmosphere that occurred when he appeared before

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Congress.

But this

That is the venue that all this occurred in.

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Next.

Now, I want you to look, please, you've got

it on your screen.

steroids or that much about it.

Clemens and steroids, the evidence will be, I noticed in the

opening statement, let me back up, Mr. Durham has backed

away kind of from the suggestion that he bulked up and

everything and made himself bigger and stronger.

Because look at this photograph.

Most of you probably haven't heard about

MR. DURHAM:
THE COURT:

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[Bench conference.]

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THE COURT:

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MR. DURHAM:

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And why?

These are the four --

I object, Your Honor.

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This is the career of Roger

Approach.

Were these cleared before?


Sure.

The pictures were, but there's

no foundation for what the inference, which is -MS. SALESKI:

The objection, Your Honor, is to

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statements like this:

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premise that Mr. Clemens -- this case is not about what Mr.

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Durham had said either in opening statement or before.

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Hardin wants to address what the Government intends to

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present all its evidence, that's fine.

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about whether --

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THE COURT:

Mr. Durham has backed away from the

Mr.

But this is not

When did Mr. Durham say that he was

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using steroids to bulk up?

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in his opening statement here yesterday.

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of them may bulk up, some don't, some do different things.

I don't recall him saying that


He said that some

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So as far as I know, he's never said that.

MR. HARDIN:

No, it's true that -- well, it's true

that he's never said it before this jury, that's certainly

right.

is going to be that originally Roger Clemens's body changed,

and that was said before Congress.

Congressional Report.

longer --

But the entire -- my intention was is the evidence

THE COURT:

That was said in the

And the Government's clearly no

Is there going to be any evidence in

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this case that he was using steroids for the purpose of

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bulking up?

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the past has in some way indicated he was using them to bulk

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up, and there's no evidence from what I understand that he

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said that.

Your statements suggested that Mr. Durham in

That needs to be corrected.

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MR. HARDIN:

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[Open court.]

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MR. HARDIN:

Fair enough.

Thank you.

Let me try to make something clear.

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The Government's point is very valid.

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suggest that Mr. Durham has first said that he bulked up and

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then has changed it.

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evidence is going to be is that originally when these

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allegations came out publicly, the suggestion was is that

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Roger Clemens's body had changed.

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issue before Congress.

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the outward indicia of steroids?

I don't mean to

What I mean to say to you is the

And that was really a big

Did he -- did his body show any of


Namely acne, namely body

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mass changing, a bigger head, different changes in the way

the person looked.

characteristics of steroids that initially when all these

allegations were, the problem with it is in trying to prove

somebody a negative, that Roger Clemens did not do

something, these pictures clearly show this man's body,

other than the aging process, doesn't outwardly change.

the evidence shows that what -- the ball keeps changing on

us with this entire area because of this.

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There are a lot of common

And

There are masseuses that we, the evidence is going

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to show, from 1986 forward, and when a time he was in

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Boston, he will say that his body never changed during the

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time he was in Boston for 13 years.

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outward characteristics of anybody using steroids.

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That he had none of the

Medical evidence is going to be there's no medical

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evidence that he ever used steroids.

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would expect to find present in the medical records of

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somebody that had used steroids over several years the way

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that Mr. McNamee contends, there are things there that you

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would expect that you don't find.

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The things that you

So, I take it from the opening statement of the

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Government that now its contention is, or their contention

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is that Roger Clemens took steroids to loosen up his joints

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and stuff like, and to recover more quickly from injuries.

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That's what I heard Mr. Durham say.

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Well, there's never going to be any physical

evidence in this case from any source except Brian McNamee

suggesting in any way that Roger Clemens used steroids.

None.

Pettitte's testimony.

directed to one small thing by Government, I think, and that

is his memory, he believes that Roger Clemens back in '99 or

2000 told him one time in a casual workout he used HGH.

They mentioned Andy Pettitte.

We welcome Andy

Andy Pettitte's testimony will be

I'm not going to get into what Andy Pettitte's

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testimony is and all.

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later.

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Durham indicated, we're never going to be saying anything

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bad about Andy Pettitte.

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Mr. Attanasio will deal with that

I would just tell you this.

There are still friends.

Contrary to what Mr.

They haven't been able

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to have any contact because of this case, but they are still

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friends.

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stand and tell the truth as he believes it and as he knows

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it.

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And we believe that Andy Pettitte will take the

And we think at the end of the day Andy Pettitte's

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testimony will be some of the most convincing of all as to

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why Roger Clemens did not take steroids, or HGH at the end

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of the day.

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to ever be bad mouthing him, and we believe he will tell

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what he believes is the truth.

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who's right and who's wrong and what's correct and so on.

So we welcome Andy Pettitte.

We're not going

And then you can decide

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Let's go through quickly his career.

I want --

and the reason I'm going to put this up, his career.

born in '82[sic], he goes to high school in Texas.

family moves to Texas.

high school.

McNamee.

you here and then go on to some other points is, this --

this case -- I want you to see what he accomplished before

he ever met Brian McNamee.

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He's
His

He's the number three starter in his

He wasn't a guy, this is all before Brian

What I'm going to run through real quickly with

If you look at San Jac [sic] College here, you'll

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see a sort of -- a very sort of stern looking man who's in a

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Rice jacket, name's Wayne Graham.

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Clemens was the hardest working athlete he ever saw.

He'll testify that Roger

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When Roger Clemens graduated from high school, he

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wasn't good enough to get a college scholarship, and he got

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on with the San Jacinto Junior College.

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junior college to get play baseball, hoping that he'll do

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well enough to get the attention of a college.

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So he goes to a

High school teammates of Roger Clemens will say

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his work habits were the most amazing they'd ever seen.

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Wayne Graham will say he had the greatest work ethic of any

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athlete he ever met, and Wayne Graham is in his late

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seventies now, and has been coaching for almost 50 years.

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Never ever seen an athlete who made himself into something

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the way Roger Clemens did.

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High school teammates will say that when they were

out doing things that other kids do at the age of sixteen or

seventeen, they would see the ballpark lights on.

they'd drive over there at 10:30 or 9:30 on a Friday night

just to find out who in the world and what is somebody

doing.

weights on his hands, weights on his ankles, and he is

running from foul pole to foul pole at 9:30 at seventeen

years of age to make himself into the ballplayer he dreamed

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And

Roger Clemens is over there with a plastic bag with

of being.

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And he was so successful.


Oh, by the way, Wayne Graham will say that when he

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was working on the mound and doing -- after everybody is

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gone, he looked out in the outfield there, when this guy was

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a kid, and he is going from foul -- he's figured out this

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routine.

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here, he's a big guy, he's trying to get himself in shape,

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and he wants to be able to move laterally back and forth, so

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he has golf balls there.

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side to side picking up golf balls, they're sweeping them

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down, sweeping them down, just like you do a grounder, just

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like you move as a ballplayer.

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Not Brian McNamee's routine.

He's got golf balls

And he's running side to side to

That continues on, and he goes to the University

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of Texas.

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junior year that they win the national championship, and

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he's drafted in 1983.

At the University of Texas they do so well in his

He's drafted at nineteen by the

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Boston Red Sox.

plays in the minors only less than a year before 1984, he

goes up to the big leagues.

He's with the Boston Red Sox from '83, he

For those of you who are not a baseball fan, it

may not seem much much.

any profession you want to pick, pick it, and think of the

achievers in that profession.

only thing he ever wanted to do was be a baseball player,

and be the best he could.

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Just pick, the evidence will be,

That's who this guy was, the

So at Boston, he takes the town by storm.

He goes

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up in '84 halfway through the season.

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shoulder injury and has surgery in August.

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first full season that he plays for the Boston Red Sox.

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has a season that anybody would just die for if you cared

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about baseball.

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In '85, he gets a
So 1986 is the
He

In 1986, he wins the Cy Young award the first

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time.

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of Major League Baseball for that year.

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unbelievable year, and he's twenty-four years old.

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It is the award given to the premier pitcher in all


He has an

In 1987, he wins the Cy Young award again at

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Boston.

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In 1996, he gets to the year -- his statistics weren't as

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good, his strike-out record and everything were incredible.

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He's now thirty-four years old.

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wants to go four more years in Boston and he's going to

And then in 1991, he wins it again, three times.

His contract expired.

He

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retire at thirty-eight or thirty-nine.

in Boston decides he's not giving any -- said I'm not giving

any thirty-four-year-old guy a four year contract.

Clemens, he's in the twilight of his career was the famous

quote in sports pages, and so Roger Clemens signs with

Toronto.

The general manager

So Roger

He goes to Toronto in 1997, a year before he meets

Brian McNamee.

fourth time.

He wins the Cy Young award again for the


Brian McNamee comes there in '98 as a strength

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and conditioning coach.

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Brian McNamee?

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conditioning coach.

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routine.

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Toronto, he would have had one of the most incredible

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careers in the history of baseball already.

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They say why this attraction to

Two things.

Brian McNamee was a good

But Roger Clemens already had his

If he had retired in 1996 and never gone to

In 1997, he has this unbelieve year in Toronto

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before he meets Brian McNamee, again wins the Cy Young, four

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of them.

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In 1998, after he and Brian McNamee start working

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out, the attraction to Brian McNamee to him was he is a

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two-fer.

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doesn't just help work Roger out and drive him.

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us, Mike Attanasio has a lot of self-driven discipline

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himself about working out.

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For those of you who don't care about baseball, he


A lot of

Others of us, it may be generational, we need

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somebody sometimes to help push us for the things we already

know how to do and we do regularly,but we just aren't quite

as intense about them as we would be necessarily.

push us further, and that was part of it.

thing of Brian McNamee.

a picture.

Or they

That was one

And he was good for that.

The second thing was he was a catcher.

You saw

He played

as a catcher in college.

could get somebody to help him work out and somebody that he

And he knew how to catch, so Roger

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could also pitch to.

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in during the off season.

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relationship.

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He didn't have to bring somebody else


So they did have this

Brian McNamee's version of the testimony's going

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to be that sometime around June in 2008 -- in 2000 -- excuse

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me.

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Prolong his career.

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Young the year before.

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before.

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not true.

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In 1998, Roger tells him he wants to use steroids to


Prolong his career?

He just won the Cy

He had an incredible year the year

The evidence is going to be it's not true.

It's

But that's what Brian McNamee says.


And then Roger goes on.

Now, I want to do if I

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can, these blue marks here, look at these.

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what Roger Clemens's career, the only little telegraphs, the

23

only time, these blue marks are the only time Brian McNamee

24

claims he gave Roger Clemens steroids in the entire 24-year

25

career, only these periods here.

This tells you

22

These are taken from Brian McNamee's previous

testimony that I would anticipate he'll say there on the

stand, too.

together in '99.

there.

Roger Clemens decided he wanted to use steroids in 2000 when

Brian McNamee came back to the Yankees.

period here, he says he gave them.

This little period in '98, then they weren't


Roger went to the Yankees and was pitching

Then according to Brian McNamee, he'll say that

And so this little

He'll say, if he's consistent with the past, he'll

10

say he always gave Roger steroids around August, July or

11

August each year when Roger was getting tired, and then

12

Roger would usually quit taking them in August.

13

And then he has the year 2001.

The evidence will

14

be irrefutable, Brian McNamee has said in a bunch of forums

15

he never gave Roger Clemens steroids after August of 2001,

16

he never talked to Roger Clemens about steroids after 2001.

17

None of that happened, according to Brian McNamee.

18

After that, they stayed working together for

19

another six years, and according to Brian McNamee's past

20

testimony for always it will be, we never talked about it

21

again, I never gave them to him again.

22

So the evidence that you'll be asked to calculate

23

and look at is, what was Roger Clemens like before Brian

24

McNamee?

What was Roger Clemens like after he met Brian

25

McNamee?

And what was he like in his career after Brian

23

McNamee says, I never gave him any steroids or HGH

afterwards?

Well, it's the same.

His career stays the same.

In 2001, Roger Clemens is with the New York Yankees from

1999 to 2003.

his hometown talks him into coming out of retirement, and he

pitches in Houston for three years with his friend Andy

Pettitte.

In 2004, he retires in 2003 from the Yankees,

In 2004, Roger Clemens wins his seventh Cy Young

10

award in Houston.

11

the last time he ever gave or talked to Roger Clemens about

12

steroids.

13

Three years after Brian McNamee says is

From the beginning the question will be always,

14

from the evidence, if Roger Clemens supposedly took steroids

15

to prolong his career, why in the world would he stop the

16

last six years of that career?

17

one single evidence on God's green earth from anybody that

18

Roger Clemens ever took steroids or HGH after 2001.

19

from 1998 to 2001, the only person that will say that in the

20

evidence is Brian McNamee.

21

Because there will not be

So who is Brian McNamee?

And

Well, if I can have ten,

22

please.

23

first picture.

24

celebrity.

25

He goes on the Howard Stern show about a year after his

This is Brian McNamee now, and you saw him in the


This is Brian McNamee in his newfound

This is Brian McNamee on the Howard Stern show.

24

testimony before Congress loving, loving the celebrity

nature he has now, in an interview that lasts quite a long

time in which he talks about looking for -- believing Roger

will end up in a yellow jump shirt.

MR. DURHAM:

Objection to the hearsay, Your Honor.

MR. HARDIN:

I believe Mr. McNamee is going to

have to testify he said that.

THE COURT:

[Bench conference.]

10

Approach.

MR. DURHAM:

The objection, Your Honor, is that

11

it's hearsay.

12

presumably never used for impeachment, but certainly is not

13

admissible within the context of an opening statement.

14

It's on out-of-court statement by Mr. McNamee

MR. HARDIN:

It's just not hearsay, it's not

15

offered for the truth of the matter, it's offered to show

16

bias on the part of --

17

THE COURT:

18

[Open court.]

19

THE COURT:

20

MR. HARDIN:

Overruled.

The objection's overruled.


In this long-ranging interview where

21

he laughs and giggles with Howard Stern, he talks about how

22

Roger Clemens is going to end up in a yellow jumpsuit. Only

23

Mr. McNamee will be able to tell us whether he was paid for

24

this appearance or not.

25

celebrity nature.

But he's certainly enjoying the

25

What else is he doing during that period of time?

Well, here he is with Mai Tran.

company that he is -- and remember, the evidence is going to

be no one knew who Brian McNamee was before he made this big

splash with his allegations against Mr. Clemens.

him appearing on You Tube.

her interviewing him about his career and his ideas about

nutrition.

these allegations about Roger Clemens.

10

And this is a woman in the

This is

There will be interviews with

Nobody cared about any of that until he made

He has been making money off of his celebrity

11

nature, culminating with the next one.

12

"Death, Taxes and MAC."

13

book.

14

for this book before he made these allegations about Roger

15

Clemens.

16

the market, you'll find that it was going to be published in

17

December of 2009, but the furor, I think, we'll be able to

18

find Mr. McNamee, the decision not to publish it as yet is

19

probably going to be based on waiting until this case was

20

over.

21

What does he do?

Brian McNamee decides he'll print a

That is -- there certainly would have been no market

It hasn't been published yet.

It was announced in

He talks in all in this book about Roger, he talks

22

about everything else.

23

he hadn't made these allegations about Roger Clemens?

24

can judge for yourself.

25

sprung on the national scene making these allegations.

Is there any market for that book if


You

All of this has happened since he

26

He was asked before Congress, and I anticipate Mr.

McNamee will acknowledge this in his testimony.

asked by a Congresswoman from North Carolina, "Mr. McNamee,

are you going to publish a -- write a book about your

experience?

"No.

"Do you have any plans to write a book

about this?

"No."

10
11

He was

Howard Stern:

"Mr. McNamee, are you

going to write a book?

12

"I don't know."

13

That's like in March of 2009 as I recall.

14

December '09, this unpublished manuscript which is waiting

15

to be published.

16

Now, this guy the Government, I'm going to tell

17

you -- let me say this as nicely as I can.

18

Durham told you in a lot of different instances is half the

19

story.

20

Government that they want you to look at and listen to.

21

in many, many ways it is only half the story.

22

Much of what Mr.

It's the story from the perspective of the

He put up a neat picture of materials that Mr.

