1973 Watergate Hearings; 1973-06-28; Part 2 of 4

That's what I was hearing My first experience of scraping This place is actually a large family I am sure it will be a black cell There must be some nature And, of course, Some people can only be seen Some don't There's some that is alley Some people don't There's some adults. There's some that is crazy It's because he was concerned about his clients' Fifth Amendment rights. So those are the only points I'd make on that closing statement that was offered

by the White House. I want to thank Senator Norif for putting these questions at request of the White House Council and also for calling attention the witness to the contention of the White House Council. Mr. Dean, you've been testifying for about an hour and a half and I'll imagine you wouldn't be very adverse to having a very brief recess at this time. I would appreciate that, Mr. Chairman, and I thank you for your thoughtfulness. The break at this point is to give John Dean a chance to rest his voice, but as you'll see, it also affords Senator Irvin a chance to get his questions ready for the witness. It's now the Chairman's turn. Committee will come to order. On the unusual routine, it would be of the time for Senator Baker to interrogate the witness however he has kindly agreed to allow me to do so for on account of certain obligations I have.

Mr. Dean, if there are one or two exhibits I want to ask you about, and you might as one of his exhibit five, which is a Shererson Hamill incumbent in a statement. Do you have a copy of that there? I do not know, sir. Can someone supply him with a copy of that? And another is the number two, what I call the Dean Papers, that is, the papers that are turned over this committed by, it's all of the judge's reacon. You have a copy of that? I do not. And another is the exhibit number three of the Dean Papers, a memorandum of Mr. Huston from Mr. Houston, for Mr. Hallman. I'd like you to have a copy of those three documents before I begin. I have some of the documents that were turned over to me yesterday for identification relating

to Judge Siricca. I have, I don't know what you're referring to with regard to the Shererson and Hamill statement. When did you all transfer from the Justice Department to the White House July of 1970? We winded Mr. Tom Hall's Houston transfer from Justice Department to the White House. I don't believe he was at the Justice Department of the best of my knowledge, Shererson. Was he at the White House, the White House, yes? Do you know anything about a meeting having been held in the office of the President on about to filter June 1970 at which the President and Mr. Houston and others discussed laying

plans for all gathered in domestic intelligence? I have hearsay knowledge of that, Mr. Chairman, that such a meeting did occur that at President at the meeting, Mr. Houston was there, various representatives of the intelligence agencies and the President at that point in time stated to those President that Mr. Houston would be in charge of the project for the White House. Now, well, you will inform in substance that the President assigned to Tom Charles Houston save responsibility, that is, White House save responsibility for domestic intelligence and internal security affairs. That's correct. Now, as a result of this meeting, there was a review by the heads of the CIA, the FBI, the NSA and the DIA of all the techniques used by these information or intelligence

gathered and organizations together, intelligence both domestic and foreign, what's not as my general understanding on, can say again. And that review is embodied in one of the papers that you identified yesterday, which I call number one of the dean papers that was not introduced in evidence. I don't identify them as the dean papers. They happen to fall into my possession. I wasn't the author, but of course, I did turn them over to the court. Now, last year, if the, to look at the, the, the, the, the, the exhibit entitled Recommendations on top secret handle, the, our, C O M I N T channels only, operational restraints on intelligent collection that you have left. Is this your number two?

Yes, that's what I call number two. I, the top doesn't say Recommendations on it to me. It just has top secret handle via comment channels only, operational restraints on intelligence collection. And then A is missing and B, the document begins. Yes. In other words, the parts of it were deleted, the part that had any reference to foreign intelligence matters. Now, that does that not constitute a recommendation from Tom Charles Houston concerning domestic intelligence apart you have there? What I understand this document, as I recall, when, when this, when I received it, it appeared to me to be a summation of a, of a rather lengthy document, the 43 page document that was being forwarded, either to Mr. Hallman or to the president for their review. Yes.

Now, that document make, it does not that document in short make these recommendations as to the amount or rather the techniques that should be followed in Mr. Houston's view in gathering domestic intelligence and matters effect in internal security. Yes, it does. And otherwise it says that the recommends that one first technique has a so repetitious entry. The, on mine, which is number B, the first recommendation is electronic surveillance and penetrations and says recommendation present procedures should be changed to permit intensification of coverage of individuals and groups in the United States who pose major threats to internal security. Yes. In other words, the first recommendation, instead of what I asked was a recommendation following electronic surveillance and penetration, that is correct. Then the next second recommendation was for the use of male coverage, that is correct. The third recommendation was a recommendation of a technique designated as so repetitious

entry. That is correct. So that does not do the, the exhibit showed that that so repetitious, so repetitious entry. It does not state that this, a third technique was described by Mr. Houston in that document as follows, use of this technique is clearly illegal. It amounts to burglary. It is also highly risky and could result in great embarrassment if exposed. However, it is also the most fruitful tool and can, and can produce the type of intelligence which cannot be obtained in any other fashion. That isn't on the document I have before me, but I do recall something of that effect in the larger report that we're referring to, yes, Mr. Chairman.

The fourth technique was development of the campus sources of information concerning violence, prone student groups, old campus groups, was that is correct. And the fifth technique recommended by this statement is the use of undercover military agents. That is correct. Now I'll ask you, all of these recommendations were recommendations that didn't exist in restrictions on the use of these five techniques except the one about military and cover agents be removed. It was not. That is correct, as I recall the larger document that many of these recommendations had footnotes that had been placed on there by Mr. Hoover as to each one of them. Now did not do the original document of which this is a next-circuit deletions point out

on several occasions that Mr. Hoover, the director of the FBI, was wholly opposed to the use of any of these techniques for domestic surveillance. Yes, sir. It did. And I'll ask you if they only talk, the Americans who were to be the subject of these information of intelligence gathering activities were designated by such terms as the subversive elements without further definition. It was very broad. That is correct. Now a second of selected targets of internal security interests. Yes, sir. Again, that was a very broad. There is no definition anywhere in the document as to what those two things mean. That is correct, sir. There was a prephysory section of the document explaining somewhat of the dimensions of the columnism was perceived at that time, but again, there was not even a lot of specificity

