1 IN THE UNITED STATES DISTRICT COURT 2 FOR THE CENTRAL DISTRICT OF CALIFORNIA 3 ---oOo--- 4 5 THE ESTATE OF CHRISTOPHER G.L. ) WALLACE, by and through its ) 6 Personal Representatives, ) FAITH EVANS, and VOLETTA ) 7 WALLACE, et al., ) ) 8 Plaintiffs, ) No. CV 02-02929 FMC ) (RZx) 9 vs. ) ) 10 CITY OF LOS ANGELES, et al., ) ) 11 Defendants. ) ________________________________) 12 13 14 ---oOo--- 15 DEPOSITION OF 16 WAYMOND JOSEPH ANDERSON 17 Monday August 20, 2007 18 by ROBERT J. FRANK, Attorney at Law 19 ---oOo--- 20 21 22 23 Reported by: 24 CHERI FIKE, RMR, CCR, CSR #6200 25 1 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A P P E A R A N C E S 2 ---oOo--- 3 4 FOR THE PLAINTIFFS, THE ESTATE OF CHRISTOPHER G.L. WALLACE, ET AL. 5 ROBERT J. FRANK & ASSOCIATES, LLC 8 S. Nevada Avenue, Suite 301B 6 Colorado Springs, Colorado 80903 (719) 635-7025 7 BY: ROBERT J. FRANK, Esq. Attorney at Law 8 LAW OFFICES OF CHRISTOPHER BRIZZOLARA 9 1528 16th Street Santa Monica, California 90404 10 (310) 394-6447 BY: CHRISTOPHER BRIZZOLARA, Esq. 11 Attorney at Law 12 FOR THE DEFENDANT CITY OF LOS ANGELES 13 BIRD, MARELLA, BOXER & WOLPERT 1875 Century Park East 14 23rd Floor Los Angeles, California 90067-2561 15 (310) 201-2100 BY: VINCENT J. MARELLA, Esq. 16 Attorney at Law PETER J. SHAKOW, Esq. 17 Attorney at Law THOMAS V. REICHERT, Esq. 18 Attorney at Law 19 ALSO PRESENT: 20 JERRY WINTER, Videographer 21 22 23 24 25 2 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 ---oOo--- 2 I N D E X O F E X A M I N A T I O N 3 4 PAGE 5 EXAMINATION BY MR. FRANK...................................... 5 6 EXAMINATION 7 BY MR. MARELLA.................................. 205 8 FURTHER EXAMINATION BY MR. FRANK.................................... 241 9 FURTHER EXAMINATION 10 BY MR. MARELLA.................................. 257 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 ---oOo--- 2 I N D E X O F E X H I B I T S 3 PAGE 4 Exhibit No. 1 ................................... 180 5 Diagram drawn by the deponent 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 4 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 BE IT REMEMBERED THAT, pursuant to Notice 2 of Taking Deposition, and on Monday, August 20, 2007, 3 at the hour of 9:34 a.m. thereof, at the California 4 Substance Abuse Treatment Facility, Corcoran, 5 California, before me, CHERI FIKE, a Certified 6 Shorthand Reporter in and for the State of California, 7 there personally appeared 8 WAYMOND JOSEPH ANDERSON 9 called as a witness by the Plaintiffs, The Estate of 10 Christopher G.L. Wallace, et al.; who being by me first 11 duly sworn, was thereupon examined and testified as 12 follows: 13 ---oOo--- 14 THE VIDEOGRAPHER: This is the videotaped 15 deposition of Waymond Anderson in the matter of The 16 Estate of Christopher G.L. Wallace versus the City of 17 Los Angeles, Case No. C.V. 02-02929. It is being held 18 at the California Substance Abuse Treatment Facility at 19 Corcoran State Prison in Corcoran, California, on 20 August 20th, 2007. 21 The Court Reporter is Cheri Fike representing 22 the firm of Kings Court Reporters. I am Jerry Winter, 23 a Certified Legal Videographer, representing the firm 24 of Video Image Productions. 25 Counsel will now introduce themselves for the 5 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 video and then the Court Reporter will swear in the 2 deponent. 3 MR. FRANK: This is Robert Frank with Chris 4 Brizzolara appearing for the plaintiffs. 5 MR. MARELLA: Vincent Marella appearing on 6 behalf of the City of Los Angeles, defendant. 7 MR. SHAKOW: Peter Shakow also appearing on 8 behalf of the City of Los Angeles. 9 MR. REICHERT: And Tom Reichert also on behalf 10 of the City of Los Angeles. 11 (Witness sworn.) 12 MR. FRANK: 13 Q. Sir, could you state your name and spell 14 it for the record? 15 A. Waymond Joseph Anderson, W-a-y-m-o-n-d, 16 A-n-d-e-r-s-o-n. 17 Q. And Mr. Anderson, this deposition is being 18 taken at the Corcoran State Prison; is that correct? 19 A. Yes, sir. 20 Q. All right. My understanding is you're 21 currently being held here on a murder charge stemming 22 from an arson fire? 23 A. Well, I'm wrongfully being held here 24 stemming from a murder charge. 25 Q. And it's my understanding you're actually 6 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 working with The Innocence Project to secure your 2 release? 3 A. Yes, sir, along with David L. Bernstein. 4 Q. Okay, The Innocence Project is associated 5 with Barry Scheck and Mr. Bernstein is assisting on 6 that matter? 7 A. Yes. 8 Q. And it's my understanding that you have a 9 hearing coming up in that sometime soon; when is that? 10 A. I should be -- they already put a moving 11 order in for me. I don't know exactly when the hearing 12 is going to take place. They asked for a extension 13 because they sent some special task force out to 14 interview witnesses in Jackson, Mississippi, from the 15 D.A.'s office, so... 16 Q. And it's also my understanding, 17 Mr. Anderson, that there are travel-related records 18 indicating that you were in Mississippi as of the time 19 of the fire; is that correct? 20 A. Yes, it is. 21 Q. And this includes both travel agent 22 records and credit card information? 23 A. Yes. 24 Q. And there are eye witnesses including a 25 church bishop that place you there? 7 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. Yes. 2 MR. MARELLA: I'm going to object to relevance 3 to this. 4 MR. FRANK: 5 Q. And there were also other eye witnesses 6 who have since recanted in relation to that case? 7 A. Yes. Since you're speaking of my case, 8 before we go any further, I cannot do this deposition 9 according to David L. Bernstein if no one -- he wants 10 the videotape, any written statements or any audiotapes 11 from this deposition turned over to him immediately 12 whenever they're available and can be made ready for 13 him, and I'm willing to testify or do whatever I need 14 to do. So he told me to give you his address, his 15 phone number, and he wants anything done in this 16 deposition turned over to him. 17 MR. MARELLA: Thank you. 18 MR. FRANK: 19 Q. That's fine. 20 A. All right. 21 Q. On behalf of the plaintiffs, Mr. Marella, 22 I'll make sure that Mr. Bernstein gets copies of -- 23 MR. MARELLA: Sure, we have no -- 24 THE WITNESS: He wants both sides to agree 25 that whatever will be turned over to him, because he 8 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 doesn't want -- I have an active appeal right now and 2 we don't need anything messing up what he has going on 3 in my case. 4 MR. MARELLA: We can stipulate that 5 Mr. Bernstein will be provided with copies of the 6 video, audio, whatever is necessary. 7 MR. FRANK: 8 Q. And just to make sure the record's clear, 9 we'll give him the video, the audio, any transcript of 10 the proceeding, as well as a copy of any exhibits. 11 A. Okay. 12 Q. Is that fine, Mr. Anderson? 13 A. That's fine. 14 MR. MARELLA: And that's agreed. 15 MR. FRANK: 16 Q. Mr. Anderson, we're here to ask you some 17 questions about some interviews that you gave to the 18 L.A.P.D. specifically regarding the murder of 19 Christopher Wallace and also some activity by two 20 former L.A.P.D. Officers, David Mack and Rafael Perez. 21 Now, I think that I've gathered all the times that 22 you've discussed these matters with the L.A.P.D., but I 23 don't know that I have, so what I'm going to try to do 24 is kind of go over them and see whether you remember 25 anything other than what I've been -- been given. 9 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. Uh-huh. 2 Q. I have a tape, which is number 368662, 3 regarding a call that you made to the Wallace murder 4 hotline; do you recall making a call to the Wallace 5 murder hotline? 6 A. I never made a call to the Wallace 7 hotline. 8 Q. Okay. Do you recall speaking with a 9 Officer Balderama in April of 1997, on the telephone? 10 A. No, sir. I know the call that you're 11 speaking of, but I did not place the call to the 12 hotline. 13 Q. Okay. Tell me your recollection or 14 understanding. You indicate you know the call, tell me 15 what you know of the call. 16 A. I was housed at NCCF at Wayside County 17 Facility, L.A. County Facility, and inside the housing 18 facility I was housed at there was an inmate that I 19 became acquainted with inside of the, uh, jail, as well 20 as I knew from outside of the jail, his name is Michael 21 Robinson, aka Psycho Mike, as well as was on the 22 telephone with a guy by the name of Keith Davis, aka 23 Kevfe D, who I was very, very close to for many, many 24 years and was associated with on the streets from South 25 Side Compton Crips. Those two individuals asked me to 10 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 do that interview with the L.A.P.D.'s finest that 2 you're speaking of. I never contacted L.A.P.D. on my 3 own. I conducted a interview by the instructions of 4 Psycho Mike and Keith Davis. 5 Q. All right, so to make sure that I'm 6 correct, then, what it is, is you did speak with 7 L.A.P.D. on the telephone, but you weren't the one who 8 initiated the call? 9 A. I never spoke to L.A.P.D. on the 10 telephone. Those two individuals initiated the phone 11 call and I was picked up by L.A.P.D. and taken to 12 Parker Center. 13 Q. Do you know of any telephone call where 14 you were purportedly speaking with L.A.P.D. but it 15 really wasn't you? 16 A. Not that I can recall from -- again, my 17 recollection is that Michael Robinson made the phone 18 call, actually his girlfriend made the phone call, and 19 20 -- about 30 minutes later some FBI agents showed up 20 to NCCF and tried to interview me. I refused to talk 21 to them. The next day, I believe, four or five 22 L.A.P.D. officers picked me up and took me down to 23 Parker Center. 24 MR. FRANK: All right, would you go ahead and 25 play track one. Hold on before you play that. Don't 11 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 play it yet. 2 Mr. Marella, the Court Reporter has asked me a 3 very good question, which is should she attempt to 4 transcribe that section of the tape. What I've done on 5 most of these is to cut it into sections. I would be 6 happy to attach a disk referencing the sections as 7 opposed to have the Reporter transcribe them. 8 MR. MARELLA: If we could just have a moment. 9 MR. FRANK: Sure. 10 MR. SHAKOW: I know we've got video and audios 11 too, so I don't know the quality of the tape. I think 12 we can probably do it that way. 13 MR. MARELLA: Assuming that the quality is 14 fine and you can -- we can hear it, we have no 15 objection to that. 16 MR. FRANK: You know, I have to be completely 17 honest, these were L.A.P.D. tapes and at times the 18 audio is somewhat spotty. I think -- I think that 19 it's -- it's -- certainly you can make out everything 20 on the tape if you listen closely. I am a little bit 21 concerned that it would not be picked up obviously in 22 this proceeding by the microphones that are available. 23 MR. SHAKOW: Can we go off the record just for 24 a minute rather than -- 25 MR. FRANK: Sure, absolutely. 12 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 THE VIDEOGRAPHER: We're going off the record 2 at 9:33. 3 (Recess taken.) 4 THE VIDEOGRAPHER: We are going back on the 5 record at 9:35. 6 MR. FRANK: Pursuant to stipulation of 7 counsel, the Court Reporter is relieved of her 8 obligation to transcribe the audio portion of the tapes 9 that we're going to play. Plaintiffs' counsel will 10 provide defense counsel with a disk containing discrete 11 tracks to the extent that tapes are referenced by 12 minute and second. They're already in defendant's 13 possession, and I don't think we need to go beyond 14 that. 15 MR. MARELLA: That's so stipulated. 16 MR. FRANK: Okay. 17 Q. Mr. Anderson, what I'm going to -- what 18 I'm about to play for you is a tape which the L.A.P.D. 19 has indicated to us is a call to the Biggie hotline 20 wherein you gave statements to the L.A.P.D. I'd like 21 you to take a listen to it and tell me whether it in 22 any way refreshes your recollection. 23 A. All right. 24 MR. BRIZZOLARA: Ready? 25 MR. FRANK: Yeah, go ahead. 13 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 (Audiotape played.) 2 THE WITNESS: I remember now. That call was 3 placed from NCCF. I didn't recognize it as a hotline. 4 That number was given to me by a guy by the name of 5 Michael Robinson. And before that phone call Michael 6 Robinson asked me to do him a favor. I thought the 7 guy's name that I met with from the FBI was Miller, but 8 now if it's Dan McCullin, I couldn't remember. I 9 actually just typed up some information and sent it to 10 somebody on the street about this case. And I actually 11 called the guy, the FBI agent named Miller, but it was 12 Dan McCullin. 13 Michael Robinson, as well as a guy named Keith 14 Davis, who I was associated with on the street, asked 15 me to contact the Los Angeles Police Department to see 16 if their names were implemented into the crime. 17 Michael Robinson asked me to place the call so he could 18 receive his payment for working for the FBI. He was 19 actually supposed to bring them information monthly, 20 but he was incarcerated at the time. And we were in 21 the K-9 tank at NCCF. So that's why that phone call 22 was placed. 23 Q. All right, so you do recall that phone 24 call? 25 A. Yes. 14 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. All right. And the information that you 2 gave the L.A.P.D. during that phone call, was it true 3 or not true? 4 A. No, it wasn't true. 5 Q. Okay. And why was it that you gave the 6 L.A.P.D. false information during that call? 7 A. Well, first of all, I wouldn't help the 8 Los Angeles Police Department turn on a light bulb 9 during a terrorist attack, so... When you're in prison 10 or incarcerated and there's certain gang members who 11 ask you to, uh, assist them in doing something when 12 they're trying to manipulate the police or they're 13 trying to receive payment for the police because 14 they're one of their informants, when you've never been 15 in jail before in your life, you sort of, you know, 16 follow suit or, you know, fall in line and do what 17 you're asked to do. And Michael Robinson is a known 18 BGF gang member, aka Psycho Mike. And he was working 19 for the FBI. 20 He overheard me having a conversation with 21 Keith Davis, who I am very, very close with from South 22 Side Compton Crips, he used to work for my company on 23 the street. During the phone conversation I was having 24 with Keith Davis, as well as Christopher Wallace, on 25 March 8th and March 9th, I spoke to Biggie on the 15 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 phone. I was very close to Christopher, Damian Butler, 2 Puff Combs, Sean Combs, Gene Griffin, all the 3 individuals, Andre Harrell, who started Uptown 4 Entertainment. I know all those guys. 5 I was on the phone speaking to Keith Davis on 6 March 8th and March 9th, and Michael Robinson overheard 7 that phone conversation and then pulled me to the side 8 and asked me would I be willing -- after he heard what 9 he heard, I won't go into what I said to Keith Davis 10 over the phone, but he asked me at that point would I 11 assist him in receiving his monthly payments that he 12 was getting from Dan McCullin. I thought the guy's 13 name was Miller again from the FBI. 14 He was receiving 2500 to $5,000 a month for 15 information he was providing on Lueders Park Street 16 Gang. He told me that he was initially assigned to get 17 any information from this guy named Rick James, I don't 18 know Rick James. He mentioned the name Rick James to 19 me. Not Rick James the entertainer, but Rick James the 20 gang member who works for Suge Knight. 21 Out of fear and, you know, not wanting to, I 22 would say, get assaulted inside of a jail cell, I 23 agreed to take his concocted story to the Los Angeles 24 Police Department. He was dealing with a guy that 25 worked for the Sheriff's Department named Richard 16 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Valdemar was his handler for the Sheriff's Department, 2 and anything that Michael Robinson wanted done inside 3 the county jail he could have done in a heartbeat 4 because of Richard Valdemar's influence. 5 So at the table inside of NCCF he concocted 6 the story. He wanted me to say that I saw Suge in a 7 holding facility. I know Suge very well. Me and Suge 8 used to do business together and Michael Robinson was 9 aware of that. So out of fear I made -- initiated the 10 phone call to what he gave me a detective's number. I 11 didn't know anything about a hotline. He told me his 12 girlfriend had already previously called and told the 13 detective that I had information and that they would be 14 picking me up. Then he begged me all that day to call 15 that detective on the telephone, and that's why that 16 phone call was placed. 17 Q. Now, I thought I heard you say that you 18 spoke with Christopher Wallace on March 8th or 9th; is 19 that correct? 20 A. I did speak to Christopher Wallace on 21 March 8th and March 9th. 22 Q. Okay, was it March 8th or March 9th? 23 A. On both days, sir. 24 Q. And approximately what time of the day did 25 you speak with him? 17 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. Several times that day. I'm not going to 2 sit here -- I don't remember it was so long ago, years 3 ago, but I spoke with him both those days. 4 Q. Okay, did he call you or did you call him? 5 A. I called him, I was in jail. 6 Q. And did you use a phone in your specific 7 unit or pod? 8 A. Inside of the pod at the L.A. County -- at 9 the NCCF jail facility. 10 Q. And where did you call him? 11 A. On his cell phone that was in Andre 12 Harrell's name and at Andre Harrell's home, as well as 13 at the Marquis Hotel. 14 Q. And what was the substance of your 15 conversation with Mr. Wallace? 16 A. Due to I could be incriminated by that 17 until I'm given immunity I will not talk about that. 18 Q. And, Mr. Anderson, I'm asking you this 19 simply for matter of structure, I'm not trying to push 20 you around or anything, but -- 21 A. Uh-huh. 22 Q. So by that you're refusing to answer my 23 question? 24 A. I don't want to be incriminated in 25 anything. 18 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. Okay, and, again, you're asserting your 2 Fifth Amendment rights and you're refusing to answer my 3 question? 4 A. Yes. 5 Q. Okay, thank you. Did you have any phone 6 conversations with any other person on March 8th or 7 March 9th? 8 A. Yes, I did. 9 Q. And with whom did you speak other than 10 Mr. Wallace on March 8th or 9th? 11 A. Keith Davis. 12 Q. And where was Mr. Davis when you spoke 13 with him? 14 A. He was trailing Christopher Wallace. 15 Q. And on what phone were you calling him? 16 A. On his cell phone. 17 Q. And do you recall that number? 18 A. No, sir, I'm sure they can be found from 19 the county jail. I'm not going to sit here and lie. 20 I've never been under oath, I'm telling the whole truth 21 and nothing but the truth. 22 Q. And any conversation with anyone aside 23 from Mr. Davis and Mr. Wallace? 24 A. I spoke to Shane I think on March 9th. 25 Q. Who is Shane? Shane, what's Shane's last 19 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 name? 2 A. I don't know his last name. He hangs out 3 with Christopher and them and Sean. I spoke to Shane 4 and Sean. I spoke to a guy by the name I'll just 5 identify by Hawkins at this point. I will not reveal 6 his first name. 7 Q. And he's your former business manager? 8 A. It's several Hawkins. My former business 9 manager has about ten brothers who are all South Side 10 Compton Crips. 11 Q. Was this a different Hawkins than your 12 business manager? 13 A. Yes, sir. 14 Q. And is there a specific reason you can't 15 reveal his name to me? 16 A. Out of fear for the safety of myself and 17 my family. 18 Q. Do you have some concern about your safety 19 as a result of this deposition and the testimony you 20 may give? 21 A. Yes, I do, but I've come to the point 22 where I'm gonna just tell the truth now. I want the 23 truth to come out. 24 Q. Where did you speak with Mr. Combs? 25 A. Which time? 20 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. On March 8th and March 9th. 2 A. Through telephone conversations. 3 Q. And do you know where he was when you 4 called him? 5 A. He was at Andre Harrell's home. 6 Q. And did you reach him on his cell phone or 7 on a landline? 8 A. On a direct landline. 9 Q. And do you recall what time of the day 10 that call was? 11 A. No, sir. 12 Q. Was it multiple calls or just one? 13 A. Multiple calls. Trying to convince him to 14 pay 1.2 million dollars to somebody they owed for drug 15 money. 16 Q. And who was that that they owed 1.2 17 million dollars to? 18 A. Again, because of the safety of my family, 19 I already said the guy's name. Their family is known 20 as the Hawkins family, they're out of Compton, 21 California, and that's all I can say on that right now. 22 Q. So to the extent that you don't answer 23 completely, again, is that a Fifth Amendment privilege 24 that you're asserting? 25 A. Well, I want to answer your question 21 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 completely, I just don't want to place myself -- 2 L.A.P.D. has a way of leaking out their information, 3 their tapes get to people, and I'm fully aware of what 4 discovery is and how lawyers -- these people have a lot 5 of money and eventually their attorneys are going to 6 get these tapes. So until my family is secure and 7 myself is secure, as well as me having an open appeal 8 right now, I'm not going to place myself in any danger. 9 Q. And you believe if you answered the 10 question any more completely than you have, you would 11 be placing yourself and your family in danger? 12 A. Yes, sir. 13 Q. And part of what you're trying to do here 14 today, Mr. Anderson, is make sure that when you answer 15 these questions, you're answering them to the extent 16 that you can in a way that does not subject you or 17 yourself or your family to additional danger? 18 A. Yes. 19 Q. And by danger you mean danger or risk of 20 bodily harm; is that correct? 21 A. Bodily harm, and I've been threatened that 22 if I come forth with the truth on this case that 23 certain individuals are going to sabotage my case. So 24 I'm -- you know, again, I want to be truthful. This is 25 the first time I've ever been under oath with anybody 22 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 in the Christopher Wallace case and I'm gonna tell the 2 truth. I'm -- you know, the truth needs to come out. 3 Q. Who threatened you in that regard? 4 A. In regard to speaking in this deposition? 5 Q. Yes, sir. 6 A. I've been threatened by Kenneth Boagni, 7 I've been threatened by Freddie Mingo, I've been 8 threatened by Mario Hammonds aka Abu Hakk, all the 9 participants that are involved in this charade that is 10 going on. 11 MR. REICHERT: I've sorry, can I just ask, was 12 the last name Abu Hakk? I didn't -- 13 THE WITNESS: Abu Hakk. Mario Hammonds goes 14 by Abu Hakk. 15 MR. REICHERT: Every so often -- you speak 16 quickly and faster than -- 17 THE WITNESS: I'm sorry. 18 MR. REICHERT: -- I write, so... 19 THE WITNESS: I'm sorry. 20 MR. REICHERT: Every so often I'm going to ask 21 you to slow down or repeat it. Thanks a lot. 22 MR. FRANK: 23 Q. And, Mr. Anderson, I'm sorry, I'm going to 24 have to do the same thing. You mentioned Mr. Boagni, 25 you mentioned Mr. Hammonds, there was a third name, who 23 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 was that? 2 A. Freddie Mingo. 3 Q. And when did Mr. Boagni threaten you? 4 A. Well, Mr. Boagni has been calling my house 5 for the last three months. I have phone records and 6 I've turned those phone records over to someone that I 7 trust. 8 Q. Have you turned them over to the law 9 enforcement? 10 A. I don't trust L.A.P.D., again, as I 11 wouldn't help them turn on a light switch in a blackout 12 in a terrorist attack. I don't trust L.A.P.D. So 13 someone has them who I trust. 14 Q. And what is the nature of the threats from 15 Mr. Boagni? 16 A. Well, they progressed. You know, first it 17 started that, you know, he was offering $25,000, uhm, 18 that was the first phone call to back his story of what 19 he told the plaintiffs in this case. Uh, then they 20 progressed up to $50,000 if I would back what he's 21 saying in his, uh, statements, because he has not done 22 his deposition what he told me yet with you guys. Uh, 23 then it went up to $75,000. Then it went up to 24 Christopher Wallace's mother was willing to pay me a 25 hundred and 50,000 dollars. Then he had his CCO 24 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 friend, who is the leader of the Crips, transferred 2 down to this prison yard, and, you know, try to twist 3 my arm to lie. I'm not gonna lie. I'm not for sale. 4 So, uh, those have been Boagni's threats. Everything 5 Boagni has provided to the Los Angeles Police 6 Department, as well as to the plaintiffs in this case, 7 is a lie. And half of the information he himself, as 8 well as Mario Hammonds, concocted and asked me to be a 9 part of their lies inside of this yard here at this 10 facility. We were all housed in Delta 3 in 2001 and 11 2002 when he revealed to me that he had first started 12 speaking to Russell Poole, the detective that used to 13 work for the Los Angeles Police Department. 14 Q. In relation to the hundred and 50,000 that 15 Mrs. Wallace allegedly offered, you've had no 16 conversation with Voletta Wallace, have you? 17 A. I wouldn't call her. They asked me to 18 call her. She's supposed to be sick or something 19 Boagni said and he wanted me to actually -- I guess 20 Damian's in jail. I know Damian Butler from whatever 21 we used to do, you know, on the streets. And I guess 22 he's incarcerated now, and he -- they wanted me to call 23 her. I actually know Preme, too. He's like the big 24 shot in New York. He's a good friend of mine. And I 25 refused to call her, so... 25 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. All right, so my question was slightly 2 different from that, Mr. Anderson, and that is you've 3 never spoken with her at all? 4 A. No. 5 Q. All right. 6 A. Because I wouldn't call her. If I wanted 7 to speak to her, I'd speak with her. 8 Q. And she never offered you a hundred and 9 50,000, somebody told you that she offered you a 10 hundred and 50,000, right? 11 A. Yes, sir. 12 Q. All right. And when was this offer made 13 to you? 14 A. Whatever day Freddie Mingo arrived at this 15 prison. I don't remember the exact day. Again, I've 16 turned the information over to someone that I trust and 17 he has that information. 18 Q. Okay, and who is that that you turned that 19 over information to? 20 A. I'm not gonna divulge that. 21 Q. And, again, is that as a result of a 22 personal security concern? 23 A. It's someone who I know that will expose 24 the truth and make sure my family is safe when the time 25 comes. 26 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. All right, who is Freddie Mingo? 2 A. He's the leader of a prison gang called 3 the CCOs, Consolidated Crip Organization. He is 4 Kenneth Boagni's confidant. Kenneth Boagni himself is 5 a 111 Crip and is a member of the CCOs. 6 Q. And when did he threaten you? 7 A. Well, the threat was more why would I want 8 to assist or -- or get the Los Angeles Police 9 Department out of a lawsuit? Why would I be willing to 10 help clear -- I'm speaking out of -- out of context 11 here or content here because I'm, like, breaking the 12 story down, but to answer your question is because they 13 feel why would I want to tell the truth about David 14 Mack and Rafael Perez? They have nothing to do with 15 this case. They had no involvement with the Biggie 16 Wallace murder, none at all. And they're mad at me 17 because they feel that I'm going to assist the police, 18 are willing to tell the truth to help the police out, 19 that's how they see it, instead of trying to lie to 20 help the Wallace family win a lawsuit against the City 21 of Los Angeles. And I just can't do it anymore. I'm 22 not -- I'm not scared anymore. 14 years of my life has 23 been taken from me that I've been in prison and I don't 24 care anymore, I'm just gonna tell the truth. 25 Q. Okay, so Mr. Mingo didn't threaten you, 27 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 it's -- it's more at this point of your life you just 2 feel a need to tell things different? 3 A. It's not tell -- 4 MR. MARELLA: Objection, that misstates the 5 testimony. 6 MR. FRANK: 7 Q. I didn't mean to misstate it, 8 Mr. Anderson. Go ahead and tell me where I am wrong. 9 A. What I'm trying to say is, yes, there were 10 threats, because in prison, it's just like if you in a 11 room with ten terrorists or you in a room with Osama 12 Bin Laden, and you President Bush, you know you're not 13 gonna leave outta that room, you know what I mean? So 14 if -- if you're in that type of environment, I'm in 15 prison, this is a level four prison, this guy is the 16 leader of the Crips. When he telling you to do 17 something and you don't do it, I still have a life 18 sentence over my head. There's only one -- one option 19 he has when you disobey something he says to do, and 20 that's get stabbed, get shanked, get beat down. So 21 when he's coming to me telling me to do something, it's 22 really a direct order. Not that I'm a gang member, but 23 I come out of a Crip neighborhood. I was born on 39th 24 and Western, which is called the Rolling 30's Crips. 25 I've never been a gang member in my life. I've never 28 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 been in jail in my life, and so I'm scared. I'm not 2 gonna sit here and act like I'm a tough guy, but I 3 can't fight, you know, 700 Crips on a prison yard. 4 Q. When did Mr. Hammonds threaten you? 5 A. Mr. Hammonds is falling in suit with 6 Freddie Mingo and Kenneth Boagni, so there's something 7 called kites in prison. I've received what are called 8 several kites, which is a message from Mario Hammonds 9 who is now living in I guess up in the north -- 10 northern area somewhere in California. His message was 11 that, you know, if I want to survive, that I should 12 back, uh, the first story that himself and Kenny Boagni 13 formed here in this prison that they were going to say 14 Suge Knight, Reggie Wright, Big Psychs, and, you know, 15 all the other lies they told were involved with this 16 murder. And, again, up until this day of this 17 deposition I've been telling them I'm gonna do what 18 they've asked me to do, but I've come in here and in my 19 heart I got to do what's correct and what's right. 20 Q. Is your answer complete? 21 A. Yeah, the best as I can answer your 22 question. 23 Q. Sometimes, Mr. Anderson, I'll ask you 24 that, I'm not trying to get you to tell me more. I 25 just want to make sure that I don't start talking 29 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 before you're done. 2 A. I just -- again, I think this is being -- 3 I'm breaking up -- this isn't, you know, the order 4 of -- of how you're asking the questions so I'm trying 5 to decipher from you what I can to describe to you the 6 correct answer that you're asking for. 7 Q. All right. Now, I have a second time that 8 you were interviewed, which was on March 27th of 2002. 9 And for the record that's -- excuse me, a second time 10 you were interviewed you were brought to Parker Center 11 by Katz and Poole; do you remember that? 12 A. The second time I was interviewed? Or 13 that should be the first time I was interviewed. 14 Q. Okay, I'm sorry, I was referring to the 15 telephone call as an interview, I apologize. 16 A. Uh-huh. 17 Q. All right, so the first actual interview 18 you had was by Detective Katz and Poole, correct? 19 A. Right. 20 Q. And that was in Parker Center? 21 A. Yes, sir. 22 MR. FRANK: All right, and for the record 23 that's identified as tape number 173974. The 24 plaintiffs have not been given a copy of that tape, so 25 to the extent that's locatable, we'd sure like to have 30 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 that. 2 MR. MARELLA: Are we talking about 1997, 3 counsel, for the record? 4 MR. FRANK: April of 1997. 5 Q. Then the next interview we show, 6 Mr. Anderson, is on March 27th of 2002. 7 A. Yes. 8 Q. And that's tape number 275549. Do you 9 recall that interview? 10 A. Yes, I do. 11 Q. All right. Then I show that you were 12 interviewed twice on June 18 of 2002; do you recall 13 that? 14 A. I don't remember those interviews. 15 Q. Okay. 16 A. Who was involved with those interviews? 17 Q. It was a Detective Hampton and also 18 present were Investigator Doug Kennedy from the 19 Organized Crime Unit of the Orange County District 20 Attorneys and a person named Guarneri, I believe it is. 21 A. Uh-huh. I remember those interviews, yes, 22 sir. 23 Q. All right. And then the last -- I have 24 another interview on July 18 of 2002; do you recall 25 that? 31 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. Was Kennedy involved there? 2 Q. I'm sorry, I'm sorry, yeah, Kennedy was 3 the July 18th. 4 A. Uh-huh. 5 Q. And you indicated that you did recall the 6 June tape-recordings; is that correct? 7 A. Yes. 8 Q. Okay. And then you were given a polygraph 9 examination as well; is that correct? 10 A. Yes. 11 Q. And when did the polygraph take place? 12 A. I don't -- you tell me, you got the paper 13 there, I don't know. 14 Q. Well, it's not on the paper, that's why 15 I'm asking. 16 A. I don't know. I believe it was the first 17 time that Russell Poole and them held me captive at the 18 Parker Center. 19 Q. All right, other than the interviews that 20 I've just gone over with you, have you had any other 21 interview where you've discussed the Christopher 22 Wallace murder with any detective? 23 A. Not that I can recall. 24 Q. At the time of your polygraph you were 25 under a doctor's care -- 32 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. Uh-huh, and I tried to tell him that. 2 Q. -- for mental health issues; is that 3 correct? 4 A. Uh, yes. 5 Q. What were those issues? 6 A. I had never been in jail, I was having a 7 nervous breakdown. You know, scared as hell of being 8 in -- in jail. I was on medication at the time and 9 diabetic and I have epilepsy. And, again, I guess it 10 was just, you know, a mental breakdown from, you know, 11 being taken out of a 10,000 square foot home and being 12 put in a box, you know, every day. My life was 13 dramatically, you know, changed. And I'm trying to get 14 somebody to listen to me, and Los Angeles Police 15 Department, they don't, you know, give a damn, nor any 16 other detectives that have interviewed me. As soon as 17 -- they want me to tell them what I know, but they 18 don't want to talk about my case. And this is the 19 first time that I'm in a position that I finally got 20 someone to investigate my case correctly. 21 And so when detectives come and see you, 22 you're trying to tell them that, "Hey, I'm innocent for 23 a crime." They're saying, you know, "Yeah, yeah, yeah, 24 we hear you, but, you know, tell us who killed the 25 biggest rapper in the history of L.A., you know, we'll 33 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 talk about that a little later." To me that's 2 degrading and disrespectful so, okay, if you guys think 3 I'm a sucker or full of shit, then here you go. You 4 want a story, here you go. So I have no respect for 5 any law enforcement in Los Angeles. And any time they 6 come to me thinking that I'm stupid enough to help them 7 solve their -- their case, I'm basically just giving 8 them the bone that they wanted. 9 Q. Okay, my question was a little bit 10 different than that, Mr. Anderson. 11 A. I heard it differently. 12 Q. That's fine. And when -- when I tell you 13 that, it's because I, as the guy asking the 14 questions -- 15 A. Uh-huh. 16 Q. -- am responsible for the questions. 