23

McNamee produced as evidence against Mr. Clemens.

24

show you what it looked like when it was delivered.

25

Let me

According to Mr. McNamee, in 2001 he started

But

27

distrusting somehow Roger Clemens, and he decided to start

collecting stuff.

did all of this and preserved it from 2001 until he produced

it in January of 2008 to his own lawyer is in this beer can

he says that he had a bunch of stuff, that he had needle and

gauze.

three neat little packs were actually stuffed in this can

and aren't on this picture.

around in there that is supposedly going to tell everybody

10
11

And so the very scientific way that he

The gauze they told you about that they had in these

This is other trash he had

about Roger.
This needle had some of Roger's DNA on it, but the

12

sample was so slight and so small that they won't tell you

13

the percentage is as high as they usually do, but they'll

14

say they believe it -- believe it is Roger's DNA.

15

not going to challenge that.

16

And we're

This that he says, has testified several times,

17

this gauze over here, he's testified several times had

18

Roger's DNA.

19

Mr. McNamee's DNA.

20

Well, it does have DNA, but it turns out to be

By the way, he says all this stuff was kept in a

21

box in his basement of his house.

And it moved from

22

different locations in the house.

And it had other stuff in

23

there, the next picture, all of these actors and everything,

24

these are all -- these contain steroids and all.

25

gathered up that stuff.

He says he

Well, look at these surfaces, and

28

guess what?

on all this stuff that he says he got from Roger Clemens,

not one single fingerprint on that or anything else of Roger

Clemens.

When the FBI is asked to check for fingerprints

Next, this is a picture of Mr. Richard Emery that

I assume will be a witness for the Government because

somebody's got to establish the chain of custody on all this

stuff.

Government, he took it to his lawyer, Mr. Emery, who was

Because Mr. McNamee didn't take this stuff to the

10

shepherding him and helping him and representing him since

11

the Mitchell Report came out.

12

And this is the lawyer as he has a press

13

conference after the hearing showing the two photographs,

14

because those two photographs I showed you, those were not

15

law enforcement photographs, that was somebody working in

16

Mr. Emery's office photographs as they gathered and split up

17

this evidence as they thought it ought to be.

18

enforcement.

19

Clemens for a case presently pending in New York Court for

20

$10 million.

21

Still no law

And is this is the lawyer that has sued Mr.

Mr. McNamee wants $10 million, get this, saying

22

that Roger Clemens owes him $10 million because Roger

23

Clemens denied that he got illegal dope from McNamee.

24

other words, somebody is suing Mr. Clemens for $10 million

25

for claiming that he nor the sewer didn't commit a crime.

In

29

Roger Clemens is saying, you didn't give me any

dope.

a dope dealer, and because you say I'm not a dope dealer to

you, I'm suing for $10 million.

Next picture, please.

Now, this is after law enforcement gets it.

I didn't take it.

Mr. McNamee says, yes, I did.

I'm

That's who these --

This

is a picture taken after Mr. Novitzky lays out, and these

things in this picture are the different things that were in

the can.

They open up the beer can and they spread it out.

10

This needle had two steroids -- two different types of

11

steroids in it.

12

This was in blue.

Over here, these needles, none of these have Mr.

13

Clemens's DNA or have any connection to Mr. Clemens.

14

these, I'm not sure which, is the same ones that they showed

15

you, have Mr. Clemens's DNA and steroids on there.

16

here's something that the evidence will make irrefutably

17

clear.

18

call the expert that they retained to Mr. Catlin.

19

Mr. Catlin because if they don't, we are.

20

Catlin just a month or two ago tells the Government, yeah,

21

it wouldn't be hard to have B-12 in a needle --

And

It is not clear to use whether they are going to

22

MR. DURHAM:

23

[Bench conference.]

24

MS. SALESKI:

25

Two of

I want to object.

Because Mr.

May we approach?

Your Honor, what Mr. Hardin is about

to say is a hearsay statement, what Dr. Catlin told the

30

Government is a hearsay statement.

to say that we expect to call this witness and he will

testify as follows, that's fine.

MR. HARDIN:

[Open court.]

MR. HARDIN:

If Mr. Hardin would like

I expect to say that.

I expect Mr. Catlin to say that it

would be very easy to take a needle that had B-12 in it and

get the B-12 out of the needle and put it the steroid.

scientific tests would not find the B-12.

10
11

And

And that is the

Government's expert.
And he will say further, I would anticipate,

12

because we will call him if they don't, he will say further

13

it wouldn't require any high level of sophistication to be

14

able to manipulate the evidence that way.

15

And the evidence is always going to be from our

16

side of this courtroom that what this man did, Mr. McNamee,

17

is manipulate that evidence.

18

could be done through the expert into which you can very

19

easily take the needle and create somebody's DNA that you

20

have on a gauze from blood for any kind of needle and mix

21

them together as to whether that person's DNA and the

22

steroid would be together without the needle ever having

23

been injected into that person.

24

evidence will be.

25

And we'll show you how it

Simple, simple, simple, the

And we contend that's what happened.

So, Mr. McNamee has this evidence.

He has it in

31

his basement or his house, his basement, he wasn't living

there consecutively.

Now, what I want to do with you is, I want to talk

about this half story for a minute.

to you about and ask you as the jury to keep -- I certainly

endorse what Mr. Durham said.

open mind.

8
9

Because I want to talk

And that is, is that keep an

Let's do first what the case we thought was about.


Let's do number 17, please.

10

This is what the case should be about.

Act number

11

one.

12

statement talked to you about things that he hopes you will

13

do and your common sense and your burden and everything.

14

want you to understand what's happened with this indictment

15

and what evidence is supposed to be directed at.

16

Now, Mr. Durham toward the end of his opening

Their first charge is obstruction of Congress.

17

And they allege 15 different ways they say he obstructed.

18

Only four of those ways we contend have anything to do with

19

what this case should be about.

20
21

Act one, "Have you ever used human


growth hormone?

22

"Never."

23

Act four, "Let me be clear, I have never

24
25

taken HGH."
Act five, "I never used steroids, never

32

1
2
3

performance-enhancing steroids."
Number six, "Let me be clear, I have
never taken steroids."

That's what this case is supposed to be about.

And if you believe from the evidence beyond a reasonable

doubt that he intentionally lied, knowing it was a lie at

the time he said that about these matters, and that he did

it with the intent to mislead Congress in a lawful discharge

of their responsibilities and obligations, then you're

10
11

supposed to vote guilty.


But here's what the Government, I suggest to you,

12

is really trying to create here.

13

obstructive acts.

14

about as far as keeping your eye on the ball.

15

Look at the rest of the

And here's what I want to talk to you

Mr. Durham told you that they are entitled to

16

conviction if they convince you unanimously beyond a

17

reasonable doubt of any one of these obstructive acts.

18

look at the kind of things that they want you to decide.

19

"Did you ever speak with Mr. McNamee

20

about growth hormone?

21

"I have not."

22

That's an obstructive act, they say.

23

"And did you on your own do any research

24
25

about human growth hormone?


"No, I haven't, I've researched it.

So

33

couldn't tell you the first thing about it."

What in the world does that have to do with

anything?

that, let's go to the half whorl.

please.

We should be back at those four.

All right.

But having said

Go down to act 15,

This is a -- "And couldn't

you have been at Jos Canseco's house during

the time period of June 8th to 10th, 1998?"

Remember the Government showed you a picture of

10

the boy and Roger Clemens in the pool?

11

clear why they think that's significant.

12

premier example of half the story.

13

you put it up in 19, please.

14
15
16

I'm not sure it was


But here is the

Here's number 15 if will

Government's alleged act of obstruction number 15.


Take this as an example.
"Question:

And could you have been at

17

Jos Canseco's house during this time period,

18

June 8th, 10th, 1998?

19

"No."

20

Now, what does that have to do with anything?

21

Well, let's now look at what the full exchange before the

22

Congressional questioner was.

23

be Mr. Barnett.

24

[Videotape played.]

25

MR. HARDIN:

And, in fact, it's going to

I want y'all to listen to Mr.

34

Clemens's voice.

deposition we also have the audio, you know, we're going to

have the TV thing that the Government wants to play excerpts

from his testimony live in front of Congress, but in the

week before in his deposition, there was an audio taken for

the court reporter just like this.

One of the advantages here, in the

And so what we asked for was the audio so you can

listen to Mr. Clemens's voice as he answers these questions,

which will be true for anything said in the deposition.

And

10

what we've done here is we've put together the audio with

11

just like when you're looking on the airlines when you're

12

listening to the reporter to see what happened that we put

13

below the writing.

So now let's do that, please.

14

[Audio played.]

15

MR. HARDIN:

16

Now, what I want you to look at, the exchange is,

Stop.

Thank you.

17

it is only after what you just heard where Roger Clemens was

18

telling them, "I could have been by there after a golf

19

outing, but I wasn't at the party."

20

What the significance of the party is as far as

21

the Government is concerned is you'll find out from Mr.

22

McNamee that supposedly at this party on June 9th of 1998,

23

Jos has a party, he's a teammate of Mr. Rogers [sic].

24

Canseco is a notorious user of steroids by his own

25

admission, he's written books about it and everything.

Jos

And

35

so the Government wanted to tie Roger Clemens to

Mr. Canseco.

And McNamee contended that at this party he saw

Roger Clemens, Jos and some other mysterious guy is what's

in the Mitchell Report, talking, and then -- then Mr.

McNamee is going to say it's several days after that meeting

that Roger comes to me for the first time about steroid.

And so Mr. McNamee in his previous testimony, I don't know

what he's going to say now, has always tried to tie those

10

events together.

11

So the Government wanted to show that Roger

12

Clemens, Jos Canseco and another man met at this pool party

13

given for the Toronto Bluejays.

14

young boy we were shown a minute [sic], according to the

15

Government, were supposedly taken to show that Roger was at

16

the party.

17

And the picture of the

Roger Clemens has always testified, "I played golf

18

that morning.

19

after the team left on its bus, but I wasn't at any party

20

there."

21

I wasn't at the party.

I may have come by

And that's what he's saying in this exchange.


And as you can clearly hear what we're playing,

22

before he says he was never at Jos Canseco's house between

23

the 8th and the 10th, he had earlier in the same exchange

24

said, "I might have gone by there then, but only after I

25

played golf."

36

The significance is, without telling you too much

about this, the evidence is going to be is, the bus taking

the players back for the game that night to the stadium left

at two.

two o'clock bus.

Mr. McNamee's always testified he left on that

So if the conversation take places after

two o'clock, Mr. McNamee could not have seen what he first

told the Mitchell Commission and then Congress he saw.

what is the half story?

So

Well, the half story is that Roger

10

Clemens, we produced to them, and you will hear about,

11

whether you hear or not, a baseball broadcast that day in

12

which two baseball announcers are going to come in and

13

say --

14
15

MR. DURHAM:

Objection, Your Honor's, this is

hearsay.

16

THE COURT:

17

[Bench conference.]

18

MS. SALESKI:

Approach.

Your Honor, this is exactly what the

19

Court said Mr. Hardin couldn't do with respect to these

20

baseball announcers.

21

statements.

22

He can't talk about their out-of-court

MR. HARDIN:

I said they're going to come in and

23

testify, I was stopped.

24

record, I say these two baseball announcers are going to

25

come in and testify to that, and that's when I was stopped.

I think if you go back to the

37

And they are.

2
3

THE COURT:

during the broadcast, though, can they?

4
5

But you can't say what they said

MR. HARDIN:

Probably not, but they can say what

they saw, and this is what I was about to say.

MS. SALESKI:

Your Honor, Mr. Hardin keeps

referring to Brian McNamee's prior testimony, and that's

also the subject of the Court's earlier ruling that Mr.

Hardin is perfectly able to say that he expects witnesses to

10

testify a certain way.

11

prior testimony because those are out-of-court statements.

12

THE COURT:

13

MR. HARDIN:

14

a difference.

15

the testimony to be.

16

before, he will say X.

But he's not supposed to refer to

Any response?
I think it's the distinction without

I'm trying to say is this is what I expect


If he testifies the way he testified
If he testifies differently, I --

17

THE COURT:

18

MR. HARDIN:

19

[Open court.]

20

THE COURT:

Phrase it that way.


Thank you.

I'll sustain the objection to the last

21

statement regarding these announcers.

22

statement.

23

MR. HARDIN:

Rephrase the

These announcers were announcing a

24

baseball game, and they will come in and tell you that one

25

of them played golf that day, the day at issue, June 9th,

38

1998, and they saw Roger Clemens playing golf that day at

the golf course during the time that the party was going on.

And during the party Roger Clemens -- let me back

up.

in this exchange to Congress.

after the party, but I wasn't at the party, I played golf

that day."

8
9

So that's what Roger Clemens's evidence will be, says


"I might have been by there

So then you have this picture that the Government


has broadcast.

And the evidence will be from the

10

Government's own witnesses, this picture doesn't show any of

11

the ballplayers.

12

Government's represented that this young man may come in as

13

a live witness and say, I was at -- I was at the party that

14

day, and Roger Clemens came by.

15

It doesn't show anybody at the party.

The

So the Government decides, hey, if the key time is

16

two o'clock and Brian McNamee is gone after two o'clock,

17

let's see if we can look at some digital enhancement and see

18

when this picture was taken.

19

out there now, maybe we can find out exactly what time of

20

day this picture was made.

21

It's a pretty wonderful world

So they go to their digital people in March of

22

this year to see if they can narrow it down.

23

And guess what they find out?

24

to testify or we'll call them if they don't, it looks like

25

this picture was made sometime shortly before or after three

And they do.

Their own experts are going

39

o'clock.

By the way, they do shadows and everything.


That's half a story.

That's half a story that

they told you.

for this kind of thing to be in there.

And the other half clearly shows it's insane

Let me tell you what one of the -- the evidence is

going to show.

resolved all along has been the one I mentioned to you

before.

Brian McNamee, where's the evidence that he did it after

One of the most glaring issues to be

If Roger Clemens truly took steroids and HGH from

10

2001 when you would think there would be an even bigger need

11

for it if it was to prolong his career?

12

You're going to see from this evidence that there

13

are several things totally inconsistent with what you would

14

expect of steroid use.

15

improve his career.

16

didn't go from hitting 20 home runs to hitting 50 home runs.

17

He maintained his performance consistently for 24 years, so

18

that he wins a Cy Young, his first Cy Young award is in

19

1986, and his seventh Cy Young award is in 2004.

20

Number one is Roger Clemens didn't

He didn't change his performance.

He

Neither one of those are doing a period where

21

Brian McNamee had anything to do according to Brian McNamee

22

with giving him steroids or anything else.

23

that he's able to perform those last six years the way he

24

did without steroids or HGH?

25

like bulb goes off for the Government, we've got to find

So how is it

So the evidence will be, a

40

1
2

corroboration for Brian McNamee.


Because otherwise how do we explain this?

Because

one other thing I didn't mention.

anonymously first in 2003 for these drugs.

testing before.

evidence is going to be that Roger Clemens tested negative

for steroids in May of 2003 the first time it was done and

from then on.

Baseball started testing


They weren't

And then consecutively from 2004 on.

The

So now you hear the Government contending he used

10

steroids, but from the time testing began in 2003 forward,

11

Roger Clemens always tested negative.

12

tested negative whose body doesn't show any of the outward

13

signs of using steroids, whose medical records show no signs

14

of somebody having used steroids, who nobody contends used

15

steroids except Brian McNamee.

16

better find some corroboration.

So you have a guy who

So what we better do is, we

17

So what do we do?

18

Now, let's look at this.

Exhibit 24.
This is the use of

19

Government attempts to find corroboration for what Brian

20

McNamee says.

21

phone or in person all over the country and some phone calls

22

outside the country.

23

interviews they did.

24
25

These are interviews conducted either by

This is the use of resources and

And keep in mind, I'm not talking about this point


of waste of government resources, that's not my issue.

My

41

issue is this:

people, to show that this guy was using steroids after 2001.

And not one single piece of evidence was developed

from that that would indicate anything other than what Brian

McNamee said.

individuals interviewed, 268 interview reports written up

meaning some people were talked to two and three times.