in that as I recall, but it's been several quite a times since I've read the document. Now was anything in the document that told who was going to do the selecting of these selected targets of internal security interests, not to my knowledge? And that was left up about the document to the imagination or interpretation of anybody engaged in the intelligence work. That is correct. Now, there was another, I believe, that one of the reasons for developing this was to get intelligence that was more responsive to the requirements of the White House. There it is. I think I have testified. They were continued complaints about the intelligence, and I think that's why the White House took charge of the project. The White House was dissatisfied with the work being done by the FBI, the CIA, NSA, and the other intelligence government of agencies that wanted to assume some degree of supervision

of those agencies, didn't it? That is correct. And Alaskan is a lawyer. If you do not think that a self-reptitious entry or burglary and the electronic surveillance and penetration constituted a violation of the Fourth Amendment—yes, sir, I do—the Fourth Amendment just provides that the right of the people to be secure in their persons, houses, papers, and effects against unreasonable searches and seizures shall not be violated. And no warrant shall issue but upon probable cause supported by oath of affirmation, and particularly describing the place to be searched and the personal things to be seized. Hasn't it always been a violation of the Fourth Amendment under the decisions of the Court

to resort to burglary for the purpose of getting information? Yes, sir, it has been. And has in the Supreme Court the recently held by a unanimous opinion that the use of electronic surveillance and penetration to obtain information concerning persons allegedly guilty of domestic subversive activities is also a violation of the Fourth Amendment? That is correct, Mr. Chairman. Now I call your attention to what I designated as document number three, and ask if you read this document to the committee. This is a memorandum for Mr. Euston, subject to domestic intelligence review. The recommendations, I might add here, it's from Mr. Holman to Mr. Euston. The recommendations you have proposed as a result of the review have been approved by

the President. He does not, however, want to follow the procedure you outlined on page four of your memorandum regarding implementation. He would prefer that the thing simply be put into motion on the basis of this approval. The formal official memorandum should, of course, be prepared, and that should be the device by which to carry it out. I realize this is contrary to your feeling as to the best way to get this done. I feel very strongly that this procedure won't work, and you'd better let me know, and we'll take another stab at it, otherwise, let's go ahead. Now, that letter can only be construed as a statement on the part of Mr. H.R. Holman to Mr. Tom Charles Euston, the aid in charge of domestic intelligence that, to the effect that the President of the United States had approved his recommendations about removing

the limitations on surreptitious around electronic surveillance and penetration, surreptitious entry or burglary, the use of our campus of mail coverage and sources of information on the campuses, and the military undercover agents for the purpose of gathering information upon the objectives of that. That is correct, Mr. Chairman. Now, when did Mr. Euston leave the White House? I don't recall specifically the date. It seems to me he was on my staff six to eight months at the most, as I recall. He had been talking about leaving for some time and returning to private practice. This had been one of his pet projects.

He had apparently gotten into a serious dispute with Mr. Hoover over it, and he felt that his effectiveness at getting this accomplished had been diminished as a result of the fact that his plan was not being implemented and was floundering. I can recall him coming to me and asking me if I could do anything, I told him I couldn't. Now, do you not know that this plan was put into effect, was rather approved for use by the President without the prior knowledge of Mr. Mitchell? I don't know that for a fact, no, sir. When I talked to Mr. Mitchell about it, it had reached the stage that they wanted to do something. Mr. Mitchell and I talked about it, and we decided that the best thing to do was to create the IEC, and that would possibly satisfy everybody's request to do something. Now, the IEC, in effect, was a proposal to set up a group representing representatives

from the FBI, CIA, NSA, DIA, and the counter of intelligence units of the Army, the Navy, and their force to fund some information about the activities of all of these agencies to the White House. I believe that's correct, but I believe at that time also that the military, I'm not sure they were involved because they had already made a decision that they were not going to do any domestic intelligence work. Now, as lawyer, you are well, the fact that the section of 403D3 of Title 50, the United States Code, provides that the CIA, quote, shall have no police, subpoena, law enforcement powers of internal security functions. Domestically.

Yes, that's internal security functions. Yes. And I was generally aware that I wasn't specifically aware of these things. And yet, despite the fact that the statute for bad, bad, the CIA have exercised in internal security functions, here was a consolidation, in a sense, of activities or risk of coordination of activities of the CIA in the domestic intelligence field, wasn't it? Well, Mr. Chairman, I believe what the CIA did in this instance was to share their own intelligence from a foreign nature that would have a domestic implication, and they were apart because of their expertise and analysis and evaluation of an intelligence to not withstand the fact that the statute gave a no-oil internal security functions. They were called upon to evaluate domestic intelligence skills at the amount of agencies. That is correct.

I'm not familiar specifically with how the evaluation group operated at all as to the mechanics of that, but they were a part of the group, yes, sir. Do you know of the lawyer, do you know of any statute which gives the White House the power to set up an agency units of this kind? I don't know of any statute, no, sir. Now, the member from Mr. Holloman, who has dated the fourth day, 14th of July, and states that the President has approved the recommendation made by Mr. Houston, that's not correct. The President made a statement on March 20th, I believe, to the fact that he descended this approval after five days, you recall that? I was late July when I came on, and I don't recall whether it was rescinded or not, too.

Now, on yesterday, Senator Wycker interrogated you about one of the documents that you turned over to Judge Sereka and Judge Sereka turned over to this committee, one dated September 18th, 1970, in which consisted of a memorandum from you to the Attorney General, in which you recommended the setting up of this interagency evaluation unit. That is correct. And I might add that when Mr. Mitchel and I talked about that, we decided that with this on with Mr. Holloman and others being aware of this, that we thought this might satisfy the needs and the requests at the time to do something.

I also recall that the liaison between the FBI and other intelligence agencies had really broken down. I believe Mr. Hoover had withdrawn all of his liaison relationships with everyone except the White House. And Mr. Mitchel hoped that this might be a vehicle to start getting the FBI dealing with the agencies because they're up, of course, are quite proper and natural reasons to have liaison amongst the intelligence community. Anyway, is it not true that, first, do you know of any written document which it, which tends to show that the President disapproved of all rescinded these plans, which Mr. Holloman said he had approved on the 14th of July? I have never seen such a document. Now, after Mr. Houston left the White House, you had some responsibility in his field, didn't you?

That is correct. Well, did you ever receive any instruction from anybody to the effect that the President had rescinded of these plans of recommended by Mr. Houston? No to the contrary, as this document indicates in September 18th, I was asked to see what I could do to get the first step started on the document. And this was a reflective of that effort. Now, all of these papers were marked, uh, up, uh, Russia, all of them were marked up for secret, weren't they? That is correct. And, um, I don't know whether you're familiar with executive order number 11,652 dated March 8th, 1972, which was published in 37 Federal Registered Page 5209, and Section 1 of that shows that the only thing that can be classified on the basis of national security is information or material which requires protection against unauthorized disclosure in the interests of national defense or foreign relations of the United States.