17 A. Okay. 18 Q. If you don't understand the questions, 19 it's usually because I screwed up. 20 A. Okay. 21 Q. So -- so if we could have an agreement, 22 Mr. Anderson, if at any time you don't understand what 23 it is I'm asking you, you just tell me and I'll make 24 sure that I do my best to make it understandable. 25 A. Okay. 34 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. All right. I was trying to get to your -- 2 your mental health condition. You indicated at the 3 time of your polygraph that you were under medication? 4 A. Yes. 5 Q. Do you recall what medications you were 6 on? 7 A. That was so long ago, I don't remember. I 8 don't -- 9 Q. Are you currently on any medications? 10 A. No, sir. 11 Q. Now, you indicated -- 12 A. Oh, excuse me, yes, sir, I take insulin. 13 I'm diabetic. 14 Q. You indicated that you were epileptic as 15 well, is that -- 16 A. Yes. 17 Q. Okay, are you on any anticonvulsant? 18 A. I go off and on. I take Dilantin, so it 19 depends on, like, if I go into -- I have episodes where 20 I'm twitching or my muscles are usually -- I have a 21 tick, so sometimes I'm ticking or when I get anxious or 22 something like that, then I'll go get back on it. 23 Q. So you have myoclonic seizures? 24 A. Yes. 25 Q. Do you have absence seizures? 35 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. No. 2 Q. And do you have grand mal seizures? 3 A. I haven't had a grand mal seizure since I 4 was, like, 15. 5 Q. I have the exact same seizure disorder, so 6 I'm aware of it. 7 A. So you know a lot about it. I was 8 wondering. You're a lawyer. 9 Q. When's the last time you were on Dilantin? 10 A. Five months ago. 11 Q. Did you do anything in preparation for 12 this deposition, Mr. Anderson? 13 A. I don't understand your question. 14 Q. Okay. Oftentimes when folks know they're 15 going to be deposed, they go back, they review 16 documents, they review notes, sometimes they talk to 17 people about their deposition. Did you do any of those 18 types of things? 19 A. I've lived this. I know it in my head. I 20 don't have to talk to anybody or review anything. 21 Newspaper clippings, magazines, I don't need any of 22 that stuff. 23 Q. All right, so -- 24 A. The answer is no. 25 Q. Okay, thank you. When is the last time 36 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 you spoke with anyone from the City of Los Angeles 2 regarding the Wallace murder? 3 A. I've never spoke to anyone from the City 4 of Los Angeles. I placed a phone call when I received 5 a threat from Kenneth Boagni in, like, 2002 to a guy by 6 the name of Don Vincent, and he never took my phone 7 call as I recall. And I was trying to warn him at that 8 time that Kenneth Boagni was lying and was asking me to 9 continue to back his lie, and I wasn't lying anymore. 10 As soon as my son graduated from high school, I was 11 ready to tell the truth, you know. 12 Q. And I apologize, Mr. Anderson, I wasn't 13 listening close enough, when did you place that call to 14 Mr. Vincent? 15 A. I don't remember, sir. You asked me, 16 that's the only person I ever talked to about it from 17 the City. 18 Q. Okay, do you recall what year it was? 19 A. No, sir. My son graduated from high 20 school in 2005, so I would say maybe 2000 -- the summer 21 of 2005 maybe. Actually, would you consider a Los 22 Angeles Police Department officer a city employee? 23 Q. Yes. 24 A. Okay, I also placed a call to Detective 25 Kates or Katz, whatever his name is, when I learned 37 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 that Kenneth Boagni's statements were supposedly had 2 been found in some drawer of his, because Kenneth 3 Boagni told me that those statements were placed in his 4 drawer by a certain police officer. So I tried to warn 5 him because I didn't -- I didn't believe what was being 6 done to him was -- was fair. And call me stupid or 7 whatever, but I didn't think it was fair what was going 8 to be done to Mr. Kates. 9 Q. Okay, you lost me. You indicated that 10 Boagni said that they had been placed in a drawer by a 11 police officer other than Mr. Katz? 12 A. Yes, sir. 13 Q. Okay, did he tell you who placed them in 14 the drawer? 15 A. Yes, sir. 16 Q. Who placed them in the drawer? 17 A. Ya May Christie. 18 Q. And how is it that Ya May Christie came to 19 place the -- 20 A. Well, again, I'm going out of 21 chronological order here, and it's out of context. I'm 22 trying to answer the questions as you ask me, but -- 23 Q. Sure. 24 A. -- going back to the 2002 interview that I 25 did with the Los Angeles Police Department, I was 38 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 instructed when I was down on my appeal with Larry 2 Longo if I did not corroborate and call -- Kenneth 3 Boagni gave me those detectives' phone number and told 4 me when I was down at the L.A. County Jail that if I 5 came back to prison without calling those detectives, I 6 wouldn't last on the yard a week. And so when I knew 7 that Larry Longo had messed up my appeal purposely for 8 Mr. Knight, I placed a phone call to detective, 9 whatever the detective's name, instructed by Kenneth 10 Boagni. That was the story that was conducted -- 11 conducted -- or concocted I should say, by myself, 12 Kenneth Boagni and Mario Hammonds on this yard, and I 13 did exactly what Mario Hammonds and Kenneth Boagni 14 asked me to do. 15 Q. Okay, but my question to you is how do you 16 know that Ya May Christie put those documents in Katz's 17 drawer? 18 A. Because part of that interview -- my 19 interview was supposed to be the interview that would 20 come up in Detective Katz's drawer. Kenneth Boagni and 21 Ya May Christie had a personal relationship from him 22 working on the Perez cases, and that's how he knew her. 23 And so he told me that my statement would come up 24 missing, and then that Mr. Sanders people, as he 25 referred to them as "his boy," would have the statement 39 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 placed into -- it would magically appear. And that the 2 burden of proof was a lot lower for civil cases. It's 3 a big answer around what you're asking me so I don't 4 know how to explain it to you without going into all 5 these details about it. 6 Q. I'm just trying to understand it, 7 Mr. Anderson, and maybe I can say it back to you. Your 8 -- your understanding was that Ya May Christie had a 9 personal relationship with Boagni as a result of the 10 Perez -- 11 A. Investigation. 12 Q. -- investigations, correct? 13 A. It's not -- I know it is. He used to call 14 her at some place in Arcadia on the telephone directly. 15 They had in my opinion a improper sexual relationship. 16 Q. Okay. 17 A. So... 18 Q. That's not anything you witnessed, right? 19 A. Yes, it is. I used to be right next to 20 him on the phone whenever he would call her from this 21 building here, from Delta 3. 22 Q. All right. 23 A. Again, I don't know the year. I'm sure 24 you guys could find it out. 25 Q. All right, so you witnessed one side of a 40 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 phone call; is that correct? 2 A. Yes. 3 Q. All right. Okay. And then what was 4 supposed to happen is that she was supposed to put an 5 interview of yours -- 6 A. Uh-huh. 7 Q. -- in a desk drawer so that it could 8 suddenly appear later in the litigation? 9 A. Yes. 10 Q. Okay. When was this plan to occur? 11 A. Again, I don't know the dates, but if 12 you're saying that interview took place in 2002, that's 13 when I was instructed by Freddie Mingo and Kenneth 14 Boagni to conduct that interview with the Los Angeles 15 Police Department as I did, as they asked me to. Uhm, 16 and he said that when the trial started, my 17 statement -- he was going to go give his statement 18 first, and then Mario Hammonds was going to give his 19 statement, and then my statement would magically 20 appear, because, really, they didn't know anything 21 about the case. 22 Mario Hammonds never had any direct contact 23 with Suge Knight, nor did Kenneth Boagni ever receive 24 any information from Rafael Perez that David Mack was 25 involved with this murder. It's a pure lie. They 41 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 concocted this story in front of me in the jail, and 2 they wanted to use my information to enhance what they 3 knew from just being in -- in Boagni's case he was in 4 the presence of Perez inside of a K-1 tank at the 5 county jail which his brother Mike set up for him to 6 do, and in Mario Hammonds case he was just on the same 7 yard as Suge Knight at CMC, but never had any direct 8 contact with this man. And so I was the one who 9 actually had all the information they needed, but I 10 wasn't stupid enough to give them the proper 11 information. 12 Q. Okay. So going back to my question, it 13 was around 2002 that it was planned that the interview 14 would be placed in the desk drawer and come out during 15 trial? 16 A. Yes. Again, I don't know when -- he 17 didn't say exactly when it would be placed in the 18 drawer by her, but it would come out at the trial was 19 how it was stated. And that's when I heard that his 20 statement had magically -- that everyone already knew 21 about appeared in this drawer, I knew it was a lie. 22 And so I tried to warn Mr. Kates, Katz, whatever, even 23 though his same department has me wrongfully in prison, 24 I wanted to do the right thing. 25 Q. All right, have you ever had any 42 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 conversation with Mr. Marella or any of the members of 2 his firm? 3 A. I don't any of these people. I never 4 talked to them, never saw them, I don't even know them. 5 Q. Have you ever had any conversation with 6 any investigator retained by their firm? 7 A. No. 8 Q. Okay. 9 A. I had someone call me by the name of 10 Sergio Robleto. That's the only investigator who's 11 ever contacted me. 12 Q. Okay. 13 A. To my knowledge I've had conversations 14 with someone from your firm. 15 Q. Okay. And who was that? 16 A. Mr. Sanders. I placed four phone calls 17 for Kenneth Boagni to his wife and he called 18 Mr. Sanders. 19 Q. And when is the last time you spoke with 20 Chuck Phillips? 21 A. I'm not going to answer that. He has -- 22 you know, that's -- I'm not going to answer that 23 question. 24 Q. Okay. 25 A. I don't see what Mr. Phillips has to do 43 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 with this deposition. 2 Q. Okay. So my understanding of your 3 response, Mr. Anderson, is not that there is any fear 4 for your safety or any Fifth Amendment issue relating 5 to answering that question, you just don't think it's 6 relevant so you're not gonna answer it? 7 A. I don't see what it has to do with this 8 case. 9 Q. Okay, and that's why you're not gonna 10 answer it? 11 A. Yes, sir. 12 Q. Okay. 13 MR. MARELLA: I would point out, counsel, that 14 it very well might be, and I believe it is, that the 15 answer to that question will be covered by the 16 California Shield Law, and while I'm not representing 17 the witness, that the witness has a right not to answer 18 that under the California Shield Law. 19 MR. FRANK: Well, again, you're not 20 representing the witness. 21 MR. MARELLA: I'm not representing him, but I 22 want to point that out for the record. 23 MR. FRANK: And you're not instructing him not 24 to answer? 25 MR. MARELLA: I am not instructing the witness 44 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 not to answer. 2 MR. BRIZZOLARA: He wouldn't take our 3 instruction, I'm sure. 4 THE WITNESS: I have a lawyer. He -- I 5 already know -- he told me what to do. I mean, he's 6 somebody working on my case, he has nothing to do with 7 this. 8 MR. FRANK: I'd like to take a brief break. 9 MR. BRIZZOLARA: Can we go off the record? 10 THE VIDEOGRAPHER: We are going off the record 11 at 10:12. 12 (Recess taken.) 13 THE VIDEOGRAPHER: We're back on the record at 14 10:20. 15 MR. FRANK: 16 Q. Mr. Anderson, before we took a break, we 17 were talking about how Mr. Boagni, Mr. Mingo and 18 Mr. "Ha-mons" were -- 19 A. Mr. Who? 20 Q. Hammonds. 21 A. I thought you said "Ha-mons," okay. 22 Q. -- were applying various types of pressure 23 on you -- 24 A. Uh-huh. 25 Q. -- to -- to give false statements. Why 45 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 were they doing that, do you know? 2 A. Yes, I know. 3 MR. MARELLA: Objection, calls for a 4 conclusion, speculation. 5 MR. FRANK: 6 Q. Okay, one of the things I'm going to try 7 to do during this deposition, Mr. Anderson, is to draw 8 a distinction between things that you know personally 9 against things that you witnessed -- 10 A. Okay. 11 Q. -- things that were told to you -- 12 A. Right. 13 Q. -- and then things that you concluded 14 based upon things that you observed or things that were 15 told to you. 16 A. Uh-huh. 17 Q. All right. So based on anything which was 18 told to you, do you have an understanding as to why 19 they wanted to concoct a story? 20 A. Yes. 21 Q. Okay, tell me why that is. 22 A. Because they told me that we would receive 23 5 percent to 10 percent of whatever settlement the 24 plaintiffs got from the City if we would all be able to 25 verify that Rafael Perez, David Mack, Martin, uh, as 46 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 well as other Los Angeles police officers, were 2 involved with the Christopher Wallace murder. They 3 said that three individuals, such as ourselves, 4 verifying that these officers and the City were 5 involved with Christopher Wallace murder, the burden of 6 proof was lower in a civil case, along with Russell 7 Poole's testimony and Mr. Miller's testimony, that we 8 would be in -- receiving millions of dollars if we did 9 this. So that's why. 10 Q. Okay. And who told you that about the 5 11 to 10 percent? 12 A. Kenneth Boagni and Mario Hammonds. 13 Q. And when did they tell you about this? 14 A. Again, in Delta 3 on this yard at this 15 prison. I don't know the year, I don't know the time, 16 but I'm sure you guys can find it out. 17 Q. Okay. Can you help me, though, it would 18 have been 2002 at the same time -- 19 A. I would say 2001. You know, it started in 20 probably 2001 -- 21 Q. Okay. 22 A. -- to 2002. 23 Q. And then you just indicated the testimony 24 of a Mr. Miller, who is Mr. Miller? 25 A. He's a cop that used to work for Robbery 47 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Homicide. 2 Q. Fred Miller? 3 A. Fred Miller, yes, sir. 4 Q. How do you know Fred Miller? 5 A. He's a crooked cop. There's not much I 6 don't know about L.A.P.D. anymore. 7 Q. In the interviews that I have from the 8 L.A.P.D., I don't notice any mention of Detective Fred 9 Miller. 10 A. He was there. 11 Q. He was where? 12 A. He was in the interviews. A skinny guy, 13 got whitish hair, grayish hair if I remember correctly. 14 Q. And which interviews was he in? 15 A. Two or three of them. 16 Q. And do you recall which ones? 17 A. No, sir. I just know he was there. 18 Q. All right, do you recall who was with 19 him -- 20 A. Russell Poole, uhm, two or three 21 lieutenants. They didn't at this point know anything 22 about the record industry. You know, it's very complex 23 to understand the royalties. They wanted me to educate 24 them on the record industry. They were trying to 25 figure out how at that time the type of money that 48 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 these individuals were getting ahold of. They couldn't 2 understand was the money also coming from narcotics 3 or -- you know, they wanted to become educated about 4 the record industry. So it was individuals in that 5 room who I don't know who they were. They probably 6 weren't on the record of the interviews. 7 Q. Okay, so the interview with Poole, Miller 8 and two or three lieutenants -- 9 A. Uh-huh. 10 Q. -- when did -- first of all, where did 11 that take place? 12 A. That took place at Parker Center, and that 13 was the first interview. They were brought in. 14 Q. Okay, was there anyone aside from Poole, 15 Miller and two or three lieutenants? 16 A. I believe the other guy that you -- that 17 was on that phone call was also there. Some people 18 from Wilshire division. Whoever Michael Robinson 19 initially had me place the call after his girlfriend 20 did. I don't know the guy's name. 21 Q. Balderama? 22 A. Balderama if you say it is. 23 Q. That's what the tape said. 24 A. Okay, no problem. 25 Q. All right. So there was Poole, Miller 49 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Balderama and two or three lieutenants, correct? 2 A. Yes, sir. 3 Q. Okay, at a meeting in Parker Center? 4 A. Yes, sir. 5 Q. All right. And was this meeting in Parker 6 Center at the same time as they brought you up from the 7 Honor Ranch? 8 A. Yes. 9 Q. So that would have been in -- 10 A. '97. 11 Q. April of 1997? 12 A. I guess, April. 13 Q. Did they bring you up to Parker Center 14 more than once? 15 A. No, they, again, held me captive there for 16 four days. They wouldn't let me go. They wanted -- 17 they came back day after day after day after day. The 18 guy told me, he goes, "I know you're lying. I know you 19 know something about this case, you're telling me a 20 lie." And he wanted to know about the record industry. 21 He wanted to know how Death Row got formed, how 22 royalties were paid. They didn't have anybody at that 23 time even in the FBI that knew how the record industry 24 worked. And so they kept me literally there for days. 25 Q. Okay, when you said that, that he was 50 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 asking you those questions, who was he? 2 A. All of them. I mean, when I'm saying 3 "he," I should say "they" were asking me all these 4 questions. 5 Q. All right, so you were held at Parker 6 Center for four days? 7 A. Uh-huh. 8 Q. Where you met with Miller, Poole, 9 Balderama and two or three lieutenants, correct? 10 A. Uh-huh. 11 Q. Is that correct? 12 A. Yes, sir. 13 Q. And the reason I did that, Mr. Anderson, 14 is although the audio and the video can figure out 15 uhm-uhm and uhn-uhns -- 16 A. I understand, I'm sorry. 17 Q. -- the Court Reporter can't. That's okay. 18 A. Being diabetic, my mouth gets dry a lot so 19 I have to hurry up and say what I'm saying, so I'm 20 sorry. 21 Q. Got it. And if you need a break to get 22 something to drink, you just let us know. Was 23 Detective Katz present during that interview with 24 Poole, Miller, Balderama and two or three lieutenants? 25 A. He could have been, I don't remember. 51 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. And you indicated that you were 2 interviewed over a four-day period of time. Were 3 Poole, Miller, Balderama and two or three lieutenants 4 present at each interview or were different folks 5 present at different interviews? 6 A. Different people were present at different 7 interviews. 8 Q. Okay. So in how many interviews were 9 Poole, Miller, Balderama and two or three lieutenants 10 all present? 11 A. If I recall, the detectives were always 12 present. But, again, there were individuals coming up 13 from what they call upper floor to -- to, uh, get as 14 much information they could about Death Row, Bad Boy 15 Entertainment and the record industry period, the West 16 Coast rival. So I don't know who -- different days it 17 was a different lieutenant or it could have been a 18 commander, they were in suits, so... 19 Q. Do you recall their ethnic background, 20 were they Caucasian, Hispanic, African American? 21 A. One of the guys looked Hispanic. There 22 never was an African American present. 23 Q. Does a name Lieutenant Hernandez ring a 24 bell? 25 A. Hernandez? 52 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. Hernandez. 2 A. No. 3 Q. All right, so at all of the interviews 4 Poole, Miller and Balderama were present, and at some 5 of the interviews two or three lieutenants were 6 present? 7 A. Yes, sir. 8 Q. Okay. Now, were all of those interviews 9 tape-recorded? 10 A. As I recall, they were. 11 MR. FRANK: Counsel, do you know the tape 12 numbers of those? 13 MR. MARELLA: I don't know. I don't know 14 anything about them. 15 MR. FRANK: 16 Q. Did you know Michael Robinson before you 17 were incarcerated? 18 A. Yes, I did. 19 Q. And how did you know Mr. Robinson before 20 your incarceration? 21 A. Through activities that I once 22 participated in that I'm not proud of. That's the best 23 way I can answer that question. 24 Q. Okay, and I'm not trying to go into those 25 things real deep, Mr. Anderson, but that was 53 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 narcotics-related activity? 2 A. Yes, sir. 3 Q. And did you know Mr. Davis before you were 4 incarcerated? 5 A. Mr. Davis? 6 Q. Kevfe -- 7 A. Kevfe D, yeah, excuse me. I just know 8 Knuckle Head by that name, but, yes, sir, very well. 9 Q. Well, Mr. Anderson, I try to be respectful 10 to everybody. 11 A. I understand. 12 Q. Especially if I don't know them. 13 A. When you said "Davis," it was just -- I 14 was caught off... 15 Q. So you knew him before? 16 A. Yes, sir. 17 Q. And how did you know him? 18 A. Through the Hawkins family. He's related 19 to them. 20 Q. And when did you first meet Michael 21 Robinson? 22 A. '87, '88. 23 Q. And where did it happen? 24 A. In Compton. 25 Q. And do you recall exactly, was it a social 54 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 gathering? 2 A. At the car wash. No, it was just where 3 everybody hung out at, at the car wash. I mean, I 4 could be wrong. It could have been at one of the 5 Handy's house, it could have been at one of the Crip's 6 house, I don't know, but I recall seeing him first at 7 the car wash. 8 Q. And Mr. Davis, where did you first meet 9 him? 10 A. At the Hawkins family home, along with 11 Baby Lane, which is Anderson Orlando. No relation to 12 me. 13 Q. And when did you first meet Mario 14 Hammonds? 15 A. I would say in 2000, but he claims he met 16 me in 1986, and I don't remember. He's tried to 17 convince me for years that we met in 1986, and I don't 18 remember it. 19 Q. And did you know him before you were 20 incarcerated? 21 A. I knew of Mario before I was incarcerated. 22 Q. Okay. And I think I pronounce his name 23 wrong half the time, how does he pronounce it? 24 A. Which one? 25 Q. Mario Hammonds. 55 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. That's his name. That's his real name. 2 Q. He doesn't pronounce it "Ha-mons"? 3 A. No, no. 4 Q. And how did you know of him before your 5 incarceration? 6 A. Again, because of what I used to be 7 involved with in the early '80s. And there has been a 8 contract on Mario Hammonds' life since 1982, a major 9 contract on Mario Hammonds' life. And if anybody can 10 get to Mario, it's a known thing from Northern 11 California to Southern California that if you can kill 12 Mario Hammonds, you could get a million dollars. 13 Q. And who is going to pay a million dollars 14 for Mr. Hammonds' death? 15 A. The Mitchell family. He told on one of 16 the biggest drug dealers in the history of this 17 country. His name was Felix Mitchell. It got him a 18 life sentence and actually got him killed in federal 19 prison, which made Mario Hammonds a marked man. 20 Q. Now, you had indicated, too, that 21 Mr. Hammonds, Mr. Robinson, and Mr. Boagni applied 22 pressure to you; did Mr. Davis apply any pressure to? 23 A. Yes, he has. 24 Q. Okay, tell me about Mr. Davis. 25 A. What do you mean tell you about Mr. Davis? 56 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 You want to know everything about him? 2 Q. No, that was a bad question. 3 A. Yeah, yeah. 4 Q. It's okay to tell me that. What pressure 5 did Mr. Davis apply to you? 6 A. Well, the initial contact was made to the 7 Los Angeles Police Department by Keith Davis' 8 girlfriend, her name is Michelle. 9 Q. Do you know Michelle's last name? 10 A. No, I do not. I could find out if you 11 need me to. 12 Q. Okay. 13 A. Uhm, Mr. Davis wanted me to contact the 14 Los Angeles Police Department. Something that gang 15 members do, a lot of people think that the police 16 are -- law enforcement is intelligent enough to send 17 individuals in to spy or to see what they can find 18 intelligence on, if you want to use that word, or 19 gather information. Well, a lot of people don't 20 understand that street people do the same thing. 21 They'll send one of their people in from the gang just 22 to, you know, be interviewed or to gather information 23 to see if they mention Orlando's name or see if they 24 mention his name as in being a -- coming up in their 25 investigation on the Christopher Wallace murder. And 57 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 so he wanted me to show my loyalty to him and be 2 interviewed by the Los Angeles Police Department 3 detectives that were handling the case, and that's why 4 that initial interview was initiated. 5 And when Michael Robinson overheard these 6 several days -- I didn't know he was actually spying on 7 me while I was on the telephone. He overheard me 8 speaking to Christopher Wallace, as well as to Keith 9 Davis, and he then started, you know, "Man, you need to 10 talk to this dude, Dan McCullin. You need to talk to 11 this guy." Again, excuse me, I didn't know his name 12 was McCullin, I thought it was Miller. And it started 13 that way. 14 And then it was, you know, a daily, I would 15 say, pressuring or baiting me in to help him to what he 16 was trying to do with the FBI. So they both were 17 attacking me basically at the same period of time. So 18 I agreed to -- to conduct the interview. 19 Q. Now, is there a reason why Mr. Davis 20 wanted to know whether his name had come up in the 21 investigation? 22 A. Yes. 23 Q. And why is that? 24 A. Because he is responsible for Christopher 25 Wallace's death. 58 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. Okay, and why do you say that? 2 A. I talked to him before Christopher Wallace 3 was murdered and I talked to him after Christopher 4 Wallace was murdered, and he did it. That's the best 5 way I can answer that question without incriminating 6 myself. 7 Q. Okay. How do you know he did it? 8 A. Because he told me he did it. 9 Q. Okay, how does that incriminate you, 10 Mr. Anderson? 11 MR. MARELLA: Objection, calls for a legal 12 conclusion. 13 MR. FRANK: 14 Q. To the extent you know. 15 A. Hmm? 16 Q. To the extent that you know, how does that 17 in any way implicate you? 18 A. Well, I don't know if there's something -- 19 MR. MARELLA: Same objection, excuse me. 20 THE WITNESS: If there's something called 21 aiding and abetting before the fact and aiding and 22 abetting after the fact, so I don't know that illegal 23 line of -- although I tried to warn certain people in 24 Andre Harrell's house that he was going to be killed 25 that night. Well, first of all, both of them was 59 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 supposed to be killed that night, Sean Combs and 2 Christopher Wallace. But at the last minute Sean Combs 3 placed a phone call to one of the individuals in the 4 South Side crew, and in my opinion Sean Combs is partly 5 responsible for the death of Biggie Smalls. 6 Q. All right. Let's go back. So you had a 7 conversation with Mr. Davis before the murder. When 8 did you speak with him before the murder about the 9 murder? 10 A. Before the murder took place. When he was 11 planning how he was going to -- when they initially 12 found out -- they initially found out that they were 13 confirmed to go to the Vibe party at the Peterson 14 Museum at about, I would say, 4:00 something. Before 15 they went to the Peterson Museum they were in a 16 restaurant in the back of Westwood and they were going 17 to take care of Christopher and Biggie at that 18 restaurant parking lot. 19 Q. What restaurant was that? 20 A. I want to say Hamburger Hamlet. Someone 21 else has asked me that question, and I can't remember 22 the restaurant, but they had been telling them for two 23 days. They had been arguing over the phone for two 24 days leading up to the murder over some money. 25 Q. Who had been arguing? 60 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. I'll say the South Side Compton Crips with 2 the New York party, put it that way. 3 Q. Okay, now you -- this is one of those 4 things where I want to figure out whether it's 5 something you observed, something somebody told you -- 6 A. This ain't nothing I observed. This is 7 something I know. 8 Q. Okay. Well, you got to have a basis for 9 knowledge, Mr. Anderson, and I'm trying to figure out 10 what that basis is. So this is something that somebody 11 told you these conversations were taking place, right? 12 A. No. I got this from Chris, I got this 13 from Kevfe D. I was the middleman in that negotiation. 14 Q. Okay. So Mr. Davis was giving you 15 information that you were then passing on to 16 Mr. Wallace? 17 A. Yes, because they were mad at each other. 18 They were not talking at this point. 19 Q. All right. 20 A. Before that everything was chum, chum, 21 chum. 22 Q. So you were the conduit for Mr. Davis to 23 Mr. Wallace and then from Mr. Wallace back to 24 Mr. Davis? 25 A. Yes, sir. 61 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. Okay. And this was occurring during a 2 period of time that you were incarcerated, correct? 3 A. Yes, sir. 4 Q. All right. And was all of this 5 communication by telephone? 6 A. Yes, sir. 7 Q. All right. And how often would these 8 calls take place? 9 A. I was on the phone all day long at the 10 county jail. That's one of the beautiful things about 11 being in the Los Angeles County Jail, they put phones 12 in their cells and you can talk on the phone all day 13 long. And at this time, because Keith Davis is also 14 involved with the crime that I am wrongly convicted of, 15 so I had to play butter-up boy to keep my family safe 16 and stay affiliated with the individuals that I was 17 affiliated with before they got me placed in jail. 18 And -- 19 Q. So -- I apologize, I interrupted you, 20 Mr. Anderson. Go ahead. 21 A. So with that said -- this thing that 22 you're trying to have me describe, again, I'm going out 23 of chronological order because it takes back to Las 24 Vegas, and the murders are connected. So when they 25 came out here to Los Angeles, even before I spoke to 62 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Biggie before they arrived here, he was actually not 2 supposed to come, he was supposed to go to London, but 3 he for some reason decided to come even when I told him 4 not to come. Uhm, I told Preme, I told Butler, they 5 still came. 6 Q. Okay, so when you were making these calls 7 to Mr. Wallace -- 8 A. Uh-huh. 9 Q. -- were you calling him on his cell phone, 10 or landline, where were you calling him? 11 A. Which day? 12 Q. Well, were there multiple calls? 13 A. Yes. 14 Q. All right. And over what period of time? 15 A. I spoke with him the week before they 16 arrived here, and I spoke with him during the time 17 period he was here in California. 18 Q. Okay, the week before he arrived here 19 where did you call him? 20 A. In New York. 21 Q. All right. And the week that he arrived 22 here? 23 A. Uh-huh, cell phone, Andre Harrell's house 24 and at the Monarch Hotel in Westwood. 25 Q. All right, and what was Mr. Davis' 63 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 grievance against Mr. Wallace? 2 A. His grievance was they hired -- first of 3 all, Christopher Wallace and the New York people, I 4 will not reveal their name until my family is safe and 5 secure, but they owed for 50 kilos of cocaine at 22,500 6 apiece, which is 1.2 something million dollars. For 7 over a two-year period of time, even before I was 8 incarcerated, the New York people had been coming down 9 to California buying kilos of cocaine, taking it back 10 to New York. I don't know if you know much about the 11 drug trade, but in New York kilos have always been more 12 higher than they are in the State of California. 13 Q. Pricewise? 14 A. Pricewise, yes, sir. So meaning you can 15 get a kilo of cocaine in California for 14,000. That 16 same kilo in New York would cost you 25, $30,000. So 17 instantly you can make a $15,000 profit just for 18 selling a brick to somebody. So those individuals were 19 coming out here and buying heavily amounts of cocaine. 20 The guy who actually is -- well, I don't even want to 21 say his name in this tape, but one of the guys who was 22 actually an investor in Bad Boy Entertainment was a big 23 drug dealer who was close to somebody in the Hawkins 24 family. 25 Q. And who is that? 64 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. I'm just gonna identify him as Hawkins and 2 the guy. 3 Q. Okay, now your reluctance to identify the 4 guy, is that a personal safety issue? 5 A. Yes, sir. 6 Q. Okay. 7 A. I already said that. I don't know if you 8 heard me, yes. 9 Q. And I apologize, I keep talking over you, 10 Mr. Anderson, and I don't mean to do that. But, again, 11 each time you don't give me information, I'm gonna 12 confirm -- 13 A. I understand. 14 Q. -- why you're doing that. 15 A. Okay, no problem. 16 Q. All right, so Hawkins and the guy were 17 purchasing large amounts of drugs? 18 A. No, Hawkins wasn't purchasing the drugs. 19 Hawkins is receiving the drugs, put it that way. The 20 people in New York, including Christopher Wallace, 21 including Sean Combs, including Damian Butler, 22 including Pedro, including Supreme, these individuals 23 were all involved in narcotics in New York. 24 Q. How did you know Mr. Butler? 25 A. Through the Cash Money Crew. It's a drug 65 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 ring in New York. 2 Q. And had you met him personally? 3 A. Yes. 4 Q. On how many occasions? 5 A. Ten, 15. 6 Q. And would that have been on the East 7 Coast? 8 A. That would have been the Park Meridian 9 Hotel in Manhattan, I met them there. And I've been in 10 homes with them in Compton, California, before I was 11 arrested. 12 Q. Okay. All right, so you were telling me 13 what the dispute was between Mr. Davis and Mr. Combs? 14 A. That was part of the dispute. 15 Q. Excuse me, I apologize, Mr. Wallace. 16 Okay, so the 1.2 million dollars owed for cocaine was 17 one part of the dispute; is that correct? 18 A. Right. The second part of the dispute is 19 that the night before Tupac Shakur was killed on March, 20 I would say, 6th or 5th of November, Christopher 21 Wallace was in Las Vegas and met Keith Davis, Orlando. 22 Q. Okay, how do you know Mr. Wallace was in 23 Las Vegas? 24 A. I spoke to them at the hotel room. 25 Q. Who's them? 66 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. I was going to tell you the names, but you 2 cut me off and asked me how did I know they was there. 3 Q. Okay. 4 A. They were at the Monte Carlo Hotel. Their 5 rooms were booked in my name, Julian Suave Scott. 6 Q. Okay. 7 A. They met with the South Side Compton Crips 8 in Las Vegas where $50,000 was delivered. This is when 9 the tickets were confirmed and Mike Tyson had given the 10 Hawkins family tickets to be allowed to go to the 11 fight. And it was confirmed that Tupac would be at the 12 fight. A lot of stuff that I'm going to answer to you 13 here I'm cutting off because I don't want to 14 incriminate myself until I'm given immunity by 15 somebody. 16 Q. All right, so there were rooms booked on 17 behalf of Mr. Wallace at the Monte Carlo under the name 18 Julian Suave Scott? 19 A. No, there were rooms booked by Keith Davis 20 underneath my name. And Christopher met Keith Davis in 21 Las Vegas where he supplied him with a weapon, and he 22 supplied him -- you want me to stop? 23 Q. Yeah. 24 A. All right. 25 Q. Because I want to break this down. 67 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. All right. 2 Q. How do you know Mr. Davis was in Las 3 Vegas? 4 A. I spoke with him over the telephone before 5 he went and why he was in Las Vegas. 6 Q. Okay, and how do you know Christopher 7 Wallace was in Las Vegas? 8 A. I spoke with him on the telephone before 9 he went and when he arrove there. 10 Q. And when you spoke with Mr. Wallace, did 11 you speak with him by cell phone? 12 A. I spoke with him on the hotel phone, 13 landline. 