Seventy-nine interview locations.

103 federal law enforcement officers over whether a baseball

10

These are the resources they employed, these

A hundred and eighty-seven witnesses,

One hundred and three,

played used steroids.

11

Eight Assistant U.S. Attorneys have touched this

12

file.

13

the Government has been turned over in a salutary way all

14

their interviews.

15

and notes of FBI agents and others provided to us by the

16

Government.

What's the basis of that, Mr. Hardin?

17

The basis is

Those figures are based on the reports

And my point about this is, this was done seeking

18

to answer that common sense question if a man takes an

19

illegal substance totally contrary to his entire

20

professional career to prolong that career, there must be --

21

there must be somebody out there that will say, I saw him I,

22

I sold it to him, I gave it to him, I was with him when he

23

used it.

24

of effort, they do not turn up one single thing.

25

half the story.

So let's go find him.

And in spite of this kind


That's

42

Another half of the story.

I made some notes

here.

They talked to you about the Radomski mailing steroids to

Mr. Clemens' house; right?

mean, you know, we're sitting over there, we see a couple

jurors, their eyes perked up.

was it was addressed to Brian McNamee, it wasn't addressed

to Roger Clemens.

And I'll see if I can go through these real quickly.

Do you remember that?

Wow.

But what they didn't tell you

That's half the story.

They didn't tell you that Brian McNamee one time

10

ordered HGH, and because he was staying at Roger's and

11

worked out there and came back and forth sometimes, he had

12

it mailed to him there, that's all.

13

Mr. Radomski, if he testifies the way he's always

14

testified before, will say Brian McNamee never told him one

15

single time that he was providing steroids or HGH to Roger

16

Clemens.

17

And by the way, the HGH that they say that

18

Mr. Radomski is going to say was in 2003 mailed to Roger

19

Clemens' house, do you remember Brian McNamee's testimony?

20

His testimony is, is that he never -- he never -- he only

21

gave Roger HGH.

22

before and testified previously, he will say I only gave

23

Roger HGH in the year 2000.

24

should have told you.

25

Roger HGH in 2000.

If he testifies the way he's always said

That's half the story.

They

Brian McNamee has said he only gave

43

So Radomski is mailing HGH to Brian McNamee at

Roger Clemens' house in 2003, wouldn't the other half of the

story be must be for somebody else?

McNamee?

gauze?

Maybe for Brian

Whose DNA was found on samples he kept and the


Brian McNamee's.

Half the story.

He says Roger -- Mr. Durham said Roger had made up

this story of getting shots in spite, yeah.

had this fixation, the evidence will be, about B-12 shots,

that somehow that's a false story.

10

They've always

The evidence is going to be, the other half of

11

this story is, there are going to be people taking the

12

strand that say, whether they call them or we call them,

13

that B-12 shots were regularly given to ball players on

14

three of these four teams.

15

others didn't believe B-12 shots did that much good.

That the Astros doctors and

16

But there will be ballplayers, and interestingly

17

some of them will, there will be ballplayers who will say,

18

now, we got B-12 shots for the Red Sox.

19

for the Yankees.

20

mean, trainers?

21

people who saw or got trainers -- got B-12 shots from

22

trainers.

23

We got B-12 shots

And yes, can managers legally do it -- I


Maybe not, but they did.

There will be

So the half of the story is Mr. Durham's suggested

24

to you that nobody legally could do it.

25

believe that trainers wouldn't periodically give a shot

Okay.

Do we really

44

harmless like B-12 to ball players?

believe it not doesn't matter.

testimony that they did.

they weren't authorized to.

aren't authorized to do it, but they did it.

Well, whether we

There's going to be

So it's half the story to suggest


The first story that they

Let me -- I'm going to look for the note I have

that tells me -- it's really kind of interesting.

back and looked down, you remember that story about Brian

Cashman -- I'm looking for a note I had here.

10

And while

I --

11

By the way, I'm not acting Columbo, I am Columbo,

12

okay.

13

stumble or so, that is not an act.

14

y'all forgiving me.

15

We went

When you see me fishing around for this or you see me


And I'm counting on

What I'm looking for is a note we made here that

16

somehow I have misplaced -- oh, what I liked about it so

17

much was he talks about -- Mike is writing is down again.

18

You remember that scene where Roger is supposed to be so

19

dejected and he's sitting there, and it's a series, I think,

20

in the playoffs in '99.

21

are not together because McNamee is still in Toronto,

22

Roger's gone to the Yankee.

23

Okay.

The year McNamee and Roger

Mr. Durham talks about this -- this dejected down

24

guy got bombed.

25

got to have McNamee.

Okay.

Got bombed in this game, and I've

45

Well, he didn't tell you the other half of the

story.

And then -- thank you, Mike.

it to me.

Roger Clemens the next game has a heck of a game.


Mike is the one who mentioned

All right.
Roger has such a great game, he has -- he has a

bad game against Boston, and then, maybe some of you, none

of you are baseball fans, I think very few of you are, maybe

two or three.

who pitched the winning game in 1999 and had a great game?

10

The Yankees win the World Series, and guess

Roger Clemens.

11

During this time that he is supposedly so dejected

12

in the playoff series that he's got to have McNamee.

13

the half story.

14

to.

15

what they're doing.

16

they are so tragically wrong.

It's

It's the thing that they want to you listen

These people, I have no doubt, in good faith believe in

17

But the evidence is going to be that

But what they and Congress and Mitchell have done

18

is they have taken one perspective and they fit everything

19

into it.

20

didn't do it.

21

And all Roger Clemens has done throughout is say I

They talked about the physical evidence.

Yeah,

22

one thing, a half story.

23

you say you took lidocaine and B-12 if -- I know why you

24

would, says Mr. Durham.

25

what you want to do was have some explanation for all this

Mr. Durham says, well, why would

You might make that story up if

46

garbage.

For all this garbage that Mr. McNamee collected.

Well, the problem with that is, at the time Roger

is telling everybody in the world he didn't do it, and he's

telling Mike Wallace on "60 Minutes" in early January of

2008 that Brian McNamee gave him lidocaine and B-12 shots,

but he never ever gave him HGH or steroids.

Roger is saying that, it is before McNamee has gone to his

lawyer and said, look what I have.

my basement for seven years.

10

At the time

I've been saving it in

By the way, I didn't mention, you're going to find

11

out from the expects that all of this stuff when it's done,

12

it is mixed with ampules that could have poured steroids out

13

of them because the caps are missing.

14

up hodgepodge of garbage you could ever imagine.

15

It is the most mixed

There will be an expert who will testify it is

16

ludicrous, ludicrous to ever try to suggest this is evidence

17

of anything in a criminal case.

18

Clemens, rather, didn't even know that half that stuff had

19

been collected at the time he first starts talking about

20

lidocaine.

21

And Brian McNamee, Roger

Half a story.
The Pettitte conversation real quickly, and I'm

22

about through.

23

if Roger Clemens has claimed that he never had a

24

conversation with Andy Pettitte in the 2005, 2006 period

25

about whether or not Andy had heard Roger say he used --

Another half story.

They make it sound as

47

that Roger used HGH.

Clemens has never denied they had a conversation like that.

His memory has always been that the conversation occurred in

November of 2006 after a mistaken LA Times story came out

about them.

half a story.

The half of the story is, folks, Roger

And that that's when Andy -- about it.

It's

Roger Clemens has never said that conversation

didn't take place.

occur after the 2005 hearings, it came out after the 2006 LA

He's always said my memory is it didn't

10

Times article.

11

the conversation that Andy's talked about.

12

called Andy a liar or saying Andy's doing anything like

13

that.

14

But Roger's always agreed with the gist of

And while I'm at it.

He's never

If we talk about -- we're

15

not going to talk bad about anybody except Brian McNamee.

16

And you decide from the evidence whether we're right about

17

that.

18

fact, Roger Clemens, when he testified before Congress, made

19

it clear that he was not criticizing George Mitchell, he was

20

only criticizing the things the Mitchell Report had based on

21

what Brian McNamee said.

22

Mitchell Report came out based solely on what Brian McNamee

23

said.

24
25

We're not going to talk about George Mitchell.

In

And you will find that the

And finally, in the Brian McNamee matter, and


those of you who have been kind of enough to only subtlety

48

look at your watch and the clock, okay, I am almost through.

And I will tell you this.

he's almost through.

Be careful of a lawyer that says

But I promise you I am almost through.

What I want y'all to keep in mind when you watch

this evidence is his career never changed.

was before Brian McNamee.

McNamee.

It was what it

It was what it was during Brian

It was what it was after Brian McNamee.

You cannot go anywhere with the Government's case

unless you believe beyond a reasonable doubt Brian McNamee.

10

They can talk about corroboration until the cows come home.

11

But there is not going to be any real corroboration of Brian

12

McNamee.

13

And you will look to motive.

The evidence will

14

talk to you about motive.

15

about believability, and you will find from the evidence

16

that as to these matters Brian McNamee has lied to first the

17

Government agents, starting in June of '07.

18

the Mitchell Commission.

19

The evidence will talk to you

He's lied to

He's lied to these prosecutors.

You will find out, for instance, by his own

20

admission he lied to law enforcement in 2001 involved during

21

a criminal investigation of him in Florida.

22

You will find that he told the Mitchell Commission

23

repeatedly in three or four interviews, he told the agents

24

that started the case in two interviews, I have no physical

25

evidence to support anything I'm saying.

49

He was repeatedly asked.

And then in January of

2008, before the hearings, he comes to his lawyer with this

stuff, this garbage.

You will find that every step of the way they or

their representative have had to keep going back to Brian

McNamee and say you're not telling us everything.

is a lie.

convoluted explanation was as to how his DNA ends up on that

evidence, and then you decide whether it makes any sense.

10

How do you explain this?

Or this

You'll hear what his

But this lawyer who is finishing up now begs you,

11

absolutely begs you to watch the evidence and see if, in

12

fact, this case all along has only been about one man's

13

insistence on trying to clear his name.

14

against all public view.

15

the evidence will show, is a thousand times more consistent

16

with not having done it than it is.

17

Against all odds,

Everything Roger Clemens has done,

What lies the evidence will scream out would go to

18

Congress and lie under oath knowing what the consequences

19

could be if he hadn't done it?

20

If he did it, you say he did it.

Andy Pettitte

21

will come in and tell you he did it and he admitted it.

22

That was always the evidence is going to be shown.

23

reasonable logical thing for any intelligent person to do.

24
25

The only

But God help me if we have reached the stage in


this country where we're going to make a federal case out of

50

denying you committed a crime.

to deny it.

what could happen, he said it any way.

crazy man does that?

Congress knew he was going

They called him up anyway.

He knew the result,


What man except a

I shuddered a little bit when Mr. Durham said they

didn't ask for this.

you, but he came to our city.

Let me tell you something, it is not Mr. Durham's Congress.

It's all of our Congress.

He was down there retired.

He said to

And he lied to our Congress.

And our Government should never

10

punish someone for trying to clear his name and our

11

Government should never ever prosecute somebody for saying I

12

did not do it.

13

Hopefully we start prosecuting people for what

14

they did.

15

the country, many of you from here.

16

comfortable that you folks will remember it's all of our

17

country.

18

to be listened to, and he has a right to be allowed to deny

19

allegations that ruin his reputation he spent a career

20

building.

21

We're from Texas.

You're from different parts of


I am totally

And he has a right to his name, and he has a right

This is the first time anybody on Roger Clemens's

22

behalf will have a chance to challenge the allegations.

23

probably comes as no great surprise, but we will not be shy

24

in doing so.

25

Thank you very much.

It

51

1
2
3
4

[Thereupon, other matters were reported,


but not transcribed herein.]
CERTIFICATE
I, Cathryn J. Jones, an Official Court Reporter

for the United States District Court of the District of

Columbia, do hereby certify that I reported, by machine

shorthand, the excerpt of proceedings had and testimony

adduced in the above case.

I further certify that the foregoing 51 pages

10

constitute the official transcript of said proceedings as

11

transcribed from my machine shorthand notes.

12
13

In witness whereof, I have hereto subscribed my


name, this the 25th day of April, 2012.

14
15
16
17
18
19
20
21
22
23
24
25

/s/_____________________________
Cathryn J. Jones, RPR
Official Court Reporter

25th [1] 51/13


268 [1] 41/6

aggressiveness [1] 4/14


aging [1] 15/7
$10 [5] 28/20 28/21 28/22 28/24 29/4
ago [1] 29/20
$10 million [5] 28/20 28/21 28/22 28/24 3
agreed [1] 47/10
333 [1] 2/7
aided [1] 2/15
29/4
airlines [1] 34/11
'
4
all [39] 4/11 4/16 4/17 5/9 5/10 7/23
'07 [1] 48/17
4401 [1] 1/21
9/24 12/12 12/25 13/20 15/3 16/10
'09 [1] 26/14
4th [1] 1/15
16/20 17/5 19/17 25/21 25/24 27/3
'82 [1] 17/3
27/20 27/23 27/24 27/24 28/2 28/7 33/6
5
'83 [1] 19/1
39/7 40/21 41/13 42/12 45/4 45/19
'84 [1] 19/11
50 [2] 17/23 39/16
45/25 46/1 46/11 49/12 49/13 49/14
'85 [1] 19/11
51 [1] 51/9
50/9 50/16
'98 [2] 20/9 22/3
555 [1] 1/15
allegation [1] 5/3
'99 [3] 16/7 22/4 44/20
allegations [13] 5/17 8/12 8/16 8/19
6
14/22 15/4 25/5 25/9 25/14 25/23 25/25
.
60 [6] 8/11 8/23 8/24 9/4 9/14 46/4
50/19 50/22
...............................x [1] 1/8
6521 [1] 2/6
allege [1] 31/17
alleged [1] 33/14
/
7
allowed [1] 50/18
/s [1] 51/17
77010 [1] 1/19
almost [4] 17/23 48/1 48/3 48/3
along [2] 39/7 49/12
0
8
already [4] 5/6 20/12 20/15 21/1
09-223 [1] 1/3
8th [3] 33/8 33/18 35/23
also [4] 2/2 21/10 34/2 37/8
always [18] 5/9 11/8 11/23 22/10 22/20
1
9
23/13 30/15 35/9 35/17 36/4 40/11
103 [1] 41/9
92121 [1] 1/22
42/13 42/21 43/7 47/3 47/8 47/10 49/22
10:30 or [1] 18/4
9:04 [1] 1/7
am [4] 44/11 48/1 48/3 50/15
10th [3] 33/8 33/18 35/23
9:30 [2] 18/4 18/8
amazing [1] 17/20
11 [1] 11/3
9th [2] 34/22 37/25
AMERICA [1] 1/3
12 [13] 29/21 30/7 30/8 30/9 43/8 43/13
ampules [1] 46/12
A
anathema [1] 8/17
43/15 43/18 43/18 43/21 44/1 45/23
A.M [2] 1/7 1/10
Andy [14] 16/4 16/4 16/5 16/9 16/13
46/5
13 [1] 15/13
a/k/a [1] 1/6
16/16 16/19 16/22 23/7 46/24 46/25
13th [4] 5/12 6/4 7/14 7/17
able [7] 16/14 18/17 24/23 25/17 30/14 47/5 47/12 49/20
1401 [1] 1/18
Andy's [2] 47/11 47/12
37/9 39/23
15 [5] 11/2 31/17 33/4 33/12 33/14
about [79]
ankles [1] 18/7
17 [1] 31/9
above [1] 51/8
announced [1] 25/15
19 [1] 33/13
absolutely [1] 49/11
announcers [5] 36/12 36/20 36/24 37/21
1982 [1] 11/16
accomplished [2] 12/16 17/8
37/23
1983 [1] 18/25
according [6] 22/5 22/17 22/19 26/25
announces [1] 8/9
1984 [1] 19/2
announcing [1] 37/23
35/14 39/21
1986 [4] 15/11 19/12 19/16 39/19
accurate [1] 7/7
anonymously [1] 40/4
1987 [1] 19/20
accused [1] 10/19
another [5] 11/17 22/19 35/12 42/1
1991 [1] 19/21
achiever [1] 12/1
46/22
1996 [2] 19/22 20/13
achievers [1] 19/7
answer [2] 7/17 41/18
1997 [2] 20/7 20/16
acknowledge [1] 26/2
answers [1] 34/8
1998 [8] 6/5 20/19 21/15 23/19 33/8
acne [1] 14/25
anticipate [3] 22/2 26/1 30/11
act [8] 31/10 31/20 31/23 31/25 32/22
any [29] 4/10 14/9 14/24 16/1 16/2 16/3
33/18 34/22 38/1
1999 [2] 23/5 45/9
33/4 33/14 44/13
16/15 17/21 19/6 20/2 20/3 23/1 25/8
acting [1] 44/11
25/22 26/7 29/1 29/13 30/13 30/20
2
actors [1] 27/23
32/17 32/23 35/19 37/12 38/10 40/12
acts [5] 11/2 11/4 11/7 32/13 32/17
20 [1] 39/16
48/11 49/9 49/23 50/3
actually [3] 6/24 12/11 27/7
2000 [5] 16/8 21/14 22/6 42/23 42/25
anybody [8] 7/15 8/12 15/14 19/14
address [1] 13/19
20001 [1] 2/7
23/17 38/11 47/15 50/21
2001 [12] 7/24 22/13 22/15 22/16 23/4
addressed [2] 42/7 42/7
anything [14] 5/13 11/24 16/12 28/3
adduced [1] 51/8
23/18 23/19 26/25 27/3 39/10 41/2
31/18 33/3 33/20 34/9 39/21 39/22 41/4
admissible [1] 24/13
48/20
46/17 47/12 48/25
2003 [7] 23/5 23/5 40/4 40/7 40/10 42/18 admission [2] 34/25 48/20
anyway [1] 50/2
admitted [1] 49/21
anywhere [1] 48/8
43/2
2004 [4] 23/5 23/9 39/19 40/5
advantages [1] 34/1
apparently [1] 5/8
2005 [6] 6/11 9/2 9/24 10/2 46/24 47/9 advertising [2] 12/9 12/13
appear [1] 7/17
2006 [3] 46/24 47/4 47/9
after [30] 6/15 9/20 18/12 20/19 22/15
appearance [1] 24/24
2007 [3] 5/12 6/4 6/20
APPEARANCES [2] 1/12 2/1
22/16 22/18 22/24 22/25 23/10 23/18
2008 [5] 4/24 21/14 27/4 46/5 49/2
23/25 28/13 29/6 29/7 34/17 34/18 35/6 appeared [3] 11/5 12/6 12/24
2009 [2] 25/17 26/13
35/19 35/24 36/6 38/6 38/16 38/25 39/9 appearing [2] 2/2 25/6
2010 [1] 12/7
appreciate [1] 4/11
41/2 47/4 47/9 47/9 48/7
2012 [2] 1/6 51/13
afterwards [1] 23/2
approach [4] 13/10 24/8 29/22 36/16
20515 [1] 2/4
again [7] 19/20 19/21 20/8 20/17 22/21 April [2] 1/6 51/13
20530 [1] 1/16
are [36] 5/19 5/25 8/25 11/14 13/8 15/2
22/21 44/17
219 [1] 2/3
against [6] 4/10 25/5 26/23 45/6 49/13
15/10 15/19 16/14 16/15 19/4 21/23
223 [1] 1/3
49/14
22/1 26/4 26/10 27/24 29/8 29/17 29/19
2250 [1] 1/19
age [2] 18/2 18/9
32/15 36/12 36/24 37/1 37/11 38/23
24 [4] 1/6 8/15 39/17 40/17
agent [2] 6/4 7/3
39/13 39/20 40/20 41/1 41/14 43/11
24-year [1] 21/24
agents [3] 41/15 48/17 48/23
44/21 45/7 45/7 45/16 46/13