I'm aware of that. That was a result of the, uh, the extreme overclassification of documents in the government, uh, if somebody, uh, wanted to get somebody's attention, I think often they put top secret on a memorandum and send it forward, uh, uh, under that procedure with a big red stamp on it or something marked on it. Now, these, just for the sake of the record, the statute contains certain information, a certain, uh, the United States code title 18 in Section 793, 794, 795, 796, 797, clearly revealed of what defense information is. And the only statute I can find on the subject of classified information, generally, is that it embodied in 18 United States code 798, and there's nothing in any of these statutes that gives anybody any authority to classify information and relates to the domestic intelligence

on internal security. I believe there are some statutes back in Title 50 with regard to the Atomic Energy Act that also applied to this, but I, uh, I'm just recalling that off the top. The Atomic Energy Act is designed to govern secrecy of secrecy relating to atomic energy. That's correct, but I say that they have no relation to demonstrations on persons who are attempt to petition government for a redress of grievances in compliance with the First Amendment. That is correct, Mr. Chairman. Now, isn't it true to say that among some of the officials in the, uh, committed to reelect the president, and, uh, the White House, there was a great climb to the fair at, uh, during 1970 and 1971 and 1972? I, I would say there's a great concern about demonstrators. I think demonstrators were viewed as a political problem, uh, and I, you use the word fear.

Uh, I don't know. That connotes to me physical concern about them, uh, is one who has walked with many demonstrators to go out and get the pulse of the crowd. There, there certainly, uh, are not a fearsome group. There were some militants who were bent on, you know, destroying office buildings and, and, uh, breaking windows and things of that nature, the, the looters and the, you know, trashers and the groups like that. But I wouldn't say that, I'd say it was a concern as I, uh, well, the two common fails as physical fail and intellectual fail. Don't you think it was an intellectual fail prevalent at that time in the, among some, uh, people in the committee and some people in the White House about Americans who undertook to, uh, exercise that First Amendment right to petition for redress agreements? Uh, I think that's correct when you put it in the political context, uh, well, all of this was unpolitical.

Yes, it was. Now, not only, uh, wasn't there a feeling there among some White House officials, such as Mr. Colson, and perhaps among, uh, some in the committee to elect the president, that every person who was not back in their efforts to re-elect the president, all who descended from, uh, the programs of the president was an enemy? I think that, uh, many people who were most vocal and could command some audience in their, in their dissent were considered, uh, opponents or enemies, yes. And that applied that, uh, law, uh, great list of people, including some of the most, uh, distinguished, uh, uh, commentators of the, of the news media on the National Seaman. Yes, sir. And not only that, just a, a, a, a, a, a, a position was, the document was put in evidence and identified to you as I recall, it's coming from Mr. Colson's office, entitled opponent

prior to activity. And on pace three of that document has got this, among other opponent prior to activity, number 14, Samuel M. Lambert, L-A-M-B-E-R-T, president, national, education association, has taken us on, in this notation, has taken us on V-R-V, federally, to broke the schools, a 72 issue, didn't, uh, this, uh, didn't know, in the White House interested in, uh, President Nixon's real election committee and then the, rather, the real election and then the real election committee classified among the analysts, people who descended from, uh, President Nixon's programs. As I say, those who were able to command an audience, uh, were slightly, uh, now, here's a man who's, uh, listed among the opponents of the analysts, who's only offensive is that he believed in the First Amendment and shared Thomas Jefferson's conviction as expressed

in the Virginia statute for alleged freedom, that to compel a man to make contributions of money for the dissemination of religious opinions he disbelieves is simple and tyrannical, isn't that true? I cannot disagree with the chairman at all. So we have the help, just, uh, plans to, uh, violate the Fourth Amendment, which will prove by the President, Carter, Mr. Hallerman, we have, uh, people being branded the enemies whose male offense is that they believed in enforcing the First Amendment as proclaimed by the Supreme Court of the United States just about a week ago. That is correct. Yes. Now, I was very much intrigued by Mr. Buzz Hart's, uh, document, and I'd like to invite your attention to page eight of the statement he makes on there.

Mr. Chairman, he does not have the Bazaar document, so close I can read this very short statement. In February, however, with the Urban Committee beginning its work, the President was concerned that all of the available facts be made known and also a statement on page 10 to the effect. During this period, the point was frequently raised by various people, including Prime Maryland, the President, that the whole thick story of the Watergate should be made public. You know any action the President took on the subsequent to, uh, the status of this committee and prior to the time his committee started to function and we showed his concern at all the available facts that they respect to the Watergate being made known.

Mr. Chairman, I must testify to the contrary that I think some of the documents that, uh, I have submitted regarding Mr. Hall of Mons specific instructions to me on dealing with, uh, what was called the Watergate Tactics and then the subsequent La Costa meeting which occurred on June 11th and 12th, the subsequent meetings, uh, where there were efforts to woo members this committee, uh, the discussions of executive privilege to prevent the testimony of people from the White House, uh, could well be concluded to evidence quite the contrary intention. Now, um, you've testified about a September 15 meeting with the President and was what, when was that meeting held with respect to the time that the Abilson indictment were

handed down in the, uh, original, uh, criminal action? As I recall, the meeting it was in the late afternoon, I believe the President was just about to leave to go somewhere and in fact, the, uh, the helicopter might have even landed during the very end of the meeting. I don't know where at this point in time he was going. Uh, I remember we continued to chat on, uh, we'd gotten into a subject that the book I was reading at that time, uh, which was inside Australia and we were discussing Australians, uh, well, while we were waiting, uh, the indictments had been handed down, uh, or announced far earlier in the day and have been running on the wires all day. Now, um, isn't it true that a short time after the, uh, the five burglar that, uh, isn't it true that a short time after the break-in, the news media carried the information to the effect that five burglar had been called in the Democratic National Headquarters in

the Watergate and the four of the burglar had money in their pockets, which came from the committee to re-elect the President. I don't believe that was reported immediately, but shortly thereafter it was, yes. And, um, notwithstanding in that fact, was it not revealed shortly thereafter that this money had been paid to Mr. Liddy, by, by Mr. Sloan, at the instigation of Mr. Magruder and with the consent of Mr. Stans and Mr. Russ, Mr. Mitchell. I believe that is correct. And, uh, notwithstanding the fact, rather, you do not agree with me that this was, was, actually, this, these facts indicated that to a footsteps which went from the Watergate right into the office, rather, right into the committee to re-elect the President. Uh, there's no doubt about that. And yet, uh, nobody in the committee except Mr. Liddy and Mr. Hunt were indicted.