14 Q. And this was a call from your jail cell 15 again? 16 A. Yes. Well, placed to my home which was 17 then placed to Las Vegas. 18 Q. Okay, how did that work? 19 A. It's called a three-way phone call. I'm 20 sure you do them all the time, conference calls or 21 whatever. Which is done by a guy by the name of 22 Derrick Davis, which is Kevfe D's cousin who used to be 23 my roommate. 24 Q. Okay. And you indicated that you knew why 25 they were there, who told you why they were there? 68 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. Keith Davis -- again, I'm getting into a 2 sticky line before the fact of, you know, aiding and 3 abetting -- aiding and abetting, before the fact and 4 after the fact. All I was trying to do was to keep my 5 family and myself safe, so, again, I stayed affiliated 6 with these individuals from Compton South Side Crips 7 who had did the murder that I'm in jail for. It's the 8 best way -- best thing I could do to keep my family 9 safe. They're not the type of people you just say, you 10 know, "I don't want to deal with you anymore," and you 11 walk away from them. 12 Q. Okay, so Mr. Davis told you why they were 13 there? 14 A. Yes, sir. 15 Q. Okay, and what did he tell you? 16 A. That they were there to assassinate Marion 17 Knight, as well as Tupac Shakur -- 18 Q. All right. 19 A. -- for Sean Combs, Biggie Smalls, and the 20 New York people. 21 Q. Including the guy? 22 A. Yes, that's why I say New York people. 23 Q. Okay. 24 A. I know his name. 25 Q. But you're not gonna tell it to me? 69 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. Not from this prison I'm not. 2 Q. All right, so those statements came from 3 Mr. Davis to you by telephone? 4 A. Yes. Again, we have -- just like you 5 can -- you know, he says I stipulate or you object or 6 you do that, when you're affiliating with an organized 7 crime ring like that, you have language that when you 8 talk, or slang, we know what we're saying to each 9 other. So he didn't come out right and tell me, "I'm 10 gonna go to Las Vegas and kill Tupac Shakur," but when 11 they use the words, you know, "I'm about to put 12 somebody to sleep," and, you know, "I got to go to 13 bed," and, you know, certain language and terms I knew 14 what -- we both knew what we were talking about. 15 Q. Is your answer complete? 16 A. Yes. 17 Q. Okay. 18 A. But I just wanted to explain to you that I 19 didn't want you next to say, "So he just told you over 20 the jail telephone that he's going to go kill 21 somebody?" We have languages that we use that we know 22 what murder means, we know what dope means, we know 23 what guns mean, you know, stuff like that. 24 Q. What slang terms mean murder? 25 A. "Sleep." 70 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. Any other? 2 A. Right now I just want to reveal "sleep." 3 Q. Okay, is there a reason why you don't want 4 to reveal others? 5 A. I tried to explain to you the best I can. 6 I know about discovery now. I didn't know that before, 7 and I know that everybody and their mom and lawyer are 8 going to get these tapes, so I'll just tell you "sleep" 9 right now. I think that's sufficient enough to -- you 10 know, if you say a "heater," you know, they're not 11 talking about a heater to warm up the room, they're 12 talking about a gun. 13 Q. Now, you indicated that you had a 14 conversation with Mr. Wallace in Las Vegas; is that 15 correct? 16 A. Yes. 17 Q. Okay, tell me the content of that 18 conversation. 19 A. Well, the Hawkins crew, put it that way, 20 and the South Side Compton Crips were trying to break 21 into the record industry. That was my whole 22 affiliation with them, how I got into bed with these 23 guys. A lot of street people were trying to break into 24 the record industry, and I have a lot of knowledge and 25 was very well connected in the record industry when I 71 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 started messing around with these guys, even before I 2 had gotten into the industry. And my knowledge of that 3 was usable to them, because part of the contract they 4 put on Marion Knight and Tupac Shakur involved a 5 production deal that they would receive from the New 6 York people for doing the murder. And so during that 7 time my conversations with Chris were about points and 8 about putting this production deal together. So that's 9 what they were about. 10 THE VIDEOGRAPHER: Mr. Frank, we're going to 11 have to go off the record for a moment to change the 12 tape. 13 MR. FRANK: That's fine. 14 THE VIDEOGRAPHER: We'll be going off the 15 record at 1:6 -- I'm sorry, at 10:49. 16 (Recess taken.) 17 THE VIDEOGRAPHER: We are back on the record 18 at 10:52. 19 MR. FRANK: 20 Q. Okay, if you'll relate to me the content 21 of your conversations you had with Mr. Wallace prior to 22 him going to Las Vegas. 23 A. Those conversations were partially about 24 narcotics and they were about a production deal that 25 was being put together for the South Side Compton 72 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Crips. That's the best way I can answer that question. 2 Q. And the production deal was as partial 3 payment for -- 4 A. The murder of Tupac Shakur and Marion 5 Knight. They were hiring not myself, but the people 6 from Compton. 7 Q. And I thought you mentioned something 8 about guns, getting guns? 9 A. Yes. 10 Q. Okay, tell me about that. 11 A. Those guns were taken down -- I want to 12 say the murder happened on November 7th, I believe it 13 was, so it's the 5th or the 6th that they were down 14 there. Everybody is trying to say he was there on the 15 day of the fight, he was not there on the day of the 16 fight, he had left. He wanted to stay, but he went 17 back to New York. 18 Q. When did he go back to New York? 19 A. I want to say the day before. I think 20 November 7th was the murder date. I don't know it by 21 heart, but... 22 Q. How do you know he went back the day 23 before? 24 A. Because he told me he was leaving. I 25 spoke to him personally over the telephone. 73 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. And where did you speak with him -- where 2 was he, what phone did you call him on? 3 A. He was at the Monte Carlo Hotel. I don't 4 remember the room number. Had L.A.P.D. done their job 5 correctly, I'm sure they would have got all that from 6 Keith Davis if they would have went and arrested him 7 and got his car at the time or raided his home. So I 8 don't remember the room numbers. 9 I know that they used my name all the time. 10 That was my whole affiliation with that organization. 11 They used my profile because I had perfect credit, and 12 I was not in -- how do I put it? Involved with illegal 13 activity. I could prove where my money was coming 14 from. I had a multimillion dollar record deal with 15 Capitol Records. They were drug dealers. So I was 16 really, like, their front per se if you want to say 17 that. 18 Q. And this continued even after your 19 incarceration? 20 A. Yes, sir. 21 Q. I'd like to go back to the April meeting 22 that you had with Detective Poole, Detective Miller, 23 Detective Balderama and two or three lieutenants. 24 A. Uh-huh. 25 Q. What did you discuss with those gentlemen 74 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 during that interview? 2 A. I really don't remember, because it was a 3 lie. Again, I was only there to see if those 4 detectives would mention Keith Davis' name or Orlando 5 Anderson's name in that interview, and they never 6 brought those names up to me. And that was my only 7 reason for being there, as well as doing it per se for 8 Michael Robinson at the same time. Because Michael 9 Robinson received his $2500 from the FBI as soon as I 10 got back within days of doing that interview. 11 Q. Did you tell Detective Poole, Miller and 12 Balderama that Michael Robinson persuaded you to speak 13 with them? 14 A. Again, after what L.A.P.D. did to me in my 15 case -- I'm going to be perfectly honest with you, the 16 best way to answer that question, I would have if they 17 would have listened to me. When you're telling the 18 detective you're innocent and you're calling yourself 19 law enforcement and they don't want to listen to you, 20 so, no, I did not tell them that. 21 Q. Okay. 22 A. Because they wouldn't have cared. 23 Q. Let me -- let me tell you what I'm really 24 looking for, Mr. Anderson, and maybe you can help me. 25 A. Uh-huh. 75 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. My understanding is that part of what 2 Michael Robinson wanted was credit for you giving 3 information to the L.A.P.D., that's how he got payment 4 from the FBI? 5 A. Exactly, and the Sheriff's Department. 6 Q. Okay. 7 A. Right. 8 Q. So who did he tell about your involvement 9 such that he was able to receive payment? 10 A. That would -- 11 MR. MARELLA: Objection, calls for 12 speculation. 13 MR. FRANK: 14 Q. To the extent that you know? 15 A. McCullin, Richard Valdemar, and some 16 lieutenant that he had contact with at L.A.P.D., I 17 don't know his name, but I'm sure Michael Robinson will 18 tell you the truth when he's cornered. 19 Q. All right, so -- so your understanding is 20 that the FBI and L.A. County Sheriff Balderama -- 21 A. Valdemar, not Balderama. 22 Q. Excuse me. 23 A. Richard Valdemar. 24 Q. Thank you, thank you for the correction. 25 And an L.A.P.D. lieutenant knew that the statements 76 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 given by you should be attributed to Michael Robinson 2 for purposes of his payment? 3 A. Yes, sir. 4 Q. Okay. 5 A. He made the initial contact with those 6 people. 7 Q. Okay. Now, which L.A.P.D. lieutenant knew 8 that, do you know? 9 A. To be perfectly honest with you -- 10 MR. MARELLA: Objection, lack of foundation. 11 MR. FRANK: 12 Q. You can go ahead, Mr. Anderson. 13 A. Oh, I don't know what they meant, that's 14 what I'm saying. I didn't know I'm supposed to talk. 15 Q. Well, let me explain it to you, 16 Mr. Anderson, so that you don't have to guess. From 17 time to time Mr. Marella is going to object to my 18 questions. 19 A. Uh-huh. 20 Q. Generally when he objects it means that I 21 haven't asked the question correctly, and his objection 22 is a way of preserving for the record that I screwed it 23 up -- 24 A. Oh, okay. 25 Q. -- and I can either fix it or not. 77 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. All right. 2 Q. It's not an instruction to you not to 3 answer. 4 A. Okay. 5 Q. Okay? 6 A. All right. 7 Q. So, first of all, do you have any idea who 8 the lieutenant may have been? 9 A. I want to say it was the same guy that 10 works for Mr. Sanders that contacted me, if I'm 11 correct. I don't know if there's two Robletos, but I 12 remember the name Robleto that came out of Psycho 13 Mike's name. 14 Q. Okay, and was he a then -- was he a -- was 15 he then working for the L.A.P.D.? 16 A. Yes. This would have been in 1997. But I 17 don't know if there's two Robletos or what. 18 Q. Okay. Aside from Kenny Boagni, Freddie 19 Mingo, Mario Hammonds and Mr. Davis, have you been 20 pressured by any other person to give any account as it 21 relates to the Wallace murder? 22 A. No, sir. 23 Q. Have you ever received payment from any 24 party for any statement that you've given in relation 25 to the Wallace murder? 78 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. No, sir. 2 Q. When is last time you spoke with 3 Mr. Wallace prior to his death? 4 A. The day of his death. 5 Q. Okay, and how -- how -- how long before 6 his death, was it in the afternoon, was it in the 7 evening? 8 A. I'd say maybe 6:00 or 7:00. In the L.A. 9 County Jail, like I have a watch on now, in prison 10 you're not allowed to have a watch, and, really, time 11 wasn't on my mind. I was caught in the middle of 12 something I didn't want to really be a part of. And so 13 I would say maybe -- I think Davis said, you know -- 14 excuse my language, ma'am, but, "Fuck it, we're going 15 to do it at this time." It may have been 6:00 or 7:00 16 that evening, and maybe I spoke to him last about 7:00, 17 I'm not sure. I could be off so I don't want to tell a 18 lie or say anything different, because in the county 19 jail there's no windows. You don't know if it's 20 nighttime or whatever. But maybe I'd say 7:00, 21 7:00ish. 22 Q. And what -- 23 A. P.m. 24 Q. And what was the content of that 25 conversation? 79 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. I tried to warn him, but I knew if I would 2 have warned him, because every time I spoke with him, 3 Derrick Davis was on the phone, which is Keith Davis' 4 cousin. So I really could not warn him. But I did 5 call Sean back afterwards and tried to tell -- I placed 6 a phone call to Andre Harrell's house and told him to 7 be careful because he was going to be killed. And I 8 had a female, whose name I will not reveal at this 9 time, place that phone call with me instead of using 10 Mr. Davis to make the phone call. My calls were being 11 monitored to Chris again by somebody who was on the 12 phone, so... 13 Q. Okay, I need to back up. My understanding 14 was you had phones in your cell and that's how you were 15 making those calls -- 16 A. Yes. 17 Q. -- is that incorrect? 18 A. Yes. 19 Q. All right, so how was Derrick Davis 20 monitoring your phone calls? 21 A. Because what I would have to do, because 22 you can't call a cell phone collect, nor can you call a 23 hotel room collect, so what I would do was call my 24 home. Me and my wife were separated at the time, which 25 I lived on 930 South Figueroa, that was my apartment 80 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 that I -- Derrick Davis was my roommate, which is Keith 2 Davis' cousin. And so I would call my apartment and 3 then they would call whoever I wanted to call, whether 4 it be Keith Davis, you know, anybody, Biggie Small or 5 my record label, whatever. Those are how I made my 6 phone calls. It's called a three-way call. 7 Q. All right. So on all of the calls that 8 you placed by way of three-way calls, Derrick Davis was 9 involved in those? 10 A. Yes. His real name is Demarshay. I don't 11 know if that will help you. 12 Q. Do you know how to spell that? 13 A. No, sir. 14 MR. MARELLA: Spelled the usual way. 15 MR. FRANK: 16 Q. All right, you mentioned somebody named 17 Sean, who is Sean? 18 A. He hangs out with Bad Boy, uhm, he's a 19 rapper. 20 Q. Now, you indicated in that last 21 conversation you tried to warn him? 22 A. Yes, sir. 23 Q. What did you tell him? 24 A. I told him to not go to Peterson Museum 25 because they were gonna get killed, tell Biggie to stay 81 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 at home, and hung up the telephone, had them hang up 2 the phone. And the individual that I warned at Bad Boy 3 Records, her name is Monica. I'm just gonna go ahead 4 and tell you the girl's name. She used to be Andre 5 Harrell's assistant. She was in the group called The 6 Girls. 7 Q. Do you know Monica's last name? 8 A. She works for Sean, she still works there. 9 She used to be signed to Uptown. Excuse me, she wasn't 10 signed directly to Bad Boy, before Bad Boy was Uptown. 11 Q. When were you first incarcerated in 12 relation to the fire? 13 A. January 29th, 1994. 14 Q. And when did you go to trial? 15 A. August of 1997. 16 Q. And between January of '94 and August of 17 '97, where were you housed? 18 A. L.A. County Jail. 19 Q. The whole time? 20 A. That I recall. I was also at Patton. I 21 went to do a 90-day observation at Patton. 22 Q. When did you do the observation at Patton? 23 A. I don't know. 24 Q. And I read in an article by Mr. Phillips 25 that you actually escaped from Patton? 82 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. I didn't escape, it was a walkaway. 2 Q. Okay, tell me about that. 3 MR. MARELLA: Objection, relevance. 4 THE WITNESS: I've been instructed by my 5 attorney not to speak about anything about my case. 6 MR. FRANK: 7 Q. Okay. Do you recall when the walkaway 8 was? 9 A. It's public record, I don't know. 10 Q. Where were you incarcerated on March 8th 11 and 9th of 1997? 12 A. L.A. County Jail. 13 Q. Did you have a cellmate there? 14 A. No. Michael Robinson was my neighbor, but 15 we didn't have cellmates where we were housed at. It's 16 like 22 guys in a pod or something like that. He also 17 testified in my trial, if that will help you find the 18 date. 19 Q. Who testified in your trial? 20 A. Michael Robinson. He was a witness in my 21 trial. 22 Q. For you or against you? 23 A. For me. 24 Q. What did he testify to? 25 A. Again, I can't elaborate -- 83 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 MR. MARELLA: Objection, relevance. 2 THE WITNESS: I can't -- I'm just -- I can 3 tell you that he testified in my trial, but I cannot 4 tell you. You can read it yourself or find it, it's 5 public information, I'm sure. 6 MR. FRANK: 7 Q. All right. Prior to your incarceration, 8 did you assist the L.A.P.D. as an informant to the Mid 9 Level Narcotics Division? 10 A. I'm not gonna answer that question. 11 Q. Okay, and is there a reason why you're not 12 gonna answer that question? 13 A. I'm at war right now with the Los Angeles 14 Police Department, so I can't answer that question. 15 It's connected to my case. 16 Q. All right, all right, so you're not 17 answering that because it's connected to your case? 18 A. Yes, sir. 19 Q. Okay. Can you pull up 275549? 20 MR. BRIZZOLARA: 275549. 21 MR. FRANK: Don't play it, just go to minute 22 2. 23 MR. BRIZZOLARA: Give me a second. 275549. 24 MR. FRANK: And go to minute 2. 25 MR. BRIZZOLARA: Starting at 2:02 minutes. 84 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 MR. FRANK: Yeah, just pause it. 2 Q. Mr. Anderson, I'm gonna play for you a 3 portion of your taped interview of March 27, 2002, 4 conducted by Detective Hampton and Trujillo. This is 5 identified on tape number 275549, and we're going to 6 play from minute 2 to 2 minutes and 34 seconds. Could 7 you go ahead and play that, Mr. Brizzolara. 8 MR. BRIZZOLARA: Sure. 9 (Audiotape played.) 10 MR. FRANK: That's a problem with trying to go 11 tapes, there's two sides, we've got the wrong side. 12 (Audiotape played.) 13 THE WITNESS: I know what I said on the tape. 14 Do you want to ask me a question or something? 15 MR. BRIZZOLARA: Is that good? 16 MR. FRANK: Yeah, that's good. 17 Q. All right, on that tape you indicated that 18 you worked as an informant for Mid Level Narcotics for 19 L.A.P.D.; was that a true statement in May? 20 A. I take the Fifth on that question. 21 Q. 275549, side A, starting at 8:59. And 22 just pause it there while I ask questions. 23 MR. BRIZZOLARA: 8:59? 24 MR. FRANK: Yeah, 8:59. 25 MR. BRIZZOLARA: Okay, we're there. 85 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 MR. SHAKOW: Can you tell me the tape number 2 again, please? 3 MR. FRANK: Of course, 275549. 4 MR. SHAKOW: Oh, the same tape? 5 MR. FRANK: Side A. We're going to attempt to 6 play 8:59 to 9:52. If you're off, just state for the 7 record where exactly you start so these gentlemen have 8 it. 9 Q. Before he gets that started, can you tell 10 me, Mr. Anderson, how you know David Mack? 11 A. I don't know David Mack. 12 Q. Okay. You never met David Mack? 13 A. No, sir. 14 Q. Okay, go ahead and play the tape. 15 (Audiotape played.) 16 THE WITNESS: I know what the tape says, sir. 17 MR. FRANK: Where did you stop? 18 MR. BRIZZOLARA: I stopped at 9:31. 19 MR. FRANK: 20 Q. All right, on the tape where you indicate 21 that you knew David Mack from Mid Level Narcotics, was 22 that truthful when made? 23 A. No. 24 Q. So you lied on that tape? 25 A. I lied for Kenny Boagni on that tape, as I 86 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 stated before. You asked me the question 20 minutes 2 ago. 3 Q. And you've never met David Mack in your 4 life? 5 A. No, sir. 6 Q. Never worked for him? 7 A. No, sir. 8 Q. Did you at any time assist the Los Angeles 9 Police Department as it related to an arrest of a 10 gentleman named Willie Smith for selling guns? 11 A. I take the Fifth on that. 12 Q. Okay, 275549, side A, at 2:34. 13 MR. BRIZZOLARA: Back to 2:34. 14 MR. FRANK: 2 minutes, 34 seconds. 15 MR. BRIZZOLARA: Okay. 16 MR. FRANK: And Mr. Brizzolara, if you could 17 for the record tell the defendants exactly where it is 18 that you start the tape and exactly where it is you 19 stop the tape when you stop it. 20 MR. BRIZZOLARA: Okay, I'm trying to get on to 21 it. 22 MR. FRANK: Okay. 23 MR. BRIZZOLARA: I'm starting at 2:33. 24 MR. FRANK: Okay. 25 (Audiotape played.) 87 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 THE WITNESS: Again, I know what the tape 2 says. 3 (Audiotape played.) 4 MR. FRANK: Stop the tape. 5 MR. BRIZZOLARA: It stopped at 3:11. 6 MR. FRANK: 7 Q. All right, so were you at any time 8 involved with the L.A.P.D. in an arrest of a Willie 9 Smith? 10 A. Can I answer that question the way I want 11 to answer it so I can get you what you want and we can 12 move forward? 13 Q. Mr. Anderson, my -- my job is to ask the 14 questions, yours is to answer them. And there will be 15 sometimes you answer them that I'll follow-up, and 16 sometimes I won't, so if you can answer the question. 17 A. All right, I'm gonna answer this question 18 this way: Uh, when Boagni and I and Mr. Hammonds met 19 here at this prison, when I was instructed to do that 20 interview in 2002 with the Los Angeles Police 21 Department or don't come back to this yard if I return 22 back from my appeal, I took truthful information, uhm, 23 on things that I did with the Los Angeles Police 24 Department in the early '80s and I incorporated what 25 Mr. Boagni wanted me to do with David Mack. I never 88 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 worked a case with David Mack. That is public record, 2 all those cases that you are talking about. 3 Yes, I was an informant for the Los Angeles 4 Police Department, Mid Level and Major Level Narcotics, 5 and all that I did for those son of a bitches they set 6 me up for a murder and would not even listen to me 7 anymore because I would not tell them the truth about 8 what we're here today. So, yes, I was an informant. 9 No, David Mack. All those cases that are 10 mentioned in that tape are true cases, and you can call 11 Detective Strong and he can pull them up. What I did 12 was do what Boagni asked me to do was incorporate David 13 Mack's name into true statements so it would be able to 14 support you guys' case. As well as Boagni and I had 15 personal conversations when he divulged to me that his 16 brother was a police officer or sheriff, his name is 17 Mike, for the L.A. County Sheriff's Department. 18 He told me that he used to give information to 19 the Los Angeles Police Department. So I shared with 20 him that I did the same thing. And then that's when he 21 suggested, "Well, you can take cases you did and 22 include David Mack's name in those cases." I never met 23 David Mack, I never met Rafael Perez. Rafael Perez did 24 not come to no cell and threaten me. Kenneth Boagni 25 told me to put that in there and that he would say that 89 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Rafael Perez told him when they were together at the 2 holding facility where they were in Los Angeles that he 3 went and threatened somebody that he knew that could 4 give up the whole murder of him being involved in it. 5 It was a lie, and I'm ashamed of it, and being in 6 prison wrongfully for 14 years, David Mack, nor Rafael 7 Perez, nor Suge Knight or anybody should be accused of 8 anything they had nothing to do with. So I'm here to 9 tell the truth. 10 I told the cops a lie because they did not 11 want to listen to me and my case, and at that point I 12 didn't give a damn about the Los Angeles Police 13 Department. Those were not sworn statements. I wasn't 14 Miranderized (sic) or anything. I did the best thing I 15 could do to keep myself and my family safe. So, yes, I 16 was an informant for the Los Angeles Police Department. 17 Q. Is your answer complete, Mr. Anderson? 18 A. Yes. 19 Q. Thank you. All right, so the portion of 20 that statement which was true was that you did assist 21 in an arrest of a Mr. Smith, the portion of it which 22 was false is that David Mack was involved, correct? 23 A. Yes. And there are -- those cases are 24 documented and they can prove that David Mack was -- 25 that's why I did it, because they can prove that David 90 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Mack was never a part of those cases. They are 2 documented and officers testified and those people were 3 convicted. 4 Q. And, again, when you told them that David 5 Mack threatened your life if you didn't assist him in 6 setting up drug dealers, that was a lie as well? 7 A. Yes, I don't know the man. 8 MR. FRANK: Tape 275549 at 3:10. 9 MR. BRIZZOLARA: Side A? 10 MR. FRANK: Side A. And I'm gonna ask you to 11 stop at about 3:45. 12 MR. BRIZZOLARA: Okay. 13 MR. FRANK: Don't play it yet. 14 MR. BRIZZOLARA: Okay. 15 MR. FRANK: 16 Q. Did you tell the L.A.P.D. that you made a 17 complaint regarding David Mack's threat to you that he 18 would commit bodily harm upon you if you did not assist 19 in setting up drug dealers? 20 A. That's a lie, sir. 21 Q. Okay, play the tape. 22 (Audiotape played.) 23 MR. BRIZZOLARA: Stopped at 3:43. 24 MR. FRANK: Okay. 25 Q. Was -- were those statements from 3:10 to 91 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 3:43 regarding a personnel complaint and no 2 investigation false statements? 3 A. Again, Kenneth Boagni told me to say that 4 and said his brother could falsify a report and make a 5 report appear. Everything in that interview besides 6 the cases and names are all true, and anything in that 7 tape about Rafael Perez or David Mack are false. 8 Q. All right, so that statement that we just 9 played for you was false? 10 A. That was false, yes, sir. 11 Q. All right, so you lied then? 12 A. For Kenneth Boagni, sir. 13 Q. Okay, I'm not asking you who you lied for. 14 A. I'm not answering the question the way I 15 want to answer them. I'm not gonna sitting here and 16 say I lied, I lied with reason. 17 Q. Okay. Did you participate in a robbery 18 with David Mack occurring on New Castle Avenue? 19 A. No, sir. 20 MR. FRANK: Please play 275549 beginning at 21 6:30 stopping at 8:10. 22 (Audiotape played.) 23 THE WITNESS: Do you have a question or? 24 (Audiotape played.) 25 MR. BRIZZOLARA: Stopped at 8:47. 92 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 MR. FRANK: Okay. 2 Q. The tape section from 6:30 to 8:47, 3 wherein you discuss the robbery at New Castle Avenue 4 with David Mack, that was a lie? 5 A. The robbery is true, but David Mack was 6 not involved with that robbery. 7 Q. Okay, who was involved with that robbery? 8 A. Other Los Angeles police officers and 9 sheriff's officers that were documented cases. A guy 10 by the name of Miller, who actually got arrested and 11 was -- I think he's dead now -- was a crooked cop. I 12 had knowledge of cases that were true cases that 13 involved police officers, and I incorporated them in 14 the story that Kenneth Boagni and Mario Hammonds 15 concocted in Delta 3 along with me, and I did what they 16 asked me to do out of fear. 17 David -- I don't know David Mack, I don't know 18 Rafael Perez, they had no involvement with the 19 Christopher Wallace murder. You don't have to play -- 20 I mean you can if you want to, but, you know, I did 21 what I had to do to survive. 22 Q. All right, so that portion of the tape 23 where there was a robbery at New Castle Avenue is true, 24 that portion where you or David Mack were involved is 25 untrue? 93 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. Yes. 2 Q. You had no involvement with that? 3 A. No, sir. 4 Q. Go to 9:33 to 9:57. 5 Have you ever met Rafael Perez? 6 A. No, sir. 7 Q. Were you ever involved in robbing drug 8 dealers with Rafael Perez? 9 A. No, sir. 10 Q. Okay, play 9:33. 11 MR. BRIZZOLARA: Actually it will start at 12 9:32. 13 MR. FRANK: Okay. 14 (Audiotape played.) 15 MR. FRANK: 16 Q. All right, so were you -- 17 MR. BRIZZOLARA: Stopped at 9:56. 18 MR. FRANK: 19 Q. When you indicate that Officer Perez was 20 present during this robbery, that was a lie, too? 21 A. That was what Kenneth Boagni asked me to 22 say and I said it. 23 Q. Okay. 24 A. Because he was going to -- he has not 25 given his deposition, and had I come in here and said 94 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 that -- verified what on that tape was true, when you 2 guys deposed him, he would have verified that. Only 3 thing he said so far -- his statement change as he 4 comes in the presence of me if you look at his 5 statement that he's made to you guys. So everything in 6 that tape that involves Rafael Perez or David Perez was 7 said because Kenneth Boagni and Mario Hammonds asked me 8 to say it and I said it. 9 Q. It was a lie, right? 10 A. That's the way I'm gonna answer that 11 question. 12 Q. Did you participate in the robbery of a 13 person named Harold Henry? 14 A. No, sir. But that was a true robbery. 15 Q. Okay. Do you remember telling the 16 L.A.P.D. that you were involved in a robbery of Harold 17 Henry? 18 A. Everything that was stated in that tape 19 that involved myself, Mack or Perez involved when those 20 robberies were done because of Mario Hammonds and 21 Kenneth Boagni asked me to say it and I said it. 22 Q. Okay. All right, so you did say it and it 23 was untrue when you said it, right, Mr. Anderson? 24 A. Because I was instructed to say it. 25 Q. Okay, I'm not asking you why -- 95 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. It was untrue, yes. 2 Q. All right, thank you. Did there come a 3 time when you stopped working as an informant for 4 narcotics? 5 A. That's a problem. That's the best way I 6 can answer that question. 7 Q. Okay, how is that a problem? 8 A. Well, again, that's related to my case 9 that's about to come out. 10 Q. Okay. And because it's related to your 11 case, upon instructions of Mr. Bernstein you're not 12 gonna talk about it? 13 A. Yes, sir. 14 Q. 275549, let's start at 12:36. 15 MR. BRIZZOLARA: Side A? 16 MR. FRANK: Side A. 17 MR. BRIZZOLARA: 12:36? 18 MR. FRANK: 12:36. 19 MR. BRIZZOLARA: The closest I can get is 20 12:35. 21 MR. FRANK: Close enough. 22 (Audiotape played.) 23 MR. BRIZZOLARA: Stopped at 14:18. 24 MR. FRANK: Thank you. 25 MR. BRIZZOLARA: Let me ask you this, is this 96 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 coming through when you're listening to this? Can you 2 hear it on the videotape? 3 THE VIDEOGRAPHER: Yes, I can. 4 MR. FRANK: 5 Q. Was there a robbery of a person named 6 Harold Henry? 7 A. Yes, sir. 8 Q. Were you truthful when you indicated that 9 David Mack was involved in that robbery? 10 A. No, sir. 11 Q. Did David Mack at any time attempt you -- 12 attempt to force you to assist in the robbery of 13 Michael Conception? 14 A. I don't think you can get anybody in 15 California to rob Michael Conception. 16 Q. Who is Michael Conception? 17 A. He's one of the leaders of the Crips. 18 Q. It would be the wrong guy to rob? 19 A. Yes, sir. A very good friend of mine. I 20 would never, ever -- you couldn't pay me to cross that 21 guy. 22 Q. How do you know Mr. Conception? 23 A. We used to be business partners. 24 Q. In the music business -- 25 A. Yes, sir. 97 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. -- or drug business? And what was his 2 role in the record business? 3 A. He owns a record label. 4 Q. What's his record label? 5 A. I'm not gonna speak about Mike too much on 6 this tape. Mike's a great person. Everybody likes 7 Mike. 8 Q. Is he associated with Death Row? 9 A. No, it's two different functions. 10 Q. Go ahead and go to 275549, 18:15. 11 Did David Mack at any time threaten you with 12 bodily harm if you did not assist him with setting up 13 Michael Conception? 14 A. It wasn't David Mack. I don't know David 15 Mack. I don't know Rafael Perez. 16 Q. All right. Did anybody threaten you with 17 bodily harm in an attempt to set up Michael Conception? 18 A. Yes, they did. 19 Q. Who? 20 A. I'm not gonna answer that question and 21 tell you. 22 Q. Okay, and, again, why is that, 23 Mr. Anderson? 24 A. Because it involves circumstances that led 25 to the Los Angeles Police Department wrongfully 98 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 convicting me for my crime. 2 Q. Okay, so that isn't a personal safety 3 issue, that's an issue associated with your ongoing 4 case? 5 A. Both. 6 Q. Got it. 7 MR. BRIZZOLARA: I'm actually at 18:13. 8 MR. FRANK: That's fine, go ahead and play it. 9 (Audiotape played.) 10 MR. FRANK: And what sections were played? 11 MR. BRIZZOLARA: I stopped it at 18:35. 12 MR. FRANK: 13 Q. All right, did a white officer ever 14 threaten to kick your ass if you did not set up drug 15 dealers? 16 A. Yes. 17 Q. Okay, who is that? 18 A. I'm not gonna reveal his name because of 19 my case and because of my safety. These officers still 20 work inside of the L.A.P.D. 21 Q. That portion of the tape where you are 22 indicating that a white male officer threatened you in 23 order to set up Mr. Conception, was that truthful? 24 A. Yes. 25 Q. All right. So the only part of that that 99 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 was not truthful was that it was David Mack who was 2 involved? 3 A. That's what I'm trying to explain to you. 4 I took real events that I have personal knowledge of, 5 and when Kenneth Boagni and Mario Hammonds twisted my 6 arm to try to compel me or force me to participate with 7 their little scam, I incorporated David Mack and Rafael 8 Perez's name. So I knew one day this day would come 9 and the information would come out, as I've told 10 someone else, and that's how all their lies can be 11 disproven, those two guys are lying, because I don't 12 know Rafael Perez, I don't know David Mack. 13 Q. Do you know Suge Knight? 14 A. Yes. 15 Q. Okay, tell me how you know Suge Knight? 16 A. From the record industry, and before the 17 record industry when he was just a bodyguard. 18 Q. In one of the interviews you indicated 19 that Mr. Knight worked for you; did Mr. Knight ever 20 work for you? 21 A. I would say he assisted my personal 22 bodyguard on a couple of events with us before there 23 was a Death Row, when he didn't even have a car. So, 24 uh, I guess that would be partially true, partially not 25 true, whatever. 100 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. All right, so the only role he ever had 2 with your musical career by way of being an employee of 3 yours was -- 4 A. He never was an employee of mine. 5 Q. Okay, thank you for the clarification -- 6 A. All right. 7 Q. -- Mr. Anderson. He at one point assisted 8 your bodyguard, and that's the only time you worked 9 with him -- 10 A. Well, I mean -- let me -- there's a story 11 behind that if you want to hear it. 12 Q. I like stories. 13 A. There's a place called Galaxy Studios. A 14 guy by the name of Dick Griffey owns it. He's a great 15 ol' friend of mine. Galaxy Studios is Solar Records. 16 Dick Griffey owns Solar Records. At this time Mandella 17 had got out of prison and Dick Griffey had gotten the 18 contract to -- for the tours that Mandella was doing 19 out here. Suge had just hurt his knee, and he has a 20 stepbrother named Wesley Crockett, he used to be head 21 of security up there at Galaxy Studios which Dick 22 Griffey owns. Galaxy Studios is where Capitol Records, 23 because Solar Records was distributed by Capitol 24 Records, most of the independent artists that were 25 signed to Capitol like myself would do our recordings 101 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 at Galaxy Studios. So like keeping all the money 2 in-house. We would get better rates, hourly rates and 3 stuff like that. 4 So, when I started recording at Galaxy 5 Studios, Suge would be hanging up at Galaxy Studios 6 when he was just a bodyguard working with Mandella. 