A
area [1] 15/9
aren't [3] 21/2 27/8 44/5
argument [2] 4/18 7/7
around [6] 4/8 11/19 21/14 22/10 27/9
44/12
article [1] 47/10
as [50] 4/7 4/15 4/22 5/3 5/4 5/23 5/25
6/11 7/1 7/5 8/5 8/5 9/18 14/1 14/1
16/17 16/17 16/20 18/21 19/22 20/9
21/3 21/3 21/8 25/18 26/13 26/17 26/17
26/23 27/13 27/13 28/12 28/16 28/17
30/3 30/21 31/5 32/14 32/14 33/15 34/8
34/20 34/20 35/21 38/12 46/22 48/16
49/8 50/23 51/10
ask [3] 5/24 31/5 50/6
asked [7] 9/1 22/22 26/1 26/3 28/1 34/7
49/1
Assistant [1] 41/11
ASSOCIATES [1] 1/18
assume [1] 28/6
assumptions [1] 10/13
Astros [1] 43/14
athlete [3] 17/13 17/22 17/24
athletes [1] 6/12
atmosphere [1] 12/24
Attanasio [3] 1/20 16/10 20/23
attempts [1] 40/19
attention [2] 4/12 17/18
ATTORNEY'S [2] 1/15 5/18
Attorneys [1] 41/11
attraction [2] 20/10 20/20
audio [5] 34/2 34/5 34/7 34/10 34/14
August [5] 19/12 22/10 22/11 22/12
22/15
AUSA [4] 1/13 1/13 1/14 1/14
authorized [2] 44/4 44/5
Avenue [1] 2/7
avoid [1] 10/8
award [9] 7/25 8/1 19/16 19/17 19/20
20/8 23/10 39/18 39/19
away [2] 13/6 13/16

B
B-12 [13] 29/21 30/7 30/8 30/9 43/8
43/13 43/15 43/18 43/18 43/21 44/1
45/23 46/5
back [15] 5/9 5/23 7/20 8/7 13/5 16/7
18/17 22/7 33/3 36/3 36/23 38/3 42/11
44/8 49/5
backed [2] 13/5 13/16
bad [4] 16/13 16/23 45/6 47/15
bag [1] 18/6
ball [4] 15/8 32/14 43/13 44/1
ballpark [1] 18/3
ballplayer [2] 18/9 18/21
ballplayers [3] 38/11 43/16 43/17
balls [3] 18/15 18/18 18/19
ballyhooed [1] 6/12
Barnett [3] 9/16 9/25 33/23
baseball [25] 6/14 6/15 6/18 7/1 7/23
7/24 7/25 7/25 8/5 8/15 17/17 19/4 19/8
19/15 19/18 20/15 20/21 36/11 36/12
36/20 36/24 37/24 40/3 41/9 45/7
based [4] 25/19 41/14 47/20 47/22
basement [4] 27/21 31/1 31/1 46/9
basically [1] 11/19
basis [2] 41/12 41/12
be [102]
because [27] 5/1 5/9 5/17 6/7 7/6 7/22
8/7 11/19 13/8 15/9 16/15 23/16 28/6
28/8 28/14 28/22 29/3 29/19 29/19
30/12 31/4 37/11 40/2 40/2 42/10 44/21
46/13

bed [1] 9/5


been [20] 8/15 10/18 10/19 16/14 17/23
25/10 25/13 25/15 30/23 33/7 33/16
34/18 38/5 39/7 41/13 46/8 46/19 47/3
47/25 49/12
beer [2] 27/4 29/9
before [46] 1/10 4/22 4/24 6/4 7/12 7/24
8/24 9/11 9/19 10/1 10/14 11/4 12/7
12/8 12/20 12/24 13/12 13/18 14/3 14/6
14/24 17/5 17/8 19/2 20/7 20/17 21/17
21/18 22/23 24/1 25/4 25/14 26/1 33/21
34/5 35/22 37/16 38/25 39/8 40/5 42/14
42/22 46/7 47/18 48/6 49/2
began [1] 40/10
beginning [1] 23/13
begs [2] 49/10 49/11
behalf [3] 3/5 4/3 50/22
being [5] 11/10 11/11 11/11 12/16 18/10
believability [1] 48/15
believe [11] 16/16 16/23 24/6 27/14
27/14 32/5 43/15 43/25 44/2 45/14 48/9
believes [3] 16/7 16/17 16/24
believing [1] 24/3
below [1] 34/13
Bench [4] 13/11 24/9 29/23 36/17
best [1] 19/9
betrayal [1] 4/16
better [2] 40/15 40/16
between [1] 35/22
beyond [3] 32/5 32/16 48/9
bias [1] 24/16
big [4] 14/23 18/16 19/3 25/4
bigger [3] 13/7 15/1 39/10
bit [1] 50/5
blood [1] 30/20
blow [1] 7/16
blue [4] 12/8 21/21 21/23 29/11
Bluejays [1] 35/13
body [7] 14/5 14/23 14/24 14/25 15/6
15/12 40/12
bombed [2] 44/24 44/24
book [7] 25/13 25/14 25/21 25/22 26/4
26/7 26/11
books [2] 4/6 34/25
born [2] 11/16 17/3
Boston [10] 15/12 15/13 19/1 19/1 19/10
19/13 19/21 19/25 20/2 45/6
box [1] 27/21
boy [3] 8/4 33/10 35/14
breath [1] 11/13
Brian [70]
bring [1] 21/10
broadcast [4] 5/6 36/11 37/3 38/9
brought [2] 5/21 12/16
building [2] 2/3 50/20
bulb [1] 39/25
bulk [3] 13/23 13/25 14/12
bulked [2] 13/6 14/19
bulking [1] 14/11
bunch [3] 5/8 22/14 27/5
burden [1] 31/13
bus [3] 35/19 36/2 36/5
business [1] 12/14
Butler [1] 1/13

C
calculate [1] 22/22
California [1] 1/22
call [9] 5/7 9/17 9/21 29/18 30/2 30/12
38/24 43/12 43/12
called [5] 6/17 6/20 7/22 47/12 50/2
calls [1] 40/21
came [10] 6/23 14/22 22/7 28/11 38/14
42/11 47/4 47/9 47/22 50/7
cameras [1] 12/11

can [22] 10/1 10/8 16/24 21/21 23/21


25/24 26/17 27/4 27/7 29/9 29/9 30/18
34/7 35/21 37/3 37/4 38/17 38/19 38/22
42/2 43/19 48/10
can't [3] 11/24 36/20 37/2
Cannon [1] 2/3
cannot [1] 48/8
Canseco [3] 34/24 35/2 35/12
Canseco's [3] 33/7 33/17 35/22
caps [1] 46/13
care [1] 20/21
cared [3] 12/15 19/14 25/8
career [22] 8/14 12/18 12/20 13/3 17/1
17/2 20/4 21/16 21/16 21/22 21/25
22/25 23/3 23/15 23/16 25/7 39/11
39/15 41/20 41/20 48/5 50/19
careers [1] 20/15
careful [1] 48/2
Carolina [1] 26/3
case [17] 13/17 14/10 16/2 16/15 17/8
25/19 28/19 31/8 31/10 31/19 32/4
46/17 48/8 48/24 49/12 49/25 51/8
Cashman [1] 44/9
casual [1] 16/8
catch [1] 21/8
catcher [2] 21/7 21/8
Cathryn [3] 2/5 51/4 51/18
Catlin [5] 29/18 29/19 29/20 29/25 30/6
celebrity [4] 23/24 24/1 24/25 25/10
certain [1] 37/10
certainly [5] 14/3 24/12 24/24 25/13
31/5
CERTIFICATE [1] 51/3
certify [2] 51/6 51/9
chain [1] 28/7
challenge [2] 27/15 50/22
championship [1] 18/24
chance [1] 50/22
change [2] 15/7 39/15
changed [5] 14/5 14/20 14/23 15/12
48/5
changes [1] 15/1
changing [2] 15/1 15/8
characteristics [2] 15/3 15/14
charge [1] 31/16
charged [1] 9/13
cheap [1] 8/17
cheated [1] 8/20
check [1] 28/1
child [1] 11/17
children [1] 11/17
choices [1] 10/6
chosen [1] 5/19
chronologically [1] 5/23
city [1] 50/7
claimed [1] 46/23
claiming [1] 28/25
claims [1] 21/24
clear [9] 14/17 29/17 29/17 31/23 32/2
33/11 47/19 49/13 50/10
cleared [1] 13/12
clearly [4] 14/7 15/6 35/21 39/3
CLEMENS [89]
Clemens' [4] 6/4 42/4 42/19 43/2
Clemens's [12] 6/5 7/3 12/18 14/5 14/23
21/22 29/13 29/15 34/1 34/8 38/4 50/21
clock [1] 48/1
closely [1] 4/11
clothes [1] 4/9
coach [2] 20/10 20/12
coaching [1] 17/23
collected [2] 46/1 46/19
collecting [1] 27/2
college [6] 17/10 17/15 17/16 17/17
17/18 21/8

C
COLUMBIA [2] 1/2 51/6
Columbo [2] 44/11 44/11
come [14] 7/4 9/3 9/9 9/23 10/1 10/12
35/18 36/12 36/22 36/25 37/24 38/12
48/10 49/21
comes [8] 7/12 7/13 7/20 8/7 20/9 35/7
49/2 50/23
comfortable [1] 50/16
coming [2] 5/9 23/6
Commission [7] 6/6 6/8 6/10 7/11 36/8
48/18 48/22
commit [1] 28/25
committed [2] 5/21 50/1
committee [2] 8/25 9/1
common [3] 15/2 31/13 41/18
company [1] 25/3
company's [1] 12/9
computer [1] 2/15
computer-aided [1] 2/15
concerned [1] 34/21
conditioning [2] 20/10 20/12
conducted [1] 40/20
conference [6] 9/7 13/11 24/9 28/13
29/23 36/17
Congress [32] 4/22 5/18 5/22 6/11 6/16
7/9 8/25 9/19 9/20 10/1 10/5 10/7 10/14
11/3 11/12 12/25 14/6 14/24 24/1 26/1
31/16 32/8 34/4 36/8 38/5 45/17 47/18
49/18 50/1 50/7 50/8 50/9
Congressional [3] 9/16 14/7 33/22
Congresswoman [1] 26/3
connection [1] 29/13
consecutively [2] 31/2 40/5
consequences [1] 49/18
consistent [2] 22/9 49/15
consistently [3] 5/2 5/11 39/17
constitute [1] 51/10
Constitution [1] 2/7
Constitutional [1] 10/9
Cont'd [1] 2/1
contact [1] 16/15
contain [1] 27/24
contempt [1] 10/7
contend [3] 11/6 30/24 31/18
contended [2] 6/10 35/3
contending [1] 40/9
contends [2] 15/19 40/14
contention [2] 15/22 15/22
CONTENTS [1] 3/1
context [1] 24/13
continues [1] 18/22
contract [2] 19/24 20/3
contrary [2] 16/11 41/19
conversation [8] 9/8 36/6 46/21 46/24
47/2 47/3 47/7 47/11
conviction [1] 32/16
convince [1] 32/16
convincing [1] 16/20
convoluted [1] 49/8
COOLEY [1] 1/21
correct [1] 16/25
corrected [1] 14/14
corroboration [5] 40/1 40/16 40/19
48/10 48/11
could [12] 19/9 21/9 21/10 30/18 33/16
34/18 36/7 43/24 46/12 46/14 49/19
50/3
couldn't [3] 33/1 33/6 36/19
Counsel [2] 2/2 2/3
count [1] 11/2
counting [1] 44/13
country [5] 40/21 40/22 49/25 50/15
50/17

couple [1] 42/5


course [1] 38/2
court [17] 1/1 2/5 2/6 2/6 14/16 24/11
24/18 28/19 30/5 34/6 36/19 36/20
37/11 37/19 51/4 51/5 51/18
Court's [1] 37/8
Courtney [1] 1/14
courtroom [1] 30/16
coveted [1] 7/25
cows [1] 48/10
CR [1] 1/3
crazy [1] 50/4
create [2] 30/19 32/12
crime [6] 5/10 5/19 5/20 5/21 28/25 50/1
criminal [2] 46/17 48/21
criticized [1] 9/6
criticizing [2] 47/19 47/20
culminated [1] 6/20
culminating [1] 25/11
custody [1] 28/7
Cy [10] 8/1 19/16 19/20 20/8 20/17
21/16 23/9 39/18 39/18 39/19