That is correct. And, um, had, had, had not been, uh, Mr. Magruder had resorted to your knowledge in his testimony for the, for the grand jury to purge it, to keep the, the, um, the grand jury for implicating him and others. That is correct. And so this meeting in which the President said that, uh, Bob Holman had told you that, uh, I, I told him, rather, about your activities, was held in the office of the President right after it had been announced that, um, that, uh, the indictments had stopped with Mr. Liddy and Mr. Hunt and Mr. McCormick. That is correct. And, there had been discussion within the White House of this very strategy of stopping them at, uh, or stopping the case at Mr. Liddy. And there was an awareness of the fact that Mr. Magruder was going to have to purge

himself to have that accomplished. Do you know any action that the President took at any time between, uh, the 17th day of June until the establishment of this committee? And until the February that's mentioned here by Mr. Buzzard, to have the facts concerning this matter discovered? I do know that, uh, after the election there was discussion with Mr. Holman in his office in which, uh, Mr. Holman said that the President would like to, uh, lay out some of the facts and we discussed what the implications of those facts would be. And when I said that I felt that I, well, I didn't know everything that had happened in advance, uh, I didn't know what had happened since June 17th. And I thought that as a result of those activities that, uh, Holman, Erlichman, and Dean, and, I might have mentioned somebody at that time also could be indicted, uh, Mr. Holman's response, uh, which I can remember very clearly because of the stuck in my mind.

He says that doesn't seem like a very viable option, does it? Now, well, the truth is that during this period of time that the FBI was giving you, that is Mr. Gray, was permitting you to receive some FBI reports. What, uh, what occurred is, I recall there were, uh, two deliveries, uh, where I returned the first group of, uh, files that I'd received, uh, back in his out-of-shake case to him and then picked up another bunch of documents, uh, subsequently and then, then returned those later. And it's only been through press accounts that I learned that I received some 82, uh, of 160, uh, total documents. Now, uh, at whose estates did you contact the CIA, that is, General Walters?

Uh, after discussing this with Mr. Erlichman, he thought that I should, uh, explore the possible use of the CIA, uh, with regard to assisting in, in supporting and, uh, dealing with the individuals who had been involved in the incident. So, the CIA was, uh, an effort made to involve the CIA. Also, the FBI, Mr. Gray, destroyed some documents which came from Mr. Hunt. So, all safe, didn't it? That is correct. And also, there was suggested by those in charge of things, uh, this, this, this, who, uh, concerned about these so-called animus, that the processes, the internal revenue service should be perverted and prostituted in order to harass people who, uh, animus has spewed about the, the White House and the committee to re-elect the President.

That is correct. I, uh, I might add also, in addition to, uh, the harassment through, uh, tax audits. There were a number of memoranda I received from Mr. Colson regarding the tax, uh, exemption status of groups that did have tax exemptions that were opposed to presidential policy. Uh, now, my files would contain those. I don't have them in my possession. Uh, a review of my files would indicate that, uh, uh, 99 out of 100 times and one of these would come down. It would go right in the file and go no further. Now, uh, returning to Mr. Buzzard's assertion that the President was desires to begin in in September to have all of the facts revealed after the establishment of this committee, will

you tell us again of what the meetings were had in the White House in respect to this committee? And who was President? With, with dealing with this committee? Yes. Uh, uh, with, with respect to the President or the leading up to that as well. Well, I, I, particularly interested in the President since, uh, Mr. Buzzard says he was anxious that all facts be revealed. Oh, it was when the President was in San Clemente and, uh, uh, this is, I arrived on the, left on the ninth. It's out there. The 10th and the 11th for meetings. I recall it, uh, February of this year. I recall, Mr. Halleman, uh, departed the meeting once or twice and, uh, he finally told the President what we were meeting on, uh, while we were out there. Uh, we left there and went to, uh, down to La Costa where the meetings proceeded. And there we had, uh, the remainder of the two days of discussions about how to

deal with this committee, uh, during the course of the, the meetings at one point in time. As I, as I have mentioned earlier, there was an assessment made, uh, by Mr. Ehrlichman, there had been disappointment that they had not been able to influence the selection of the committee. There had been disappointment that they hadn't been able to amend successfully your resolution, uh, to put a bipartisan, you know, have equal representation between Republicans and Democrats that the floor amendments that have been offered, uh, have been defeated. Uh, they, uh, some of these are evidenced in the memorandum from Mr. Halleman that's in the Exhibit I submitted. Uh, it was, make the testimony about that short. Was that one of the, one of the times you said that there was, there was consensus was there should be an effort to show, to claim open cooperation with the committee, but the effort to impede it from discovering the truth. Well, I would, I would call the, uh, I would call the,

uh, chairman's attention to the Exhibit regarding the meeting with the Attorney General, where there was great concern that this committee might, uh, uncover additional, uh, criminal activity. There was also a very strange relationship at that point in time between the Attorney General and Mr. Halleman and Mr. Erlichman. Uh, I was asked to prepare an agenda for the president to woo the president or have the president woo the Attorney General back into the family. Uh, the president was aware of the problem and this is, uh, also spelled out somewhat in the agenda that was submitted to him. I believe on February 22nd. Now, uh, returning to the President's desire for about the truth, you spoke of some meeting that the President attended in which, uh, after press conference in which he wanted, if the committee was going to swallow the bait he'd put out in the press conference about a court, uh, that was on St. Patrick's Day. That was, um, St. Patrick's Day, the 17th of the, I believe. Now, before that, the President had a press conference in the not on March