7 And my bodyguard's name was John Henry with a aka 8 Whacky. Both of them being, you know, out of Blood 9 gangs, they took a liking to each other. So he would 10 just hang at the studio when I was in there recording 11 because my bodyguard would be there. So that was his 12 only relationship to being involved with -- with, you 13 know, my record career or with my production company. 14 They just took a liking to each other so they would, 15 you know, hang out at the studio together, and then he 16 would, you know, be there. 17 At this time he wasn't into bullying people 18 or, you know, pressuring people or any of that type of 19 stuff. He was just, again, doing security work. So 20 that's my -- my introduction to -- to Marion. 21 Q. All right, and you were never a Death Row 22 artist? 23 A. No, not at all. 24 Q. Did Mr. Knight know that you were -- that 25 on occasion you would act as an informant for L.A.P.D. 102 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Mid Level Narcotics? 2 MR. MARELLA: Objection, calls for 3 speculation, lack of foundation. 4 MR. FRANK: 5 Q. Okay, let me ask it differently. Did 6 Mr. Knight or anyone on Mr. Knight's behalf ever 7 express to you that he knew that you were working on 8 occasion as an informant for Mid Level Narcotics? 9 A. You really want me to answer that? 10 Q. Yes, I do. All the questions I ask you, 11 Mr. Anderson -- 12 A. I'm just saying I don't think that -- that 13 -- if certain people had knowledge of that, I probably 14 wouldn't be sitting here before you. There are certain 15 people who may have insinuated, but I can't -- I don't 16 know how to answer that question just to be honest with 17 you. 18 Q. All right. Well, let me -- I'm not trying 19 to play hide the ball, let me tell you exactly why I'm 20 asking. 21 A. Uh-huh. 22 Q. On one of these tapes, and we'll probably 23 play it here in a minute -- 24 A. Uh-huh. 25 Q. -- you indicate that David Mack threatened 103 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 you that he would inform Marion Knight of your work as 2 an L.A.P.D. informant if you didn't assist him with 3 robberies. Do you recall saying that on the tape, 4 Mr. Anderson? 5 A. Again, everything that's on those tapes 6 were a concocted story that Mario Hammonds, Kenneth 7 Boagni and myself participated in. So I don't remember 8 everything that was said on that tape that re -- that 9 relates to Mr. Mack or Mr. Perez because it was a 10 concocted story and I did it out of fear. I don't know 11 any other way to explain it to you. So if it's on the 12 tape, it's on the tape, but it was said because of 13 Kenneth Boagni and Mario Hammonds were also supposed to 14 add to those statements down the line. 15 Again, I know that Kenneth Boagni has not 16 given his deposition from what he told me, and 17 depending on what I said here today, then he would go 18 and verify if I backed his play. And I'm not gonna 19 lie. I don't want to lie anymore. I'm not lying for 20 anybody. I want the truth to come out and I'm here to 21 tell the truth. So, if it's on the tape, it's on the 22 tape. 23 MR. FRANK: 275549 at 2038. 24 (Audiotape played.) 25 MR. FRANK: Okay, and you stopped where? 104 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 MR. BRIZZOLARA: Stopped at 2054. 2 MR. FRANK: Okay. 3 Q. Did David Mack every disclose to anyone or 4 threaten -- strike that, let me ask it this way: Did 5 David Mack ever threaten you that he would lay you out 6 as an informant? 7 A. No, sir. 8 Q. Okay, so when you said it on the tape, you 9 were lying? 10 A. I told you why I made that statement on 11 the tape. 12 Q. Okay. It was false when you made it, 13 right? 14 A. Because Kenneth Boagni asked me to. 15 Q. Now, you mentioned Jerry Hawkins, who's 16 Jerry Hawkins? 17 A. I refuse to answer that question. 18 Q. Okay, and what is the basis of that 19 refusal? 20 A. I just refuse to answer. I take the Fifth 21 on that. 22 Q. Okay. And what I'm trying to delineate, 23 Mr. Anderson, and again, I'm not trying to hide the 24 ball. It's just when you're not answering, so far 25 you've given me three separate reasons, personal 105 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 safety, Fifth Amendment, and your ongoing case. 2 A. Uh-huh. 3 Q. And I'm just trying to determine which one 4 it is or whether it's a different reason? 5 A. It's just a name that you, me and nobody 6 in this room want to talk about. 7 Q. Okay. Did Mr. Hawkins at any time have 8 any cell phones that belonged to you? 9 A. I take the Fifth on that. 10 Q. Did Death Row at any time have any cell 11 phones that belonged to you? 12 A. No, sir. 13 Q. Did you ever sell any cell phones that 14 were registered under your name to Death Row Records? 15 A. I introduced Death Row Records to a phone 16 guy, but I never sold them any phones. 17 Q. Who did you introduce them to? 18 A. A guy by the name of Phillip Morev. 19 Q. And do you know how to spell Morev? 20 A. M-o-r-e-v. Palm Spring, California. He's 21 still in the cell phone business. 22 Q. Did he supply you with your phones? 23 A. Yes, he did. 24 Q. Do you know who Reggie Wright is? 25 A. Yes, I do. 106 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. And who is Reggie Wright? 2 A. Head of Death Row security. 3 Q. Did you have a discussion with Reggie 4 Wright following the murder of Christopher Wallace -- 5 A. No, sir. 6 Q. -- about the shooting? 7 A. No, sir. 8 MR. FRANK: If you could go to track 14. 9 MR. REICHERT: Of? What's the tape? 10 MR. FRANK: This is actually from the 11 polygraph, so the tape would be 177610, side A. 12 MR. BRIZZOLARA: 14? 13 MR. FRANK: Yeah, 14. 14 MR. BRIZZOLARA: Ready to go? 15 MR. FRANK: Yeah, go ahead. 16 (Audiotape played.) 17 MR. FRANK: 18 Q. All right, so in your polygraph where you 19 talk about having a post shooting discussion with 20 Reggie Wright, are you lying then? 21 A. Everything that was in those tapes was 22 discussed by Kenneth Boagni, Keith Davis and was said 23 because of them. So I wasn't lying, I was doing what I 24 was instructed to do. And that's what I did. 25 Q. Well, that wasn't true, was it? 107 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. That's the best way I'm gonna answer that 2 question. I keep answering -- I feel like I'm 3 answering the same question. I told you about the 4 tapes. I understand this might be how you have to do 5 it, but -- 6 Q. Right. 7 A. -- you're calling me a liar and I'm 8 telling you why I did it. If some of these people were 9 threatening you, you would probably do the same thing. 10 Q. Okay, I'm not going into your subjective 11 motive for doing it, Mr. Anderson, all I'm trying to 12 determine is whether the information you previously 13 gave to the Los Angeles Police Department was true or 14 was false, so -- so hold on, Mr. Anderson. 15 A. Okay. 16 Q. I want to make sure that you and I are on 17 the same page. 18 A. Uh-huh. 19 Q. Because I'm not a bully and I don't bully 20 people and I treat everybody with respect, and I'm 21 trying to do that with you. 22 A. All right. 23 Q. But for each one of these individual 24 statements, because you've made statements which are 25 contrary to what you're telling me now -- 108 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. Right. 2 Q. -- I need to go into them with you and 3 find out whether you knowingly made them falsely when 4 you made them, all right? So that's what I'm trying to 5 do. 6 A. Okay. 7 Q. And this statement that was on your 8 polygraph that you spoke with Reggie Wright 9 afterwards -- 10 A. Uh-huh. 11 Q. -- that was false? Irrespective of what 12 your motive was, that was a false statement, right? 13 A. Everything in that tape is false. That's 14 what I've tried to tell you, so it's like when you keep 15 asking me, it's like I'm repeating myself or whatever. 16 But everything in those statements -- Reggie Wright, 17 Rafael Perez, David Mack and Suge, all those statements 18 are false. Just as they are in Kenneth Boagni's 19 statement and Mario Hammonds' statement, they're false. 20 Q. Well, let me ask you this: Larry Longo 21 represented you, right? 22 A. Yes, he did. 23 Q. And Mr. Longo is an attorney, correct? 24 A. Yes, he is. 25 Q. And Mr. Longo is an attorney with a 109 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 relationship to Suge Knight, correct? 2 A. Yes, he is. 3 Q. All right. Is it true that Mr. Knight 4 caused Mr. Longo to be paid for assisting you on your 5 case? 6 MR. MARELLA: Objection, lack of foundation. 7 THE WITNESS: I can't answer anything about my 8 case related because Larry Longo is about to be 9 subpoenaed in my case. 10 MR. FRANK: 11 Q. All right. 12 A. So, I can't answer anything about 13 Mr. Longo, that would be breaking confidenti -- he's my 14 -- he's an attorney, I would be breaching that. 15 Q. Okay. So in respect to any question I may 16 have about Larry Longo and the source of payment, 17 that's a question while sitting here today you're gonna 18 choose not to answer, right? 19 A. I can't answer. But if you want me to -- 20 I can tell you this, that Suge Knight has never given 21 me a dime, nor has he ever -- how do I -- I can't 22 answer that question anything to do with my case. 23 Q. Okay. Has -- has Mr. Hawkins paid for any 24 of your legal counsel? 25 A. Keith Davis and Hawkins have paid for some 110 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 of my -- not the legal counsel I have now. I mean, I 2 don't even have any money. These guys doing my case 3 pro bono. But they paid for my trial attorney who 4 railroaded me on the case, yes, they did. 5 Q. Okay. I'd like to take another break. 6 We're getting close to the end. 7 MR. MARELLA: Okay. 8 THE VIDEOGRAPHER: Going off the record at 9 11:45. 10 (Recess taken.) 11 THE VIDEOGRAPHER: We are back on the record 12 at 11:54. 13 MR. FRANK: 14 Q. Mr. Anderson, you had indicated that Fred 15 Miller, who was present during the April 1997, meeting 16 with Poole and Balderama and Miller and two or three 17 lieutenants, was a bad cop, what do you mean by that? 18 MR. MARELLA: I'm going to object to relevancy 19 grounds. 20 THE WITNESS: He's a bad cop. It involves my 21 case and I was set up by the Los Angeles Police 22 Department, and I believe that Mr. Miller has 23 participated in that framing that they've done to me. 24 And continues to do to this day. 25 /// 111 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 MR. FRANK: 2 Q. And then you also mentioned a Miller who 3 was an officer involved in the New Castle robbery; is 4 that a same Miller or a different Miller? 5 A. A different Miller, he was a sheriff. 6 Q. Okay, do you know the sheriff's name? 7 A. I don't know. We used to call him Miller. 8 Any narcotic officer in Los Angeles will know who I'm 9 talking about. I believe he's dead actually, he got 10 killed by a drug dealer. 11 Q. Do you recall telling the L.A.P.D. that 12 while you were in Parker Center that Perez came to your 13 holding cell and threatened your life? 14 A. I remember telling them that because 15 Kenneth Boagni told me to say that and he would verify 16 it in his statement, that's why I said that. I never 17 saw Rafael Perez, he never came to my cell. I don't 18 know David Mack. And I understand the guy, according 19 to Mr. Boagni, was very remorseful for what he did, and 20 Mr. Boagni has been lying on Mr. Perez for the last 21 several years. So, I don't know the man, he never came 22 to my cell. I don't know David Mack. 23 Q. How do you know Perez is remorseful for 24 what he did? 25 A. Because Kenneth Boagni shared it during 112 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 the conversation of concocting this story to assist the 2 plaintiffs in this lawsuit. 3 Q. That Mr. Perez was feeling bad about what 4 he had done? 5 A. Yes. He specifically told me -- to give 6 you an example, during the conversation we had in the 7 building, he said that Perez and him were watching 8 television, and he says that everything that Perez 9 would tell him he would just reverse it because his 10 brother, Mike, told him that if he gathered information 11 on Perez to assist to clear the police officers that he 12 was going to the Board of Rights hearings for, it would 13 help him in getting a sentence reduction on his 14 burglary charge. He had a three strike case. And that 15 he at first was assisting the Los Angeles Police 16 Department to get a benefit for himself to not get a 17 life sentence. And when that didn't work out, then he 18 turned on the Los Angeles Police Department, because he 19 said one of the Internal Affairs officers promised him 20 that he would give him a lighter sentence if he 21 assisted him with gathering information, according to 22 Boagni. 23 So he told me that how he would twist up what 24 Rafael Perez would said -- would say to him during 25 their conversations in the pod, that they were watching 113 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 television one day and they were watching Heraldo or 2 Oprah or something, and it was something about the 3 World Trade Center. And he would say that Perez said 4 he was going to blow the city up like the World Trade 5 Center, but what Perez was actually saying was he 6 wished he could go back into the military and start his 7 life all over again because he had messed up. He was 8 very -- he was truthful about the statements that he 9 made against those crooked officers. Everything he 10 said to Boagni was the truth, but Boagni would switch 11 it around to benefit himself to gain credit with the 12 Internal Affairs officers that were representing the 13 officers in those Board of Rights hearings. 14 Q. But you never spoke with Perez yourself? 15 A. No, sir. 16 Q. And to this day you've never met him? 17 A. No, sir. 18 Q. Okay, and when you told the L.A.P.D. that 19 he came to threaten you while you were being held at 20 Parker Center, that wasn't true, was it? 21 A. No, it was not. 22 Q. Okay, why don't you go to 275549, side A, 23 2630. 24 (Audiotape played.) 25 MR. FRANK: Time on that? 114 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 MR. BRIZZOLARA: Stopped at 2813. 2 MR. FRANK: 3 Q. Okay. So the statements on that tape you 4 just heard, those weren't true? 5 A. Everything con -- con -- those statements 6 were concocted in Delta 3 with Kenny Boagni and Mario 7 Hammonds. 8 Q. Now, during the time that you were up in 9 Parker Center -- 10 A. Uh-huh. 11 Q. -- was it Poole that was asking the 12 questions or was it Balderama or Miller? 13 A. I don't want to lie, so I don't know. 14 Q. Okay. 15 A. I can't recollect who was saying the 16 questions. 17 Q. Okay. Can you describe Detective Poole 18 for me? 19 A. I want to say heavyset, kind of tall. 20 Miller is skinny. Because one was big, one was small, 21 if I remember correctly. 22 Q. Do you remember Detective Katz talking to 23 you at all? 24 A. He looked sort of like a foreigner guy 25 maybe, like he was from the Middle East somewhere 115 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 maybe. 2 Q. Okay, did he ask you questions? 3 A. I don't remember. 4 Q. All right. And you had indicated that 5 Mr. Boagni had a relationship with Ya May Crystal; is 6 that correct? 7 A. Yes, sir. 8 Q. Did she speak with you while you were at 9 Parker Center? 10 A. I believe once I spoke with her on the 11 phone, and I also spoke with her I believe at Parker 12 Center when I was down there in 2002. 13 Q. What were you at Parker Center for in 14 2002? 15 A. I was down for my appeal. 16 Q. Okay. Prior to your appeal in 2002, did 17 you ever have a chance to speak with Miss Crystal? 18 A. Yes. 19 Q. Okay, in person? 20 A. No, over the telephone. 21 Q. Okay. On how many occasions did you speak 22 with her on the phone? 23 A. I want to say twice, but I know definitely 24 once. 25 Q. And what was the content of those 116 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 conversations? 2 A. It was, again, Boagni trying to gain 3 influence with the Internal Affairs officers at 4 L.A.P.D., and he would call her directly. And I want 5 to think -- say the guy's name is Mike. I don't 6 remember if that was her partner's name, I believe his 7 name was Mike also because Boagni's brother's name is 8 Mike, but I could be wrong. And those were the two 9 individuals that were Boagni's handler or who had 10 contact with Boagni on the -- the Rampart 11 investigation. 12 Q. And you indicated that Mr. Boagni had 13 frequent phone contact with her? 14 A. Yes, he did. 15 Q. How frequent? 16 A. Maybe once a day, once every other day. 17 Boagni received a lot of special privileges. He used 18 to get called out to go to -- I don't want to go there 19 right now -- but someplace at this prison. Him and 20 Mario Hammonds received a lot of leeway over calling 21 Russell Poole, as well as Ya May Christie and her whole 22 unit down there at Internal Affairs. 23 Q. Now, were you present during these calls 24 to her? 25 A. Yes. 117 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. And what subjects were discussed? 2 A. Again, I believe that the relationship 3 that Kenneth Boagni -- one conversation that comes to 4 my mind is they were talking about a chief of police or 5 a deputy chief and a lieutenant who was supposed to be 6 wearing pajamas, and they had this whole scam that the 7 plaintiffs had set up that it was a -- that they were 8 going to discredit the investigation that the Internal 9 Affairs had did on -- that was the whole part of 10 me doing it, they wanted to discredit the Internal 11 Affairs investigation. And that this -- this guy used 12 to wear pajamas or something and they were going to 13 file a complaint against him. 14 Q. What Internal Affairs investigation were 15 they trying to discredit? 16 A. The Rafael Perez investigation. 17 Q. Which one? 18 A. Rampart. 19 Q. Okay. 20 A. That was Boagni's initial dealing with 21 this case was the Rampart stuff, because he was housed 22 in the same unit with Rafael Perez. 23 Q. All right, so -- so they're -- a portion 24 of the Crystal conversations with Boagni was they were 25 going to use this what you call a scam regarding the 118 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 lieutenant in the pajamas to discredit -- 2 A. No, he was the chief. It was a 3 lieutenant's name he said. I remember Berkow, his name 4 was Berkoe, Berkow or something, I remember that name. 5 Q. Okay, was he the one with the pajamas? 6 A. Yes. 7 Q. So they were using this claim against 8 Berkow and the pajamas to discredit the I.A. 9 investigation against Perez? 10 A. Well, how it started was is that Poole 11 evidently considered Parks to be a "house nigger" is 12 what he called him. He felt that the "house nigger" 13 was the words that was used in the conversation, was 14 impeding or interrupting his -- 15 Q. Hold on a minute, I'm gonna -- I apologize 16 for interrupting you, Mr. Anderson, but, okay, this 17 conversation that you're telling me now with Poole, did 18 you have this conversation with Poole? 19 A. I was in the room when the conversation 20 was taking place. 21 Q. Okay, who is it -- who were the 22 participants to the conversation? 23 A. Kenneth Boagni, Mario Hammonds and myself. 24 Q. And Detective Poole? 25 A. Yes. 119 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. Okay, and where did it take place? 2 A. Over the telephone. 3 Q. Okay, how do you know Poole was on the 4 other end? 5 A. Because Boagni called him. 6 Q. Okay. Could you hear Detective Poole? 7 A. I know he was on the phone, I spoke with 8 him. 9 Q. Okay. So you spoke with him? 10 A. See, this is getting real sticky in here 11 because I'm still in this prison, and I told somebody 12 that until I'm taken out of this prison, I'm not gonna 13 talk about Russell Poole. There were favors given here 14 by this prison to those two inmates, and that's the 15 best way I can answer that question. I don't know 16 who's looking through that window, I don't if there's a 17 microphone in here, I don't know what. 18 Q. Well, there are microphones in here. 19 A. I'm not talking about your microphones. 20 Q. All right. How do you know Detective 21 Poole used a racial epithet? 22 A. I heard it. 23 Q. Okay. Were you -- were you the one on the 24 phone when he used it? 25 A. Mr. Franks, I'm not trying to be 120 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 disrespectful. 2 Q. Sure. 3 A. But this is Corcoran State Prison. I 4 don't know if you heard rumors about Corcoran, but I 5 don't know who's listening. This involves officials 6 that work here at this prison so I'm not gonna go into 7 that. 8 Q. Okay, and Mr. Anderson, I'm not trying to 9 be disrespectful either, and -- and I'm appreciative of 10 things. And it will often be the case today that I'll 11 ask you something that you either don't know or -- or 12 for some reason that may be perfectly legitimate -- 13 A. Uh-huh. 14 Q. -- you don't want to tell me. It's not 15 gonna stop me from asking. 16 A. I understand. 17 Q. And it's not gonna stop you from telling 18 me that you don't want to tell me. 19 A. Okay. 20 Q. And I don't get offended when you tell me 21 that, and I hope that you don't get offended when I ask 22 you. 23 A. I'm not getting offended, I just hoped 24 that this would have been done in a different setting, 25 then I can be more open with what I want to say about 121 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 what you're -- that particular question that you're 2 asking me. 3 Q. All right, so if this were to be done, for 4 example, at the federal courthouse, that would be a 5 place where you would feel a little bit more free to 6 discuss things with us? 7 A. I would feel more free down at the Los 8 Angeles County Jail in my own backyard to where my 9 appropriate attorney could be there and certain people 10 could be there that I feel should know about this 11 information. But right now at this prison is not the 12 time for me to talk about that particular phone 13 conversation. I can describe other content of the 14 conversation to you, but how the call went down, who 15 did the call and so forth, I can't answer that question 16 right now at this point. 17 Q. Okay. And the point I'm getting at right 18 now is apparently Detective Poole used a racial epithat 19 (sic) as it related to -- 20 A. Chief Parks. 21 Q. -- Chief Parks? 22 A. Yes, sir. 23 Q. And you weren't necessarily on the phone, 24 but you heard the epithat (sic)? 25 A. I heard that it took place, yes, sir. 122 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. Okay. 2 MR. REICHERT: Epithet. 3 THE WITNESS: It's the seizures. 4 MR. FRANK: 5 Q. No, no, it's not. I've told all these 6 guys, Mr. Anderson, that I'm not a -- I'm not the 7 smartest lawyer in the room. They all know that, but I 8 do my best to talk to folks. 9 MR. MARELLA: Watch out for country lawyers. 10 MR. FRANK: 11 Q. All right, so what -- you indicated that 12 you could tell me some more portions of the 13 conversation, you just can't tell me how it all went 14 down? 15 A. That's correct. 16 Q. Tell me what you can about this 17 conversation, please. 18 A. Well, Poole's feeling in this is that the 19 house nigger, Parks, is what he called him, was 20 destroying his investigation. And for the first time 21 the Los Angeles Police Department had it right, South 22 Side Compton Crips killed Biggie Smalls. And Russell 23 Poole got an inkling behind Sharitha's Kevin Gaines and 24 he wanted to follow that lead. And in short, in doing 25 so, he felt through conversations he had with the 123 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Internal Affairs Office -- him and Christie Ya May have 2 been friends for -- or I feel were in cahoots with this 3 thing from the beginning because they were sharing 4 information that Kenneth Boagni was providing her about 5 Rafael Perez. And he -- he felt that his investigation 6 was getting shut down with him trying to investigate 7 Rafael Perez and David Mack to this case, because he -- 8 Q. How do you know that, Mr. Anderson, was 9 this a conversation you had with him or you overheard 10 with him? 11 A. This was a conversation that I took part 12 of with Russell Poole -- 13 Q. Okay. 14 A. -- Kenneth Boagni and Mario Hammonds at a 15 certain place in this prison. Again, that's why I say 16 I'm trying to pick my words wisely here. 17 Q. All right. So -- so there was a 18 conversation where Mr. Boagni was present, Mr. Hammonds 19 was present, you were present, and Detective Poole was 20 on the phone? 21 A. Detective -- Detective Poole was able to 22 hear our conversation, put it that way. 23 Q. Okay, all right. 24 A. Was a part of the conversation. 25 Q. Okay. Who else was part of the 124 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 conversation? 2 A. Mario Hammonds, myself and Kenneth Boagni. 3 Q. Okay, and Detective Poole? 4 A. Yes, sir. 5 Q. All right. And it was during this 6 conversation that he relayed to you that he had been 7 receiving information from Miss Crystal from 8 Mr. Boagni? 9 A. That was part of the conversation. It was 10 also a part of the conversation trying to convince me 11 that if I would endorse or verify and would participate 12 in what was going on, that this would be beneficial to 13 everybody. And that my information of what I know -- 14 he was trying to -- I was very reluctant to participate 15 because of my involvement with Larry Longo at that 16 time, and my excuse for always trying to string them 17 along was that Larry Longo was my attorney and I really 18 couldn't say anything. So I was brought in on this 19 conversation, and during this conversation he was 20 trying to inform me that me being close to knowing Suge 21 and what I can bring to the table was one part of it, 22 what Kenneth Boagni can bring to the table from him 23 being around Rafael Perez, and what Mario Hammonds 24 could bring to the table him being in the presence of 25 Suge Knight at CMC prison was -- was -- was like a 125 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 heaven scent, and what -- what he can bring to the 2 table from his involvement with the investigation with 3 the house nigger, what he felt the house nigger was 4 trying to do, he specifically called him the house 5 nigger. 6 Q. All right, when -- when did this 7 conversation take place? 8 A. It was in between 2001, 2002. It had to 9 be, because if you're saying that the interview took 10 place in 2002, it was sometime in between, though, 11 before I went down to the county jail. 12 Q. Okay, and was the Boagni and Crystal 13 attempt to discredit Berkow part of this conversation? 14 A. Yes. 15 Q. So the Boagni/Crystal attempts to 16 discredit Berkow began in the 2001, 2002 time frame? 17 A. Yes, sir. It could be 2000, I don't want 18 to -- don't box me in, but I know it was before the 19 tragedy that happened in New York, before the 911 20 thing. 21 Q. And how do you know it was before 911, 22 just based on recollection? 23 A. Yeah, I'm trying to pinpoint it in my 24 brain as I'm sitting here talking to you during this. 25 I'm bad at dates. I know the information, but I don't 126 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 the dates. 2 Q. And was Detective Poole part of the 3 attempt to discredit Berkow? 4 A. Yes, he was, as well as he wanted to -- 5 I'm trying to find the perfect word to tell you -- he 6 also wanted to shame, I should say, Chief Parks. 7 Q. Have you ever met Chief Parks? 8 A. No. He was the Chief when they wrongly 9 convicted me, too. 10 Q. Do you know whether Mr. Boagni provided 11 any written information to Miss Crystal? 12 A. The way he explained what he was doing, 13 yes, sir, and to somebody named Cliff, I don't remember 14 the last name. He told me something about Cliff or 15 Clifford. He was also he considered to be in his 16 pocket. 17 Q. And do you know what written materials he 18 provided to Miss Crystal and to Mr. -- is Clifford a 19 first name or a last name? 20 A. I don't know. He just said -- I remember 21 him calling him Cliff or something like that. 22 Q. All right, I'll just use the term "Cliff." 23 A. Okay. 24 Q. I don't know who it is. 25 A. He was an investigator for the L.A.P.D. 127 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 that had something to do with the Rafael Perez 2 investigation in the Rampart aspect of this case. 3 Q. Do you know what written information 4 Boagni gave to Crystal and to this Cliff? 5 A. Well, he -- first of all, when Boagni 6 first came here, he told me he was transferred down to 7 this prison through a special transfer, which I don't 8 really want to go through. It had something to do with 9 Poole here at this prison. But he specifically told me 10 that when he was in Rafael Perez's presence, he would 11 never talk about David Mack. He, like, would never 12 even mention nothing about the robbery, he never said 13 anything about Christopher Wallace murder to him. He 14 would talk about -- to Boagni he was very remorseful 15 for what he had done, and he was telling the truth and 16 he wanted to clear his conscience according to Boagni. 17 Q. Okay, that's something Boagni told to you? 18 A. Yes, sir. But I'm trying to get to what 19 you're asking me. 20 Q. Got it, go ahead. 21 A. Okay, so Boagni when he got here, was 22 telling me, "Hey, man, I got it from good sources that 23 you really know what happened in this murder, and you 24 know everything about these guys in the record 25 industry, so if you can inform me about --" he told me 128 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 that in his statements that he gave to these people, 2 all he would ever say to them is, is that he didn't 3 want to talk about that right now, but Perez had told 4 him and he really only could -- could misscrew things 5 that Rafael Perez actually told him what he did in 6 Rampart. But because Rafael Perez never told him 7 anything about Christopher Wallace cases, he never 8 could provide any names. So according to him in his 9 statements, all he would say is Perez told him he went 10 to Las Vegas and something about some cocaine, he had 11 cocaine parties and he went to Vegas. And he said 12 Perez told him he went to Vegas, but he didn't do 13 drugs. So he would add in incriminating things to try 14 to discredit Perez in those statements. So he needed 15 me to provide him with certain names, such as Fletcher, 16 such as Reggie, Psychs, and I don't remember all the 17 names that I told him right now, because I'm trying to 18 get to your point. But he didn't know anything because 19 Perez had never told him anything about the -- the 20 murder. 21 He tried to say -- he wanted to say that Perez 22 told him that he -- that he picked up some bullets or 23 something at the murder scene, and I told him, "That's 24 not how the murder happened so I'm not gonna verify 25 that." He said that he tried to ask Perez was he -- 129 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 where was he on the day of the murder, and he told him 2 that, point blank, he had nothing to do with the 3 murder. So he was trying to get my information what I 4 knew about the murder to include with the information 5 he was given, which was again he only could say about 6 Las Vegas, something about some drugs, gang activity. 7 But they were all lies he told me what he said in his 8 statements. 9 Q. Did -- did Mr. Boagni ever relate to you 10 whether Officer Perez indicated he was on or off-duty 11 on the night of the murder? 12 A. I believe he told me that Rafael Perez -- 13 again, he never talked to Kenneth Boagni about the 14 murder. He never had one conversation about the 15 murder. Kenneth Boagni told me he was going to say 16 that Rafael Perez told him he was on the scene of the 17 murder and that he received a phone call from David 18 Mack, or he called David Mack or Mack called him and 19 told him to get out of the way because it was about to 20 go down, and that Perez was working that night and that 21 he was going to go pick up the bullets. That's what he 22 said he was going to lie and say. 23 Now, he told me that David Mack, or I mean 24 Rafael Perez specifically told him he didn't know 25 nothing about the murder, but he made this up in his 130 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 mind about the bullets. And when he told me that, I 2 told him I'm wasn't gonna say that because that's not 3 how the murder happened. The murder happened with a 4 car in front of it. A lot of people are -- are saying 5 that Puffy went through the light when the shooting 6 happened. Puffy did not go through the light when the 7 shooting happened. 8 Q. How do you know that? 9 A. I know it. I'm not gonna go into that. I 10 know who killed him. 11 Q. Did someone tell you that? 12 A. I just told you an hour ago that Keith 13 Davis told me everything that happened that day, 14 everything that was planned out that day to kill him. 15 Q. All right. Let me -- let me get at it 16 another way, then. 17 A. Okay. 18 Q. Mr. Anderson, you weren't there, you 19 didn't see it? 20 A. No, I wasn't there and I did not see it -- 21 Q. All right. 22 A. -- but I was told by the individual who 23 did it. 24 Q. Okay, so that's what I was getting at. 25 A. But I said that an hour ago, I don't know 131 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 if you remember it. 2 Q. Well, no, I got it. 3 A. Oh, okay. 4 Q. But as I told you at the beginning, I'm 5 going to try to make a differentiation when I can 6 between stuff you actually witnessed -- 7 A. Okay, got you. 8 Q. -- and stuff that somebody told you. And 9 that's one of those things that somebody told you. 10 A. Well, and it was Keith Davis who was part 11 of the conversation. So when Boagni wanted me to 12 verify that part of the lie for him, I was trying to 13 tell him, "Man, you're gonna say some stuff and it's 14 eventually gonna cross you up because that's not how 15 that happened." 16 Q. Okay, well, let me go back to my question 17 to you, which was: Did anybody at any time represent 18 to you Officer Perez's on-duty or off-duty status? 19 A. He could not -- Perez never discussed the 20 Christopher Wallace murder. I was telling you what 21 Boagni said he was going to say. 22 Q. All right. 23 A. That should be in his statement because 24 that's what he told me he was going to say. 25 Q. Okay. So he didn't discuss the murder 132 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 with him sufficient to let anybody know one way or the 2 other whether he was on-duty or off-duty? 3 A. Perez specifically told him point blank 4 one time he had nothing to do with that and he had 5 nothing to say about David Mack. 6 Q. Okay, but I'm not asking about the murder, 7 I'm not asking about David Mack, I'm asking about his 8 duty status. Did he ever say whether he was on or 9 off-duty? 10 A. Boagni you mean? 11 Q. Did Boagni ever say whether Perez had 12 indicated he was on or off-duty? 13 A. He -- he indicated to me that Perez never 14 told him anything about the murder, but he made the lie 15 up that Perez was going to be on duty. I don't know 16 how to answer that question, because Boagni told me 17 what he was going to say in his lie, but he 18 specifically told me Perez wouldn't talk to him about 19 the murder, so it's a two-sided answer to that 20 question. 21 Q. All right. So Boagni was going to lie 22 about him being on duty? 23 A. Yes. 24 Q. Got it. All right, that's what I wanted 25 to find out. Okay, now just a minute ago you mentioned 133 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 a guy named Fletcher, who is Fletcher? 2 A. He was my best friend growing up. I fed 3 Boagni the name so I could bust him out with his lie. 4 He would never -- he didn't know the name William 5 Fletcher in his first interviews. William Fletcher -- 6 we played Pop Warner Football together in the San 7 Fernando Valley. 8 Q. Why would you indicate Fletcher did the 9 shooting? 