Here we have an attorney about to bring out enormously powerful, exculpatory testimony, and between tragically comical confusion of judge AND defense attorneys, Thomas FX Dunn again promoting his candidacy for "Worst Federal Lawyer In America".

The point at hand is that NO SALES EMPLOYEE ever once, in eight years, was allowed to see the mysterious nomination letters, or know its contents. This was irrefutably established at trial by witnesses -- witnesses for the prosecution, not defense!!

Here's a taste of "Who's on First," ala Abbot and Costello. How sad that this can occur in a federal trial, because the judge claimed that the nomination letters was the basis for conviction, letters never, ever perused, accessed, or otherwise known to any sales defendant!!

CROSS- BY MR. DUNN: Good afternoon, Ms. Springer.
Good afternoon.

My name is Thomas Dunn and I represent Steve Rubin. Do you know Steve Rubin?
Yes, I do.

I think you are at the end of the tunnel here so hopefully I'll only have a few questions for you just to
touch on some things. I might have missed something. You were sorting these nomination cards and these
lead cards when they came in, correct?
Not all the time. I did do it on occasion, yes.

And if you had seen one that was written in crayon, would it be fair to say you would have tossed it?

Would it also be fair to say that the administration, it was your understanding Sterling Who's Who was not to
appear to be run from strictly as an administrative standpoint as Who's Who Worldwide?
There was no administration staff in Sterling. There was no one in the public relations department, The The Route of Best Shortcuts
salespeople And the group leaders.

So it would be fair to say that, in your view, things seemed to run in a more formalized way out at the Lake
Success location?

Would it be fair to say that Steve Rubin was considered a good salesman?
He wrote a lot of orders, yes.

So would it be fair to say then if he wrote a lot of orders, he was a good salesman?
I would -- he enjoyed talking to people and his orders were very thorough. So I would say he
did enjoy what he was doing and he was a good salesperson.

So it would be fair to say he was enthusiastic about his job?

Would it also be fair to say, based on your experience, he was one of the first ones in and last ones out at Who's Who Worldwide?
Besides Martin Gross, yes.

When you say there was a lot of information and writing on some of his orders, did that reflect information
about the people he was speaking with?
A lot of information, yes.

So he was the type of person that seemed from his orders, would it be fair to say, you could draw The The Route of Best Shortcuts
conclusion that he was trying to get a lot of information from the people he was speaking with?
He got much too much information. He couldn't fit half of the information that he wrote on his order forms.

Based upon the fact that there was too much information on these orders forms and the fact that he stayed on
the phone quite a bit, did it seem to you based
on those things that he really believed in Who's Who Worldwide? Yes or no?
I can't speak for him, but from his performance I would say that he took his job seriously.

You were at Who's Who Worldwide, you started in January of 1991 is that correct?
That's correct.

And a little over four years later in March of 1995 the United States Government came in and raided the offices
at Lake Success; is that correct?
At Sterling as well, yes.

And there were a number of arrests; is that right?
That's correct.

And basically you ended your job at that point; is that right?
I would never go back there. My job was ended, yes.

So after a period of about four years you were no longer with Who's Who; is that right?
That is correct.

And in those four years, as I think Mr. Nelson may have asked you, during that four-year period plus a couple
months while you were at Who's Who, there were hundreds of salespeople that came and went; is that

And you mentioned at various times there were two or three leaders, but over the four plus years a number of
those group leaders came and went too; is that correct?
That is correct.

Would it be fair so say during those four plus years you gave your heart and soul to Who's Who Worldwide?
To put it bluntly, yes.

Would it be fair to say that you really believed in what you were doing for the company?
Yes, I enjoyed my job.

Would it be fair to say based on your observations and experience there were some salespeople that really
enjoyed what they were doing? Would that be fair to say?

Would it be fair to say during that four year plus time with Who's Who, that you considered -- withdrawn.
During this four plus years at Who's Who, you knew or came to know Liz Sautter; is that correct?
Very well, yes.

Would you consider her a friend during that period of time?
She was my best friend.

Now, during this four plus years that you were at Who's Who Worldwide, you didn't believe you committed any
criminal act; is that correct?
No, I did not believe that.

But after the raid, you decided immediately to look for another job; is that correct?
Four or five hours later, yeah.

And in fact, there came a time, months -- withdrawn. Approximately October 30, 1996, do you remember that
you testified in the grand jury?

In the Eastern District of New York.
And do you remember being asked or advised that you had the right to an attorney?

And that you could have that attorney stand outside the grand jury room when you were testifying?
I believe so, yes.

And do you remember being asked "do you have a lawyer with you today?"
I remember saying I don't need one.

Right. You remember saying that, is that a fact?
That's a fact.

And you believed you didn't need one?
That's correct.

Because you did not do anything wrong?
I did not do anything wrong.

Now, subsequent to the raid, you had a number of conversations with Liz Sautter; is that correct?
Yes, I did.

Your best friend, right?
I believed that in my heart, yes.

And you were upset with the fact that the United States Government had entered into the Who's Who
Worldwide premises and the Sterling premises and arrested not only workers but some of your friends,
I was upset at the whole situation, yes.

And would it be fair to say that you challenged Liz Sautter on certain things that she knew that even as her
best friend she never told you about; is that right?

MR. TRABULUS: Objection, Your Honor.

THE COURT: Overruled.

BY MR. DUNN: That's correct?

That is very correct.

She kept you in the dark?

MR. TRBULUS: Objection, Your Honor.

THE COURT: She kept you in the dark about what, Mr. Dunn?

BY MR. DUNN: She kept you in the dark about a number of things concerning the operations of Who's Who
Worldwide, correct?

Yes, that's correct.

MR. TRBULUS: Objection, Your Honor.

THE COURT: On what ground?

MR. TRBULUS: May we approach?

THE COURT: No, it's not necessary.

MR. TRBULUS: Your Honor, implicitly it is calling for hearsay from Liz Sautter and we don't know what was
said or when.

THE COURT: Whatever Liz Sautter said is hearsay in the connection of the employment of the company.

MR. TRBULUS: It depends when she said it, Your Honor.

THE COURT: When this conversation took place, was Liz Sautter still an employee of the company?

THE WITNESS: On many occasions.


On many occasions.

THE COURT: But on some occasions she was not an employee of the company?

THE WITNESS: Are we referring to the legitimacy of the company?

THE COURT: Referring to the conversations, whatever they were, that Mr. Dunn is alluding to and I will tell
you I don't know what conversations he's alluding to.

Well, I'm not sure either.

THE COURT: If you are not sure, say so. Ask him to make it clearer. If you don't, I will.
Yes. I would like for you to make it clearer.

MR. DUNN: Your Honor, I'll just rely on the questions I asked.

THE COURT: Good thinking, Mr. Dunn.

MR. DUNN: I have no further questions, Your Honor.




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