12th, 1973, which was, uh, approximately a month after Mr. Burzard said in his statement that the President was anxious that the facts be revealed and last year, this press conference he didn't save. And I quote from presidential documents, a, a member, a former member of the President's personal staff, normally should, shall follow the well-established precedent and decline a request for a formal appearance before a committee of the Congress. Are you familiar with that press conference? I recall hearing that at the press conference, yes. At the same time, it will continue to be my policy to provide all necessary and relevant information through informal contacts between my press and staff and committees of the Congress in ways which preserve intact the constitutional separation of the branches. I believe that was the thing that provoked my statement that I wasn't going to let anybody come down

to see me, who traveled by night like Nicodemus and whispered my air something, and he wasn't willing for all of the American people to hear. Now the press conference on March 15, 1973, this question was asked, Mr. President, does you offer to cooperate with the Irvin Committee include the possibility that you would allow your age to testify before his committee? And if it does not, would you be willing to comply with the court order if Irvin went to court to get one that required some testimony from White House Aids, the President? In answer to your first part of the question, the

statement that you made yesterday answered that completely, not yesterday, 12th, I think it was, my statement on executive privilege, members of the White House staff will not appear before Committee of Congress in any formal session. And this, given us, we will finish the information under the proper circumstances. We will consider each amount on a case-by-case basis. With regard to the second point, that is not before us. Let us say how, with that, if a Senate feels at this time, that this amount of separation of powers, whereas I said this administration has been more forthcoming than any, the Democratic administration I know of, if the Senate feels that they want a test case, we would welcome it. Perhaps this is the time to have the highest court of this land make a definitive decision with regard to this matter. I am not suggesting that

we ask for it, but I would suggest that if the members of the Senate and their wisdom decide that they want to test this amount of the court, the courts say we will, of course, present outside of the case. And we think that the Supreme Court will uphold, as it always usually has, the great constitutes the principle of separation of powers rather than uphold the Senate. Now, was that debate that the President mentioned in the meeting on St. Patrick's Day? That is correct. And the President stated that he discussed, again, on St. Patrick's Day, that it was not women for in his age, past, or present, to appear before the Committee and give testimony in person. Well, we had discussed that before he made that statement, Mr. Chairman, that he certainly didn't want Mr. Hall or Mr. Ehrlichman coming up here before the Committee. No, did he want me appearing before this Committee? And this was on the 15th and the 17th day of March, about a month after Mr. Buzzard says that the President was anxious for all the facts to be revealed. Do you know how facts can

be revealed except by people who know something about those facts? No, sir, I do not. I think that the theory that was developing was that take the very hard line initially, and back down to written in erogatories, but that would be the bottom line, I believe, that was as far as the President was willing to go, because he felt that written statements could be handled, and quite obviously it's much easier to prepare a written brief of a situation than it is to submit yourself to cross-examination. And a written statement can be written to conceal as well as to reveal the facts, can't it? Absolutely, correct. And I believe the discussion at that time, the session I made that I wasn't written except written statements, because you can't cross-examine a written statement.

Yes, and I did, I had a discussion with the President about that very statement. Just one other matter, article two of the Constitution says in defining the powers of the President, section three of article two, he, that is the President, shall take care that the laws be faithful executed. Do you know anything that the President did or said at any time between June the 17th and the President's moment to perform his duty to see that the laws of faithful executed in respect to what is called the Watergate of Hell? Mr. Chairman, I've given the facts as I know them, and I would rather be excused from drawing

my own conclusion on that at this point in time. Now, you've been asked several questions about the credibility of, by Joe Kretabelsi. I'll ask you as a lawyer if the experience of the English-speaking race, both in its legislative bodies and in its courts, has not demonstrated that the only reliable way in which the credibility of a witness can be tested, is for that witness to be interrogated upon the oath, and have his credibility determined not only by what he says, but by his conduct and demeanor, by his saying it, and also by whether his testimony is corroborated or not corroborated by other witnesses, is there any way what so ever to test the credibility

of any body that when the credibility has to be judged merely upon the basis of written statement? No, sir. Thank you very much. The committee will stand and then recess to two o'clock. Senator Irvin is backtracked to the summer of 1970 and gone well beyond the Watergate break-in and the scope of his questions, and while the Senators take a lunch and break, we're also going to take a break. And public television's coverage of the Watergate hearings will continue after this pause for station identification. On a bridged coverage of these hearings is provided as a public service by the member stations of PBS, the Public Broadcasting Service. Hello, everyone.

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. . to appear and, of course, against whatever other information the committee can gather from circumstantial evidence, from whatever source. It occurs to me that at this point, the central question and in no way in derogation of the importance of the great volume of material and the implications that blow from it. But the central question at this point is simply put, what did the president know and when did he know it? In trying to structure your testimony, I would ask that you give attention to three categories of information, that information that you can impart to the committee that you know of your own personal knowledge, that type of information that we lawyers refer to as

circumstantial evidence, which would include evidence given based on your opinion or on inferences you draw from circumstances and the situation. And third, that type of evidence that ordinarily would not be admitted in the court of law, but is admitted here for whatever purpose it may serve, that is hearsay evidence or evidence about which you have only second hand information. I would hope that in that third category, that is in terms of hearsay evidence or second hand information, that we would try, you and I, to limit the scope of that to situations which may be further ventilated by the testimony of other witnesses on the roster of witnesses to appear before this committee, because if we range too far, there is no way that we can compare and assess and evaluate the importance of that testimony.

But I want it. And I'd like to divide the information then as we go along into three parts, that is direct evidence, circumstantial evidence, and hearsay or second hand information. And in no way criticizing your testimony, I think you've really been a very remarkable witness. But I would all ask Chairman, I might say this, in preparing my testimony, I made a very conscious effort to not write a brief against any man, but merely to state facts sequentially as close as I could by sequentially, I mean some things, it was necessary to follow forward to explain a given sequence of events that bring them out of a time sequence. But I did not, by design, try to write a brief or a document that focused in on any individual or any set of circumstances surrounding any individual, rather lay them out in the

totality of their context. I understand that, Mr. Dane, and I really do hope you understand that what I'm saying to you is not a criticism of you, nor any implication of criticism. Rather, instead, you have presented us with a sequential presentation, and I'm trying to convert it into an organized presentation according to categories and to the quality and scope of the information that you possess. So please believe me, I'm not trying to attack your testimony, but rather to organize it for our own committee purposes. Now, there's one other thing I'd like to say, and it may or may not be possible to do this. And again, I'm not being critical of you as a witness, as I said just a moment ago, I think you've been a very remarkable witness. But when I used to practice law, I used to call on the trial judge from time to time to instruct the witness to first answer the question and then to explain it. So I hope I can keep my questions brief, and I hope you might preface your answers with the yes or no, if that's possible, and then whatever explanation you wish.