10 A. I'm a lot smarter than Kenneth Boagni and 11 Mario Hammonds. Although I might be in fear of them, I 12 can outthink them. It's like playing chess. I put the 13 moves before they do. I was -- I was -- meaning those 14 statements I made to the Los Angeles Police Department 15 were not under any -- any sworn statement as this 16 statement is here, nor was I Miranderized (sic). So, I 17 felt L.A.P.D. had them coming from them wrongfully 18 convicting me of a crime so I was more than willing to 19 do whatever I needed to do towards them and at the same 20 time protect myself with Kenneth Boagni and Mario 21 Hammonds. 22 MR. FRANK: Play track 16, please. This is 23 from the polygraph. 24 MR. BRIZZOLARA: Track 16. 25 (Audiotape played.) 134 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 MR. FRANK: And go ahead and play 13 as well, 2 please. 3 (Audiotape played.) 4 THE VIDEOGRAPHER: Mr. Frank, we're going to 5 have to take a break for a tape change. 6 MR. FRANK: Okay. 7 THE VIDEOGRAPHER: Going off the record at 8 12:23. 9 (Recess taken.) 10 THE VIDEOGRAPHER: We're back on the record at 11 12:24. 12 MR. FRANK: 13 Q. Mr. Anderson, so in those two portions of 14 your polygraph where you indicate William Fletcher was 15 involved in the shooting, that wasn't true, was it? 16 A. No, sir. 17 Q. All right. What does -- what does William 18 Fletcher do for a living? 19 A. Now? 20 Q. Yeah, now. 21 A. Or before? 22 Q. Now. 23 A. Probably just plays Pac -- Play Station 2 24 it all day long. 25 Q. Okay, what did he do before? 135 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. He was a bodyguard. 2 Q. For whom? 3 A. Death Row Records. 4 Q. And you indicated that he is a long-time 5 friend of yours? 6 A. Yes. 7 Q. Is there a specific artist that 8 Mr. Fletcher would guard? 9 A. No, he's actually Reggie's cousin -- first 10 cousin, and he was just -- was part of Wrightway 11 Security. 12 Q. All right, so when referring to Reggie, 13 you're referring to Reggie Wright, Jr.? 14 A. Yes, sir. 15 Q. Why -- why did you choose to throw 16 Mr. Fletcher's name out during this interview? 17 A. Because it was a name that was chosen 18 during conversations that I would be able to at a later 19 date pick out and prove that Kenneth Boagni and Mario 20 Hammonds plotted this, because I also know that Kenneth 21 Boagni has said William Fletcher's name and Kenneth 22 Boagni would not even know who William Fletcher is. If 23 you look at the dates of Kenneth Boagni's original 24 statements, he does not state any names, he doesn't 25 know anything, but as soon as he gets in my presence, 136 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 he comes up with these names. 2 Q. Was Mr. Fletcher ever a gang member? 3 A. Yes, he is. 4 Q. Okay, and what gang? 5 A. The same gang as Suge and the same gang as 6 anybody else in Death Row. 7 Q. And what gang is that? 8 A. Lueders. 9 Q. And that is a Blood's gang? 10 A. Yes. 11 Q. You also mentioned a Wesley Crockett, who 12 is Wesley Crockett? 13 A. It is Suge's stepbrother, had nothing to 14 do with this case. Mario Hammonds wanted me to say 15 that Wesley and Big Reg, which he says was Big Reg, and 16 he was also going to say somebody named Big Psychs. 17 They were coming up with names and they wanted to know 18 names of individuals that they were verifying. When I 19 would tell them the names, they would know if I was 20 lying to them because Mario Hammonds would get on the 21 phone and call the FBI, and he would say, "Oh, yeah, 22 that guy is connected to Death Row." So that's why I 23 gave them the real name of William Fletcher, as well as 24 Wesley Crockett, because, again, at a later date I 25 would be able to prove that those individuals were 137 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 lying. I was not going to go into a courtroom and lie 2 to anybody or go under oath and tell a lie, so... 3 Q. When did you first throw out William 4 Fletcher's name as a possible shooter? 5 A. I don't remember the date. I don't 6 remember the time. 7 Q. Do you remember when the agreement was 8 with Boagni that you would do that? 9 A. Again, whenever the times they were here. 10 I don't know what time we were all here together. I 11 don't know. 12 Q. Okay, when is -- when did you decide to 13 throw out Wesley Crockett's name? 14 A. Again, it was in the same time frames or 15 periods, I don't remember the -- the interview. And 16 not only, you know, was it -- was it Boagni who said 17 those -- those names, the South Side Compton Crips also 18 wanted to implement the Bloods as being involved 19 because they wanted to get it off of them because of 20 other reasons, but... 21 Q. And by that what you're -- what you're 22 telling me is that when -- when a person has potential 23 criminal liability, they're going to do what they can 24 to try to shift that to somebody else? 25 A. Exactly. 138 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. All right. And so it wouldn't be unusual 2 if a gang member or a gang was -- 3 A. Oh, they do it all the time. It probably 4 just happened five minutes ago somewhere, you know. 5 Q. And if I could finish my question. It 6 wouldn't be unusual for one gang to try to come up with 7 evidence to demonstrate that another gang did a murder 8 that they did? 9 A. Yes. 10 Q. Okay. 11 A. That is the way it works out there on the 12 street, as well as try to convince the police it's 13 someone else to where the evidence would fit what the 14 police trying to say. 15 Q. Is Wesley Crockett a Blood? 16 A. No, he's not. He's not a gang member. 17 He's just a security guard with a -- you know, a career 18 in -- in assisting artists. He's never been to my 19 knowledge in any trouble. 20 Q. Were you -- did you spend any significant 21 time around the Death Row recording studio? I think 22 it's in Tarzana. 23 A. You're talking about Can-Am Studio? 24 Q. Yeah, Can-Am Studio, that's right. 25 A. We -- we were -- by the time Can-Am Studio 139 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 came into play -- I've been to Can-Am Studio, but that 2 wasn't Death Row's studio, so that's just another myth 3 that's thrown out there. But Suge Knight is a Blood 4 and my affiliation is with Crips, so when Death Row 5 came into form, we were no longer, you know, where we 6 went out to dinner or lunch together. My manager was 7 Jerry Heller who hates Suge Knight. And so we didn't 8 hang at Can-Am Studio when Can-Am Studio became the 9 Death Row camp. 10 Q. Okay, you indicated you're affiliated with 11 the Crips, what does that mean? 12 A. I was born -- you know, being born in 13 inner cities across this country, you're sort of like, 14 even though you're not a member of a Crip gang, you're 15 affiliation is with that Crip gang because you're born 16 into that, you know, neighborhood. I didn't choose 17 where I was born at. My grandmother bought a house on 18 39th and Western and it just so happened that 19 neighborhood is in what's called the Rolling 30's. So 20 you fall underneath what's called the Crip category. 21 Suge being born in Lynwood, where his mom 22 bought her house at and he was born at, put him in a 23 community where Bloods hang at. So Suge was never a 24 gang member, but his affiliation was with Bloods, so... 25 Q. Did Mr. Crockett have an affiliation? 140 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. Mr. Crockett, again -- 2 Q. And by this I mean Wesley Crockett. 3 A. Mr. Crockett is -- I know you're -- you 4 know, I don't know how long you've been in California 5 or know about Los Angeles, but certain names like 6 Wesley Crockett and Mike Conception, Hawkins name, 7 people like that you really don't discuss on tapes what 8 they do, so... Those guys are what they considered 9 OG's, so I don't know how to answer that question 10 without putting myself -- again, some lawyer is going 11 to get this tape. I have nothing bad to say about 12 Wesley or Mike Conception. 13 Q. Okay, what's an OG? 14 A. An original, so people who are the 15 founders of gangs. So certain people you don't say, 16 you know, anything about. He had nothing to do with 17 the murder of Christopher Wallace or Tupac Shakur. 18 Q. Okay, but Wesley Crockett fills -- fits 19 into the OG category? 20 A. Yes. And, I mean, that's just common 21 knowledge from the street people would know that so I'm 22 not really sitting here snitching on them or saying 23 anything about them, yes. 24 Q. And then Hawkins falls into that category? 25 A. The whole Hawkins family falls into that 141 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 category. 2 Q. Now, you mentioned Jerry Heller? 3 A. Uh-huh. 4 Q. He was your manager? 5 A. Yes. 6 Q. And when did he become your manager? 7 A. Shh, man, I'd say '87, '88. I saw him at 8 Capitol in '86, so maybe '87, '88. 9 Q. And how long did he work as your manager? 10 A. Oh, we kept an ongoing relationship. I 11 mean, he's full of knowledge about the record industry. 12 I spoke with him all the way up to -- I still speak 13 with him, so... I don't know how to -- 14 Q. Is Mr. Heller affiliated with any gang? 15 A. He's older than -- he could be your 16 grandfather, no. Jerry's not -- Jerry's like in his 17 late 60s, 70s maybe. He's old. He's never been -- I 18 mean, he claims he's from Cleveland. Maybe you want to 19 give him The Mob credit or something. He's an ol' 20 white guy, I mean... 21 Q. All right, so Mr. Heller is not a OG, he's 22 an OW? 23 A. No, man. 24 MR. MARELLA: Just o-l-d. 25 THE WITNESS: No, Jerry's a -- 142 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 MR. FRANK: 2 Q. An OWG, got it. All right, who is Ricky 3 Crockett? 4 A. I don't know who Ricky Crockett is. 5 That's one of the names that Boagni and them guys gave 6 me. 7 Q. Okay, so that's not somebody that you 8 know? 9 A. No. 10 Q. Now, you told me about Boagni giving Ya 11 May Crystal some written materials; do you know what he 12 gave her by way of written materials? 13 A. I know he told me he gave them a 14 statement, and in these statements from what -- 15 according to him is he provided them skeleton 16 information because he didn't have anything to really 17 tell them. He was lying on Mr. Perez, he was switching 18 around information. Something about a sergeant, a bust 19 he did with -- or Perez did something with a sergeant, 20 and he went and actually told the sergeant what these 21 people had did, and the sergeant took a bottle of wine 22 or took some type of liquid and poured it around or 23 something, and Perez was actually telling the truth, 24 but Boagni switched the story around. I know that was 25 one of them. Something about the World Trade Center. 143 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Mario Hammonds said something about -- 2 asked -- asked how -- Boagni was going to try to say 3 Perez said he was on duty and removed the bullets from 4 the murder scene. Mario Hammonds said something to me 5 about he was going to say that he saved Suge's life 6 from the Rolling 60's when he was at CMC. And I told 7 Mr. Hammonds he didn't want to say that because that 8 would be -- it would backfire on him if they brought 9 that information forward, because Suge was actually 10 protected, which a lot of people don't understand, by 11 the Rolling 60's Crips because his friend -- one of 12 Suge's best friend's name is Marcus Nunn. And Marcus 13 Nunn is -- what Freddie Mingo is to Crips in prison, 14 Marcus Nunn is to Bloods in prison. It's called the 15 UBN Association, United Bloods Nation. And Mario -- 16 Marcus Nunn has a brother-in-law named Peetie Whack, 17 aka Rodney Glaze, that's his real name, who is the 18 leader of the Rolling 60's Crip gang. 19 So when Suge went to CMC prison, he was 20 protected not only by the Bloods, but he was protected 21 by the Rolling 60's Crips as well. So Mario Hammonds 22 said he said in his statement that the 60's wanted to 23 kill Suge, and that he saved Suge's life, and that he 24 was going to read -- he said something about he read 25 Suge's letters to him and did all of his writing and -- 144 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 and Suge can read and write. I've been in a room and 2 seen -- Suge is very intelligent. A lot of people 3 think Suge is stupid, but Suge is not stupid by any 4 means. He knows how to read and knows how to write. 5 So certain things that they said they were going to lie 6 about I tried to instruct them, but was filing away the 7 information because I knew these things would later 8 come back out to haunt them. 9 Mario said he said something about being in 10 Las Vegas when the fight took place when Tupac was out 11 there, and that he said that they told him that 12 something about he was asked to kill -- Suge asked him 13 to kill Tupac when he told me he never was in Las Vegas 14 and met Suge. First of all, Mario -- everybody knows 15 that Mario Hammonds is a labeled snitch because of 16 Felix Mitchell's case was publicized, and Suge never 17 even had any -- any dealings or contact with Mario 18 Hammonds when he was at CMC prison. He only -- he 19 fabricated this information. He actually said that the 20 Bloods told him to stay the hell away from Suge when he 21 was at CMC, but he tried his best to get information 22 from him, but he was providing false information that 23 the -- someone from the prison was telling him to the 24 FBI to get the search warrants they got on Suge's 25 place. 145 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 So they had fabricated a whole bunch of 2 information. It would take me hours to sit here and 3 say all the lies that they wanted to -- to say in their 4 statements and stuff like that, so... 5 Q. Okay. But my question was a little bit 6 different than that, and that is, what written material 7 did he give to Crystal, do you know? 8 A. I was -- everything I just said to you in 9 those statements. They were a statement. 10 Q. All right. So he gave to Crystal writings 11 that contain the information -- 12 A. Yes. 13 Q. -- you just relayed to me? 14 A. Yes, and to somebody named Cliff. 15 Q. Okay. When -- when -- when did that 16 happen? 17 A. He told me he gave one of them I think in 18 '99 or 2000, when he said he first met Miss -- Mrs. 19 Christie, Crystal or whatever her name is. I just know 20 her by Christie is what I thought her name was. And he 21 said that he mailed them to somewhere in Arcadia. He 22 used to send her letters in Arcadia, somewhere in 23 Arcadia, California. He said something about this guy, 24 Cliff, he gave a statement to at Calipatria State 25 Prison. And then he said Poole had him moved down here 146 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 to get to me to see if I would verify what he wanted to 2 say. 3 Q. Were you ever moved in with a Cliff? 4 A. No, Cliff is a L.A.P.D. officer. I don't 5 know -- 6 Q. Okay, I didn't -- I didn't get that. 7 A. Okay. 8 Q. Okay, so thank you for letting me know 9 that. 10 A. Some -- and, you know, he said he did a 11 interview at Calipat before he got here, and then he 12 had did interviews -- they used to pick him up from 13 here. They would give him removal orders and take him 14 to Boagni out of this prison once a week, twice every 15 other week. 16 Q. Did Mr. Boagni ever give you written 17 information? 18 A. Oh, no. Although I read the -- you know, 19 he has a book he wrote called "He Told Me So" that 20 he -- it's about Rafael Perez. I've read some of the 21 material and I gave it back to him, I've read some of 22 that. He has a book deal now. That's the only written 23 material that I've actually -- 24 Q. Who has a book deal? 25 A. Kenneth Boagni. Which he claims that 147 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Perry Sanders got for him is what he's telling 2 everybody. From the attorney there in Atlanta and one 3 of them is in New York. I have the addresses, I turned 4 them over to the person that I trust with this 5 information. If you'd like me to send them to you or 6 whatever. 7 Q. And Boagni never gave you any written 8 materials or notes? 9 A. I just said that I read what he was 10 writing about Perez in his book, that's the only 11 written material that he's ever given to me, but it was 12 for 25 minutes of -- again, of trying to correct him of 13 what he was trying to say he was going to lie about 14 Perez. Because I told them if they wanted me to be a 15 part of this, that it had to be done more smoothly to 16 where we all wouldn't be made to look like liars, 17 because a lot of the information they were saying were 18 verifiables to be proven that they are lying, because, 19 again, the 60's thing, saying the 60'ss were going to 20 kill Suge and Mario Hammonds was protecting him at CMC, 21 and with Boagni that, you know, saying that Perez was 22 on duty when Perez didn't tell him he was on duty. And 23 certain things can be verified, and I tried to point 24 those things, you know, out to them, but still they 25 wanted to do it their way, so I participated. I feared 148 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 them so I did what they wanted to do. 2 Q. Are you still afraid of them? 3 A. Yes. 4 Q. If -- if you're still afraid of them, how 5 come it is, Mr. Anderson, that you're telling all of 6 this right now? 7 A. Because for one, I don't believe that I 8 will be in prison longer than another 10 to 14 days, 9 and I know that my attorney is -- as I'm sitting here 10 doing this deposition, is filing removal orders and 11 everything else to remove me from this prison and to 12 have me moved to a safer facility, and that we have a 13 hearing that's scheduled in a few days. My case has 14 been all in the media, and it's -- the truth is out 15 there now, so... My family and my son in particular 16 and my wife and individuals, I feel it's now time to 17 tell the truth. 18 Being in prison wrongfully for something you 19 didn't do -- David Mack might be the worst cop that 20 ever worked for L.A.P.D., Perez might be the worst cop 21 that ever worked for L.A.P.D., but if you didn't do 22 something, I don't think you should be accused of 23 doing, and I just want the truth to come out. When 24 Mr. Robleto contacted me months ago and now that I'm 25 subpoenaed and under oath, I want to tell the truth, so 149 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 that's why I'm doing it. And I want to show Boagni 2 that I'm not for sale, so... 3 Q. Did Perez know Hawkins? 4 MR. MARELLA: Objection, foundation. 5 MR. FRANK: 6 Q. Do you know whether Perez knew Hawkins? 7 A. You couldn't pay a Hawkins member to have 8 anything to do with law enforcement, so they don't know 9 Rafael Perez or any other law enforcement knowingly. 10 Q. Okay. Please pull up 275549, side B. 11 MR. BRIZZOLARA: 275549. 12 MR. FRANK: 275549, side B, and start at 38 13 and play it through one minute. 14 MR. BRIZZOLARA: 275549, side B, and what -- 15 what now? 16 MR. FRANK: 38 seconds to one minute. 17 MR. BRIZZOLARA: Actually, 37. 18 (Audiotape played.) 19 MR. FRANK: 20 Q. Was that true what you said? 21 A. When I said Hawkins and everybody else, 22 have I been threatened by Hawkins? Yes, I've been -- 23 Q. When you said Perez and Hawkins. 24 A. That didn't -- tape didn't say that. Play 25 it again. 150 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. Play it again. Listen to the -- close to 2 about the last about five seconds of it -- five, ten 3 seconds of it. 4 (Audiotape played.) 5 MR. FRANK: 6 Q. Did you hear that? 7 A. No, he doesn't know Mr. Hawkins at all. 8 Q. That you know of? 9 A. I know he doesn't know Mr. Hawkins. 10 Q. How do you know that? 11 A. Because everything that involved Rafael 12 Perez on that tape again was placed into true people 13 threatening me, and was added because I was asked to by 14 Mario Hammonds and Kenneth Boagni. Perez never had any 15 affiliation with the South Side Compton Crips, nor did 16 he have -- it's actually two different police 17 departments. That's one of those things that I can 18 point out to you that can be verified and proven. 19 Where the Hawkins family does their business it used to 20 be patrolled by the Compton Police Department. So 21 Perez would have no jurisdiction or even be with the 22 South Side Compton Crips. Especially him supposedly 23 being affiliated with Lueders Park. I mean, those are 24 the things that I'm trying to say to people that can be 25 pointed out. That's like, you know, saying an apple 151 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 can be grown on an orange tree. It just doesn't 2 happen. 3 So, I said that statement involving Rafael 4 Perez and everybody because I was instructed to by 5 Kenneth Boagni and Mario Hammonds. And have I been 6 threatened by the people from South Side Compton Crips? 7 Yes, that's a true statement. So, again, it's just 8 adding in that name of Rafael Perez. That's true. 9 Q. Did you provide the L.A.P.D. a chart 10 showing the relationships between various people in 11 Death Row Records and -- and L.A.P.D. officers? 12 A. I provided Los Angeles Police Department 13 with a chart of people involved with the narcotic 14 trafficking ring. No -- nothing with the chart should 15 not have detailed, or, again, if the Los Angeles Police 16 Department is adding into that chart, it is because of 17 the story that was concocted between Mario Hammonds and 18 myself and Kenneth Boagni, that was during the same 19 interview. 20 Again, had the Los Angeles Police Department 21 had the -- the integrity to do what I'm now doing, I 22 have no reason to sit here and to lie for the Los 23 Angeles Police Department, they took 14 years of my 24 life from me. And I tried to tell every officer that 25 interviewed me in the beginning, "Hey, I'm wrongly 152 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 convicted for this crime." "Uhm-uhm, yeah, we're here 2 to talk about this." To me that's insulting. So had 3 they listened to me, I might have told the truth at 4 that point about everybody and everything that I do 5 know truthful about this murder, but in doing so with 6 how they acted, I did not. So everything that has to 7 do with Rafael Perez or anything to do with a cop from 8 the Los Angeles Police Department involved with this 9 crime was added because of Kenneth Boagni and Mario 10 Hammonds asked me to do that and that's why I did it. 11 MR. FRANK: Counsel, I couldn't find looking 12 where we were ever provided with the chart which was 13 referenced in the March 27, 2002, interview. Do you 14 recall whether that, in fact, was given to us? 15 MR. REICHERT: I don't know. 16 MR. FRANK: And we don't have to address it on 17 the record now, but -- 18 MR. MARELLA: Yeah, we'll have to check. 19 MR. FRANK: -- if that's something that we 20 could find out about. 21 MR. MARELLA: We'll have to check. 22 MR. REICHERT: It was on which -- I'm sorry, 23 it was on which interview? What's the reference to it? 24 MR. FRANK: It was the March 27, 2002, 25 interview. If you take a look at tape 275549 and 153 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 generally look at about 4230 through 4245, they 2 reference the chart on the tape and Mr. Anderson giving 3 the L.A.P.D. the chart. 4 Q. Did Suge Knight ever tell you that he was 5 going to make a move on Biggie Smalls? 6 A. No, sir. 7 Q. Play track 5. This is from the hotline 8 call. 9 (Audiotape played.) 10 MR. FRANK: Was that track 5? 11 MR. BRIZZOLARA: No, for some reason it's 12 coming up with that other tape. 13 MR. FRANK: Well, you got to hear something 14 about the chart, so... 15 MR. REICHERT: Is that what that was? I 16 wasn't even listening, sorry. 17 MR. BRIZZOLARA: Okay, track 5. 18 (Audiotape played.) 19 MR. FRANK: 20 Q. Do you recall saying that to the police? 21 A. You played that an hour and maybe 20 22 minutes ago, and I told you that that statement was 23 made because Keith Davis and Psycho Mike, Michael 24 Robinson, asked me to participate in an interview with 25 the Los Angeles Police Department. And Suge Knight's 154 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 name was mentioned because, as you just said ten 2 minutes ago about gang members switching the blame to 3 other people, and Suge was who Keith Davis wanted to 4 switch the blame to. Because there was a conspiracy 5 between some individuals to take over Death Row Records 6 while Suge was in jail, which I know about and I'm not 7 going to go into, but that is why that was said. 8 Q. Were Mr. Boagni and Mr. Hammonds part of 9 that conspiracy? 10 A. No, sir. The first interview I ever did 11 with the Los Angeles Police Department behind this case 12 was because of Michael Robinson and Keith Davis asked 13 me to. 14 Q. Were they associated with the conspiracy 15 to take over Death Row? 16 A. No, they weren't. 17 Q. So -- 18 A. But Keith -- not they, but Keith Davis was 19 a part of the conspiracy, yes, sir, along with Lydia 20 Harris, Michael Harris and other drug dealers' names 21 that I will not say on this tape again until I'm where 22 I feel I'm secure. 23 Q. Okay, so there was a conspiracy to take 24 over Death Row Records that was in part the motive for 25 the statements that you made to the L.A.P.D. 155 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 implicating Marion Knight -- 2 A. Yes, sir. 3 Q. -- in this murder? 4 A. Yes, sir. 5 Q. Okay. And you indicated Michael Harris, I 6 think you said Lydia Harris, and who -- who else can 7 you name as part of that conspiracy? 8 A. Those are all that I can do at -- at this 9 point. 10 Q. Did you say that -- 11 A. Keith Davis was involved, yes. 12 Q. Mr. Davis. Okay, so -- so part of the 13 motivation for this, then, was the takeover of Death 14 Row Records by these folks and some other people? 15 A. Part of the murder of Biggie Smalls was 16 behind money being put -- put in place to take down a 17 certain individual who was at jail who ran Death Row 18 Records at the time. 19 We went to Las Vegas for a minute and then you 20 skipped, you never went back there after you took the 21 break about the $50,000 and the gun in the hotel room. 22 That was the first meeting. Then he gave him $450,000. 23 There was supposed to be a million dollar payment made 24 for the murder of Tupac Shakur and Suge Knight, but 25 only half of the money was paid. So they had a 156 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 outstanding balance of, you know, like a million seven 2 owed to the South Side Compton Crips. And certain 3 individuals were willing to pick up that tab for them 4 to make the murder of Biggie Smalls appear that Death 5 Row Records founder Suge Knight had him killed. 6 Q. And how do you know that? 7 A. I spoke with the individuals who were 8 directly involved in the planning and plotting of 9 Christopher Wallace murder. I'm in prison for a crime 10 that they also did. 11 Q. Okay, and who is that? 12 A. Keith Davis in particular and Lydia Harris 13 in particular and Michael Harris in particular, and 14 there's some other individuals that are involved whose 15 names I will not say on tape. 16 Q. Okay, but now Keith Davis, Lydia Harris, 17 Michael Harris, they were all involved in Christopher 18 Wallace's murder? 19 A. Yes, they were. 20 Q. Okay. And to whom did Mr. Wallace pay 21 $450,000? 22 A. He gave it to Keith Davis and one of the 23 Hawkins people. 24 Q. And how do you know that? 25 A. I was on the phone when the money was 157 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 delivered to Las Vegas. 2 Q. And by whom was it delivered? 3 A. Christopher Wallace himself. 4 Q. And to whom was it received, by whom was 5 it received? 6 A. Keith Davis. 7 Q. And you were on the phone when the 8 delivery happened? 9 A. Yes. And I want to make it clear on this 10 record, I did not know until after the fact the full 11 plan of the murder of what took place in Las Vegas. I 12 was told afterwards. Had I been -- known that a murder 13 was taking place, I would have called the police or 14 something. But, I found out afterwards, they told me 15 everything that went down in Las Vegas of what they 16 were there for. I only knew that they had something 17 going on with the people in New York and that they were 18 going to get paid, and they were supposed to be hiring 19 me an attorney. My attorney was paid -- my trial 20 attorney was given money soon after these people came 21 back from Las Vegas. 22 Q. And as we indicated previously, this 23 wasn't something that you observed, this was something 24 that was told to you? 25 A. I couldn't observe it because I was in 158 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 prison. But, again, it's very well-documented in my 2 case file that I'm a part of this -- I have a 3 affiliation with the South Side Compton Crips and that 4 they were involved in the crime that I'm in jail for. 5 Q. Okay, but my question was different. 6 Remember how I told you sometimes I'm gonna try to 7 figure out, you know, whether it was something you 8 observed, whether it was something told to you, this 9 was something told to you, right? 10 A. Right, by the individuals involved. 11 Q. What was the source of this $450,000 12 payment, do you know? 13 A. When you say "source," that's a broad 14 question, what do you mean? 15 Q. Well, where do you come up with $450,000? 16 A. I think when you're running a drug empire 17 in New York, in the Bronx and in Brooklyn, you got a 18 lot of cash going around, so that was the source of the 19 money for the payment. But the payment for the murder 20 was independent from my understanding after the fact of 21 the murder taking place. I knew that the murder -- 22 money was being delivered, but didn't know what the 23 money was being delivered for. So after the fact I was 24 told about the 450,000 and the initial $50,000 that was 25 given, so... I believe it was drug money I guess to 159 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 answer your question. 2 Q. And, again, that's not something you 3 observed, that's just a belief you had? 4 A. Well, I mean, he was a recording artist, 5 he could have took the money out of the bank, but I'm 6 very doubtful that he took $450,000 knowing the way 7 that, you know, the modus -- modus operindus (sic), 8 however, you guys say it in the legal term. I know the 9 way that that criminal activity enterprise functions on 10 the East Coast and West Coast. So more than likely the 11 $450,000 was drug money. Maybe my attorney still has 12 some of it in his safe, because they paid him with cash 13 when they hired him to represent me, I don't know. 14 Q. What attorney are you talking about? 15 A. David Herriford, another crook. 16 Q. Now, this is going to seem like a silly 17 question, Mr. Anderson. 18 A. Uh-huh. 19 Q. And I apologize, it's still a question I 20 got to ask. 21 A. Uh-huh. 22 Q. When -- when you were in the L.A. County 23 Jail, you didn't have a cell phone, did you? 24 A. There were cell phones around. 25 Q. Okay. Let me ask it different then. Did 160 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 you have a cell phone? 2 A. I refuse to answer that question. Now 3 you're asking me to incriminate myself bringing 4 contraband into a facility. 5 Q. Okay. So that's a question you don't 6 believe you can answer -- 7 A. No. 8 Q. -- without incriminating yourself? 9 A. No. 10 Q. And for that reason you're not going to 11 answer the question? 12 A. Yes. 13 Q. The L.A.P.D. in the course of their 14 investigation -- 15 A. Into what? 16 Q. Of the murder of Mr. Wallace? 17 A. Yes. 18 Q. Pulled a number of cell phone records. 19 A. Uh-huh. 20 Q. And one of the records that they pulled 21 was ostensibly a cloned phone used by certain members 22 of Death Row Records. 23 A. Uh-huh. 24 Q. And it has a number of calls both 25 immediately before and -- excuse me, immediately after 161 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 the shooting of Mr. Wallace that ostensibly came from a 2 phone owned by you; can you explain that? 3 A. Excuse me? 4 Q. Can you explain that? 5 A. A phone, what was the number? 6 Q. I believe it was (213) 293-8655. 7 A. Other than I told you that -- I can't 8 explain that. I don't -- I don't understand why 9 someone from Death Row Records would have a phone in my 10 name. That's -- that's quite shocking. If you're 11 saying that it's Death Row Records, I don't -- 12 Q. Let me back up. Do you remember having a 13 phone with the number (213) 293-8655? 14 A. I had 30, 40 cell phones. Again, I 15 can't -- I can't even begin to answer that. That's -- 16 that's very, very shocking to me, but, believe me, I'm 17 gonna find out. If there was a phone in my name on 18 that crime scene, it would have to be in the presence 19 of Keith Davis in my opinion. 20 Q. Why -- why is that? 21 A. Because those are the only people that I 22 allowed to place -- to have personal things placed in 23 my name, such as automobile -- that's what got me in -- 24 in prison was the cell phone that I allowed Keith Davis 25 to use. 162 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 MR. FRANK: I'd like to take a break and talk 2 to Mr. Brizzolara and see where we are. 3 MR. MARELLA: Sure. 4 THE VIDEOGRAPHER: We are going off the record 5 at 12:58. 6 (Recess taken.) 7 THE VIDEOGRAPHER: We are back on the record 8 at 1:08. 9 MR. FRANK: 10 Q. Mr. Anderson, briefly when we were off the 11 record you and I had a conversation where you were 12 asking me some questions about the tape log which was 13 the basis of a couple of my questions for you. 14 A. Uh-huh. 15 Q. And here is the information I have. That 16 there were phone calls from a cloned phone with the 17 number of (714) 337-5214. Mr. Wallace was shot at 18 about 40 minutes after midnight on 3/9/97. 19 A. Uh-huh. 20 Q. Following that shooting there were one, 21 two, three, four, five, six calls to (213) 293-8655, 22 and they have identified that as a phone belonging to 23 Waymond Anderson, 1739 Middleton Place, Los Angeles. 24 A. That's my grandma's address. That's why 25 I -- that phone was in the possession of the 163 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 conspirators against Death Row, which (714) is where 2 South Sides homes were. So as I've been saying all 3 along, uhm, had -- 4 Q. Go ahead, I didn't mean to cut you off. 5 A. The -- the only person from -- that was 6 still affiliated with Death Row Records would be Lydia 7 that had that telephone, I believe. 8 Q. And why do you believe she may have had 9 that telephone? 10 A. She was a part of the conspiracy, and it 11 was asked when she was at Death Row could she put a 12 phone in my name. 13 Q. Okay, and did you give her permission to 14 put a phone in your name while she was at Death Row? 15 A. You don't give the Hawkins people 16 permission, it just happens. But when you said (714), 17 it brings to light what I've been saying all along. I 18 was just talking out loud when I said that, so... 19 Q. Okay, so you believe that this phone 20 was -- was held by Lydia? 21 A. Yes. 22 Q. Okay. And what was Lydia's position with 23 Death Row? 24 A. Michael Harris was a -- once upon a time 25 his brother and me were very, very close, David Harris, 164 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 who's now deceased. Their involvement when Death Row 2 was first formed is I know that there was money picked 3 up -- I'm trying to choose my words wisely here. You 4 know, I know about superseding indictments and I don't 5 know what the FBI is investigating, and I don't want to 6 get caught up in a federal investigation for 7 racketeering or money laundering. I don't want to 8 leave one life sentence and be given another life 9 sentence. 10 So, with that said, I know that -- that there 11 was money that was laundered through Death Row Records 12 by Lydia while Michael Harris was in jail, and then 13 they later came back and tried to say that they gave 14 Suge money to start Death Row Records, which is totally 15 untrue. A lot of people don't understand the dynamics 16 or the mechanics of how the record industry works. You 17 can get one hit record and a record label will advance 18 you 25 million dollars the next morning. So there was 19 no reason for Suge to have to get drug money to start 20 that. His "187 Cop" provided them with enough cash to 21 develop his record label. But at the same time, when 22 you grow up in inner cities the hard way, it's hard to 23 walk away from the individuals you grow up with. So 24 Suge still participated with individuals who were 25 involved in criminal activity, and in doing so he 165 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 laundered some money for Michael Harris, and then that 2 later came back to bite him in the butt to where she 3 and Michael felt that they should be provided profits 4 from Death Row Records. And when Suge basically kicked 5 her out, Michael and herself took that very personal, 6 and from there it was on trying to get back at Suge 7 Knight. 