Verbatim Trial Testimony of

Brian Sacks,

BAR/BRIís California Director,

In Federal District Court, Los Angeles, Calif.



Q    Did you curse at her in front of the young stepson?

Brian Sacks    Yes, I did.

Q    You called her a sleeze, is that correct?

Brian Sacks    Yes, I did.

Q    What were the other words you used?

Brian Sacks    Well, I think, in order to discuss this, I think I should be able to explain the situation a little bit more than just asking what the words were.

MR. JACKSON:  Mr. Sacks, your counsel can explore that with you on redirect.  My question to you is what were the other words that you used?

THE COURT:  Now, wait a minute.  I think everybody ought to know.  I'm not going to allow anybody to state their state of mind, whether it's Ms. -- is it Niemec? -- or Mr. Sacks.

You can state objectively what the incident was to the extent that it affects the issues in this case.


Q    What were the other names that you called her sir?

Brian Sacks    I called her a sleazy, smelly cunt.

Q    Did you call her anything else?

Brian Sacks    I don't believe so.