That is not meant to be an entrapment. It is not, do you still beat your life question and answer yes or no? But it is meant to try to advance the cause of fact finding. After the hitting of what did the President know, and when did he know it, fall several subdivisions. The first one is the break-in at the Democratic National Committee Headquarters of the Water Gate complex on the morning of June 17, 1972. Do you know what the President knew of that in advance? I do not. Do you have any information that he did know of it? I only know that I learned on my return to the office that events had occurred, that indicated that calls had come from Kivas Gaines to Washington, to Mr. Strong, to destroy

incriminating documents in the possession of Mr. Hallerman. The question is I hope not impossibly narrow, but your testimony touches many people. It touches Mr. Erlichman, Mr. Hallerman, Mr. Colson, Mr. Mitchell, Mr. Dean, and many others. But I am trying to focus on the President. What did the President know and when did he know it? Is it possible for you to say that based on direct knowledge or circumstantial information and you've given us an indication of circumstances, or even hearsay? Can you tell us whether or not you can shed any further light on whether the President knew or in the parlance of tort law should have known of the break-in of the Water Gate complex on June 17? Do you mean did he have prior knowledge of it? Yes.

I cannot testify of any first-hand knowledge of that. I can only testify as to the fact that anything that came to Mr. Hallerman's attention of any importance was generally passed to the President by Mr. Hallerman, and if Mr. Hallerman had advanced knowledge or had received advanced indications, it would be my assumption that that had been passed along, but I do not know that for a fact. So that would fall in category two of my organization. That is an inference that you do draw from the arrangements of the organization of the White House and your knowledge of the relationship between Mr. Hallerman and the President. That is correct, but it does not fall into category one or three, which is to say direct knowledge or hearsay information from another part.

That is correct. The cover-up is the second heading. And of course the cover-up embraces and involves so many things and so many people over such a span of time that it's difficult really to place it in a single category, but I'd like to try. What did the President know and when did he know it about the cover-up? Now, you've already testified about this, Mr. Dean, and I understand I believe the burden of your testimony, the thrust of your testimony, but for the sake of clarity and understanding and organization of this record, tell me briefly, based on your personal knowledge based on circumstantial evidence or based even on hearsay, what the President knew and when he first knew it. I would have to start back from personal knowledge, and that would be when I had a meeting on

September 15th when we discussed what was very clear to me in terms of cover-up. We discussed in terms of delaying lawsuits, compliments to me on my efforts to that point, discussed timing and trials because didn't want them to occur before the election. That was direct conversation that I testified to. Going back from September 15th, back to the June 17th time, I believe I have testified to countless occasions in which I have reported information to Mr. Holman and Mr. Erlichman, made recommendations to them regarding Mr. McGruder. I was aware of the fact that often Mr. Holman took notes, I know that Mr. Holman met

daily with the President. I was quite aware of the fact that this was one of the most important and virtually the only issue that was really developing at all and given the normal reporting channels I worked through. It was my assumption without questioning that this was going into the President. Now, at what point in time this was Mr. Holman, discuss this with the President, I have no idea. If I understand you correctly, you say that based on inference, drawn from your knowledge of the White House organization and relationships, you surmise that the President knew of the situation from June 17th until September 15th, and some degree, but the jail of personal knowledge.

I'm sure of this that there were press releases put out within a short time after the incident. There must have been discussion in Florida, while there were still in Florida, about how to handle this. Some of the early press releases, as I recall, indicated immediately before I had even talked anybody had done anything, that this was something that didn't involve the White House in any way. But once again, simply searching for an organizational format, these conclusions are inferences on your part of based on your knowledge of the White House organization and not on direct information. I've spent in almost three years at the White House, and that's- Which is an important circumstance, and I'm not trying to discredit that. I'm simply trying to isolate and define the quality of the testimony. And I don't mean to say the quality means the quality of its desirability, but the quality of it in the technical sense.

Was it direct information, circumstantial information, was an inference or conclusion based on a valid set of circumstances, i.e., your situation at the White House, or is it your plain guess? So you've been very helpful in that respect. Let me try to restate it then. From the very first moments after the break-in on June 17th, 1972, and based on a number of factors, including the fact that press releases issued from- I believe you said Keyba Skin, that's correct. Based on your knowledge and understanding of the White House organization and the relationship between Mr. Holderman and the President, you draw an inference that the President used something between June 17th and September 15th. Well, I also am aware of the fact that there were a flurry of telephone calls between Mr. Erlichman and Mr. Holderman, as some of the things I was telling Mr. Erlichman in Washington after I did come back on the 19th, and he was calling Mr. Holderman in Florida

who was still in Florida at that time. In any of this, and I'm not trying to construct an edifice that will end up defending the President, I have stated before, it is not my purpose to defend or to prosecute the President or any witness, but only for the purpose of establishing the quality and the scope of the testimony. In any event, your personal feelings, that the President used something between June 17th and September 15th is based on Category 2, that is circumstantial evidence and inference is based on your knowledge of the relationships in the organization. Given the events that had occurred over the weekend, while I was not there, and the events that occurred on Monday, and before I met with the Attorney General on either late Monday or Tuesday, whenever I had my first meeting with him, I was deeply concerned initially that this went right to the President or certainly to other persons above myself and the White

House. I understand your concern, and I think it was an understandable concern. But what I'm struggling to establish is whether that concern was based on something other than what you just testified to. I testified if I had not talked to the President about it at this point in time and did not talk to him until September 15th, so all of the knowledge I have between June 17th or June 19th, actually, when I came back, and September 15th was through the fact of the things I was reporting to Mr. Hallamann, Mr. Erlichman, my awareness of the fact that they were meeting with the President, the fact that Mr. Hallamann often took notes. That's the basis of my knowledge at that point in time. Did anything occur that we would put in Category 3, that is, hearsay information or documentary evidence, not firsthand, that would shed any further light on the state of the President's

knowledge during the period June 17th to September 15th, 1972? Yes, I have submitted a document to the Committee in which the President was very anxious to have counter-actions against the suits that were becoming a problem, the lawsuits filed by the Democrats. There was a very active investigation being pursued through discovery procedures. These were the only headlines that were being made because as the investigation by the Department of Justice and the FBI was winding down, this was the new phase. This prompted me to receive direct requests, presidential requests through Mr. Hallamann and Mr. Colson, which resulted in a memorandum I sent back into the President ultimately went to the President and was told to follow-up on that memorandum and that it's one of the exhibits that's been submitted to the Committee.