8 Michael Harris and Lydia are protected and 9 backed by some individuals who are -- are affiliated 10 with -- with the Ariano brothers. I don't know if you 11 know who Oscar Ariano is, people from Mexico who bring 12 in drugs from Columbia. These people are very, very 13 welly connected from the Bahamas all the way to 14 Columbia down to Mexico. And so these aren't the type 15 of people you walk away from. And those people also 16 felt that they should also receive profits from Death 17 Row Records. So it was determined after the Tupac 18 Shakur murder that, you know, when a dog is down, they 19 say that's the best time to kick him. And Suge was in 20 jail at the time so these individuals conspired 21 together to, you know, frame that man for a murder, and 22 he had nothing to do with Christopher Wallace murder. 23 Q. So you believe that Michael Harris, Lydia 24 Harris -- 25 A. Keith Davis and others in Compton whose 166 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 names I will not release until someone is ready to -- 2 to put me in a secure place, and I know how the murder 3 went down, I know how the shooting went down, I know 4 where the cars were parked, I know about the flashing 5 lights, I know what side street they were on, I know 6 who was in the van, I know who was in the white car, 7 the SUV. I know it all. 8 Q. What van is that that you're talking 9 about? 10 A. There was a van that was parked right next 11 to Sean Combs as they sat in the light. And Combs is 12 dirty in this murder, too. 13 Q. Who said the van was parked next to Combs 14 vehicle? Where did you hear that from? 15 A. The individual that was in the van and the 16 individual who set the whole murder up. 17 Q. Okay, can you tell me those names? 18 A. I can tell you Keith Davis name. 19 Q. Okay. 20 A. He was the main contributor and plotter of 21 this murder. 22 Q. Okay, what was -- what vehicle was Davis 23 in? 24 A. He was in the black SS that he owned. 25 He's always had an SS, that was like his third SS, 167 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 which was a identical car it just so happened, you 2 know, by pure coincidence David Mack had a vehicle that 3 was able to manipulate it to -- that fit the same 4 description as Keith Davis' vehicle. 5 Q. Who told you that Davis was in a black SS 6 on the night of the murder? 7 A. Keith Davis did himself. 8 Q. Okay. All right, so then who was in the 9 white van? 10 A. I cannot tell you that, sir. 11 Q. Because you don't know? 12 A. No, because I know him, because of fear of 13 my safety. Right now there are certain individuals who 14 are more powerful than other individuals, and those 15 individuals' names I will not say as I have told 16 someone else until I move to a proper location where I 17 feel more secure at. 18 Q. Okay, so -- so Mr. Davis was responsible 19 for you being incarcerated; is that correct? 20 A. Yes, he killed Mr. Robert Wellington 21 behind drug money, and eye witnesses in my case know 22 it. They're scared to identify the man. And 23 eventually -- I guess a investigator is supposed to be 24 taking Keith Davis picture to show them. They know who 25 killed that guy really. 168 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. All right, and the same guy who set you up 2 for a life sentence is the person who you're indicating 3 killed Mr. Wallace? 4 A. I'm not indicating, I know he killed him. 5 Q. That's what you're telling us? 6 A. Yes. 7 Q. Okay. And you can't tell me who's in the 8 white van? 9 A. Nor who was in the SUV. There was three 10 vehicles involved in this murder. And actually four, 11 there was two SS's and one of the SS's was in a 12 professional football player's name which I won't 13 reveal until a later date, and the first SS was a 14 decoy. They flashed the lights as they were notified. 15 First of all, go back to when he -- I don't know if you 16 know who Gene is, used to be -- 17 Q. If -- if I could back you up for just a 18 minute, Mr. Anderson. 19 A. All right. 20 Q. I want you to tell me this, and I want you 21 to tell me it in the kind of detail you are. 22 A. Okay. 23 Q. But it would help me if I knew the source. 24 A. Okay. 25 Q. Because at this point we know that you 169 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 weren't there. 2 A. Right. 3 Q. Right? Because you were incarcerated. 4 A. Right. 5 Q. Okay. So somebody has to be telling you 6 these things. 7 A. The source of the major information that 8 I'm -- I'm telling you he was the perfect person who 9 was the main -- 85 percent of the actual involvement of 10 the crime and plotting was by Keith Davis. The other 11 individuals, whose names that I know and am willing -- 12 more than willing to provide, L.A.P.D. ain't going to 13 protect me or my family, so those are individuals, 14 meaning they have more resources than Keith Davis does 15 to find out certain things. So I feel comfortable 16 releasing Keith Davis' name at this point. I do not 17 feel comfortable sitting in this jail, in this prison 18 to release the other names in the vehicle. 19 Keith Davis is the main source who provided me 20 with the one-on-one information of the murder that took 21 place that night in front of the Peterson Museum at the 22 red light. 23 Q. Okay, so based on what Mr. Davis has told 24 you -- 25 A. Uh-huh. 170 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. -- tell me your understanding as to how 2 the murder went down. And if you could -- 3 A. Uh-huh. 4 Q. -- when you're going into stuff that was 5 told to you by somebody other than Mr. Davis? 6 A. Uh-huh. 7 Q. Tell me you got it from somebody besides 8 Mr. Davis, otherwise I'm going to assume you got it all 9 from him, okay? 10 A. Okay. 11 Q. All right. So -- so what's your 12 understanding as to how it went down? 13 A. My understanding as to how this went down, 14 there's a side street that sits on the adjacent side of 15 the parking lot and the SS was parked on that side 16 street. Further down the street, I guess it would 17 be Wilshire -- I've been in jail so long I don't even 18 know north, east, west, south. So I'm going again -- 19 and Keith Davis told me this information of how he 20 planned the whole thing out. He said that the -- 21 Q. When did he tell you this? 22 A. The day after the murder. 23 Q. Okay. And was that by telephone? 24 A. Partial of the information was given to me 25 by telephone and partial of the information was given 171 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 to me in a legal visit by an attorney named David 2 Herriford, who was a crooked attorney. So, I'm 3 sitting -- can I give you my description now? 4 Q. Yes, sir. 5 A. All right, the side street is adjacent to 6 the Peterson Museum, that's where the SS was sitting. 7 The van was on the street leading up to the light that 8 will go to Wilshire Boulevard. And when the Suburbans 9 pulled out of the parking lot, the first Suburban 10 leaving out of the parking lot was Sean Combs, who 11 pulled in -- 12 Q. Where is -- where is the parking lot in 13 relation to where -- 14 A. I just know there's a side street. They 15 told me the SS -- out of Keith Davis mouth he said he 16 was sitting on the adjacent street. I don't have a map 17 or anything or a piece of paper. 18 Q. Could you draw your understanding, would 19 that work? 20 A. I was trying to do it with the water 21 container, that would work. Thank you. 22 Q. And -- and if you could begin, 23 Mr. Anderson, by identifying where the parking 24 structure is and then we'll orient off the parking 25 structure. 172 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. I don't know if it's the north side of the 2 street, east side of the street, west side of the 3 street. My -- I'm like -- I haven't been in a car in 4 years. I ain't been on a -- you know what I mean? I 5 don't have -- like I've been on Wilshire Boulevard a 6 million times, but I don't even know if it's east or 7 west anymore. It's like when you've been to prison so 8 long you -- 9 MR. MARELLA: And I'm going to object to him 10 drawing because my understanding of the testimony is 11 that nobody drew for him what happened. He said he's 12 not -- can't remember the area, does not know the area. 13 The only thing he knows is what he was told either by 14 Kevfe D or someone else. So I think the best he could 15 do is relate to us, as you've already asked him, what 16 was told to him and by whom. Because drawing is -- 17 it's just going to be a jumble because he doesn't know 18 which way Wilshire Boulevard goes anymore. 19 MR. FRANK: 20 Q. Mr. Anderson? 21 A. Uh-huh. 22 Q. A picture is worth a thousand words I've 23 heard said by somebody, again a lot brighter than me. 24 I understand that something was told to you orally. 25 A. Uh-huh. 173 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. Generally when somebody tells us something 2 orally we create a picture in our mind. 3 A. Right, and that's exactly what I did. 4 Q. All right, so if I were to tell you that I 5 passed a car -- 6 A. Uh-huh. 7 Q. -- on the way up here to -- to this 8 facility, you'd get in a picture of your mind whatever 9 car I was driving passing another car. 10 A. Yes, sir. 11 Q. When Mr. Davis described to you what 12 occurred, did you try to picture it together -- 13 A. Yes, I tried to bait him in because I knew 14 he had set me up for a murder, and I digged, I digged 15 for further information from him. 16 Q. So understanding that -- that it was told 17 to you orally, could you draw it so I could better 18 understand the picture that you had in your mind while 19 at the same time telling us orally what was told to 20 you? 21 A. I don't have a problem with it. 22 Q. All right, let's do it. 23 MR. MARELLA: Same objection, but go ahead. 24 THE WITNESS: Well, again, I just know that he 25 was on an adjacent street to the parking lot of the 174 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Peterson Museum. It was some side street they were 2 sitting on where they could actually see the other 3 vehicle that was parked on the opposite side of the 4 street, which was the SUV. The SUV kept going back and 5 forth up and down, and they had an individual who was 6 part of Sean Combs' entourage that night was giving 7 them play-by-play what was going on from the cell 8 phones inside of the party when they were going to exit 9 out, as well as Lydia was giving the information back 10 and forth. 11 Q. Okay, do you know who that was in the 12 entourage? 13 A. Yes, I do, but I'm not gonna say his name 14 until again -- 15 Q. Okay, so you know somebody in the Combs' 16 entourage that was giving out information, but that's 17 something that you're not gonna tell me today? 18 A. Right, exactly. 19 Q. All right. 20 A. And so when they were notified by cell 21 phones, actually Nextel cell phones, that when the -- 22 Sean Combs and Biggie Smalls were going to exit to 23 their vehicles and come out of the parking lot -- 24 Q. Again, this is all told to you by 25 Mr. Davis? 175 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. Davis, yes, sir. I'm telling you how the 2 whole murder went down and everything. The flashing -- 3 when -- when the SUV that kept going up and down the 4 boulevard until they actually saw them coming out, once 5 they saw the first SUV, what they said, front end come 6 up out of the parking lot, they knew that they were 7 actually had seconds to get into place. So that SUV 8 then busted a U-turn to come back around. And at the 9 same time that he was busting the U-turn, the van was 10 positioned down the street and they start flicking -- 11 the sign to go was to flick the lights. Once -- once 12 the SUV flicked the lights, it was for the van to pull 13 in the first lane to where they can block Sean Combs 14 and them to where they could be on the side of them to 15 be able to shoot them if you understand what I'm 16 saying. 17 Q. Yeah, I'm not -- 18 A. There's two lanes on a street. Meaning if 19 they -- if the passenger was in the -- in the far right 20 lane, and then they came out, that would put them on 21 the side of the driver. So they had to block them to 22 where they would have to pull into the far lane to 23 where they could pull up onto the side of them. 24 Q. Okay. 25 A. So when -- once the -- the -- the -- the 176 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 truck gave the signal, the SUV gave the flashing light 2 signal, Kevfe said he started up his car, then the van 3 came down, sped down, and parked like almost blocking 4 the parking lot to where the car would be forced to 5 turn into the far lane. And then once they did that, 6 the SUV then came down slowly from the -- once he 7 received the flicker from the lights from the SU -- 8 from the SUV, came down slowly, and the second -- they 9 were behind Biggie Smalls when he pulled out of the 10 parking lot. And when he pulled out of the parking 11 lot, he immediately went behind Sean's car. And when 12 the SUV pulled up, Biggie Smalls was sitting inside of 13 the passenger seat of the vehicle. So Sean Combs was 14 in the first vehicle. 15 Q. Okay, why don't you put a circle with a 1 16 on it where Sean Combs vehicle would be. 17 A. Would be the first vehicle. 18 Q. Okay. 19 A. The second vehicle would be Biggie Smalls. 20 Q. Okay. 21 A. And they're in that lane. Right here next 22 to them you got a van, a white van. 23 Q. Okay, put a 3 where the white van is for 24 me. 25 A. A 3. Right here you got a SS that's 177 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 coming up, I guess you want me to make that number 4 2 here right now. 3 Q. That would be a good thing. 4 A. So that's number 4. That's lined up 5 with -- and Keith Davis actually told me he was shocked 6 that Biggie Smalls was sitting in the passenger seat of 7 that vehicle, because when he arrove to the Peterson 8 Museum, he said Biggie Smalls was not sitting in the 9 first front passenger seat of that vehicle. 10 Q. Where was he sitting when he -- when he 11 came? 12 A. He told me he was in the back sitting in 13 the vehicle. 14 Q. Okay. 15 A. This is what he said. So, as he pulled on 16 the side of him, they have these pillows, and I can 17 tell you where they made at, it's a shop in Compton. I 18 can't think of the name right now. I think it's called 19 All Star, it's off the Downing Boulevard. They have 20 these pillows that they make, and the window was rolled 21 down. And when the window -- when they lined up and 22 they saw that Biggie was in the front seat -- they were 23 -- they hoping to catch Sean and him in the same 24 vehicle, but that plan later changed, which I don't 25 want to go into. By anyway, this -- this vehicle on 178 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 the side saw that they had a clear shot. Keith Davis 2 rolled down the window and the individual who did the 3 shooting came over Keith Davis like this on the pillow, 4 they had these pillows in, like, 25 shootings that I 5 know that South Side Compton Crips had done, and he 6 opened up fire on the vehicle and shot him. And 7 Biggie -- and Sean Combs was not through the light when 8 the shooting first took place. That's what I was 9 trying to tell Boagni his story wasn't going to work 10 because where he was going to say the bullets were, 11 meaning they were trying to say that Biggie was sitting 12 at the light. Well, Biggie wasn't sitting at the 13 light, he was behind that vehicle. 14 Q. Okay, so who was the shooter? 15 A. I'm not telling you that right now. 16 Q. All right, so Davis was driving and you 17 won't tell me who the shooter is? 18 A. Right. 19 Q. All right. And he shot across -- 20 A. I can tell you that the shooter is no 21 longer living, he's dead. 22 Q. Okay. So the shooter is a dead person? 23 A. Yes. Now he's dead. 24 Q. Okay. Well, I assumed he wasn't dead at 25 the time of the shooting, that makes it a little bit 179 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 more difficult. 2 A. Right. 3 Q. And he shot across Mr. Davis' body? 4 A. Yeah, they make these pillows that when 5 you go down, they actually lock into the arm. They do 6 drive-bys like that in Compton. Ladd knows what I'm 7 talking about. They're very familiar. The Compton 8 Police Department knows about these. They make them 9 and they come over and it gives them the position to be 10 able to lay across. 11 Q. Who owned the SUV? 12 A. I know who did, but I can't say right now. 13 Q. Okay. Who owned the -- I think you said 14 it was a -- 15 A. It was a van, a minivan. 16 Q. Who owned the minivan? 17 A. The same person. And one other car's are 18 owned by a NFL football player. 19 Q. Okay, a current or past player? 20 A. Past. 21 Q. If we can mark this as 1, please. 22 (Exhibit No. 1 was marked for identification 23 purposes, only.) 24 MR. FRANK: 25 Q. Now, Mr. Anderson, contrary to the 180 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 statement that you gave to the police, Mr. Fletcher was 2 not the shooter? 3 A. William Fletcher had nothing to do with 4 this crime. 5 Q. Did -- did Mr. Fletcher have any murder 6 convictions? 7 A. I think he has an assault conviction and a 8 domestic violence conviction, if my memory serves me 9 correctly. 10 Q. You don't recall that he served time in 11 the -- 12 A. Oh, for manslaughter, yeah. 13 Q. -- California Youth Authority for two 14 drive-by shootings? 15 A. I don't think the person died in the 16 shooting, though. 17 Q. Well, this was a drive-by shooting, right? 18 A. This would not be considered -- a drive-by 19 shooting is when somebody drives by and shoots. This 20 was a sit by you in a car laying in a see you shoot. 21 Q. All right, so you wouldn't -- you wouldn't 22 consider this a drive-by shooting? 23 A. A drive-by shooting by term of Los Angeles 24 drive-by, which is the capitol of drive-by shootings, 25 is when a car comes by and driving shoots out of the 181 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 vehicle. That is not what happened in this case. A 2 drive-by shooting would be everyone was standing in 3 front of the Peterson Museum and a vehicle sped across 4 the light at Wilshire and opened fire with a machine 5 gun, that would be a drive-by shooting. 6 Q. Okay. Now, previously, and I forget the 7 context, it's just sticking out in my mind, you had 8 mentioned both Officer Kevin Gaines and Sharitha 9 Knight. 10 A. Uh-huh. They were childhood friends. 11 Q. Of yours? 12 A. No, sir. 13 Q. Okay. 14 A. Of each other. 15 Q. All right, well, I want to go back. Did 16 you know Sharitha Knight? 17 A. I ran into her maybe two or three times in 18 passing. I didn't have a personal relationship with 19 her or anything. I -- I was aware of Kevin Gaines and 20 their relationship. 21 Q. Okay, how were you aware of Kevin Gaines 22 and their relationship? 23 A. There used to be a club called "The Mines" 24 down in Downtown L.A. and everyone used to hang out 25 down there. I think Prince owned it at the time. And 182 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 I would see him in there. Everybody knew he was a cop, 2 he kept has badge on. And the rumor was she knew him 3 from high school or junior high, and they were just -- 4 after her and Suge separated, they were friends. He 5 had nothing to do with -- you know, that wasn't his 6 woman anymore. Suge had tooken Micha Lay from Dre and 7 was living with Micha Lay. He didn't care that, you 8 know, his ex-wife was, you know, boning a cop, you 9 know, he didn't have a concern with it. 10 Q. Did a number of Los Angeles police 11 officers work with Death Row? 12 A. No, sir, not at all. 13 Q. Okay, how do you know that? 14 A. Because Death Row security was ran by 15 Reggie Wright, Jr., and this is where that myth comes 16 from, because his father is a known police detective in 17 Compton. A lot of people when they got wind of 18 Sharitha, who was managing Tupac, not Tupac, but Snoop 19 Dog at the time, was dating a cop, that's when the 20 rumors started about there being cops. But there were 21 several Compton police officers that were working for 22 Wrightway Security. They never worked directly for 23 Death Row Records. 24 Q. Okay, how about L.A.P.D. officers working 25 for Wrightway? 183 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. No. 2 Q. And you're sure of that? 3 A. I'm 99 percent -- I understand that -- 4 that they might have participated in functions or might 5 have even -- just because you're a cop doesn't mean 6 you're not into hip hop music or, you know, don't go to 7 clubs. So, again, because Reggie Wright was so known 8 in the law enforcement community, that -- that story 9 got blown out of proportion. Because when they see 10 Reggie, a cop would give him props. His dad is very 11 well-respected in the law enforcement community. So he 12 knew a lot cops. Compton and L.A.P.D. worked closely 13 together in certain investigations. So that was the 14 extent of the relationship between L.A.P.D. David Mack 15 never worked for Death Row Records, nor did Rafael 16 Perez. 17 Q. How do you know that? Have you ever 18 talked to him about that? 19 A. Well, I've talked to several Death Row 20 Records individuals, and I've been at major -- every 21 major Death Row function before I was arrested, and I 22 never once saw Rafael Perez nor David Mack at any of 23 those functions. And I also have knowledge that Lydia 24 Harris was backed by the persons Hawkins and the South 25 Side Compton Crips. Being around them and being in 184 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 several conversations, there were no law enforcement 2 L.A.P.D. officers involved with Death Row Records. 3 That's how I know that. 4 Q. All right, you were arrested in 1994? 5 A. Yes, sir, January 29th. 6 Q. Okay, so subsequent to January 29th, 1994, 7 you wouldn't have an ability to observe who was and was 8 not at Death Row functions, correct? 9 A. Not from that time period. 10 Q. Okay. Did you ever do any work with an 11 officers Frank Lyga? 12 A. Not to my recollection. 13 Q. He was the officer you may recall who 14 shot -- 15 A. I know who he shot. 16 Q. -- shot Kevin Gaines? 17 A. Yes. 18 Q. Okay, you don't recall ever working with 19 him? 20 A. I mean, you might pull out something that 21 say he was part of Mid Level Narcotics or Major Level 22 Narcotics, but I didn't personally know him. 23 Q. Did you know an Officer Nino Durden? 24 A. I know of Nino Durden. 25 Q. How do you know of Nino Durden? 185 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. From Kenneth Boagni. 2 Q. Okay, and -- and what do you know of Nino 3 Durden based on your conversations with Mr. Boagni? 4 A. Mr. Boagni said that he was going to 5 interject -- Nino Durden being a part of the 6 disinformation that he was miscruing (sic) that Rafael 7 Perez provided him about his being remorseful that 8 Mr. Durden also participated in what Rafael Perez was 9 doing as far as, you know, using drugs, traveling out 10 of town together. When, in fact, he told me Perez 11 personally never even told him he went out of town with 12 Durden. That's just one instance that I can think of 13 to tell you. 14 He was also incorporating -- I guess the 15 quickest way to explain it, he was trying to implement 16 Durden, just as he was trying to implement Rafael Perez 17 for his self gain. 18 Q. Okay, so I think that I understand all of 19 the different conspiracies, Mr. Anderson, that we've 20 been discussing, but let me go through them to make 21 sure that I haven't missed any. 22 A. Uh-huh. 23 Q. The first is the Boagni/Crystal attempts 24 to discredit Berkow, correct? 25 A. Yes. 186 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. Okay. Then we have the Davis attempts to 2 make sure that you remain in jail for murder, right? 3 A. Yes. 4 Q. Okay, now who was -- if you can tell me 5 who was in with Mr. Davis on that? 6 A. On the murder that I'm involved in? 7 Q. Yeah. 8 A. Wrongfully convicted of? 9 Q. Yeah, the conspiracy to make sure that 10 you're wrongfully convicted and sentenced. 11 A. Again, I can't answer anything in detail 12 about my case until I'm instructed by Mr. Bernstein or 13 until someone has given me immunity. 14 Q. Okay, then we have what you understand to 15 be Christopher Wallace's agreement to have -- well, 16 strike that. Christopher Wallace owing someone 1.7 17 million for narcotics, right? 18 A. 1.2, and $500,000 that was unpaid for the 19 murder, which makes a total of 1.7. 20 Q. Okay, and then his involvement then in the 21 murder of Tupac Shakur? 22 A. Yes. 23 Q. And then -- 24 A. Just not his involvement. Sean Combs was 25 involved with that, too. 187 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. Okay, and we'll talk about that in a 2 minute, then. I don't think we've talked about that. 3 And then we have the conspiracy by Lydia, Michael 4 Harris and Davis to take over Death Row? 5 A. And others. 6 Q. Okay, and those others you didn't -- you 7 said you wouldn't tell me who they were, right? 8 A. Uh-huh. 9 Q. All right, and then you have a conspiracy 10 to try to make it so that you all could get 5 to 10 11 percent of any settlement that the Wallace estate has 12 with the City, right? 13 A. Yes. 14 Q. Okay. 15 A. As well as they've told me that they've 16 already received $25,000 from Mr. Sanders. 17 Mr. Hammonds says he's got 25,000, Boagni says he's got 18 35,000 total now. You guys got him a book deal and 19 everything else, so... 20 Q. Then to get that 5 to 10 percent, who 21 needs to be -- who needed to be implicated? I thought 22 you said three officers. Was it -- 23 A. Rafael Perez. 24 Q. Okay. 25 A. David Mack. 188 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. Okay. 2 A. And the City of Los Angeles. 3 Q. Okay. I thought you said Sammy Martin, 4 did you say Sammy Martin? 5 A. I've never said Sammy Martin's name out of 6 my mouth since we've been in this room. 7 Q. Okay, that's why I asked, Mr. Anderson, I 8 just wanted to make sure I understand. Okay, how do 9 you know that Boagni received 25,000 from Perry 10 Sanders? 11 A. That's what he told me. I made four phone 12 calls myself from Delta 3 to Kenneth Boagni's wife. I 13 believe she was in Houston at the time. She was on her 14 way back to New Orleans. And he told me that he wanted 15 to make sure -- in one of the phone conversations he 16 needed me to call his wife because she was supposed to 17 deliver some notes to Mr. Sanders' office in New 18 Orleans, this is in 2001 or 2002 that he had been 19 taking of Rafael Perez when he was incarcerated with 20 him. 21 During that phone conversation when I called 22 Mr. Sanders -- called his wife who then called 23 Mr. Sanders for me, Boagni said something about his 24 mother's house -- the plumbing had broke in his mom's 25 house or something, he needed $2500. And then I'm 189 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 listening to what Mr. Boagni says on the other end of 2 the telephone, I couldn't hear exactly what Mr. Sanders 3 said back to him, but he told him don't worry about it, 4 he was going to call Colorado or something and take 5 care of it, to that matter, and that his mom would 6 receive the money. That was the first time I was made 7 aware of him receiving money for this lawsuit. 8 Q. Okay, but that's 2500 not 25,000? 9 A. Right, I'm telling you the first part of 10 the money he told me he got. 11 Q. Okay, go ahead. 12 A. Then he said that Mr. Sanders paid for his 13 wife to move back from Houston to New Orleans. I guess 14 that was maybe another $7,000. He told me he received 15 a total of $25,000. That was before he left me at this 16 prison and returned back to Calipatria State Prison. 17 Q. All right, and then who got $35,000 18 allegedly you were saying? 19 A. Recently he has told me that you guys got 20 him a book deal through some attorneys in New York and 21 Atlanta. And he's writing a book called "He Told Me 22 So" or "I Was Told So," and that you guys got him a 23 publishing deal and the book is coming out. 24 Q. Okay. And did he get 35,000 as a result 25 of the book deal? 190 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. Yeah, he got a $35,000 book deal plus the 2 $25,000 he's already received I guess is the grand 3 total. And in Mario Hammonds case he says that he 4 received payments from Perry Sanders in this what I 5 call a scam that's going on. The money was given to 6 his girlfriend -- his ex-wife for his daughter's 7 schooling and for her living expenses. And something 8 about a woman who knew Perry Sanders from New Orleans 9 who owns a fast food restaurant or a soul food 10 restaurant, I should say. Her daughter Perry Sanders 11 represented. He knew Mario from a case that he 12 represented with this woman's daughter who got busted 13 for drugs or something in New Orleans. I don't 14 remember her name, but she used to write this prison so 15 I'm sure all the mail is logged and tagged in here, so 16 it could probably be pulled up. 17 Q. Okay, anything else? 18 A. That's pretty much it. Payments besides 19 the office -- the money that I was offered, but I 20 refused it. I'm not for sale. 21 Q. Who -- who offered you money? 22 A. Well, it went from the 25 -- the same 23 $25,000 they received, they said that Mr. Sanders would 24 place it in an account if I was willing -- or send it 25 to my wife if I was willing to participate. And then 191 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 it went up to 35, then it went to 45 and 75, and then 2 the recent offer was a hundred and 50,000. They said 3 Mrs. Wallace is sick, recently got sick or was in the 4 hospital recently, and that she would have some money, 5 put the money in an account for me if I would endorse 6 this lawsuit against the City. And that I should -- 7 you know, I should be the first person that would want 8 to speak out against L.A.P.D. since they read the 9 recent articles of my case and me being framed by the 10 Los Angeles Police Department. And I found it quite 11 insulting, actually. And I have the phone records, 12 they're already turned over to someone who I trust. 13 They have the phone records of Kenneth Boagni calling 14 my house from Calipatria State Prison in the building 15 that he housed in. 16 Q. You sold the rights to your story, didn't 17 you? 18 A. No, I never sold the rights to my story. 19 I never have. I don't even have money to hire an 20 attorney. I wish I could sell the story or a song or 21 something today, but... 22 Q. Did you tell the L.A.P.D. that's how Larry 23 Longo got paid? 24 A. No, Larry Longo had me sign a contract to 25 retain rights to my life story. I never got a dime for 192 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 my life story. 2 Q. Okay, because the money went to Longo, 3 right? 4 A. No money in my knowledge has been 5 transferred to Longo or anybody. My lawyers are now 6 recently working to retract that contract back with 7 Larry Longo. He wanted to go out and negotiate my life 8 story, and it was never negotiated. The contract has 9 expired and nothing has ever been generated or earned 10 by it. 11 Q. Have you ever met with Dan McMullin? He's 12 a FBI agent. 13 A. I told you in the beginning of this 14 interview I met with a guy because of Michael Robinson 15 was trying to get rent money for his wife, and, again, 16 you sort of do what you have to do to survive in 17 prison. 18 Q. I know the conspiracy I've forgotten, the 19 conspiracy to get stuff into Katz's desk drawer that 20 could be pulled out. I forgot that one, didn't I, when 21 I went through the list? 22 A. I said it, but I don't know if you 23 consider that to be -- to me it's one all big 24 conspiracy. I don't think that they're independent of 25 each other in my opinion, but... 193 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. All right. 2 A. You know, it involves Kenneth Boagni, so 3 it's the same conspiracy to me. 4 Q. Okay. And -- and that was done with the 5 assistance of Ya May Crystal? 6 A. What was told to me about the conspiracy 7 to place documents into Detective Katz's drawer was 8 that the interview that I did with the Los Angeles 9 Internal Affairs Department underneath the instruction 10 of Kenneth Boagni and Mario Hammonds would come up 11 missing until the trial, and that I would be the star 12 witness that would come in and verify everything that 13 him and Mario were saying was true. And they said that 14 that would be placed in one of the detective's drawer, 15 and he said Kates, he said Katz name, however you say 16 it, and they would be placed in his drawer or he said a 17 locker. And when it was brought to my attention that 18 that actually took place, I took it very insulting and 19 I placed a call, but I never was -- you know, I never 20 heard back from anybody. 21 Q. Okay, and that was referring to the I.A. 22 complaint you made against Officer Perez for 23 threatening you? 24 A. I never made a complaint. I made -- I 25 gave a statement. A complaint -- I never filed a 194 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 complaint against any officers except for the 2 detectives in my own case. There's been an internal 3 investigation done on them. 4 Q. Okay. Are you aware of an internal 5 investigation which was done by the Los Angeles Police 6 Department as it relates to your allegation that you 7 were threatened by Rafael Perez while at the Parker 8 Center? 9 A. I'm not aware of it. 10 Q. Okay. 11 A. I'm aware that I gave a statement because 12 Boagni asked me to, but I didn't know there was an 13 investigation done behind it. 14 Q. I'm not asking you the content of any 15 conversation with Mr. Phillips, how many times have you 16 met with him? 17 A. I don't understand what Mr. Phillips has 18 to do with this what we're here for today. 19 Q. No, I understand. 20 A. Again, he's -- I'm sure you've read the 21 articles he's done on my case, and I think that's 22 privileged information of how many times I met with him 23 about my case or whatever. I've never -- again, I just 24 don't think that that's relevant to what we're here for 25 here today. I think that I'm protected underneath 195 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 that -- that's why -- you know, he's a great guy. He 2 dug on my case and went out there and found the truth. 3 I don't have a personal relationship with him. I don't 4 know the man personally, but he, you know, answered 5 my -- my letter and responded to individuals' calls in 6 the record industry and he covered my story for a case 7 that I'm wrongly convicted of. I don't know any other 8 thing to tell you about the man. I don't know him like 9 that. 10 Q. Did -- did you know him before you were 11 incarcerated? 12 A. No, not at all. 13 MR. MARELLA: I'm going to object to this 14 whole line of questioning on relevance. 15 MR. BRIZZOLARA: All right, so is he going to 16 answer the question about how many times he's met with 17 Chuck Phillips? 18 THE WITNESS: I mean it has -- to me it has 19 its relevance -- I'm refusing -- it has nothing to do 20 -- as I told Robleto -- 21 MR. BRIZZOLARA: We're not here to argue with 22 you, we're just trying to find out are you refusing to 23 answer that question? 24 THE WITNESS: Yes, I'm refusing to answer that 25 question. 196 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 MR. FRANK: We're going to take another break. 2 MR. MARELLA: How much longer do you think you 3 have? 4 MR. FRANK: Let me talk to Chris. 5 THE VIDEOGRAPHER: We're going off the record 6 at 1:44. 