United States v Daniel Ellsberg and Anthony Russo: Selected Testimony (1973)
United States District Court, Central District of California

DIRECT EXAMINATION by David Nissen:

Q What occurred with regard to the use of your Xerox machine?

A Dan and Tony used the Xerox machine.

Q Did you see them?

A Yes.

Q On how many occasions did they use it?

A I'm not quite sure because I wasn't there all the time.

Q How many occasions were you there when they used it?

A At least four, maybe seven, eight. You know, I'm not clear. . . .

Q And over what period of time did these copying sessions occur?

A Ten days, two weeks.

Q Can you place for US precisely in time when those ten days or two weeks occurred?

A I can't; I thought it was after the 4th of July or I felt it was after the 4th of July, of 1969; but I'm not-I've never been sure, as you know, of exactly the date or the dates.

Q How did the documents arrive at your office? Who brought them?

A Dan.

Q How did he bring them?

A In a briefcase.

Q Will you describe it for us, please.

A It was shaped like that (pointing to an accordian-style file, and like this, like that black one that you-just like that, only it was beige. . . .

Q Did you receive any payment for the use of your Xerox machine?

A Yes.

Q From whom?

A Dan.

Q What was the amount of payment, as you recall it? . . . .

THE COURT: Before you turn to that, what did that payment represent? Was it a cost to you?

THE WITNESS: Yes.

THE COURT: For the paper?

THE WITNESS: Cost, yes, paper, and what­ever overage of copies on-you only get a certain amount on your Xerox, you know, for rental, and if you go over that, they charge you for overage.

THE COURT: It was a charge strictly for cost; no profit?

THE WITNESS: That is right.


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