D
D.C [5] 1/5 1/16 2/4 2/7 5/19
Daniel [1] 1/13
dared [3] 5/1 5/9 11/9
day [14] 5/16 6/23 7/12 11/9 16/19
16/22 36/11 37/25 37/25 38/1 38/7
38/14 38/20 51/13
days [3] 6/3 8/24 35/6
deal [1] 16/10
dealer [2] 29/3 29/3
dearly [1] 11/21
Death [1] 25/12
Deceit [1] 4/16
deceitful [1] 5/8
December [7] 5/12 6/4 6/20 7/14 7/17
25/17 26/14
December the [2] 7/14 7/17
decent [1] 4/13
decide [5] 6/2 16/24 32/18 47/16 49/9
decided [2] 22/6 27/1
decides [3] 20/2 25/12 38/15
decision [1] 25/18
decline [1] 10/1
Defendant [4] 1/7 1/17 3/5 4/3
dejected [3] 44/19 44/23 45/11
delivered [1] 26/24
denial [1] 8/7
denied [5] 5/12 5/13 9/22 28/23 47/2
deny [7] 5/1 5/9 5/17 5/20 7/15 50/2
50/18
denying [1] 50/1
deposition [8] 4/23 10/22 10/25 11/1
11/4 34/2 34/5 34/9
Deputy [1] 2/2
describe [1] 7/1
designed [1] 5/5
detail [1] 12/2
developed [1] 41/3
did [37] 5/12 6/25 7/16 9/23 10/11 10/13
10/18 11/3 11/9 11/14 12/19 12/19
13/22 14/24 14/24 15/5 16/21 17/25
21/11 27/3 29/2 30/16 32/7 32/19 32/23
39/9 39/24 40/23 43/15 43/20 44/3 44/5
49/20 49/20 49/21 50/12 50/14
didn't [28] 4/8 8/9 9/12 10/12 10/17
11/12 11/12 11/20 21/10 28/8 28/25
29/1 29/2 39/14 39/15 39/16 40/3 42/6
42/9 43/15 45/1 45/20 46/3 46/10 46/18
47/8 47/8 50/6
die [1] 19/14
died [1] 11/21
Diego [1] 1/22

difference [1] 37/14


different [9] 4/23 13/25 15/1 26/18
27/22 29/8 29/10 31/17 50/14
differently [1] 37/16
difficult [1] 7/21
digital [2] 38/17 38/21
directed [2] 16/6 31/15
discharge [1] 32/8
discipline [1] 20/23
discussing [1] 4/19
dishonesty [1] 4/16
distinction [1] 37/13
DISTRICT [6] 1/1 1/2 1/11 2/6 51/5 51/5
distrusting [1] 27/1
DLA [1] 6/17
DNA [11] 27/11 27/14 27/18 27/18 27/19
29/13 29/15 30/19 30/21 43/4 49/8
do [61]
Docket [1] 1/3
doctors [1] 43/14
does [8] 8/23 9/22 10/13 25/11 27/18
33/2 33/20 50/4
doesn't [8] 8/8 9/20 15/7 20/22 38/10
38/11 40/12 44/2
doing [8] 18/2 18/6 18/12 25/1 39/20
45/15 47/12 50/24
dollars [1] 6/19
don't [10] 13/23 13/25 14/18 15/20
20/21 26/12 29/19 30/12 35/8 38/24
done [12] 5/16 9/2 30/18 34/10 40/7
41/17 45/17 45/19 46/11 49/14 49/16
49/19
dope [4] 28/23 29/2 29/3 29/3
doubt [4] 32/6 32/17 45/14 48/9
down [9] 12/16 18/20 18/20 33/4 38/22
44/8 44/17 44/23 50/6
Dr. [1] 29/25
Dr. Catlin [1] 29/25
drafted [2] 18/25 18/25
dreamed [1] 18/9
drive [2] 18/4 20/22
driven [1] 20/23
drugs [1] 40/4
due [1] 7/4
Durham [22] 1/13 4/12 5/6 6/11 7/5 13/5
13/16 13/18 13/22 14/11 14/19 15/25
16/12 26/18 31/6 31/11 32/15 43/6
44/23 45/22 45/24 50/5
Durham's [2] 43/23 50/8
during [14] 7/20 9/10 11/4 15/12 21/11
25/1 33/7 33/17 37/3 38/2 38/3 45/11
48/6 48/20

E
each [1] 22/11
earlier [2] 35/23 37/8
early [1] 46/4
earth [1] 23/17
easily [1] 30/19
Eastgate [1] 1/21
easy [1] 30/7
effort [1] 41/24
eight [3] 6/3 20/1 41/11
eighty [1] 41/5
eighty-seven [1] 41/5
either [3] 4/9 13/18 40/20
else [6] 21/10 25/1 25/22 28/3 39/22
43/3
Emery [2] 28/5 28/9
Emery's [1] 28/16
employed [1] 41/1
end [6] 10/20 16/19 16/21 24/4 24/22
31/11
endorse [1] 31/6
ends [1] 49/8

finger [1] 4/14


finger-pointing [1] 4/14
enforcement [5] 28/15 28/18 29/6 41/9 fingerprint [1] 28/3
fingerprints [1] 28/1
48/20
enhancement [1] 38/17
finishing [1] 49/10
enhancing [1] 32/1
firm [2] 6/17 6/19
enjoying [1] 24/24
first [22] 5/18 8/2 9/17 11/2 11/17 12/20
enough [4] 14/15 17/15 17/18 47/25
14/19 19/13 19/16 23/23 31/8 31/16
entire [4] 14/4 15/9 21/24 41/19
33/1 35/7 36/7 39/18 40/4 40/7 44/4
entitled [1] 32/15
46/19 48/16 50/21
Esquire [3] 1/17 1/17 1/20
fishing [1] 44/12
establish [1] 28/7
fit [1] 45/18
ethic [1] 17/21
five [5] 8/2 8/2 8/19 11/17 31/25
eve [1] 9/14
fixation [1] 43/8
even [2] 39/10 46/18
Florida [1] 48/21
events [1] 35/10
folks [2] 47/1 50/16
ever [21] 8/2 8/18 9/19 10/16 15/16
follows [1] 30/3
foregoing [1] 51/9
16/23 17/9 17/13 17/20 17/22 17/24
forgiving [1] 44/14
19/8 23/11 23/18 30/22 31/20 32/19
forgotten [1] 10/16
46/6 46/14 46/16 50/11
every [3] 5/2 11/13 49/4
former [1] 6/16
everybody [5] 9/12 10/3 18/12 27/9 46/3 forth [2] 18/17 42/11
everything [12] 5/16 8/18 13/7 19/23
forty [1] 8/19
forty-five-year-old [1] 8/19
25/22 27/23 31/13 34/25 39/1 45/18
forum [1] 5/2
49/6 49/14
evidence [71]
forums [1] 22/14
exactly [2] 36/18 38/19
forward [4] 9/9 9/23 15/11 40/10
example [2] 33/12 33/15
foul [3] 18/8 18/8 18/14
except [5] 12/15 16/2 40/15 47/15 50/3 found [4] 6/4 6/7 6/8 43/4
excerpt [1] 51/7
foundation [1] 13/14
excerpts [2] 10/23 34/3
four [13] 11/13 13/8 19/19 19/24 19/25
exchange [5] 33/21 34/16 35/20 35/23
20/3 20/3 20/17 31/18 31/23 33/3 43/14
38/5
48/23
excuse [1] 21/14
fourth [1] 20/9
Exercise [1] 10/9
Friday [1] 18/4
Exhibit [1] 40/17
friend [1] 23/7
expect [7] 15/17 15/20 30/2 30/4 30/6
friends [2] 16/14 16/16
front [2] 12/6 34/4
37/14 39/14
expects [2] 37/9 46/11
full [2] 19/13 33/21
experience [1] 26/5
furor [2] 7/21 25/17
expert [4] 29/18 30/10 30/18 46/15
further [4] 21/4 30/11 30/12 51/9
experts [1] 38/23
G
expired [1] 19/24
gained [1] 9/18
explain [2] 40/2 49/7
game [9] 36/3 37/24 44/24 45/2 45/2
explanation [2] 45/25 49/8
eye [1] 32/14
45/5 45/6 45/9 45/9
garbage [4] 46/1 46/1 46/14 49/3
eyes [1] 42/6
gathered [2] 27/25 28/16
F
gauze [5] 27/6 27/6 27/17 30/20 43/5
fact [4] 11/8 33/22 47/18 49/12
gave [13] 21/24 22/8 22/10 22/15 22/21
Fair [1] 14/15
23/1 23/11 41/22 42/21 42/22 42/24
faith [1] 45/14
46/5 46/6
false [1] 43/9
general [3] 2/2 2/3 20/1
family [1] 17/4
generational [1] 20/25
famous [1] 20/4
George [3] 6/16 47/17 47/19
fan [1] 19/4
get [12] 4/8 9/13 10/14 11/14 16/9 17/15
fans [1] 45/7
17/17 17/18 18/16 21/9 28/21 30/8
far [4] 8/5 14/1 32/14 34/20
gets [4] 9/10 19/11 19/22 29/6
father [1] 11/20
getting [2] 22/11 43/7
FBI [2] 28/1 41/15
giggles [1] 24/21
February [1] 4/24
Gilberto [1] 1/14
federal [2] 41/9 49/25
gist [1] 47/10
fer [1] 20/21
give [2] 29/1 43/25
few [1] 45/7
given [3] 19/17 35/13 43/13
Fifth [2] 10/8 10/12
gives [2] 10/22 10/25
figured [1] 18/14
giving [3] 20/2 20/2 39/22
figures [1] 41/14
glaring [1] 39/6
file [1] 41/12
go [16] 5/23 5/25 12/18 12/20 17/1 17/7
final [1] 4/18
19/25 33/4 33/4 36/23 38/21 39/16
finally [1] 47/24
41/23 42/2 48/8 49/17
find [20] 7/3 15/17 15/20 18/5 25/16
God [1] 49/24
God's [1] 23/17
25/18 30/9 34/21 38/19 38/23 39/25
GODWARD [1] 1/21
40/16 40/19 41/23 46/10 47/21 48/15
goes [9] 17/3 17/16 18/22 19/3 19/10
48/19 48/22 49/4
fine [2] 13/20 30/3
20/7 21/20 23/25 39/25

going [73]
golf [10] 18/15 18/18 18/19 34/18 35/17
35/25 37/25 38/1 38/2 38/6
gone [6] 18/13 20/13 35/24 38/16 44/22
46/7
good [10] 4/4 4/5 4/13 9/19 17/15 19/23
20/11 21/5 43/15 45/14
got [17] 5/24 8/20 13/1 17/15 18/15 28/2
28/7 28/23 39/25 43/18 43/18 43/21
43/21 44/24 44/24 44/25 45/12
government [36] 1/13 4/12 5/6 7/9 7/15
9/17 11/1 12/22 12/23 13/19 15/22 16/6
26/16 26/20 28/6 28/9 29/20 30/1 32/11
33/9 34/3 34/21 35/1 35/11 35/15 38/8
38/15 39/25 40/9 40/19 40/25 41/13
41/16 48/17 50/9 50/11
Government's [7] 14/7 14/18 30/10
33/14 38/10 38/12 48/8
graduated [1] 17/14
Graham [4] 17/12 17/21 17/22 18/11
Grand [3] 12/7 12/8 12/13
great [3] 45/5 45/9 50/23
greatest [1] 17/21
green [1] 23/17
grounder [1] 18/20
grows [1] 11/19
growth [3] 31/21 32/20 32/24
Guerrero [1] 1/14
guess [4] 8/18 28/1 38/23 45/8
guilt [1] 5/17
guilty [3] 5/10 8/12 32/10
guy [15] 11/23 11/24 11/25 12/4 12/4
17/5 18/13 18/16 19/7 20/3 26/16 35/4
40/11 41/2 44/24
guys [2] 11/14 12/4

H
habits [1] 17/20
had [51] 6/6 6/6 6/10 6/12 7/11 7/22
7/24 8/1 8/15 8/18 8/19 9/1 9/2 9/19
10/2 10/19 11/13 11/17 12/14 13/18
14/23 15/13 15/18 17/21 20/12 20/13
20/14 21/17 27/5 27/5 27/6 27/8 27/11
27/17 27/22 29/10 30/7 35/23 39/21
42/11 43/6 43/8 44/9 45/9 46/18 46/23
46/25 47/2 47/20 49/5 51/7
hadn't [2] 25/23 49/19
half [27] 26/18 26/21 31/4 33/4 33/12
36/9 36/9 39/2 39/2 39/3 41/25 42/1
42/8 42/23 43/2 43/5 43/10 43/23 44/3
45/1 45/13 45/22 46/18 46/20 46/22
47/1 47/6
halfway [1] 19/11
hands [1] 18/7
happen [1] 50/3
happened [6] 12/3 22/17 25/24 30/24
31/14 34/12
hard [1] 29/21
hardest [1] 17/13
Hardin [9] 1/17 1/18 13/19 29/24 30/1
36/19 37/6 37/9 41/12
harmless [1] 44/1
has [53]
hasn't [1] 25/15
have [57]
haven't [3] 13/2 16/14 32/25
having [6] 9/8 10/8 30/22 33/3 40/14
49/16
hawking [1] 12/9
he [263]
he'd [2] 10/12 10/18
he'll [7] 17/12 17/17 22/2 22/5 22/9 22/9
25/12
he's [44] 8/10 8/10 9/9 11/10 11/10
11/11 11/13 11/16 14/1 14/3 17/2 17/4

H
he's... [32] 18/14 18/15 18/16 18/16
18/18 18/25 18/25 19/1 19/19 19/24
19/25 20/2 20/4 22/9 24/24 27/17 34/23
34/25 35/9 35/20 37/10 39/23 42/13
42/21 44/19 45/12 46/3 47/8 47/11 48/3
48/17 48/18
head [1] 15/1
hear [9] 8/8 10/23 10/25 11/5 35/21
36/10 36/11 40/9 49/7
heard [5] 6/11 13/2 15/25 34/17 46/25
hearing [2] 10/22 28/13
hearings [4] 6/12 9/2 47/9 49/2
hearsay [6] 24/5 24/11 24/14 29/25 30/1
36/15
heck [1] 45/2
help [4] 20/22 21/1 21/9 49/24
helping [1] 28/10
her [1] 25/7
here [26] 4/8 5/1 5/19 5/24 10/15 11/14
11/16 12/5 13/24 17/7 17/10 18/16
21/21 21/25 22/8 25/2 27/17 29/12
32/12 33/11 34/1 34/10 42/2 44/9 44/15
50/15
here's [5] 11/15 29/16 32/11 32/13
33/12
hereby [1] 51/6
herein [1] 51/2
hereto [1] 51/12
hey [1] 38/15
HGH [18] 5/13 6/7 16/8 16/21 23/1 23/18
31/24 39/8 39/24 42/10 42/15 42/17
42/21 42/23 42/25 43/1 46/6 47/1
high [7] 17/3 17/5 17/14 17/19 18/1
27/13 30/13
him [39] 4/19 5/21 6/18 6/18 7/6 8/8
9/22 9/23 12/23 13/23 16/8 16/23 20/20
20/22 21/9 21/15 22/21 23/1 23/6 23/22
25/6 25/7 28/10 28/10 28/10 28/22
30/12 39/22 41/21 41/22 41/22 41/22
41/23 42/12 42/14 46/5 46/6 48/21 50/2
himself [6] 12/1 13/7 17/24 18/9 18/16
20/24
hired [2] 6/16 6/18
his [77]
history [2] 10/2 20/15
hitting [2] 39/16 39/16
hodgepodge [1] 46/14
hold [1] 4/10
home [3] 39/16 39/16 48/10
hometown [1] 23/6
Honor [7] 13/9 13/15 24/5 24/10 29/24
36/18 37/6
Honor's [1] 36/14
HONORABLE [1] 1/10
hope [1] 4/9
Hopefully [1] 50/13
hopes [1] 31/12
hoping [1] 17/17
hormone [3] 31/21 32/20 32/24
house [11] 2/2 8/25 27/21 27/22 31/1
33/7 33/17 35/22 42/4 42/19 43/2
Houston [3] 1/19 23/7 23/10
how [13] 4/11 5/23 10/14 11/14 12/2
21/2 21/8 24/21 30/17 39/22 40/2 49/7
49/8
Howard [4] 23/24 23/25 24/21 26/10
human [2] 31/20 32/24
hundred [2] 41/5 41/8
hunting [1] 7/20