7 (Recess taken.) 8 THE VIDEOGRAPHER: We are back on the record 9 at 1:57. 10 MR. FRANK: 11 Q. Mr. Anderson, when we took a break I had 12 just finished asking you about whether I had all the 13 conspiracies kind of figured out, and there's one that 14 I think I have figured out, but I'm not sure really 15 what it's about, and that is the one relating to Berkow 16 and the pajamas. Why was there an attempt to discredit 17 Berkow? 18 MR. MARELLA: Object -- I'm going to object, 19 this has been asked and answered in great detail. 20 MR. FRANK: 21 Q. If -- if you know? 22 A. I told you they were trying to discredit 23 the investigation according to Kenneth Boagni that the 24 L.A.P.D. Internal Affairs was doing on the Rampart 25 stuff so that it would correlate with this lawsuit that 197 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 is filed by the Wallace family to show that L.A.P.D. 2 was not trying to solve Biggie Small's murder case 3 according to Kenneth Boagni. 4 Q. Chris, could you pull up the -- 5 You had discussed the gentleman in Palm 6 Springs, I think, who deals in telephones? 7 A. Uh-huh. 8 Q. Do you -- what is the name of his 9 business? 10 A. Palm Springs Cellular. 11 Q. And is there a reason why you used him to 12 purchase cell phones as opposed to anybody else? 13 A. He also used to own a store on Ventura 14 Boulevard in the City of Ventura and Rosita, and that 15 was called WWC Communications or something like that. 16 And it was more convenience. We developed a business 17 relationship and I got cell phones from him. 18 Q. Did he deal in cloned phones at all? 19 A. I refuse to answer that question. That 20 man has a family. He's not -- he's a Jewish guy who's, 21 you know, just a guy trying to make a living. He's not 22 a gangster. He's not a bad guy, or, so... But he did 23 phones for Death Row, he did phones for Tupac, he did 24 phones for Christopher and those guys whenever they 25 were in town. Most of the rappers utilized him. He 198 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 also does surveillance equipment at his business. He 2 sets up cameras, does concerts. He's even done 3 L.A.P.D. cameras. He's done the Sheriff's Department 4 cameras. He's a guy just making a living. He's a good 5 guy. 6 MR. FRANK: Could you play beginning on 275549 7 at 30 minutes and 30 seconds. 8 MR. BRIZZOLARA: Side A or B? 9 MR. FRANK: Side A. 10 MR. BRIZZOLARA: 30 minutes and 30 seconds? 11 MR. FRANK: Yeah. 12 MR. BRIZZOLARA: Okay. 13 (Audiotape played.) 14 MR. FRANK: 15 Q. Was Mr. Hawkins in any way related to the 16 conspiracy to take over Death Row Records? 17 A. I've tried to -- I'm not going to say 18 anything about Mr. Hawkins until I'm given immunity and 19 moved to the Los Angeles County Jail. I told you that 20 40 minutes ago. 21 Q. Okay. On the tapes you mentioned -- 22 A. Just, for example, you guys have those 23 tapes. I don't know how -- now I know how people get 24 tapes. These people got a lot, a lot, a lot of money. 25 And Suge Knight is considered Santa Claus compared to 199 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 the person you want me to talk about. He's nice, 2 nothing compared to this guy. 3 Q. Okay. Who is Floyd Anderson? 4 A. He's Baby Lane's cousin. He was also 5 involved. 6 Q. In what? 7 A. The murder of Christopher Wallace and the 8 murder that I'm in jail for. 9 Q. And what was his role in the murder of 10 Christopher Wallace? 11 A. I'm not gonna go into that. It could be 12 one of the people in the van you want to know about. 13 Q. Okay, so in relation to any inquiry I 14 would have as it relates to Mr. Anderson and his 15 involvement in the Christopher Wallace case -- 16 A. Uh-huh. 17 Q. -- that's a matter you're not gonna 18 answer? 19 A. I've recently been threatened by them. 20 They've recently said they're gonna sabotage my case if 21 they find out I'm snitching on them. He hangs with 22 Keith Davis to this day, and because of the safety of 23 my family and myself, I'm not gonna talk about Floyd. 24 He's also a co-defendant or was a co-defendant in my 25 case. He was the first person arrested for this murder 200 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 that I'm wrongfully in jail for and somehow just 2 disappeared and was let go out of the case. 3 Q. Was he related to the death of Tupac 4 Shakur; did he have a role in that? 5 A. Yes, he did. 6 Q. And are you able to tell me his role in 7 that? 8 A. I won't go into that. 9 Q. All right. Was -- was Orlando Anderson 10 involved in the death of Tupac Shakur? 11 A. Yes, he was. 12 Q. Was Orlando Anderson involved in the death 13 of Christopher Wallace? 14 A. Yes, he was. 15 Q. And can you tell me what his role was in 16 the death of Mr. Wallace? 17 A. I know it, but I'm not gonna tell you at 18 this time. Again, because of safety issues and my 19 concerns of -- of helping the law enforcement solve 20 their case. 21 Q. Did the same person kill both Tupac Shakur 22 and Christopher Wallace? 23 A. Yes. 24 Q. And how do you know that? 25 A. I was told by the person. And it was not 201 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 David Mack or Rafael Perez. 2 Q. Now, Mr. Knight is a Blood, correct? 3 A. Yes. 4 MR. MARELLA: Objection, that misstates the 5 record. It's been asked and answered. 6 MR. FRANK: 7 Q. Okay, I don't want to -- I don't want to 8 misstate the record. Either that's correct or not, is 9 he or isn't he? 10 A. Yes, correct. 11 Q. All right. And William Fletcher is a 12 Blood? 13 A. Correct. 14 Q. Okay, and was it Crockett, is he a Blood? 15 A. Big Wes? 16 Q. Yeah. 17 A. No. I told you I'm not gonna say anything 18 about his gang affiliation other than he is considered 19 a OG. 20 Q. Okay. And you're affiliated with the 21 Crips, correct? 22 A. Yes, sir. 23 MR. MARELLA: Objection, asked and answered. 24 MR. FRANK: 25 Q. Okay. Would it -- would it be unusual, 202 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Mr. Anderson, for a Crip affiliate to, for example, be 2 present at a bunch of Blood functions? 3 A. No, it would not at all because there's 4 certain things that -- that places your gang activity 5 to the sidelines, such as, you know, that gives green 6 lights for certain gatherings, and that's money and 7 drugs. You know, money has no color line to it. It -- 8 it embetters the lives of each gang, so... And also 9 one of the major rappers for Death Row Records was 10 affiliated with Crips, he wasn't affiliated with 11 Bloods, and that was Tupac Shakur. So to be able to 12 facilitate what Tupac Shakur needed with Death Row 13 Records, the Crips were allowed to come around. He was 14 affiliated with the Rolling 40's which is a gang right 15 down the street from where I grew up, so... 16 Q. And would that partially be an explanation 17 for the fact that you, as a Crip-affiliated artist, 18 would sometimes be at Death Row functions? 19 A. My affiliation going there is I was a 20 recording artist. So, I mean, I don't claim to be a 21 gang banger or any of that. I was a known-national- 22 charted-multimillion-record-selling recording artist 23 for Capitol Records. So my function was I went to not 24 just Death Row parties, I went to any artist party that 25 I could show my face at. That's how you get extra PR 203 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 that you don't have to pay a publicist for. So I went 2 to anything that I could get my face in at that time. 3 Q. Can you tell me some Death Row functions 4 that you went to prior to 1994 when you were 5 incarcerated? 6 A. I told you one about at The Mines, I've 7 been up to Death Row Records. I've been -- I mean I 8 don't remember. I don't want to say the names that I'm 9 wrong. I've been to several of them. I would be 10 sitting here guessing to tell you the places. 11 Q. Now, I asked you about L.A.P.D. officers 12 working for Death Row, you told me that you didn't know 13 of any. You mentioned Compton. How about law 14 enforcement officers from other jurisdictions working 15 for Death Row? 16 A. Yes, Englewood. 17 Q. Okay, where else? 18 A. Compton, Torrance P.D. 19 Q. Okay. 20 A. But they didn't work for Death Row, they 21 worked for Wrightway Security. 22 Q. Okay. 23 A. Which was ran by Reggie, which had no 24 affiliation at all. They only worked for Reggie, and 25 he was the one that brought in the law enforcement 204 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 because of his connection with law enforcement. 2 Q. Mr. Anderson, sometimes an attorney 3 grossly fails to properly estimate the time, and I came 4 in here and told you 20 or 30 minutes, well, I'm done, 5 so I misestimated, and in the words of George Bush, I 6 misunderestimated it. 7 MR. MARELLA: Misunderestimated it. 8 EXAMINATION 9 BY MR. MARELLA: 10 Q. Good afternoon, Mr. Anderson. My name you 11 may have forgotten since it's been so long from this 12 morning is Vincent Marella, and I represent -- I'm one 13 of the attorneys representing the City of Los Angeles, 14 which is a defendant in this case. 15 Mr. Anderson, I want to ask you a few 16 questions. I hope I can be brief? 17 A. Okay. 18 Q. And I'll try to keep them focused. 19 Obviously if you don't understand a question that I'm 20 asking, tell me and I'll try to rephrase it. 21 A. Yes, sir. 22 Q. I'd like to first focus on the 1997 time 23 period. 24 A. Okay. 25 Q. Now, in April of 1997, you were at 205 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Wayside, you were housed at Wayside? 2 A. Yes, sir. 3 Q. Okay. Now, I think this morning you 4 testified that at or about that time you got in touch 5 with the Los Angeles Police Department about the Biggie 6 Smalls murder, the Christopher Wallace murder? 7 A. Yes, sir. 8 Q. And can you tell us how -- briefly again 9 how it came about that you caused -- well, that you 10 contacted L.A.P.D. at that time? 11 A. Well, L.A.P.D. was initially contacted by 12 Keith Davis' girlfriend, which I believe her name is 13 Michelle. And I believe that someone told her on the 14 phone, "Well, you need to let the person who has the 15 information call back." So I was given the phone 16 number by Keith Davis over the telephone, and I then 17 had placed the call myself, but I initiated the contact 18 with the Los Angeles Police Department underneath an 19 instruction of Keith Davis to do so. 20 And I was on the phone talking to Keith Davis 21 and right next to me on the next telephone was an 22 inmate by the name of Michael Robinson, aka Psycho 23 Mike, and he was listening to my phone conversation 24 for, like, two days and I didn't know that. He heard 25 me talking to Biggie Smalls on the phone and he heard 206 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 me have this conversation with Keith Davis over the 2 phone. So when I got off the phone, he asked me, he 3 said, "Hey, man, I didn't know you was getting down 4 like that, you gonna call the police for somebody?" He 5 say, "Let me holler at you." 6 So we went over to a corner and he -- he 7 disclosed to me, or informed me that he was an 8 informant for the Sheriff's Department and the FBI and 9 that he had been working on the Death Row case with 10 them for like two years or a year trying to gather 11 information to bring a warrant against Death Row 12 Records, or criminal -- criminal activity against Death 13 Row Records. 14 So I told him, "Well, yeah," I said, you know, 15 "why are you telling me what you're doing?" He's like 16 "Awe, man," he's like, "I notice in here that you 17 really shy away from people, you're not talking to 18 nobody." He said, "You never been in jail before?" I 19 told him no. He say, "You're Way Out, aren't you?" 20 And I told him -- that's my nickname from the street 21 and I told him. And he said, "I met you in Compton at 22 the car wash years ago." So he said, "Man, I can 23 provide you protection while you're in here. Ain't 24 nobody gonna to bother you." Because being a recording 25 artist in prison, you're sort of like a sore thumb. 207 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Everybody knows something for you and they think you 2 got more money in your bank account than you do. 3 So I agreed to -- see, he told me, he said, 4 "Hey, man, if you can do me a favor." He says, "How 5 well you know Suge and them?" I said, "I know them, 6 you know, pretty well. I used to hang out with all of 7 them on the street." He say, "Hey, man, yeah, 8 everybody was saying you're that Suave dude." He said, 9 "If you would agree to talk to the dude named Dan 10 McCullin, man, it would do me a real favor." He said, 11 "He's been trying to get me to get in with Death Row, 12 but I'm having a hard time because Rick James think I'm 13 trying to set him up." He said Rick -- he had tried to 14 hang with Rick a couple times before he got arrested on 15 the charge. I think he was in jail for, like, a 16 robbery. 17 He said some Muslims or something had been at 18 his house with his girlfriend, some Muslim was sleeping 19 with his girlfriend and he beat the dude up and he got 20 arrested for a robbery or something over a wallet. So 21 he said he was unable -- he said he was being able to 22 take care of his family, provide a living for his 23 family by being an informant the FBI. And he said this 24 guy, McCullin, pays him 2500, sometimes $5,000 a month 25 if he can gather information. 208 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 So he told me, "Say, man, this thing right 2 now, I got a call, remember yesterday when I went out 3 of the tank? He said Richard Valdemar called me out of 4 here and asked me if I could find anything about the 5 Biggie Small case, they're willing to pay me my income 6 while I'm here in prison." So he said, "Man, if you 7 gonna go talk to them for Kevfe, put me down, man, and 8 let me get the credit up, I need you to talk to this 9 guy," and that's how it all took place. 10 Q. So as I understand it, Keith Davis, Kevfe 11 D? 12 A. Yes. 13 Q. Asked you to call and contact L.A.P.D.? 14 A. Yes. 15 Q. And talk to them about the Biggie Small 16 murder; is that correct? 17 A. Right. 18 MR. FRANK: Object to the form of the 19 question. To the extent that you're phrasing it in a 20 way it's calling for pure hearsay. It's a form 21 objection. 22 MR. MARELLA: 23 Q. Did Kevfe D ask you to do something in 24 connection with contacting the L.A.P.D. about the 25 Wallace murder? 209 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. Yes, he did. 2 Q. And what did he ask you to do? 3 A. He asked me to call the Los Angeles Police 4 Department and he wanted to specifically know if his 5 holler, which means his name, was being involved with 6 the murder. And he also wanted me to implement the 7 Bear he called him, which is what we call Suge. 8 Q. Okay, and then, as I understand it, after 9 Kevfe D asked you to contact the L.A.P.D., is that when 10 you had the conversation you just related with Mike 11 Robinson? 12 A. Yes, sir. 13 Q. Okay, and as a result of those two things 14 did you contact the L.A.P.D.? 15 A. Yes, I did. 16 Q. Okay, and did you also speak with this 17 Agent Mullin -- 18 A. Yes, I did. 19 Q. -- from the FBI. And as a result of your 20 initial contact, did you actually meet with L.A.P.D. -- 21 A. Yes, I did. 22 Q. -- officers? And was that when you were 23 moved down to Parker Center? 24 A. Yes, sir. 25 Q. Okay. Now, you had a series of interviews 210 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 during that time period in April of 1997, with the 2 L.A.P.D. and the FBI, correct? 3 A. Yes. 4 Q. All right, can you tell us briefly what 5 the nature of what it was that you told the L.A.P.D. 6 and the FBI about the Wallace murder? 7 A. Well, the information that I was 8 instructed to here, I'm scared of Keith Davis and his 9 South Side Crip connections. He wanted me to implement 10 the Bear, which is Suge. And he said that in that -- 11 not only did he want the Bear implemented, Lydia wanted 12 the Bear implemented, and so did Mike want the Bear, 13 which is Michael Harris. So in my -- in my own mind I 14 had to concoct this story. And it was only supposed 15 to -- he also wanted me to find out what the Los 16 Angeles Police Department implemented holler in, Baby 17 Lane's name or his name in the -- during the interview. 18 Certain times when the Los Angeles Police 19 Department or any detective interview you, you just 20 don't provide them information. They sort of ask you 21 have you ever heard of this person or do you know who 22 this person is, and they didn't do that with his name. 23 And that was one of the main things he wanted me to 24 find out, as well as implement that the Bear told me he 25 wanted Christopher Wallace -- 211 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. I'm sorry, I didn't mean to interrupt you. 2 A. -- murdered. So that was the basis of 3 the -- my initial supposed to contact the -- the 4 L.A.P.D. Michael Harris wanted me to provide the FBI 5 with background on everybody -- 6 Q. Excuse me, you said Michael Harris? 7 A. Not Michael Harris, I'm sorry, Michael 8 Robinson. So many Mike's involved. Kenneth Boagni's 9 brother's name is Mike and Michael Harris. Michael 10 Robinson wanted me to provide Mr. McCullin information 11 and background or intel was the word he actually used 12 on the whole Death Row organization because he could 13 not obtain it. He said the two conversations or the 14 meetings he had with Rick James, Rick James would not 15 go into details. He wasn't able to break him. So I 16 knew all the information about Death Row Records, and 17 so he called his FBI agent, and I mean he got there in 18 like 25 minutes after he made the phone call. 19 Q. And what -- give us the substance of what 20 it was that you told the L.A.P.D. and the FBI in this 21 series of interviews about -- about Suge Knight and his 22 associates being involved in the Wallace murder. 23 A. Because it was a story I don't remember 24 it, you know, all in detail again. 25 Q. That's fine. 212 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. So I basically implemented the Bear like 2 Keith Davis asked me to, as well as Lydia and those 3 guys. The major thing that I don't think wasn't 4 recorded in this is that the L.A.P.D. and the FBI 5 wanted to be educated on how all these little clicks of 6 entertainment forms would be gangsters that were once 7 gang bangers. So that was why they kept me there so 8 long. It really wasn't -- after I had got the 9 information from them that Keith Davis wasn't being -- 10 being sought after by them, I was really there just, 11 you know, in a -- in a mist because I didn't know what 12 else to tell them because I wasn't gonna tell them the 13 truth. 14 I actually told the detectives in the room, I 15 said, "Sir," I said, "Can I trust you before the tape 16 no longer exists?" "Well, what do you mean?" I said, 17 you know, "I didn't do this crime that I'm in jail for, 18 and if you help me, I'll tell you the truth of what's 19 going on." And he shined me on. He said, "We're not 20 here for that, I don't want to hear anything about your 21 case. You know, the detectives handling your case, I 22 know them and they're straight-up cops." And, you 23 know, sort of like pissed me off because this guy 24 didn't want to hear what I had to say, but he wants me 25 to help him with, you know, the biggest unsolved murder 213 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 of his department, so I strung him on some more. You 2 know, I just sat there and listened. He wanted me to 3 educate him about the record business, as well as help 4 him solve his case. When I told him I had been 5 threatened by real people, he just didn't want to hear 6 it. 7 Q. Would it be accurate to say that the story 8 that you told the L.A.P.D. and the FBI in or about 9 April of 1997, in the series of interviews that you had 10 wasn't true? 11 A. It wasn't true. 12 Q. Okay. You were also polygraphed at that 13 time? 14 A. Uh-huh. 15 Q. And did you tell the same story 16 essentially as you've described in your responses to 17 questions by Mr. Frank? 18 A. I don't remember what had happened, but I 19 told the guy that I have epilepsy and I have spasms, 20 what I've been saying here, and I had took a polygraph 21 before and it came up negative because of my medical 22 condition. And, you know, sometimes -- I asked to take 23 a voice analysis test, and he said that they didn't 24 have a machine at that time, and he was not going to 25 let me go back to the county jail. I wanted to get out 214 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 of there. He would not -- he was refusing to let me go 2 back until I took the polygraph, so I don't even 3 remember what questions were asked in the polygraph. 4 Q. That's fine, but what you told the 5 polygrapher about Suge Knight being involved and his 6 associates being involved in this murder, was that 7 true? 8 A. No, sir. 9 Q. Okay. And again, the story that you told, 10 the reason that you told these lies to the L.A.P.D. and 11 the FBI, why was that? 12 A. Because I was instructed to by Keith Davis 13 and Lydia Harris to tell the lies. But I did not tell 14 any lies to the FBI. The FBI wanted to know 15 information about certain individuals that hung around 16 not only Death Row, but just gangsters that were 17 involved with the record business, period. And they 18 wanted to know the way that the record industry worked, 19 like royalties, how much advances would be given, how 20 much money. So I didn't lie to the FBI. We never went 21 into detail about the murder of Wallace. They didn't 22 have any tape-recording. This guy was trying to gather 23 information against Death Row Records, Bad Boy 24 Entertainment and some other people's names that I 25 don't want to mention on the record that are still 215 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 alive today. 2 Q. And in terms of what Kevfe D said to you 3 that led you to get in touch with the L.A.P.D., did he 4 tell you what he was concerned about specifically with 5 respect to the Wallace murder? 6 A. Yes, he just -- 7 Q. What did he say? 8 A. He told me that -- I think the guy's name 9 was Ladd, and there was another detective out of 10 Compton had been heating up the neighborhood, meaning 11 they were around there and they were trying to -- I 12 guess someone informed him that they were supposed to 13 be looking for Baby Lane involved for the -- after the 14 thing happened in Las Vegas, Compton got pretty hot. 15 So he wanted to know was his name or was Baby Lane's 16 name coming out of their mouth as a part of the 17 investigation in Las Vegas or the investigation out 18 here. And just what happened he was correct, and 19 that's not the first time that they've done that. I've 20 actually been in the room with Compton where they sent 21 other people to talk to detectives to see if this 22 person was wanted for this crime or that crime. It's 23 just something that gangs do. As L.A.P.D. thinks or 24 Compton Police think they're fooling gang members, gang 25 members also do it back to them. They provide them 216 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 false information to see if they really know what 2 happened with the murder. 3 Q. Did he say anything to you about his car 4 and did he have any -- whether or not he had any 5 concern about his car? 6 A. He had concern about his -- his -- his car 7 being seen in Las Vegas, as well as his car being seen 8 on the -- in front of the Peterson Museum. 9 Q. And did you know -- I'm sorry, I didn't 10 mean to interrupt you. Go ahead. 11 A. He also wanted to know about his vehicle 12 being seen, if they mentioned anything about his 13 vehicle, or if they mentioned anything about his 14 cousin, which is Baby Lane, or if they mentioned 15 anything about his self or some other individuals' 16 names that I don't want to say at this time. 17 Q. Now, you said his cousin, Baby Lane. 18 A. Yes. 19 Q. Is that a man or a woman? 20 A. No, Baby Lane is Orlando Anderson. 21 Q. That's Orlando Anderson? 22 A. Yeah. 23 Q. Okay, that's fine. So he's related to 24 Orlando Anderson? 25 A. They're cousins. 217 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. Cousins. And did you have another 2 conversation or did you report back to Kevfe D -- I'm 3 going to call him Kevfe D -- 4 A. Okay. 5 Q. -- because I've seen that reference. Did 6 you report back to him after you had these contacts 7 with the L.A.P.D.? 8 A. Yeah, I actually called my -- somebody in 9 my family from the Parker Center. When they refused to 10 let me go back that night, I was pretty upset. And he 11 was calling everybody because he thought I had turned 12 on him because I didn't call him back for three days. 13 But when I returned back to the county jail facility, I 14 did report to him that his holler, his name was not 15 involved with the murder. 16 Q. Now, I want to change the focus time-wise. 17 I want to focus now on the year 2001. I want to fast 18 forward several years. Do you recall generally when 19 you came to the SATF? 20 A. I've been in this prison since April of 21 1998. 22 Q. Okay. And were you in Unit 4 of this -- 23 of this -- of SATF? 24 A. I've been in all the buildings on this 25 yard. 218 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. Okay. Now, I want to ask you a couple of 2 questions about Kenneth Boagni. 3 A. Uh-huh. 4 Q. Have you -- I think you made reference to 5 the fact that you were housed with him for a period of 6 time? 7 A. Yes, he -- 8 Q. Did I understand that correct? 9 A. I was in cell 134 and he was in cell 133. 10 Q. And that's here at -- 11 A. This prison, yes. 12 Q. -- SATF? 13 A. And Mario Hammonds was in cell 150. 14 Q. Okay, so the three of you, you, Mario 15 Hammonds and Kenneth Boagni, were housed together here 16 at the SATF for a period of time -- 17 A. Yes, sir. 18 Q. -- is that correct? Do you recall 19 generally when that was, what year it was? 20 A. I would say from 2000 to 2002. 21 Q. Okay, it could have been in this 2001 time 22 period? 23 A. Yes, well, I say from 2000 all the way up 24 to 2002. 25 Q. It could have been anywhere in that time 219 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 period? 2 A. Yes. 3 Q. And when you were all housed together 4 here, did you have the opportunity to spend time 5 talking with Boagni? 6 A. Yes, I did. Everyday. 7 Q. And would the same thing be true with 8 Hammonds? 9 A. Yes, sir. 10 Q. All right, and I want to ask you about 11 those conversations, and specifically did you have any 12 conversations with either Boagni or Hammonds while you 13 were housed here together where they asked you to help 14 in terms of giving testimony and information about the 15 Wallace murder? 16 A. Yes. 17 MR. FRANK: Objection, hearsay. 18 MR. MARELLA: 19 Q. Okay, and give us -- tell us what it is 20 that Boagni and/or Hammonds asked you to do at that 21 time. 22 A. They wanted me to corroborate with them 23 this story that they had concocted together before I 24 became a part of their little circle. Mario Hammonds 25 wanted me to be a part, as well as Kenneth Boagni, on 220 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 what they were trying to put together, that we all 2 three could verify that Rafael Perez and David Mack 3 were involved with the crime of the murder of 4 Christopher Wallace. 5 Q. Now, as a result of these conversations 6 that you, Boagni and Hammonds had, did you make up a 7 story during that time period about involving Mack and 8 Perez in the Wallace murder? 9 A. No, I didn't make up a story. What I 10 would do was -- was ask them what they think I should 11 say or they would take information that they knew that 12 would corroborate what they were saying, and then 13 that's how the interview in 2002 took place. They 14 would, you know, say, "Well, when you were down in L.A. 15 County Jail maybe Perez came to your cell and 16 threatened you. I can say that Perez told me that when 17 I was down with him at the county jail." And so then I 18 would figure in my mind how to bring that into 19 something that I really knew where a later date I could 20 show they were lying. 21 Q. Okay. 22 A. It's the easiest way for me to explain it. 23 Q. Uh-huh. 24 A. And then Mario Hammonds would say that he 25 was going to say that Suge told me -- told him at CMC 221 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 that he was going to pay for Larry Longo to represent 2 me so that I wouldn't say that he did Christopher 3 Wallace murder, and that's how the Larry Longo being 4 paid by Suge came about paying him to represent my 5 case. So that's how it went. They would tell me what 6 I should say or what could be done, what they could 7 corroborate from their contact with him, and that's how 8 it would go about. 9 Q. And then from the 2001 time period were 10 you interviewed again by L.A.P.D. officers in 11 connection with the Wallace murder? 12 A. No, the only interviews I had with the 13 people that Boagni gave me their business card and told 14 me to call. And I know that one of them was a guy by 15 the name of Hampton and he brought some other 16 investigator from Orange County, and that was it. 17 Q. Well, did there come a time when you told 18 L.A.P.D. that Perez had threatened you in your jail 19 cell back in '97 when you were at Parker Center? 20 A. Yeah, but that statement was made, I 21 believe, in the 2002 interview. 22 Q. Okay. Well, whenever that was, if it was 23 in the 2002 interview -- 24 A. Bless you. 25 Q. Bless you. I think you've already 222 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 testified, but I want to make it very clear, did Perez 2 ever threaten you when you were in jail. 3 A. No, sir. Kenneth Boagni told me that he 4 was going to say that when him and Perez were housed at 5 the Lynwood Facility Jail, that Perez told him that he 6 threatened this entertainer named Suave. He also 7 stated to me that since he was involved with the Rafael 8 Perez case, Detective Poole told him that the District 9 Attorney Anne Ingalls, who was wrongfully convicting me 10 for this crime, was a part of the task force that he -- 11 that was a part of the Rafael Perez prosecution team, 12 and that he was going to say that Rafael Perez told him 13 that Anne Ingalls was dirty. And, you know, I don't 14 want to gain my freedom by a lie, I want the truth to 15 come out in my case, so I told him I didn't want to 16 implement her in anything, you know. I believe in God 17 and I believe that she'll get what she has coming. 18 So when he said he was going to lie against 19 the District Attorney, he told me he was going to say 20 that in his statement anyway because he was going to do 21 that for me as a favor. And it was just little things 22 like that that he would throw in because he said the 23 police had made him so credible because of what the 24 lies he had told about Perez in the Board of Rights 25 hearings, that he could specifically say that, "Perez 223 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 told me that he threatened this entertainer," and he 2 was going to link it to Anne Ingalls, and that's how 3 that threat thing came about. So he told me that when 4 I went down to the interview say that Rafael Perez came 5 to my cell and threatened me. And that's what I did. 6 Q. But Perez never did threaten you? 7 A. No, sir. 8 Q. I think you made it very clear on at least 9 ten occasions this morning that you've never met Rafael 10 Perez; is that correct? 11 A. No, sir. 12 Q. Have you ever met David Mack? 13 A. No, sir. 14 Q. Has anybody from the L.A.P.D. ever 15 threatened you to say or do something about the Wallace 16 murder? 17 A. No, sir. 18 Q. Let me just make sure the record's clear 19 on this, do you have any information whatsoever about 20 Mack, David Mack or Rafael Perez being involved in the 21 Wallace murder? 22 A. I have information about them not being 23 involved with the Wallace murder. 24 Q. Do you have any information that any 25 L.A.P.D. officer, past or present, was involved in the 224 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Wallace murder? 2 A. No L.A.P.D. officer was involved with the 3 Wallace murder. 4 Q. Do you have any information about any 5 employee of the City of Los Angeles, past or present, 6 being involved in the Wallace murder? 7 A. No, sir. 8 Q. Now, going back to your conversations with 9 Boagni and Hammonds, when you were all housed 10 together -- 11 A. Uh-huh. 12 Q. -- can you tell us what, if anything -- 13 let's start with Boagni, what, if anything, Boagni told 14 you about why he was intent on making up a story 15 involving Mack and Perez in the Wallace murder? 16 A. Well, he was upset with the Internal 17 Affairs officers that he had assisted in the Board of 18 Rights hearings that he had conducted for them at the 19 Blueberry building, Broadberry building, or whatever it 20 was he told me. And he had been providing them with 21 information. And after he did his last Board of Rights 22 hearing, he was very upset because they told him that 23 they were going to try to get his case overturned for 24 him assisting them with those hearings. And when they 25 didn't do anything for him -- they actually said they 225 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 were going to get him a lawyer according to him. And 2 when they did not keep their part of the bargain, he 3 had actually told me he had a backup plan before that. 4 He had been contacted by Detective Poole who said the 5 Wallace family had obtained these attorneys, and that 6 he said if they did not live up to what they were going 7 to say, he was going to turn on the Los Angeles Police 8 Department and implement Rafael Perez in the 9 Christopher Wallace murder. 10 Q. Did he -- did he tell you about anything 11 that he was promised in connection with doing that? 12 Was he promised anything? 13 A. From the Los Angeles Police Department? 14 Q. No, from -- from the plaintiffs in this 15 case or -- 16 A. Yeah, he said -- 17 Q. -- from the Wallace family? 18 A. His initial thing he told me that we would 19 receive -- he was going to receive 5 percent of this 20 lawsuit, or 10 percent depending on what the initial 21 settlement would be or the outcome of the trial, 22 meaning if it was higher, he would get lesser; if it 23 was lower, we would get the 10 percent. And he had 24 already received a total of $25,000. 25 Q. And at some point did he tell you about 226 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 some work that was done for a family member of his? 2 A. He said that the first money that he got 3 was a $2500 payment for some plumbing that had broken 4 at his mother's house, the plumbing had broke. And 5 that was the first phone call that I placed for him to 6 his wife, who then called Mr. Sanders for me on the 7 phone. 8 Q. And who did he tell you, if anyone, that 9 had paid for that plumbing work? 10 A. Mr. Sanders, Perry Sanders. 11 Q. Okay, and who did you understand Perry 12 Sanders to be? 13 A. The lawyer representing the Wallace 14 family. 15 Q. Did Mario Hammonds ever tell you whether 16 he was receiving anything in connection with his 17 efforts to manufacture a story implicating Perez and 18 Mack? 19 A. Yes, he did. 20 Q. What did he tell you? 21 A. He told me he received 20 -- 20 to $25,000 22 himself and that the money was being sent to his baby's 23 mother to pay for her schooling and for their living 24 expenses since he was incarcerated. They were done in 25 increments. And he also told me that I think $6,000 227 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 went to this woman, I don't know her name, someone be 2 trying to locate her, that lives in New Orleans who 3 Perry Sanders is supposed to have represented this 4 woman in a drug case before. 5 Q. And did he tell you who had paid the money 6 that his family had received? 7 A. Faith Evans had sent packages, which is 8 Biggie's ex-wife, sent him money, sent him packages, as 9 well as the money came from Mr. Sanders according to 10 him. 11 Q. And did he -- did he, Hammonds, tell you 12 that he had received anything other than money? 