You recall, Othand, or can your Council help you tell us what that exhibit number or exhibits might be in it right quickly for you here? Now, please. That is exhibit number 17. You have that exhibit before you, Mr. Ness, I do. The first part of the exhibit is a preliminary memorandum that was prepared by Mr. Parkinson.

At my request, I asked him to send it when I had the request made of me following conversations I had with Mr. Parkinson. I modified his memorandum and sent the memorandum of September 12 into the President. Mr. Hallamann, you'll note a P up in the right-hand corner, which was checked, which indicates as my understanding of the White House procedures that was either sent directly to the President or you directly by Mr. Hallamann with the President, that they went over it. Make sure we have the same exhibit before us. I have exhibit number 17, the first page of which is entitled Counter-Actions, dated September 11, 1972. That's correct, and you'll have to go to the back part of that, consisting of four pages signed by Kenneth Welle, Wells Parkinson, and then a letter on White House Stationary dated September 12, 1972, the first line of which reads, administratively confidential, or Hallamann from Dean, consisting of four pages, are we reading from the same script?

That is correct. All right, now this is additional information on bearing on the President's knowledge of the cover-up from September 17th, I'm sorry, from June 17th to September 15th, 1972. That is correct. All right, sir. It consists of some eight or ten pages, we can read it if you like. It would be much easier, I believe, if you'd point out those sections which are relevant to the State of the Presidents' knowledge. Well, as a result of this memorandum going in to the President, I received instructions back that all of the actions in here were something that should be followed up on. And that was done. So you're referring now to the second half of the exhibit, which is the White House memorandum. That is correct. And the allegations made fall under the headings in the memo of complaint from malicious abuse of process.

What is there? This is one of several counter-actions. This was an action to be filed by the committee for the re-election of the President and the Finance Committee against Mr. O'Brien, alleging that they were violating the rights and privileges of discovery and civil suits for an ulterior purpose. That their basic action was unfounded in its... Was that suit ever filed, Mr. Daniel? Yes, it was. What was the disposition? It is still an litigation. And the second heading, certainly, I don't mean part of that at all, is a part of that. You'll note, there's a note on page two, depositions are presently being taken of members of the DNC by defense counsel in the O'Brien suit. These are wide-ranging, we'll cover everything from Larry O'Brien's sources of income while chairman of the DNC, to certain sexual activities of employees of the DNC. They should cause considerable problems for those being deposed.

Now, I would like to add something that shortly... Did you file that suit? No, sir. I did not file that suit. Who did? The re-election committee. Were those allegations made? No, they were not. That was a part of the deposition... Of the discovery. Discovery area. Were those areas covered in discovery after the filing of the suit? I have no knowledge of whether they were not... I'm sorry, Goyots. This has recalled to me something that... I earlier indicated there had been a longstanding interest in Mr. O'Brien. Some of the documents that I've submitted in documents, six, seven or eight, I don't recall which one off the top deal directly with Mr. O'Brien. I recall the line that has drawn beside that note is Mr. Holamann's marking on the... Page two of the second half of the issue.

That is correct. Sometime before this, he had told me that in a discussion, rather casual discussion, when we were talking about who was likely to be Mr. McGovern, Senator McGovern's campaign manager, and there was speculation that was going to be Mr. O'Brien. I recall Mr. Holamann telling me that he certainly hoped it would be, because we've got some really good information on him. And I believe he was referring to tax information at that time. Referring to what, sir? Tax information. I see. And this was Mr. Holamann who said that? That is correct. Do you remember when he said that? It was sometime after Mr. O'Brien or Mr. McGovern had been nominated, and before he had made his final selection for his campaign manager. Which would have been then probably in the early fall of 1972. I recall it was September before Mr. O'Brien was designated as campaign manager. That's not important.

That's not exact. That's correct. All right. Now, let's see. Before I get to the second heading, on page one of the second part of the exhibit, did I understand you to say that the penciled or penned capital P, apparently, with a checkmark through it, is a White House designation that the document was seen or known of, but the president? That is correct. Do you know this of your own knowledge? Yes, I do. Now, the second half of that memorandum is entitled complaint for libel, stands versus O'Brien. What did that mean? Well, that was an action being filed, a counteroffensive, again, as part of this. The counteractions are being requested as a result of the occurrence that before an amended complaint had been filed with a district court that the amended complaint, which charged that Mr. Stands had funded the Watergate incident with the $114,000 checks from Mr. Barker, was alleged in the complaint of the amended complaint.

The amended complaint was distributed to the press before it was filed, so it had no privilege, and I don't know if it was ultimately filed or not, but based on that, the re-election committee lawyers thought they had a very good libel action for using the processes in that matter. Was that suit, in fact, filed? Yes, it was. Do you know who filed it? The re-election committee lawyers filed it on Mr. Stands's behalf. Do you know what the present status of that litigation is? All of these cases have been consolidated in, I believe, in Judge Richie's Court. Here in the district. Yes, here in the district. I think we take really a great deal more time than we ought to if we try to go through each item, but let me try to refocus now on this exhibit for the purposes of this moment. What, in this exhibit, sheds any further light or implies any further information about the scope and extent of any of the President's knowledge of the cover of Post-June 17,

1972, I understand before you answer that so far you have suggested that the President seeing and approving this memorandum, which deals with the series of civil suits and certain other actions to be taken, implies that there was at least to be a counteraction and a backfire, if you please. But in what respect does this give us further insight into the President's knowledge of a cover-up of the Watergate break-in? Well, I don't, I'm not sure I understand that the Senator's definition of cover-up as I think I've laid out in my testimony that the cover-up was something that had a broad range, anything that might cause any problem at all in relationship to the Watergate came within the cover-up. I understand. That's not really a very good way to put it. Let me narrow it even further.