I
I'd [1] 9/13
I'll [2] 37/20 42/2

I'm [21] 10/9 16/9 17/2 17/6 20/2 26/16


29/2 29/3 29/4 29/14 33/10 37/14 40/24
44/6 44/9 44/11 44/13 44/15 46/21
47/14 48/25
I've [3] 32/25 44/24 46/8
ideas [1] 25/7
illegal [2] 28/23 41/19
imagine [2] 7/22 46/14
impeachment [1] 24/12
improve [1] 39/15
inconsistent [1] 39/13
incredible [3] 19/23 20/14 21/17
indicate [1] 41/4
indicated [2] 14/12 16/12
indicia [1] 14/25
indictment [1] 31/14
individuals [1] 41/6
inference [1] 13/14
informed [1] 8/25
initially [1] 15/3
injected [1] 30/23
injuries [1] 15/24
injury [1] 19/12
innocence [1] 5/2
insane [1] 39/3
insistence [1] 49/13
instance [1] 48/19
instances [1] 26/18
intelligent [1] 49/23
intends [1] 13/19
intense [1] 21/3
intent [1] 32/8
intention [1] 14/4
intentionally [1] 32/6
interesting [1] 44/7
interestingly [1] 43/16
interview [11] 7/8 8/10 8/11 8/23 8/24
9/4 9/10 24/2 24/20 41/6 41/8
interviewed [2] 7/6 41/6
interviewing [1] 25/7
interviews [6] 25/6 40/20 40/23 41/14
48/23 48/24
introduce [1] 11/1
investigation [2] 6/19 48/21
investigators [1] 7/5
invitation [2] 9/3 9/21
involved [1] 48/20
involvement [1] 12/14
irrefutable [1] 22/14
irrefutably [1] 29/16
is [189]
issue [8] 5/25 9/2 9/22 10/2 14/24 37/25
40/25 41/1
issued [1] 6/8
issues [3] 8/7 10/5 39/6
it [132]
it's [30] 5/3 7/18 7/21 9/11 12/5 14/2
14/2 21/18 21/18 23/3 24/11 24/11
24/14 24/14 24/15 26/19 33/22 35/6
37/13 38/18 39/3 44/3 44/7 44/19 45/12
45/13 46/11 47/5 50/9 50/16
its [4] 6/8 13/20 15/22 35/19

J
Jac [1] 17/10
Jacinto [1] 17/16
jacket [1] 17/12
January [4] 9/15 27/4 46/4 49/1
Jeremy [1] 1/17
joints [1] 15/23
Jones [3] 2/5 51/4 51/18
Jos [7] 33/7 33/17 34/23 34/23 35/4
35/12 35/22
Jr [2] 1/14 1/17
judge [3] 1/10 1/11 25/24

judgment [1] 5/20


July [1] 22/10
jump [1] 24/4
jumpsuit [1] 24/22
June [6] 21/14 33/8 33/18 34/22 37/25
48/17
June 8th [2] 33/8 33/18
June 9th [2] 34/22 37/25
junior [3] 17/16 17/17 18/24
jurors [1] 42/6
jury [5] 12/7 12/8 12/13 14/3 31/5
just [20] 7/15 8/9 9/9 10/17 11/12 12/19
16/11 18/5 18/20 18/20 19/5 19/14
20/22 21/2 21/16 24/14 29/20 34/6
34/11 34/17

K
keep [5] 31/5 31/6 40/24 48/4 49/5
keeping [1] 32/14
keeps [2] 15/8 37/6
kept [2] 27/20 43/4
key [1] 38/15
kid [2] 11/25 18/14
kids [1] 18/2
kind [7] 13/6 30/20 32/18 39/4 41/23
44/7 47/25
knew [10] 5/21 6/23 10/3 10/12 12/11
12/12 21/8 25/4 50/1 50/2
know [11] 8/22 10/18 10/18 14/1 21/2
26/12 34/2 35/8 42/5 45/23 46/18
knowing [2] 32/6 49/18
known [1] 5/2
knows [1] 16/17
KRONISH [1] 1/21

L
LA [2] 47/4 47/9
large [1] 4/25
last [5] 11/13 23/11 23/16 37/20 39/23
lasts [1] 24/2
late [1] 17/22
later [2] 7/9 16/11
laterally [1] 18/17
laughs [1] 24/21
law [6] 6/17 28/15 28/17 29/6 41/9 48/20
lawful [1] 32/8
lawyer [10] 4/13 7/18 27/4 28/9 28/12
28/18 46/8 48/2 49/2 49/10
lawyers [2] 4/7 7/3
lays [1] 29/7
League [1] 19/18
leagues [1] 19/3
leaves [1] 9/11
left [3] 35/19 36/3 36/4
legally [2] 43/19 43/24
less [1] 19/2
let [11] 10/16 13/5 14/17 26/17 26/23
31/23 32/2 38/3 39/5 44/6 50/8
let's [11] 5/23 12/20 17/1 31/8 31/9 33/4
33/21 34/13 38/17 40/18 41/23
level [1] 30/13
liar [2] 5/7 47/12
lidocaine [3] 45/23 46/5 46/20
lie [3] 32/6 49/7 49/18
lied [7] 4/22 32/6 48/16 48/17 48/18
48/20 50/7
lies [1] 49/17
lights [1] 18/3
like [19] 4/17 11/22 13/16 15/24 18/20
18/21 22/23 22/24 22/25 26/13 26/24
30/1 34/6 34/11 38/24 39/25 44/1 47/2
47/12
liked [1] 44/16
listen [4] 26/20 33/25 34/8 45/13
listened [1] 50/18

medical [4] 15/15 15/15 15/17 40/13


meeting [1] 35/6
listening [1] 34/12
meets [2] 20/7 20/17
little [6] 4/13 21/22 22/3 22/7 27/7 50/5 members [1] 9/7
live [3] 9/6 34/4 38/13
memo [1] 4/9
living [1] 31/1
memory [4] 11/3 16/7 47/3 47/8
LLP [1] 1/21
men [3] 5/24 10/20 10/21
locations [2] 27/22 41/8
mention [2] 40/3 46/10
logical [1] 49/23
mentioned [3] 16/4 39/7 45/3
long [2] 24/2 24/20
met [4] 17/9 17/22 22/24 35/12
long-ranging [1] 24/20
Michael [1] 1/20
longer [1] 14/8
might [3] 35/24 38/5 45/24
look [20] 4/8 5/24 11/6 13/1 13/8 17/10 Mike [6] 8/11 20/23 44/17 45/3 45/3
21/21 22/23 26/20 27/25 32/12 32/18
46/4
33/21 34/16 38/17 40/18 44/6 46/8 48/1 million [5] 28/20 28/21 28/22 28/24 29/4
millions [1] 6/19
48/13
looked [4] 15/2 18/13 26/24 44/8
mind [3] 31/7 40/24 48/4
looking [5] 17/11 24/3 34/11 44/9 44/15 minors [1] 19/2
looks [1] 38/24
minute [3] 8/24 31/4 35/14
loosen [1] 15/23
Minutes [5] 8/11 8/23 9/4 9/14 46/4
lot [4] 15/2 20/22 20/23 26/18
MISCELLANY [1] 3/2
loved [1] 11/21
mislead [1] 32/8
loving [2] 24/1 24/1
misplaced [1] 44/16
ludicrous [2] 46/16 46/16
missing [1] 46/13
mistaken [1] 47/4
M
Mitchell [20] 6/6 6/8 6/10 6/16 6/21 6/23
MAC [1] 25/12
6/24 7/11 8/4 9/1 28/11 35/5 36/8 45/17
machine [3] 2/14 51/6 51/11
47/17 47/19 47/20 47/22 48/18 48/22
made [14] 5/17 12/1 13/7 17/24 25/4
mix [1] 30/20
25/8 25/14 25/23 38/20 38/25 42/1 43/6 mixed [2] 46/12 46/13
money [1] 25/10
44/15 47/18
Mai [1] 25/2
month [1] 29/20
mailed [2] 42/12 42/18
Monthy [1] 1/17
mailing [2] 42/3 43/1
more [4] 4/17 15/24 19/25 49/15
maintained [1] 39/17
morning [3] 4/4 4/5 35/18
Major [1] 19/18
most [7] 7/24 13/2 16/20 17/20 20/14
make [8] 5/19 9/23 14/17 18/9 29/16
39/6 46/13
mother [1] 11/17
45/24 46/22 49/25
makes [1] 49/9
motive [2] 48/13 48/14
making [3] 7/2 25/10 25/25
mound [1] 18/12
Mall [1] 1/21
mouthing [1] 16/23
man [14] 4/13 5/1 5/2 7/22 8/3 8/19
move [2] 18/17 18/21
moved [1] 27/21
12/16 17/11 30/16 35/12 38/12 41/18
moves [1] 17/4
50/3 50/4
man's [2] 15/6 49/12
Mr [82]
manager [1] 20/1
Mr. [9] 28/5 28/9 28/16 29/7 29/18 29/19
managers [1] 43/19
30/6 35/2 42/18
manipulate [2] 30/14 30/17
Mr. Canseco [1] 35/2
manuscript [1] 26/14
Mr. Catlin [3] 29/18 29/19 30/6
many [5] 7/22 7/22 26/21 26/21 50/15
Mr. Emery [1] 28/9
March [2] 26/13 38/21
Mr. Emery's [1] 28/16
market [3] 25/13 25/16 25/22
Mr. Novitzky [1] 29/7
marks [2] 21/21 21/23
Mr. Radomski [1] 42/18
marriage [1] 11/18
Mr. Richard [1] 28/5
mass [1] 15/1
much [9] 6/12 13/3 19/5 19/5 26/17 36/1
masseuses [1] 15/10
43/15 44/17 50/25
match [1] 11/6
must [3] 41/20 41/21 43/3
materials [1] 26/22
my [10] 10/9 11/3 14/4 40/25 40/25
matter [3] 24/15 44/2 47/24
41/17 46/9 47/8 51/11 51/12
matters [3] 32/7 48/16 51/1
mysterious [1] 35/4
may [8] 10/23 13/25 19/5 20/25 29/22
N
35/18 38/12 40/7
N.W [2] 1/15 2/7
maybe [6] 7/16 38/19 43/3 43/20 45/6
name [6] 6/9 6/24 49/13 50/10 50/17
45/7
McKinney [1] 1/18
51/13
name's [1] 17/12
McNamee [95]
McNamee's [9] 18/15 21/13 22/1 22/19 namely [2] 14/25 14/25
names [2] 6/9 6/24
27/19 36/4 37/7 42/19 43/5
narrow [1] 38/22
me [20] 11/24 13/5 14/17 21/15 26/17
national [2] 18/24 25/25
26/23 29/1 31/23 32/2 35/7 38/3 39/5
44/6 44/7 44/12 44/12 44/14 45/4 49/24 natural [1] 11/20
nature [4] 8/4 24/2 24/25 25/11
50/8
neat [2] 26/22 27/7
mean [4] 14/18 14/20 42/5 43/20
necessarily [1] 21/3
meaning [1] 41/7
need [2] 20/25 39/10
media [4] 7/21 9/7 12/12 12/13

needle [9] 27/5 27/11 29/10 29/21 30/7


30/8 30/19 30/20 30/22
needles [1] 29/12
needs [1] 14/14
negative [4] 15/5 40/6 40/11 40/12
Neither [1] 39/20
never [31] 7/6 14/1 14/3 15/12 16/1
16/12 17/24 20/13 22/15 22/16 22/20
22/21 23/1 24/12 31/22 31/23 31/25
31/25 32/3 35/22 42/14 42/20 42/20
46/6 46/23 47/2 47/7 47/11 48/5 50/9
50/11
New [3] 11/15 23/4 28/19
newfound [1] 23/23
next [10] 4/24 6/9 11/5 12/4 13/1 25/11
27/23 28/5 29/5 45/2
nicely [1] 26/17
night [2] 18/4 36/3
nine [3] 6/3 20/1 41/8
nineteen [1] 18/25
no [21] 1/3 3/4 6/22 7/24 9/5 13/14 14/2
14/7 14/13 15/15 25/4 25/13 26/6 26/9
28/17 32/25 33/19 40/13 45/14 48/24
50/23
nobody [6] 8/6 9/19 12/14 25/8 40/14
43/24
none [5] 15/13 16/4 22/17 29/12 45/6
North [1] 26/3
not [70]
note [3] 44/6 44/9 44/15
notes [3] 41/15 42/1 51/11
Nothing [1] 9/18
noticed [1] 13/4
notoriety [1] 12/15
notorious [1] 34/24
November [1] 47/4
Novitzky [1] 29/7
now [24] 5/18 11/16 12/10 13/1 15/22
17/23 19/24 21/20 23/22 24/2 26/16
29/6 31/3 31/11 33/20 33/21 34/13
34/16 35/9 38/19 40/9 40/18 43/18
49/10
number [7] 17/4 31/9 31/10 32/2 33/12
33/14 39/14
nutrition [1] 25/8

O
o'clock [5] 36/5 36/7 38/16 38/16 39/1
oath [2] 10/10 49/18
object [2] 13/9 29/22
objection [5] 13/15 24/5 24/10 36/14
37/20
objection's [1] 24/19
obligations [1] 32/9
obstruct [1] 11/3
obstructed [1] 31/17
obstruction [2] 31/16 33/14
obstructive [6] 11/2 11/4 11/7 32/13
32/17 32/22
obviously [1] 4/8
occur [1] 47/9
occurred [4] 11/4 12/24 12/25 47/3
odds [1] 49/13
off [3] 21/11 25/10 39/25
offered [2] 24/15 24/15
office [4] 1/15 2/3 5/18 28/16
officers [1] 41/9
official [4] 2/6 51/4 51/10 51/18
oh [2] 18/11 44/16
Ohio [1] 11/16
okay [5] 43/24 44/12 44/20 44/24 48/1
old [4] 8/19 19/19 19/24 20/3
once [1] 10/5
one [32] 4/23 5/16 6/22 11/9 16/6 16/8
20/14 21/4 23/17 25/4 25/11 28/3 31/11

O
one... [19] 31/20 32/17 34/1 37/24 39/5
39/6 39/7 39/14 39/20 40/3 41/3 41/8
41/24 42/9 42/14 45/3 45/18 45/22
49/12
ones [1] 29/14
only [21] 10/6 10/7 19/2 19/8 21/22
21/23 21/23 21/25 23/19 24/22 26/21
31/18 34/17 35/24 42/20 42/22 42/24
47/20 47/25 49/12 49/22
open [6] 14/16 24/18 29/9 30/5 31/7
37/19
opening [10] 3/5 4/3 4/7 4/18 13/5 13/18
13/24 15/21 24/13 31/11
ordered [1] 42/10
originally [2] 14/5 14/21
other [16] 5/8 12/4 15/7 17/7 18/2 27/8
27/22 28/24 35/4 39/3 40/3 41/4 43/2
43/10 45/1 51/1
others [3] 20/25 41/15 43/15
otherwise [1] 40/2
ought [1] 28/17
our [7] 30/15 50/7 50/7 50/9 50/9 50/10
50/16
out [42] 6/5 6/7 6/8 6/23 7/4 7/4 7/12
7/13 8/17 14/22 18/2 18/5 18/13 18/14
19/23 20/20 20/22 20/24 21/9 23/6
24/11 27/18 28/11 29/7 29/9 30/8 34/21
36/20 37/11 38/19 38/19 38/23 41/21
42/11 46/11 46/12 47/4 47/9 47/22
48/19 49/17 49/25
out-of-court [3] 24/11 36/20 37/11
outfield [1] 18/13
outing [1] 34/19
outside [1] 40/22
outward [3] 14/25 15/14 40/12
outwardly [1] 15/7
over [13] 7/16 9/11 12/12 15/18 18/4
18/6 25/20 27/17 29/12 40/21 41/9
41/13 42/5
overruled [2] 24/17 24/19
Oversight [1] 8/25
owes [1] 28/22
own [6] 27/4 32/23 34/24 38/10 38/23
48/19