13 A. Packages, televisions, CDs, sometimes like 14 I say Mr. -- Mrs. Evans -- Mario told me that he had 15 this cousin who was involved with films. He's like an 16 actor or something, he did one of Faith Evan's video 17 shoots or something, and that he received perks as far 18 as packages and stuff like that. 19 Q. And did you have any discussions with 20 either Hammonds or with Boagni about what you were 21 going to receive by participating in their scheme? 22 A. I was also supposed to receive $25,000, 23 but at that time I told them that I didn't want -- I 24 could not take anything because I was connected to 25 Larry Longo, and I had to get away from Larry Longo at 228 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 first was the excuse that I gave them. Because I 2 was -- you know, I don't want to receive payment from 3 anybody. I'm not for sale. I'm not -- I told them I 4 was never going to lie on record, you know, or, you 5 know, swear to any lie. They were pretty upset about 6 it. They on a daily basis tried to convince me to take 7 the $25,000. And although I needed the $25,000, I 8 didn't want the money. 9 Q. Did you ever have any conversation with 10 Perry Sanders? 11 A. I had one phone conversation with Perry 12 Sanders. 13 Q. When roughly was that? 14 A. In between that time period that Kenneth 15 Boagni was here. 16 Q. And can you tell us -- did you -- were you 17 here at Corcoran at that time? 18 A. Yes, I was. 19 Q. And did you call him or did he call you? 20 A. I placed a phone call to Kenneth Boagni's 21 wife. Kenneth Boagni's wife had a block on her 22 telephone, so I would call a family member of mine, 23 that family member would call Kenneth Boagni's wife, 24 and then Kenneth Boagni's wife called Perry Sanders. 25 Q. Okay, and when you spoke to this person on 229 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 the phone -- have you ever met Perry Sanders? 2 A. Never met him personally. 3 Q. When you spoke to this person on the 4 phone, did the person identify himself? 5 A. Yes, he said he was Perry Sanders. 6 Q. Okay, and tell us what you said and what 7 he said during the conversation. 8 A. He asked me did I receive his message. He 9 referred to Mario Hammonds and Kenneth Boagni and "his 10 guys." He asked me if I received the message from his 11 guys, and the message was that he was willing to pay me 12 for participation in the scam against the City. And I 13 told him, yeah, that I had to think about it and that I 14 wasn't sure yet what I was going to do. And he says, 15 "Well, let my people know." He referred to them as 16 "his guys" and as "his people." And I told him I would 17 let him know. And he said if there is anything he 18 could ever assist me with, he understands that I have a 19 case that's pending, and if he could ever assist me 20 with anything, he would be willing to assist me in the 21 case. And that was, you know, the conversation. I 22 told him thank you and I got off the phone with him and 23 I gave Kenneth Boagni back the telephone. 24 Q. You testified this morning about a 25 conversation you had with Boagni where he told you 230 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 about a book deal that he had? 2 A. Yes, sir. 3 Q. What did he tell you about that? 4 A. I have recently been told by Kenneth 5 Boagni that Perry Sanders got him an attorney out of 6 Atlanta and some attorney out of New York and he got 7 $35,000 for the book called "He Told Me So." I'm 8 supposed to be all in the book. It's about everything 9 that I've just testified that he asked me to lie to. 10 The book details what Rafael Perez supposedly had told 11 him when they were housed together at the Lynwood 12 facility. 13 Q. Now, this morning you mentioned a couple 14 of times someone by the name of Sergio Robleto; do you 15 remember that? 16 A. Yes. 17 Q. Who is he to your knowledge? 18 A. He's some man who contacted my wife about 19 four or five months ago I would say. I gave someone 20 the information who I trust. I don't know exactly when 21 it was, I can get you the date or get -- if you guys 22 need it or whatever. But this guy also put in a pass 23 to come see me here at the prison, and when I got the 24 number, my wife told me, "Yeah, the guy called me too." 25 I called the guy on the telephone and I told him, I 231 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 asked him who he was and what he wanted with me, and he 2 told me that he was representing the San -- the Wallace 3 family. He worked for the plaintiffs in the case 4 against the City. And I told him that I didn't want to 5 talk to him, that I was refusing to even speak to him. 6 And he asked me something about Kenneth Boagni on the 7 phone, and I told him "Boagni is a piece of shit," and 8 that's when the phone calls started coming to me from 9 Kenneth Boagni. 10 Q. Okay, now you said that Robleto came to 11 see you here at Corcoran; is that -- 12 A. I refused to see him, I didn't go. 13 Q. And do you know how he presented himself 14 at the institution in order to get in to see you? 15 A. He said he worked for my attorney and was 16 representing my case or something like that. I 17 don't -- because I got -- I got mad at the -- at the 18 Litigation Department because I didn't, you know, 19 really want nobody knowing where -- where I was. I 20 don't even know how he even knew I was at this prison 21 or why he even contacted -- initiated to contact me. 22 Q. Did -- to your knowledge did he represent 23 himself as an attorney? 24 MR. FRANK: Objection, foundation. 25 /// 232 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 MR. MARELLA: 2 Q. To your knowledge. 3 A. Yes, he represented himself as my 4 attorney. Excuse me. 5 Q. Now, I want to direct your attention to 6 the 2006 and 2007 time frame up until now. 7 A. Uh-huh. 8 Q. Has Mr. Boagni gotten in touch with you? 9 A. Yes, he was. 10 Q. How? 11 A. Through kites through other prisoners and 12 through calling my home. 13 Q. And tell us again what a kite is? 14 A. A kite is a message sent by another inmate 15 that's transferring from a prison to another prison to 16 get a message to another inmate. 17 Q. And is it written or is it oral or can it 18 be either? 19 A. It can be either. Mostly it can be oral 20 from Boagni, from other Crips. 21 Q. Okay, and what -- what has Mr. Boagni 22 conveyed to you in the kites? Let's take the kites 23 first. 24 A. The kites have been, "Hey, I'm about to 25 give my deposition. This thing is about to go down. 233 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Stand up, fuck L.A.P.D., do the right thing. They 2 screwed your life. Why don't you verify what we talked 3 about and do the right thing?" It was that they 4 willing to pay more money, you know, whatever -- name 5 my price have been some of the kites brought to me. 6 And that, you know, it can be very difficult for me if 7 I don't do, you know, the right thing. And then 8 threats start coming into my -- my wife at my home. 9 Q. What -- what -- tell us about the threats 10 to your wife at home. 11 A. Well, they call -- my wife knows nothing 12 about any of this stuff. My wife is a total square. 13 And, you know, she started getting calls from this 14 prison in Calipatria. Actually the calls came on my -- 15 the first call came from Robleto to my wife's cell 16 phone and he knew her name and knew everything about 17 her. Then the second call came into my son's phone and 18 my son didn't even know these guys were calling because 19 it was from another prison. And so the messages were, 20 you know, we need to get in touch with your husband, 21 ask your husband is he okay. You know, women and 22 children, you know, need to be very safe out there by 23 theirselves, you know, things of that matter. And I 24 received a threatening letter. 25 Q. Okay, excuse me, before you get to that, 234 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 let's just stop with the calls to your wife and to your 2 son. 3 A. Right. 4 Q. Who was it that -- that called? 5 A. It was Kenneth Boagni and his pals. 6 Q. Okay, and go ahead, you were about to say 7 something about -- 8 A. After the phone calls, then I received a 9 threatening letter in the mail, which I turned over to 10 somebody that I trust, and they have that information 11 of the threatening letter. 12 Q. And can you tell us who that letter came 13 from? 14 A. They saying we -- you're snitching -- 15 yeah, it came from Kenneth Boagni. I know it was from 16 Kenneth Boagni because of the content of the letter. 17 And why don't I do the right thing. They've been 18 trying to intimidate me into not telling the truth 19 about this case, and I choose to tell the truth about 20 the case. 21 Q. Now, in addition to the context that you 22 just described, have you had any discussions with other 23 inmates about what, if anything, you were going to say 24 in connection with the Wallace murder? 25 A. I told them that I was going to do what 235 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Kenneth Boagni asked me to do, but, of course, I didn't 2 come in here and do what Kenneth Boagni asked me to do, 3 because I'm not for sale. 4 Q. So has someone recently here at Corcoran 5 contacted you about your testimony here today? 6 A. Yes. 7 Q. Okay, and -- and who is that person? 8 A. Freddie Mingo. 9 Q. Okay, and what has he said to you? 10 A. He asked me to please verify what Kenneth 11 Boagni -- you know, do that for blue, which is on Crip, 12 he said to verify what Kenny Boagni wants me to do, 13 because his wife had been moved -- given money to move 14 out here to Fresno by Perry Sanders, and that he was 15 going to get a big chunk of whatever Kenny Boagni got 16 if I would verify what they wanted me to verify. And I 17 told him that I would do it. 18 Q. Have you had any contact directly or 19 indirectly with Mario Hammonds? 20 A. I've only seen -- 21 Q. In the past two years, let's say. 22 A. Again, kites, messages to do the right 23 thing and that this thing is coming down the pipeline. 24 You know, we all going to get paid, and, that they 25 going to put the move on brothers of his. 236 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. Now I want to direct your attention to the 2 conversations that you've had with Kevfe D from 1997 on 3 and thereafter about the Wallace murder. Did you have 4 such conversations with him? 5 A. Yes, I did. 6 Q. And in those conversations did Kevfe D say 7 anything about whether he was involved with the Wallace 8 murder? 9 A. Yes, he did. 10 Q. And was that both before the murder and 11 after the murder? 12 A. Yes, sir. He said he killed him, man. He 13 told me how he planned it, he told me how it went down, 14 he told me that his vehicle was involved in the murder, 15 which was a black SS. 16 Q. Mr. Anderson, you said that you have been 17 on medication from time to time, is your mind clear 18 here today? 19 A. Oh, my mind's very clear. 20 Q. You have a strong sense of where you are 21 and what you're testifying about, right? 22 A. I'm in BPT at SATF Corcoran Prison, it's 23 August the 20th, and President Bush is the half 24 President of the country. 25 Q. That would make for a very long 237 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 deposition, we're not going to get into that. But 2 there's nothing by way of medicine or any other 3 substance -- 4 A. No. 5 Q. -- that has clouded your mind here today? 6 A. This is the first time that I've been put 7 underneath oath. I will not lie underneath oath in 8 this case, and everything I've said here is the whole 9 truth, nothing but the truth, so... that's it. 10 Q. And I believe you've said you never met 11 anybody -- you've never met me or any of my associates? 12 A. Never seen you in my life, never talked to 13 you on the telephone, never sent you a letter, never 14 had a conversation with you, never talked to this man 15 before. I received a message from Mr. Brizello (sic) 16 over there, a yellow piece of paper saying that this 17 interview would be conducted today. I have it in my 18 back pocket, but that's it. I don't know anybody in 19 this room. I don't know the lady, the man at the 20 videotape, nobody. 21 Q. Okay, and you talked about the murder of 22 Tupac Shakur, do you recall specifically when that was 23 at this point? 24 A. It was November 7th, 1996, if I'm correct 25 on the date. 238 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. Yeah, but could it have been September 2 7th, 1996? 3 A. Yeah, excuse me, September, I'm sorry. 4 Q. Okay. And I believe you -- you knew Kevfe 5 D even before you were incarcerated, right? 6 A. He used to be at my house everyday. 7 Q. Okay, and to your knowledge at or around 8 the time of the Wallace murder he had a black Chevy 9 Impala SS? 10 A. Yes, he did. 11 Q. A dark one? 12 A. Yes. 13 Q. Dark -- I said black. 14 A. That was like his third one. 15 Q. Black is usually dark, yeah. And the 16 diagram that you drew, which has been marked as Exhibit 17 1 in this case, all that represents is your mental 18 picture of what someone was telling you; is that 19 correct? 20 A. What was described to me. I took a mental 21 picture. I knew that Keith Davis was playing me and I 22 was going to get -- when they got me this attorney, I 23 knew it was going to get dragged out for this case. I 24 retained and gathered as much information as I could 25 from Keith Davis and the others involved, as well as 239 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Lydia and everybody else about this case. And so he 2 laid out to me, through many conversations that we had 3 through attorneys and personal conversations that we 4 had, how the murder actually went down. 5 Q. Okay, so but what -- if -- if Kevfe D told 6 you that there was a street, for example, next to or 7 across from the parking structure, you've been in jail 8 for 14 years, do you have a specific recollection of 9 that area? 10 A. Well, I grew up in -- I shouldn't say grew 11 up in that area, but I grew up in South Central Los 12 Angeles, and my -- my business manager, Gordon 13 Rantanni, before I hooked up with these other people 14 from Compton, office was on 10960 Wilshire Boulevard, 15 so I have a mental picture of what Wilshire Boulevard 16 looks like, and I also not only from that I went to 17 UCLA, which Wilshire Boulevard is one of the major 18 streets over from UCLA. So I'm pretty familiar with 19 the area, I just don't know how it runs, and what -- 20 you know, where this building is anymore, but I can -- 21 I can see the area. 22 Q. May I have a moment? The plumbing that 23 was -- that Mr. Boagni said was paid for, I believe you 24 said his mother's house, did -- did Boagni tell you how 25 that money was paid? 240 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. He specifically told me that -- when we 2 made the phone call, when he got off the telephone, he 3 told me that Mr. Sanders said he was out of the office 4 or something like that, but he would take care of it 5 and he was going to place a call to Colorado from what 6 I remember. That was it. 7 MR. MARELLA: I have no further questions. 8 MR. FRANK: If we could go off the record. I 9 have a question for you and then I got a couple 10 follow-ups. 11 THE VIDEOGRAPHER: We're going off the record 12 at 2:47. 13 (Recess taken.) 14 THE VIDEOGRAPHER: Back on the record at 2:48. 15 FURTHER EXAMINATION 16 BY MR. FRANK: 17 Q. Now, you've only had one conversation with 18 Perry Sanders? 19 A. One phone conversation, yes, sir. 20 Q. Okay, well, you've never met him 21 personally, right? 22 A. No, sir. 23 Q. All right, so the only conversation you 24 could have with him is a phone conversation? 25 A. Yes, sir. 241 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Q. All right, when did that conversation take 2 place? 3 A. As I just told the gentleman over there, I 4 don't know the time or the date. It was placed out of 5 the building. I called my family member, they called 6 Kenneth Boagni's wife, because his wife had a phone, a 7 block on her phone, and she placed the call to Perry 8 Sanders. 9 Q. All right, what year was it? 10 A. It was in between the time that he was 11 here with me. He was not originally -- Mario Hammonds 12 was here with me first and then Kenneth Boagni arrived 13 so it was soon after he arrived here. 14 Q. Okay, so soon after Kenneth -- 15 A. Boagni arrived to this prison from 16 Calipatria State Prison, then he went back to 17 Calipatria State Prison. 18 Q. Okay, so you had a conversation with Perry 19 Sanders -- 20 A. Uh-huh. 21 Q. -- while Kenneth Boagni was here in this 22 facility? 23 A. Yes. 24 Q. Okay. 25 A. The party on the phone identified himself 242 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 to me as Perry Sanders. 2 Q. Okay. And how long was the conversation? 3 A. Well, our phone calls are only 15 minutes, 4 so I think I took maybe about two minutes of the 5 conversation, maybe a minute and a half, again I'm 6 guessing. So it was real quick. I stated what was 7 said on the phone, he wanted to know if I received his 8 message, he referred to them as "his guys," as they had 9 a relationship with him. And he stressed if there was 10 anything he could do to assist me, he understood that I 11 was -- he knew a little bit about my case, and that was 12 the basis of the conversation. And I again told him 13 that I was represented by Larry Longo at the time which 14 was connected to individuals that I couldn't talk about 15 at that time and I would let them -- let him know or 16 let his people know what I would be willing to do. 17 Q. Okay, and was there anything else 18 discussed in that conversation? 19 A. No. I got off the phone and gave the 20 phone back to Kenneth Boagni. 21 Q. All right, so Boagni has offered you money 22 to testify, right? Is that what you're saying? 23 A. Perry Sanders has offered me money to 24 testify, Mrs. Wallace has offered me money to testify. 25 Q. Well, you've never spoken with 243 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 Mrs. Wallace, have you? 2 A. According to Mr. Boagni, this is where I'm 3 getting the information from. 4 Q. Okay. 5 A. Boagni don't have no money, so... 6 Q. This is the distinction I want to draw -- 7 A. Okay. 8 Q. -- Mr. Anderson, is the statement that 9 allegedly came from Voletta Wallace? 10 A. Right. 11 Q. Okay, you never talked to Voletta Wallace? 12 A. No, no. 13 Q. All right, that came from? 14 A. Kenneth Boagni, yes. 15 Q. All right. And then Perry Sanders, in any 16 conversation with Perry Sanders did he ever offer you 17 money? 18 A. Yes. 19 Q. What did he offer you? 20 A. I just specifically described it to you. 21 He asked me did I get his message from his people. The 22 message was about I was supposed to receive $25,000. I 23 told him, "Yes, but at this time I can't do anything 24 because I'm affiliated with Larry Longo." The message 25 -- I knew what he was talking about and he knew what I 244 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 was talking about. 2 Q. You assume he knew what he was talking 3 about? 4 A. Yes. 5 Q. All right. So Perry Sanders never on any 6 telephone conversation said, "I'm gonna pay you 7 $25,000"? 8 A. No, he asked that did I get his message 9 about the $25,000. 10 Q. Well, did he say, "Did you get my message 11 about $25,000?" 12 A. I knew what message he was talking about, 13 Mr. Franks. 14 Q. That wasn't my question. My question 15 was -- 16 A. He didn't say the $25,000 over the 17 telephone call. 18 Q. All right. He's never once at any time 19 mentioned any kind of dollar figure with you, has he? 20 A. No. 21 Q. All right. Who was Dan McCullin 22 investigating, do you know? 23 A. According to Michael Robinson he was 24 investigating Death Row Records, as well as other 25 African Americans involved with illegal activity that 245 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 had transformed themselves into executives in the 2 record industry. 3 Q. Okay, was his investigation solely limited 4 to African Americans? 5 MR. MARELLA: Objection, foundation. Calls 6 for speculation. 7 MR. FRANK: 8 Q. It was a poorly-phrased question. I'll 9 rephrase it, Mr. Anderson. What about Death Row 10 Records do you understand he was investigating? 11 A. Criminal activity. 12 Q. Do you have notes from any meetings with 13 Mr. McMullin? 14 A. No. 15 Q. What kind of criminal activity was he 16 investigating for Death Row Records? 17 A. Narcotics and -- 18 MR. MARELLA: Objection, lack of foundation. 19 MR. FRANK: 20 Q. If you know. 21 A. Narcotics and money laundering. 22 Q. Do you have any notes from any 23 conversation with Boagni? 24 A. I don't need notes, it's in my head. 25 Q. Okay, do you have any notes? 246 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. No. 2 Q. All right, do you have copies of any of 3 the kites that you've received either from Mr. Boagni 4 or from any other person? 5 A. No. Mostly -- 6 Q. Go ahead. 7 A. When kites were delivered by a gang 8 member, and, you know, any gang member or gang 9 coordinator at this prison or people who investigate 10 gangs, prison gangs, when a person brings a written 11 kite, once that person reads that kite in front of that 12 person, that kite is tore up. Most kites are oral 13 kites, because they have what they call keestering and 14 these people have become very sophisticated in the 15 prison system where when they transfer an inmate, they 16 go in the mouth. They look at every cavity where you 17 can hide something. So you retain, you learn how to 18 learn constitutions, as they call them in prison, where 19 you retain that information in your mind and you convey 20 it to the person that you've been instructed to give it 21 to. 22 Q. Did you make copies of any of the kites 23 when you made copies of the chart that you gave to 24 L.A.P.D. that Mr. Reichert has over there? 25 A. I don't know what charts you're referring 247 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 to. I can't see that far, and he was telling me he has 2 a chart over there, and he could have anything over 3 there. And I didn't to my recollection give L.A.P.D. 4 anything. I made that chart in front of them because I 5 knew it in my head. He gave me a pencil and I drew it, 6 just as you asked me to draw the street for you. 7 Q. Did you ever give any notes or any written 8 material other than that chart to the L.A.P.D.? 9 A. Not to my -- I don't recall. 10 MR. FRANK: Mr. Reichert, do you mind showing 11 the witness the chart so we can go ahead and identify 12 that? 13 MR. REICHERT: We put it away, hold on. 14 MR. MARELLA: I guess we should mark this as 15 Exhibit 2. 16 MR. FRANK: Unless you want to mark it and 17 retain it, I don't care. 18 MR. REICHERT: We have extras. 19 MR. FRANK: Okay, let's mark it as 2, then. 20 THE WITNESS: This is not the chart that I 21 gave L.A.P.D. L.A.P.D. made this chart. 22 MR. FRANK: 23 Q. And how do you know that? 24 A. Because there were no photos on the chart. 25 Q. Does it appear to be your chart with 248 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 photos added? 2 A. No, this is not the chart. No, this is 3 not the chart. This is a chart what has to do for my 4 case file. It has nothing to do with this case. The 5 chart that I had has Michael Harris' name, Pancho and 6 other narcotic people. 7 Q. May I see that, Mr. Anderson. 8 A. I don't know what that's doing in there. 9 That's involved in my case. 10 MR. FRANK: 11 Q. I don't feel the need to mark this and 12 attach it, Mr. Marella. If you do, that's fine. 13 MR. BRIZZOLARA: I think we should attach it 14 because he said it's not the chart. 15 MR. FRANK: Well, we have noted the page. 16 MR. BRIZZOLARA: That's true. 17 MR. FRANK: We've noted for the record that 18 it's CW06013775, it's PDF number 01179 RHDB44 produced 19 7/31/06. If you want to attach it, I have no problem 20 attaching it. 21 MR. REICHERT: We probably shouldn't because 22 it's subject to a protection order and it just 23 complicates the Court Reporter's job if we have a 24 sealed document. 25 /// 249 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 MR. FRANK: 2 Q. I'm going to represent to you without 3 playing you the tape, Mr. Anderson, that the L.A.P.D. 4 notes indicate that you gave them other materials in 5 addition to a chart; do you recall what you gave them? 6 A. I would have to see it. Again, I don't -- 7 I don't recall giving them any other material other 8 than the man asked me to explain to him how this 9 narcotic trafficking ring worked, and that was what the 10 chart was about to my -- to my memory. 11 Q. Do you have access to or do you own a 12 typewriter with a memory? 13 A. No, it's impossible to get a typewriter 14 with memory in prison. 15 Q. Have you ever owned one? 16 A. No. 17 Q. We've discussed your contract with Larry 18 Longo as it relates to your life story, who has a copy 19 of that contract? 20 A. I don't even know where to get that from. 21 Q. Okay. 22 A. It doesn't exist anymore. 23 Q. Okay, what do you mean by it's 24 non-existent? 25 A. Mr. Longo breached -- I don't know the 250 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 legal term to -- meaning when Larry Longo tried to get 2 that contract signed. 3 Q. Right. 4 A. I wasn't represented by an attorney, and 5 because I'm legally blind was how the contract was dis 6 -- dis -- disbursed of. Because I was not represented 7 by an attorney and since he was representing me on a 8 criminal matter at the time, he could not enter into an 9 agreement with me. And the lawyers took care of that. 10 I don't know any other way to explain it to you. 11 Q. Why -- explain to me how it was that 12 Mr. Longo came to represent you? 13 A. I'm not -- again, that involves my case, 14 I'm not gonna go into that. That man is about to 15 testify and that would be breaking confidentiality 16 between attorney/client before I'm going into an 17 evidentiary hearing. 18 MR. FRANK: What are the numbers on that? 19 MR. BRIZZOLARA: It starts at about 15 20 minutes. It's 282788 B. 21 MR. FRANK: And we're starting at 15. 22 MR. BRIZZOLARA: Right, there's actually two 23 sections, there's one at 457 and 508 and then it starts 24 at 15. 25 MR. FRANK: Why don't you start with the first 251 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 one first and then go right to the second. So on tape 2 282788 B first we're going to start at 457 and go to 3 508. 4 MR. BRIZZOLARA: All right, this is 457. 5 (Audiotape played.) 6 MR. BRIZZOLARA: That stopped at 510. And 7 then I'll play starting at 15 minutes. 8 MR. FRANK: And for the record, same tape. 9 MR. BRIZZOLARA: Same tape. Same side, the B 10 side. This I'm actually starting at 1458. 11 (Audiotape played.) 12 MR. FRANK: 13 Q. Your statement on the tape -- your 14 statements on the tape as they relate to the method in 15 which Larry Longo was paid, were they true when you 16 made them? 17 A. I told you -- 18 MR. MARELLA: Object, excuse me a moment. 19 Objection, I'm going to object to this whole line of 20 questioning, it's outside the scope of cross and it's 21 irrelevant. 22 THE WITNESS: You still want me to answer the 23 question? 24 MR. FRANK: 25 Q. Yes, sir. 252 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. Okay, I told you two hours ago that Mario 2 Hammonds stated at CMC that he was going to say that 3 Suge paid for my attorney and he could verify that Suge 4 did that. Larry Longo had me sign a contract and I 5 divulged that information to Mario Hammonds, and it was 6 his idea for me to say in that 2002 interview that Suge 7 paid him $350,000 for the life story because he could 8 say Suge told him that directly at CMC. I don't know 9 any other way to tell you about those tapes. 10 I -- I gave them information that I had that 11 was going on with me with Larry Longo, and Mario 12 Hammonds said he would verify that. I never got a dime 13 from Larry Longo for my life story, and Mr. Knight 14 never gave me a dime for my life story. Mario 15 Hammonds, that was one of the things that he would be 16 able to verify later on. When this case that you are 17 here for today went to a civil case trial, he would 18 verify that Suge offered Larry Longo $350,000 because 19 Larry Longo was supposed to be this dirty D.A. who Suge 20 lived in his house in Malibu, and Mario Hammonds was 21 provided that information by the FBI who he was getting 22 fake search warrants for on his property. 23 So he came up with the idea for me to say that 24 Suge bought my life story, because I was complaining 25 about Larry Longo having me sign this contract for my 253 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 life story. It was a film director who Larry Longo 2 said wanted to pay him big money for my life story. 3 That part of the conversation is true, but involving 4 Mr. Knight's name is clear involvement from what Mario 5 Hammonds and Kenneth Boagni asked me to do. I don't 6 know any other way to explain to you about those tapes 7 anything that it says with their names in it. 8 Q. You had mentioned when Mr. Marella was 9 asking you questions a letter that you received which 10 was threatening that you believed to be from 11 Mr. Boagni; is that correct? 12 A. Yes. 13 Q. What was the threat in the letter? 14 A. Oh, I don't remember all the content of 15 the letter, but it was a threat. It mentioned about 16 the valley, my, you know, son and, you know, stupid 17 people doing certain things, and I didn't think a 18 nigger would cross me like that, the N word is in it. 19 And, you know, I can get a copy of the letter. The 20 letter is with someone who I trust who has it. 21 Q. Okay, why do you believe that letter is 22 Mr. Boagni? 23 A. It's called intimidation, because of the 24 certain things I'm representing in the letter. 25 Q. What was -- 254 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. None of this stuff started until 2 Mr. Robleto contacted me and I called Kenneth Boagni a 3 liar on the phone, I don't remember my exact term that 4 I used with him that day. I said he was a "piece of 5 shit" I think it was. And when I said that, then I 6 started getting the phone calls and then that letter 7 came. Before that I never got no threatening letters. 8 Q. What specifically within the body of the 9 letter led you to believe that it was from Mr. Boagni? 10 A. Because the word "Cheese" was used, and 11 that was one of Boagni's nicknames in prison. The 12 letter was signed "Cheese," and Boagni was known -- 13 he's real light-skinned and very tall. I'm sure you've 14 met him before. 15 Q. No, I haven't. 16 A. Well, he's 6-5, 6-6, and he's very tall 17 and very light-skinned. And he looks like string 18 cheese and that's his nickname. So it's signed 19 "Cheese." That's how I know. 20 Q. Do you remember being interviewed by 21 L.A.P.D. as it relates to the Mack bank robbery? 22 MR. MARELLA: Objection, outside the scope of 23 cross. 24 THE WITNESS: Everything -- 25 MR. MARELLA: Irrelevant. 255 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 THE WITNESS: -- out of my mouth that was said 2 about David Mack and Rafael Perez and Suge Knight's 3 involvement in this murder was said because the story 4 was con -- con -- concocted between Kenneth Boagni, 5 Mario Hammonds, and they tried to implement me into 6 what they were doing, and out of fear I did it. So 7 that same interview you're talking about is all in the 8 same interview. It was never any separate interview. 9 MR. FRANK: 10 Q. So, Mr. Anderson, it's your recollection 11 that you never met separately with Wong and Lacotta on 12 the bank robbery matter? 13 MR. MARELLA: Objection, scope. Same 14 objection. 15 THE WITNESS: Wong and Lacotta, maybe they 16 were a part of the Hampton, maybe Hampton after Boagni. 17 All of these detectives you're talking about Kenneth 18 Boagni gave me their number. I didn't know these guys. 19 I had no -- it's not like I just picked up the phone 20 and said, you know, give me a detective. Kenneth 21 Boagni told me. These were people he had talked to who 22 were working on the Rafael Perez part of the case. 23 Q. One last question for you, Mr. Anderson. 24 Can you remember any other names of anybody from 25 L.A.P.D. that you may have spoken with? 256 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 A. Not at this time. 2 MR. FRANK: Thank you. 3 FURTHER EXAMINATION 4 BY MR. MARELLA: 5 Q. I just have one question for you. Several 6 times, including a couple minutes ago, in response to a 7 question that Mr. Frank asked you, you used the word 8 "implement," and you used it earlier about implementing 9 Mack and Perez in the story, did you mean implicate? 10 A. Yeah. 11 Q. In other words, involve? 12 A. Involve, implicate, I'm sorry. 13 Q. And would that be true for all the times 14 you used the word "implement"? 15 A. Yes, sir. 16 MR. MARELLA: Okay, thank you. No further 17 questions. 18 MR. FRANK: We're done. 19 THE VIDEOGRAPHER: Okay, we're going off the 20 record and this deposition has ended at 3:10. 21 (Off the record.) 22 MR. FRANK: The deposition will be sent to 23 David L. Bernstein, Attorney at Law, 11012 Ventura 24 Boulevard, Suite 350, Studio City, California 91604. 25 Mr. Bernstein currently represents Mr. Anderson. We 257 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 will request Mr. Bernstein to handle signature. 2 (Off the record.) 3 MR. BRIZZOLARA: Let me propose the following 4 stipulation: That the Court Reporter will be relieved 5 of her duties under the code. That she's going to 6 forward the original deposition transcript directly to 7 counsel for the deponent, who is Mr. Bernstein. That 8 the witness will have 60 days to read, sign and correct 9 his deposition transcript under penalty of perjury. 10 We'll be advised by Mr. Bernstein within 15 days 11 thereafter of any changes made in the transcript, as 12 well as the witness signing same. That if we are not 13 advised of any changes, or if the original transcript 14 is lost or unsigned, an unsigned certified copy can be 15 used for all purposes under the code. 16 Let me stop for a second. Who's going to keep 17 the original? Are we going to keep it? 18 MR. FRANK: Sure, we'll keep it. 19 MR. BRIZZOLARA: Okay, we'll keep custody of 20 the original deposition transcript. It will be made 21 available on reasonable notice to all parties in this 22 proceeding. 23 MR. MARELLA: So stipulated. 24 THE WITNESS: Thank you, guys. 25 MR. MARELLA: Thank you. 258 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 (The deposition concluded at the hour of 3:22 2 p.m.) 3 ---oOo--- 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 259 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 ---oOo--- 2 3 4 I declare under penalty of perjury that I 5 have read my deposition testimony contained herein, and 6 that my testimony and any corrections, additions, or 7 deletions I have made thereto is true and correct to 8 the best of my knowledge. 9 10 11 ____________________ _____________________ 12 Executed on W I T N E S S 13 14 15 16 17 18 19 20 21 22 23 24 25 260 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450 1 STATE OF CALIFORNIA, ) ) ss. 2 COUNTY OF KINGS. ) 3 4 I, CHERI FIKE, a Certified Shorthand 5 Reporter, DO HEREBY CERTIFY: 6 That the witness in the foregoing 7 deposition named was, before the commencement of said 8 deposition, by me duly sworn to testify to the truth, 9 the whole truth, and nothing but the truth; 10 That said proceedings were thereafter 11 caused, by me, to be transcribed into written form; 12 That the foregoing and annexed pages 13 constitute a full, true, and correct transcript of the 14 proceedings had and testimony given in the hearing of 15 the matter entitled as upon the first page hereof. 16 IN WITNESS WHEREOF, I have hereunto 17 subscribed my name this 23rd day of August, 2007. 18 19 ____________________________ 20 CHERI FIKE, C.S.R. #6200 21 22 23 24 25 261 KINGS COURT REPORTERS CERTIFIED SHORTHAND REPORTERS (559) 585-3450