What in this document gives us any further insider information about the President's knowledge of any Post-June 17, 1972, about the apparent efforts to conceal the connection worth and responsibility for the unlawful entry into the Democratic National Headquarters at the Watergate Complex on the morning of June 17, 1972? Well, I can only surmise what I was told when asked for for the document. And as I said, I had requested two people for the document in the President's behalf that the best defense is an offense, and this was an offensive effort. All right. Is it fair to say, and I really am not trying to put words in your mouth, but rather to digest this information from my own purposes? Is it fair to say that the documentary evidence that we've been referring to now exhibit 17 indicates some knowledge by the President of an effort to establish countermeasures

in terms of the total impact of Watergate. The counter suits, allegations of the misuse of the discovery process, and other things of that sort. These were not actions that he conceived. He asked that counteractions be taken. The request came to me. I in turn passed it on to the lawyers who were closest to it because some of the suggestions were just, you know, start filing suits. And I advised Mr. Colson that I wouldn't suggest filing any suit that wasn't well-founded, rather than rushing into court with some action just for the sake of having an action that might tie things up. This was particularly true with some of the statements of some of the individuals whose names were being speculated that they file for liable. Now, liable results in both counter-suits and counter-discovery.

Some of these people obviously could not withstand discovery. So that was why the suits, I thought, had to be well-founded and had to be suits that counter-discovery would not be a problem. All right, so if I understand what you're saying now, while these documents do not bear on the isolated issue of the President's knowledge of the Watergate and what I call the cover-up of the Watergate, post-June 17, they do shed some light on at least the willingness to commence counter-actions to avoid further prying into the situation at the White House. Is that a fair statement? Yes, it is, Senator. What other documentary evidence gives us any insider information about the state of the President's knowledge of Watergate and the date on which he acquired it? We're talking about now pre-September 15th. We're still working our way up from June 17th to September 15th. That's the only documentary evidence I have that, to my knowledge, is that document right there?

As I say, there were not a lot of documents floating around on this subject. There were a lot. Well, always some, but not... Okay. Is there any other circumstantial evidence? You've alluded to the organization and the relationships at the White House. Is there any other circumstance that would give us further insight? Or is there any category three information? Is there anything anyone's told you that would shed further light on what the President knew? And when he knew it in this time frame from June 17th to September 15th? Yes, as I say, on a number of occasions when I was in meetings with Mr. Holman or Mr. Erlequin, sometimes together I can recall that the President would call for Mr. Holman and Mr. Holman would send a message back to tell the President that he was meeting with Dean, getting a report, and he would see him after that. This was always rather struggling to me that my report was more important than Mr. Holman

going right into the President's office. So the unusual nature of that arrangement and circumstance led you to believe that there was some knowledge of the subject matters attendant to the Watergate Affair by the President? That, and another circumstance that I might add is that this... the cover-up consumed a great amount of time of Mr. Holman and Mr. Erlequin. They were spending a great deal of time in discussion with me, with discussions amongst themselves. And this was probably the major thing that was occurring at this point in time. Is there anything else now because I want to move on to the September 15 meeting, but is there anything else in either of the three categories of testimony of evidence? Direct evidence, circumstantial evidence, inferences, and hearsay.

Is there anything else that you can think of at the moment? And if you think of something later, we'll certainly add it. But is there anything you think of at the moment that would give us further insight into what the President knew and when he knew it in this time frame, September until September 15? I think I expressed... I like to... I think we're getting better at this. We understand each other now. And how I'm trying to organize and structure it. Let's take the seventh, the September 15 meeting. And let's analyze it rather very closely, if you will, Mr. Dane. And I understand this is necessarily redundant. And that has been covered at rather great length. But would you bear with me long enough to describe in as much detail as you can conjure up the meeting of September 15 for the President? I'm sorry, Senator. I was reading some notes here and I didn't... Did you want me to repeat to you the September 15 meeting? What I want to do now...

We've had a general overview of the situation. I'm going to try now to focus entirely on the meeting of September 15. Right. And I have an ambition to focus as sharply as I can on it in order to disclose as much information as possible about the September 15 meeting. And what I want to do is to test, once again, not the credibility of your testimony, but the quality of the evidence. That is, is it direct evidence, hearsay evidence, or is it circumstantial evidence? Related to the September 15 meeting. So take a little time with that if you will. All right. During the morning of the 15th, the indictments had been handed down. I think there was a general sigh of relief at the White House. I had no idea that I was going to be called to the President's office. Mr. Holman was quite aware of the fact that I had spent enough a great deal of time. He had spent a great deal of time. Mr. Erlockman has spent a great deal of time on this matter.

In the late afternoon, I received a call requesting I come to the President's office. Do you know who made the call? The call came to my secretary as I recall, and she said that you have been asked to come to the Oval Office. So I don't know who called. And it was probably one of the secretaries that conveyed those title messages. Go ahead, sir. When I entered the office, I can recall it. You have been in the office, and you know the way there are two chairs on each side of the President's desk. The Oval Office? The Oval Office. As you face, the President, on the left-hand chair, Mr. Holman was sitting, and they had obviously been conversed in a conversation. And the President asked me to come in, and I stood there for a moment. He said, sit down, and I sat on the chair on the other side. You sat on the right-hand chair? It's the one where he usually says no. But go ahead.

I was unaware of that. Go ahead. All right. As I tried to describe in my statement, the reception was very warm, very cordial. There was some preliminary pleasantries, and then the next thing that I recall, the President, very clearly saying to me, is that he had been told by Mr. Holman that he had been kept posted or made aware of my handling of the various aspects of the Watergate case, and the fact that the case, you know, had the indictments have now been handed down. No one in the White House had been indicted. They had stopped it, letty. Stop, stop, stop, just for one second.

Let's examine those particular words just for a second. That no one in the White House had been indicted. Is that as near the exact language as you can say? I don't know. Yes, well, it was a reference to the fact that the indictments had been handed down. It was quite obvious that no one in the White House had been indicted on the indictments handed down. What did he say that, though? Did he say that no one in the White House had been handed down? I can't really recall whether he said that I recall a reference to the fact that the indictments were now down, and that he was aware of that happened in the status of the indictments and expressed what to me was a pleasure to the fact that it had stopped it, Mr. Litty. Tell me what he said. Well, as I say, he told me I had done a good job. Let's talk about the pleasure. He expressed pleasure. No, the pleasure and the pleasure. As much as I've stopped it, Mr. Litty, can you, just for the purposes of our information, tell us what you make that very clear that the pleasure that it has stopped there is an inference of mine based on, as I told Senator Gurney yesterday,

the impression I had as a result of his complementing me. Can you give us any information? Can you give us any further insight into what the President actually said? Yes, I can recall. He told me that he appreciated how difficult it, a job it had been for me. Is that close to the exact language? Yes, that is close to the exact language. That stuck very clearly in my mind because I recall my response to that was that I didn't feel that I could take credit that I thought that others had done much more difficult things. And... you

you you