P
packs [1] 27/7
Page [1] 3/4
pages [2] 20/5 51/9
paid [3] 4/11 6/18 24/23
part [2] 21/4 24/16
parts [1] 50/14
party [15] 34/19 34/20 34/22 34/23 35/3
35/12 35/16 35/18 35/19 38/2 38/3 38/6
38/6 38/11 38/13
past [3] 14/12 22/9 22/19
pending [1] 28/19
people [8] 8/8 38/21 41/2 41/7 43/11
43/21 45/14 50/13
percentage [1] 27/13
perfectly [1] 37/9
perform [1] 39/23
performance [3] 32/1 39/15 39/17
performance-enhancing [1] 32/1
period [7] 22/3 22/8 25/1 33/8 33/17
39/20 46/24
periodically [1] 43/25
periods [1] 21/25
perked [1] 42/6
person [8] 4/15 5/11 8/2 15/2 23/19
30/23 40/21 49/23
person's [1] 30/21
perspective [2] 26/19 45/18

Pettitte [8] 16/4 16/13 16/16 16/22 23/8


46/21 46/24 49/20
Pettitte's [4] 16/5 16/5 16/9 16/19
phone [2] 40/21 40/21
photograph [1] 13/8
photographs [4] 28/13 28/14 28/15
28/16
Phrase [1] 37/17
physical [3] 16/1 45/21 48/24
pick [3] 19/5 19/6 19/6
picking [1] 18/19
picture [19] 12/5 12/22 12/23 21/6 23/23
26/22 27/8 27/23 28/5 29/5 29/7 29/8
33/9 35/13 38/8 38/10 38/18 38/20
38/25
pictures [2] 13/13 15/6
piece [1] 41/3
Piper [1] 6/18
pitch [1] 21/10
pitched [1] 45/9
pitcher [4] 7/23 7/24 8/15 19/17
pitches [1] 23/7
pitching [3] 7/25 8/1 22/4
Pittard [1] 2/2
place [1] 47/8
places [1] 36/6
Plaintiff [1] 1/4
plans [1] 26/7
plastic [1] 18/6
play [2] 17/17 34/3
played [8] 21/7 33/24 34/14 35/17 35/25
37/25 38/6 41/10
player [1] 19/8
players [6] 6/9 6/25 9/24 36/3 43/13
44/1
playing [3] 8/20 35/21 38/1
playoff [1] 45/12
playoffs [1] 44/20
plays [3] 9/7 19/2 19/13
please [7] 13/1 23/22 29/5 31/9 33/5
33/13 34/13
point [3] 14/18 40/24 41/17
pointing [1] 4/14
points [2] 4/19 17/7
pole [2] 18/8 18/8
pool [2] 33/10 35/12
possible [1] 5/16
poster [1] 8/3
poured [1] 46/12
practice [1] 6/17
premier [3] 7/23 19/17 33/12
premise [1] 13/17
present [2] 13/20 15/17
presently [1] 28/19
preserved [1] 27/3
press [2] 9/7 28/12
presumably [1] 24/12
pretty [1] 38/18
previous [2] 22/1 35/8
previously [1] 42/22
print [1] 25/12
prior [2] 37/7 37/11
private [3] 5/3 6/17 12/13
probably [4] 13/2 25/19 37/4 50/23
problem [4] 6/13 7/1 15/4 46/2
proceedings [4] 1/10 2/14 51/7 51/10
process [1] 15/7
prodding [1] 6/15
produced [4] 2/15 26/23 27/3 36/10
product [1] 12/9
profession [2] 19/6 19/7
professional [1] 41/20
prolong [5] 21/16 21/16 23/15 39/11
41/20
prominent [1] 6/12

promise [1] 48/3


prosecute [1] 50/11
prosecuted [3] 11/10 11/11 11/11
prosecuting [1] 50/13
prosecutors [1] 48/18
protect [1] 8/13
prove [1] 15/4
provided [2] 7/9 41/15
providing [1] 42/15
public [4] 4/25 5/17 11/23 49/14
publicity [1] 8/5
publicly [5] 5/1 5/3 7/17 11/5 14/22
publish [2] 25/18 26/4
published [3] 25/15 25/16 26/15
pudgy [1] 11/25
punish [1] 50/10
purpose [1] 14/10
push [2] 21/1 21/4
put [7] 9/5 17/2 26/22 30/8 33/13 34/10
34/12

Q
question [3] 23/13 33/16 41/18
questioned [1] 10/24
questioner [1] 33/22
questions [3] 8/9 9/6 34/8
quick [1] 5/23
quickly [6] 12/19 15/24 17/1 17/6 42/2
46/21
quit [1] 22/12
quite [2] 21/2 24/2
quote [1] 20/5

R
Radomski [4] 42/3 42/13 42/18 43/1
ranging [1] 24/20
rather [1] 46/18
reached [1] 49/24
real [5] 5/23 17/6 42/2 46/21 48/11
really [6] 4/11 11/20 14/23 32/12 43/24
44/7
reason [1] 17/2
reasonable [5] 7/15 32/5 32/17 48/9
49/23
recall [2] 13/23 26/13
recommendations [1] 7/2
record [2] 19/23 36/24
recorded [2] 2/14 7/8
recording [1] 7/9
records [2] 15/17 40/13
recover [1] 15/24
Red [4] 19/1 19/1 19/13 43/18
refer [1] 37/10
referring [1] 37/7
refuse [1] 9/23
regarding [1] 37/21
REGGIE [1] 1/10
regularly [2] 5/12 43/13
regularly,but [1] 21/2
relationship [3] 11/15 11/20 21/12
released [1] 5/3
remember [7] 25/3 33/9 42/4 42/19 44/8
44/18 50/16
repeatedly [2] 48/23 49/1
Rephrase [1] 37/21
report [15] 5/3 6/9 6/21 6/23 6/24 7/4
7/12 7/13 8/4 9/1 14/7 28/11 35/5 47/20
47/22
reported [2] 51/1 51/6
reporter [6] 2/5 2/6 34/6 34/12 51/4
51/18
reports [2] 41/6 41/14
representative [1] 49/5
representatives [4] 2/2 7/10 8/24 9/15
represented [1] 38/12

R
representing [1] 28/10
reputation [2] 8/13 50/19
request [1] 9/21
require [2] 10/11 30/13
research [1] 32/23
researched [1] 32/25
resolved [1] 39/7
resources [3] 40/22 40/25 41/1
respect [1] 36/19
respond [1] 10/6
response [1] 37/12
responses [1] 7/18
responsibilities [1] 32/9
rest [1] 32/12
result [1] 50/2
retained [1] 29/18
retire [1] 20/1
retired [2] 20/13 50/6
retirement [1] 23/6
retires [2] 8/3 23/5
Rice [1] 17/12
Richard [1] 28/5
right [10] 9/5 14/4 16/25 33/6 42/4 45/4
47/16 50/17 50/17 50/18
rights [1] 10/9
ROGER [113]
Roger's [6] 27/11 27/14 27/18 42/10
44/22 47/10
Rogers [1] 34/23
Room [1] 2/6
routine [3] 18/15 18/15 20/13
RPR [2] 2/5 51/18
ruin [1] 50/19
ruling [1] 37/8
run [1] 17/6
running [2] 18/8 18/18
runs [3] 9/4 39/16 39/16
Russell [1] 1/17
RUSTIN [1] 1/18

S
said [36] 6/25 7/18 10/24 11/13 13/18
13/24 14/1 14/3 14/6 14/6 14/14 14/19
20/2 22/14 24/7 31/6 32/7 33/3 34/9
35/24 36/19 36/22 37/2 41/5 42/21
42/24 43/6 46/8 47/7 47/8 47/21 47/23
50/3 50/5 50/6 51/10
Saleski [1] 1/14
salutary [1] 41/13
same [5] 9/1 23/3 23/3 29/14 35/23
sample [1] 27/12
samples [1] 43/4
San [3] 1/22 17/10 17/16
saving [1] 46/8
saw [10] 7/2 17/13 21/5 23/22 35/3 36/8
37/5 38/1 41/21 43/21
say [55]
saying [10] 11/12 13/23 16/12 28/21
29/1 35/20 46/7 47/12 48/25 50/11
says [19] 8/9 9/12 21/19 22/8 23/1 23/10
27/5 27/16 27/20 27/24 28/2 29/2 35/22
38/4 40/20 43/6 45/22 45/24 48/2
scene [2] 25/25 44/18
scholarship [1] 17/15
school [5] 17/3 17/5 17/14 17/19 18/1
scientific [2] 27/2 30/9
scream [1] 49/17
screen [1] 13/2
screens [1] 12/6
season [4] 19/11 19/13 19/14 21/11
second [2] 11/18 21/7
see [14] 5/15 17/8 17/11 18/3 34/12
38/17 38/17 38/22 39/12 42/2 42/5

44/12 44/12 49/11


seeking [1] 41/17
seem [1] 19/5
seen [4] 9/19 17/20 17/24 36/7
self [1] 20/23
self-driven [1] 20/23
senator [1] 6/17
sense [3] 31/13 41/18 49/9
sent [1] 7/4
series [3] 44/19 45/8 45/12
SESSION [1] 1/10
seven [3] 8/3 41/5 46/9
seventeen [2] 18/3 18/8
seventh [2] 23/9 39/19
seventies [1] 17/23
Seventy [1] 41/8
Seventy-nine [1] 41/8
several [5] 15/18 27/16 27/17 35/6
39/13
sewer [1] 28/25
shadows [1] 39/1
shape [1] 18/16
shepherding [1] 28/10
shirt [1] 24/4
shorthand [3] 2/14 51/7 51/11
shortly [1] 38/25
shot [1] 43/25
shots [8] 43/7 43/8 43/13 43/15 43/18
43/18 43/21 46/5
should [9] 4/20 4/21 9/4 31/10 31/19
33/3 42/24 50/9 50/11
shoulder [1] 19/12
show [22] 4/22 8/16 9/14 10/17 11/25
14/24 15/6 15/11 23/24 23/25 24/15
26/24 30/17 35/11 35/15 38/10 38/11
39/6 40/12 40/13 41/2 49/15
showed [4] 12/23 28/14 29/14 33/9
showing [1] 28/13
shown [2] 35/14 49/22
shows [4] 12/12 12/22 15/8 39/3
shuddered [1] 50/5
shy [1] 50/23
sic [6] 8/16 11/16 17/3 17/10 34/23
35/14
side [5] 18/18 18/18 18/19 18/19 30/16
significance [2] 34/20 36/1
significant [1] 33/11
signs [3] 20/5 40/13 40/13
simple [4] 5/4 30/23 30/23 30/23
simply [2] 6/25 10/17
since [4] 5/12 6/5 25/24 28/10
single [5] 23/17 28/3 41/3 41/24 42/15
sitting [3] 5/20 42/5 44/19
six [4] 22/19 23/16 32/2 39/23
sixteen [1] 18/2
slander [1] 9/14
slight [1] 27/12
small [2] 16/6 27/12
so [62]
sold [1] 41/22
solely [1] 47/22
some [19] 6/12 6/15 10/24 13/24 13/25
13/25 14/12 16/20 17/7 27/11 35/4
38/17 40/16 40/21 41/7 42/1 43/17 45/6
45/25
somebody [14] 9/12 15/5 15/18 18/5
21/1 21/9 21/9 21/10 28/15 28/24 40/14
41/21 43/3 50/11
somebody's [2] 28/7 30/19
somehow [3] 27/1 43/9 44/16
someone [1] 50/10
something [6] 9/12 14/17 15/6 17/24
29/16 50/8
sometime [2] 21/14 38/25
sometimes [2] 21/1 42/11

sons [1] 7/19


sophistication [1] 30/13
sort [2] 17/11 17/11
sound [1] 46/22
source [1] 16/2
Sox [4] 19/1 19/1 19/13 43/18
speak [1] 32/19
spent [1] 50/19
spite [2] 41/23 43/7
splash [1] 25/5
split [1] 28/16
spoke [1] 7/18
sports [1] 20/5
spread [1] 29/9
sprung [1] 25/25
stadium [1] 36/3
staff [1] 9/16
stage [1] 49/24
stand [2] 16/17 22/3
start [4] 4/7 20/19 27/1 50/13
started [3] 26/25 40/3 48/24
starter [1] 17/4
starting [1] 48/17
starts [1] 46/19
statement [15] 3/5 4/3 4/7 4/18 13/5
13/18 13/24 15/21 24/11 24/13 29/25
30/1 31/12 37/21 37/22
statements [4] 13/16 14/11 36/21 37/11
STATES [5] 1/1 1/3 1/11 1/15 51/5
station [1] 12/20
statistics [1] 19/22
stayed [1] 22/18
staying [1] 42/10
stays [1] 23/3
step [1] 49/4
stepfather [1] 11/21
stern [5] 17/11 23/24 23/25 24/21 26/10
steroid [5] 6/13 30/8 30/22 35/7 39/14
steroids [51] 5/13 6/7 6/10 6/14 7/1 8/5
8/16 13/3 13/4 13/23 14/10 14/25 15/3
15/14 15/16 15/18 15/23 16/3 16/21
21/15 21/24 22/6 22/10 22/15 22/16
23/1 23/12 23/14 23/18 27/24 29/10
29/11 29/15 31/25 32/1 32/3 34/24 39/8
39/22 39/24 40/7 40/10 40/13 40/14
40/15 41/2 41/10 42/3 42/15 46/6 46/12
Steven [1] 1/13
still [5] 9/6 16/14 16/15 28/17 44/21
stood [2] 8/18 9/21
stop [3] 8/6 23/15 34/15
stopped [2] 36/23 36/25
storm [1] 19/10
story [31] 26/19 26/19 26/21 31/4 33/12
36/9 36/9 39/2 39/2 41/25 42/1 42/8
42/23 43/3 43/5 43/7 43/9 43/11 43/23
44/3 44/4 44/8 45/2 45/13 45/22 45/24
46/20 46/22 47/1 47/4 47/6
straight [1] 8/20
strand [1] 43/12
Street [2] 1/15 1/18
strength [1] 20/9
strike [1] 19/23
strike-out [1] 19/23
stronger [1] 13/7
stuff [12] 15/24 27/2 27/5 27/20 27/22
27/25 28/2 28/8 28/8 46/11 46/18 49/3
stuffed [1] 27/7
stumble [1] 44/13
subject [1] 37/8
submit [1] 8/10
subpoena [5] 9/24 10/2 10/5 10/6 10/11
subscribed [1] 51/12
substance [1] 41/19
subtlety [1] 47/25
successful [1] 18/10

50/14
than [5] 4/18 15/7 19/2 41/4 49/16
such [1] 45/5
thank [5] 14/15 34/15 37/18 45/3 50/25
sue [1] 9/13
that [262]
sued [2] 9/13 28/18
that's [32] 5/10 5/22 10/3 10/14 11/10
suggest [4] 14/19 32/11 44/3 46/16
12/4 12/6 13/20 14/3 15/25 19/7 21/19
suggested [2] 14/11 43/23
26/13 29/4 30/3 30/24 32/4 32/22 33/11
suggesting [1] 16/3
35/20 36/25 37/7 38/4 39/2 39/2 40/25
suggestion [2] 13/6 14/22
41/24 42/8 42/12 42/23 43/9 47/5
suing [2] 28/24 29/4
their [13] 8/13 8/13 11/2 11/15 15/22
Suite [1] 1/19
31/16 32/9 36/20 38/21 38/23 41/14
support [1] 48/25
42/6 49/5
supposed [6] 4/18 31/15 32/4 32/10
them [21] 9/17 9/20 13/25 14/12 18/19
37/10 44/18
18/20 20/18 21/3 22/8 22/12 22/21
supposedly [6] 12/16 23/14 27/9 34/22 30/21 34/18 36/10 37/25 38/24 43/12
35/15 45/11
43/12 43/17 46/13 47/5
sure [4] 6/23 13/13 29/14 33/10
then [33] 5/24 6/16 7/3 8/1 8/10 9/4 9/22
surfaces [1] 27/25
9/24 10/7 10/20 11/17 12/9 14/20 16/24
surgery [1] 19/12
17/7 19/21 21/20 22/3 22/5 22/11 22/13
surprise [1] 50/23
32/9 35/5 35/5 35/24 36/8 38/8 40/5
surprised [1] 4/13
40/8 45/3 45/6 49/1 49/9
sustain [1] 37/20
there [45] 10/22 14/9 15/2 15/10 15/19
sweeping [2] 18/19 18/20
15/19 16/14 18/4 18/6 18/13 18/18 20/9
22/2 22/5 23/16 25/6 25/13 25/22 27/9
T
27/23 29/15 31/2 34/5 34/18 35/20
table [2] 3/1 4/8
35/24 38/5 38/19 39/4 39/10 39/12
take [13] 8/8 10/8 10/12 15/21 16/16
41/20 41/21 41/21 42/5 42/11 42/12
16/21 28/8 29/2 30/7 30/19 33/15 36/6
43/11 43/16 43/17 43/20 44/19 46/15
47/8
48/11 50/6
taken [8] 22/1 29/7 31/24 32/3 34/5
there's [5] 13/13 14/13 15/15 16/1 44/2
Thereupon [1] 51/1
35/15 38/18 45/18
takes [3] 7/19 19/10 41/18
these [44] 5/16 5/24 11/14 12/4 13/8
taking [5] 8/17 9/6 22/12 36/2 43/11
13/12 14/21 15/3 15/6 21/21 21/21
tale [2] 10/20 10/21
21/23 21/25 22/1 25/9 25/14 25/23
talk [10] 31/3 31/4 32/13 36/20 47/14
25/25 27/6 27/23 27/24 27/24 27/25
47/15 47/17 48/10 48/14 48/14
29/4 29/7 29/12 29/12 29/14 32/7 32/17
talked [9] 7/5 22/16 22/20 23/11 31/12
34/8 36/19 36/24 37/21 37/23 40/4
41/7 42/3 45/21 47/11
40/20 41/1 41/1 42/2 43/14 45/14 48/16
talking [3] 35/5 40/24 46/19
48/18
talks [7] 23/6 24/3 24/21 25/21 25/21
they [95]
they'd [2] 17/20 18/4
44/17 44/23
tall [1] 11/25
they'll [1] 27/13
tape [3] 7/8 7/8 9/8
they're [5] 5/6 5/7 18/19 36/22 45/15
tape-recorded [1] 7/8
They've [1] 43/7
taped [1] 7/8
thing [13] 8/12 16/6 19/8 21/5 21/7 33/1
Taxes [1] 25/12
34/3 39/4 40/3 41/24 45/13 45/22 49/23
team [1] 35/19
things [14] 10/24 11/1 13/25 15/16
teammate [1] 34/23
15/19 18/2 20/11 21/1 29/8 29/8 31/12
teammates [2] 17/19 18/1
32/18 39/13 47/20
teams [1] 43/14
think [12] 5/25 6/22 16/6 16/19 19/6
telegraphs [1] 21/22
25/17 33/11 36/23 37/13 39/10 44/19
tell [18] 9/9 12/2 16/11 16/17 16/23
45/7
24/23 26/16 27/9 27/12 33/1 37/24 39/5 thirty [4] 19/24 20/1 20/1 20/3
thirty-eight [1] 20/1
42/6 42/9 45/1 48/2 49/21 50/8
telling [6] 8/19 34/18 36/1 46/3 46/4
thirty-four [1] 19/24
thirty-four-year-old [1] 20/3
49/6
tells [4] 21/15 21/21 29/20 44/7
thirty-nine [1] 20/1
ten [2] 11/22 23/21
this [148]
terms [1] 8/4
those [18] 4/16 4/17 7/17 8/18 9/24 11/3
tested [3] 40/6 40/11 40/12
19/4 20/21 28/14 28/14 31/18 33/3 35/9
testified [11] 4/23 12/7 12/8 27/16 27/17 37/11 39/20 39/23 41/14 47/25
though [1] 37/3
35/17 36/4 37/15 42/14 42/22 47/18
testifies [6] 10/14 10/23 37/15 37/16
thought [2] 28/17 31/8
thousand [1] 49/15
42/13 42/21
testify [13] 9/3 10/1 10/8 10/10 10/10
three [12] 8/23 17/4 19/21 23/7 23/10
17/12 24/7 30/3 36/23 36/25 37/10
27/7 38/25 41/7 41/8 43/14 45/8 48/23
threw [1] 4/17
38/24 46/15
testifying [1] 12/23
through [11] 6/1 12/19 17/1 17/6 19/11
testimony [18] 12/20 16/5 16/5 16/10
30/18 42/2 46/22 48/1 48/3 48/3
throughout [2] 5/11 45/19
16/20 22/2 22/20 24/1 26/2 34/4 35/8
37/7 37/11 37/15 42/19 42/20 44/3 51/7 tie [3] 12/8 35/1 35/9
testimony's [1] 21/13
ties [1] 4/9
testing [3] 40/3 40/5 40/10
time [28] 7/23 8/15 15/11 15/13 16/8
tests [1] 30/9
19/17 20/9 21/23 21/23 23/11 24/3 25/1
Texas [6] 1/19 17/3 17/4 18/23 18/23
32/7 33/8 33/17 35/7 38/2 38/15 38/19

40/7 40/10 42/9 42/15 45/11 46/2 46/6


46/19 50/21
times [7] 19/21 27/16 27/17 41/7 47/4
47/10 49/15
tired [1] 22/11
together [7] 22/4 22/18 30/21 30/22
34/10 35/10 44/21
told [14] 6/6 7/10 7/11 16/8 26/18 27/6
29/25 32/15 36/8 39/3 42/14 42/24
48/22 48/23
too [2] 22/3 36/1
took [8] 4/14 5/13 15/23 23/14 23/18
28/9 39/8 45/23
Toronto [6] 20/6 20/7 20/14 20/16 35/13
44/21
total [1] 8/17
totally [4] 8/17 39/13 41/19 50/15
touched [1] 41/11
toward [1] 31/11
town [1] 19/10
tragically [1] 45/16
trainer [1] 6/5
trainers [4] 43/20 43/21 43/22 43/25
Tran [1] 25/2
transcribed [2] 51/2 51/11
transcript [3] 1/10 2/14 51/10
transcription [1] 2/15
trash [1] 27/8
TRIAL [1] 1/10
tried [2] 7/14 35/9
true [7] 7/18 8/22 14/2 14/2 21/18 21/19
34/9
truly [1] 39/8
truth [4] 9/10 16/17 16/24 24/15
try [4] 8/13 11/6 14/17 46/16
trying [6] 15/4 18/16 32/12 37/14 49/13
50/10
Tube [2] 8/8 25/6
Tuesday [1] 1/6
turn [1] 41/24
turned [1] 41/13
turns [1] 27/18
TV [2] 4/25 34/3
twenty [1] 19/19
twenty-four [1] 19/19
twilight [1] 20/4
two [28] 4/23 7/5 7/19 7/19 8/23 10/6
10/14 10/20 10/21 12/4 20/11 20/21
28/13 28/14 29/10 29/10 29/13 29/20
36/4 36/5 36/7 36/12 36/24 38/16 38/16
41/7 45/8 48/24
two o'clock [4] 36/5 36/7 38/16 38/16
two-fer [1] 20/21
types [1] 29/10

U
U.S [4] 2/2 2/6 5/18 41/11
ultimately [1] 9/10
unanimously [1] 32/16
unbelievable [2] 7/21 19/19
unbelievably [1] 12/1
unbelieve [1] 20/16
uncontradicted [1] 9/25
under [2] 10/10 49/18
understand [2] 14/13 31/14
UNITED [5] 1/1 1/3 1/11 1/15 51/5
University [2] 18/22 18/23
unless [1] 48/9
unpublished [1] 26/14
until [5] 6/23 25/8 25/19 27/3 48/10
up [33] 10/20 11/6 11/19 12/13 13/5
13/6 13/23 13/25 14/11 14/13 14/19
15/23 17/2 18/19 19/3 19/11 24/4 24/22
26/22 27/25 28/16 29/9 33/13 38/4 41/6
41/24 42/6 43/6 45/24 46/14 49/8 49/10

U
up... [1] 50/2
upset [1] 9/10
urging [2] 9/9 9/17
us [8] 15/9 20/23 20/25 21/1 21/4 24/23
41/15 49/6
use [6] 21/15 22/6 29/17 39/14 40/18
40/22
used [17] 6/6 6/10 6/13 15/16 15/18
16/3 16/8 24/12 31/20 31/25 40/9 40/14
40/14 41/10 41/23 46/25 47/1
user [1] 34/24
using [8] 8/16 11/11 13/23 14/10 14/12
15/14 40/13 41/2
usually [2] 22/12 27/13

V
valid [1] 14/18
various [1] 9/6
venue [1] 12/25
version [1] 21/13
very [11] 4/12 4/13 8/12 12/19 14/18
17/11 27/2 30/7 30/18 45/7 50/25
Videotape [1] 33/24
view [1] 49/14
visit [1] 9/15
voice [2] 34/1 34/8
vote [1] 32/10

W
waiting [2] 25/19 26/14
Wallace [2] 8/11 46/4
WALTON [1] 1/10
want [23] 5/24 5/25 10/17 11/23 12/18
13/1 17/1 17/8 19/6 21/20 26/20 29/22
31/3 31/3 31/4 31/14 32/13 32/18 33/25
34/16 45/13 45/25 48/4
wanted [8] 7/6 8/8 8/21 10/17 19/8 22/6
35/1 35/11
wants [6] 13/19 18/17 19/25 21/15
28/21 34/3
was [114]
Washington [4] 1/5 1/16 2/4 2/7
wasn't [9] 8/22 17/5 17/15 31/1 34/19
35/18 35/19 38/6 42/7
waste [1] 40/25
watch [3] 48/1 48/4 49/11
way [28] 4/7 8/5 8/17 10/7 12/1 12/6
14/12 15/1 15/18 16/3 17/25 18/11 27/2
27/20 30/14 37/10 37/15 37/17 39/1
39/23 41/13 42/13 42/17 42/21 44/11
46/10 49/4 50/3
Wayne [4] 17/12 17/21 17/22 18/11
ways [5] 4/23 10/14 26/21 31/17 31/18
we [48] 5/24 10/14 10/20 11/14 12/20
15/10 16/4 16/16 16/19 16/22 16/23
20/25 21/1 21/2 21/2 21/3 22/20 29/19
29/22 30/2 30/12 30/24 31/8 31/18 33/3
34/2 34/7 34/12 35/14 36/10 38/17
38/19 40/2 40/15 40/15 40/17 42/5
43/12 43/18 43/18 43/24 44/1 44/7
44/15 47/14 49/24 50/13 50/23
we'll [3] 25/17 30/17 38/24
we're [13] 4/18 5/1 16/12 16/22 27/14
34/2 35/21 42/5 47/14 47/16 47/17
49/25 50/14
we've [3] 34/10 34/10 39/25
week [7] 4/24 6/9 7/4 7/20 7/20 11/5
34/5
weights [2] 18/7 18/7
welcome [2] 16/4 16/22
well [16] 11/15 14/2 16/1 17/18 18/23
23/3 23/21 25/2 27/18 27/25 33/21 36/9
44/1 45/1 45/22 46/2

went [2] 22/4 44/7


were [20] 5/17 6/25 8/19 8/20 11/7
13/12 13/13 15/4 17/20 18/1 19/23 27/7
28/14 29/8 35/14 35/15 37/23 41/7
43/13 51/1
weren't [4] 19/22 22/3 40/4 44/4
what [101]
what's [4] 16/25 31/14 35/4 41/12
when [38] 4/8 4/18 4/22 5/21 6/8 7/3
7/13 8/2 8/7 10/23 11/5 11/21 12/7
12/24 13/22 14/21 15/3 15/11 17/14
18/1 18/11 18/13 22/6 22/11 26/24 28/1
34/11 34/11 36/25 38/18 39/10 41/22
44/12 46/11 47/5 47/18 48/4 50/5
where [10] 8/20 10/23 11/24 12/19
12/19 24/20 34/17 39/20 44/18 49/25
where's [1] 39/9
whereof [1] 51/12
whether [17] 4/22 5/20 6/13 6/24 6/25
7/7 13/21 24/23 29/17 30/21 36/11 41/9
43/12 44/1 46/25 47/16 49/9
which [9] 9/8 9/24 13/14 24/3 26/14
29/14 30/18 34/9 36/12
while [2] 44/9 47/14
who [25] 5/11 6/16 7/18 8/2 8/12 11/14
12/16 17/24 18/5 19/4 19/7 20/21 23/21
25/4 28/9 29/4 40/11 40/14 43/17 43/21
45/3 45/9 46/15 47/25 49/10
who's [4] 9/16 16/25 16/25 17/11
whorl [1] 33/4
whose [3] 40/12 40/13 43/4
why [7] 13/7 16/21 20/10 23/15 33/11
45/22 45/23
will [74]
WILLIAM [2] 1/6 2/2
win [2] 18/24 45/8
winning [1] 45/9
wins [7] 19/16 19/20 19/21 20/8 20/17
23/9 39/18
within [1] 24/13
without [4] 30/22 36/1 37/13 39/24
witness [7] 9/17 9/18 9/19 28/6 30/2
38/13 51/12
witnesses [3] 37/9 38/10 41/5
woman [1] 25/2
women [1] 11/19
won [5] 7/24 8/1 8/2 8/3 21/16
won't [2] 4/10 27/12
wonderful [1] 38/18
words [4] 4/16 4/17 5/8 28/24
work [5] 9/20 17/20 17/21 20/22 21/9
worked [1] 42/11
working [6] 17/13 18/12 20/19 20/24
22/18 28/15
workout [1] 16/8
world [10] 4/24 8/21 10/13 10/18 18/5
23/15 33/2 38/18 45/8 46/3
would [31] 7/15 8/6 8/11 8/13 9/18 10/3
10/12 12/15 15/17 15/20 16/11 18/3
19/14 20/14 21/3 22/2 22/12 23/15
25/13 30/1 30/7 30/9 30/11 30/22 39/10
39/10 39/13 41/4 45/22 45/24 49/17
wouldn't [4] 29/21 30/13 43/2 43/25
Wow [1] 42/4
write [3] 26/4 26/7 26/11
writing [2] 34/13 44/17
written [2] 34/25 41/6
wrong [3] 5/13 16/25 45/16

Y
y'all [3] 33/25 44/14 48/4
Yankee [1] 44/22
Yankees [7] 11/16 22/4 22/7 23/4 23/5
43/19 45/8
yeah [3] 29/20 43/7 45/21

year [20] 8/19 18/24 19/2 19/18 19/19


19/22 20/3 20/3 20/7 20/16 21/17 21/17
21/17 21/24 22/11 22/13 23/25 38/22
42/23 44/20
years [16] 8/16 11/13 15/13 15/18 17/23
18/9 19/19 19/24 19/25 22/19 23/7
23/10 23/16 39/17 39/23 46/9
yellow [2] 24/4 24/22
yes [2] 29/2 43/19
yesterday [2] 4/12 13/24
yet [2] 25/15 25/18
York [3] 11/15 23/4 28/19
you [155]
you'll [9] 10/7 10/23 10/25 11/5 17/10
22/22 25/16 34/21 49/7
you're [9] 5/15 6/1 32/9 34/11 34/11
39/12 46/10 49/6 50/14
you've [2] 6/11 13/1
young [12] 8/1 19/16 19/20 20/8 20/17
21/17 23/9 35/14 38/12 39/18 39/18
39/19
your [17] 12/6 13/2 13/9 13/15 14/11
24/5 24/10 26/4 29/24 31/13 31/13
32/14 32/23 36/14 36/18 37/6 48/1
yourself [1] 25/24

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