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This is the last part of the testimony of Joseph Lauricella, regarding a suit against someone accused of stealing computer files. Mr. Lauricella testifies that he was paid by WMX, the giant waste handling firm, and a WMX subsidiary - called Rail-Cycle - to create a fake environmental organization, buy the stolen computer files, and attempt to discredit a company opposed to a huge WMX landfill project in Cadiz, California. The proposed operation would handle the garbage of Los Angeles and would become the world's largest dump. Cadiz Land Company says it would jeopardize a precious ground water resource. (Back to Part 4 for previous testimony.)

Q. You and who?

A. Glen Odell. I set up different accounts under AOL under a difference

name.

So we became different people, answering initiating conversation,

answering and talking to ourselves through the different chat rooms and

different areas so that we can show we were having problems with the

stock or that, you know, like you are scared of buying stock in CLCI.

Or that the institutional investors should be worried about doing

anything with the stock because we had had problems with it, which is

probably what these are here.

MS. KLAR: Let me have the reporter mark as Lauricella F a series of

pages which bear the Bates numbers CLC 56, 55, 54, 53, 51 and 52.

I believe that there was an attempt to put these in chronological order.

(Exhibit F was marked for identification.)

MS. KLAR:

Q. Mr. Lauricella have you had a chance to look at Exhibit F?

A. Exhibit F, what this is, this is an Internet message talking about

Cadiz Land Company Stock, stuff we initiated, Glen and I initiated. I

can't tell whether -- maybe actually a real person, maybe somebody we

actually fished into this whole thing.

It talks about how we put in -- how we put the idea that the farm was in

bad shape and that they weren't working, the workers weren't working,

everything is rotting in the field. Basically he is just buying into it.

Something like this, if you are familiar with the Net, what happens is

you get something like this going out on the Net, it gets progressively

bigger and bigger and that's what we were hoping to do.

Glen's intention was drop the stock, that was the idea, stock to drop

you guys didn't bother with dealing with Waste Management program up

there, too busy trying to keep the company together.

Q. So these are examples --

A. These are examples of -- this is not really spamming, this is more a

conversation on the Net. All this is Glen and I just bullshitted these

people, basically, the whole thing, lied to them then got them talked in

more of it -- talked -- you end up getting little bits of that.

Q. Again this was in connection with Mr. Odell's efforts to manipulate

the price of the stock?

A. Right, yep, sure was. And of course in here also, request of San

Bernardino County, geologists involved which is one of our people,

Norman, who led Mojave Water Agency.

Q. Who is that?

A. Somebody from Mojave Water Agency, the name is familiar but it's one

of the board members. What we've done here, any one know CLCI up twenty

percent in two weeks blah blah blah. Any way talking about F.A.C.E.

environmental coalition, Marvin Shaw -- just more manipulation.

What we were doing is having them contact Wes Greeter who is one of our

people, saying how bad things are in reality. Of course stock is up

twenty percent in the last two weeks, but we're saying it's falling

apart. It's a really interesting thing right there.

Q. This number (909)798-3103, is that a telephone number you are

familiar with?

A. That's a San Bernardino phone number.

Q. It's from Wheeler Gannon, and it says if you'd like, give me a call

at (909)798-3103?

A. Sounds like a commercial number of some sort, like from a business or

something.

Q. Was Wheeler Gannon a name that you used or Mr. Odell used?

A. You know, I don't know. I would have to again check the paper, find

out. I kept a pretty good log of this stuff because I had to keep it all

straight who was who, because we were playing this role I had, wouldn't

make any sense if I all of a sudden became somebody else.

This is not something I would write.

Q. Which is the page you are looking at?

A. Last one CLC 052. This is something I wouldn't use the word

infrastructure underline assets. Isn't something I would have said.

Q. What about the handwriting on that page?

A. That is my handwriting.

Q. Do you know who a Rob Soto is? Let me show you CLC 37.

A. This would probably have been Rob Soto in the computers. One of the

computer disks is a list of all the media people we talked to, Bob is

one of the media people. This is a real fast cover sheet we sent out to

him.

Q. Do you have -- can you tell me for what period of time you were

involved in these conversations on the Net? Did that go on for a period

of a couple weeks or couple months?

A. We did stuff on the Net for almost a year.

MS. KLAR: Let me have the reporter mark as Exhibit G a one-page

document, it bears the Bates numbers CLC 0058.

(Exhibit G was marked for identification.)

MS. KLAR: Mr. Lauricella, can you take a moment to look at what's been

marked as Exhibit G and tell me if that's a page that you've seen before

today?

A. Yeah, sure is. Actually what this is, it's a note from Stu Clark to

Glen Odell letting him know I got to do something else with my mileage

because it's showing up too many.

They are paying me for mileage and showing up too many hours, many too

many days, doesn't make that much mathematical sense, doing so much

driving, so we needed to get it straightened out.

Q. Did Mr. Odell fax that to you?

A. Right. Odell from Stu.

Q. Did you have a conversation with Mr. Odell?

A. I sure did. November '95, yeah, we had to arrange something else at

that point in time, kind of cut the mileage down or split it up on

vehicles or figure out some way of doing it.

Q. The mileage as you testified yesterday is the mechanism you used to

get funds in order to pay for the activities of F.A.C.E.?

A. Right.

Q. Now why was there a change from F.A.C.E. to, is it the BVEC Group?

A. This is really silly. You want to know why they changed it from BVEC?

Q. Yeah?

A. Okay. Because we've had the environmental group up in Essex,

population twelve and we had the F.A.C.E. environmental group down in

Cadiz, population ten. And neither these little towns have ever

historically been able to get along with each other, even though we

don't have a population total of twenty-two people in all of them.

And the people in Essex were upset because the people in Cadiz had named

the group before they had a chance to name the group since the first

meeting was held in Cadiz and not in Essex. So they made a deal and they

said they didn't like the name F.A.C.E. Environmental, so that's why

they changed it around and renamed it.

Q. Local politics?

A. Local politics.

MS. KLAR: Let me have the reporter mark as Lauricella H, a one-page

document that bears the Bates number CLC 45, which appears to be a

F.A.C.E. press release.

(Exhibit H was marked for identification.)

BY MS. KLAR:

Q. Mr. Lauricella, if you can look at Exhibit H and tell me whether or

not that was one of the press releases which was prepared by Waste, and

you were instructed to send out?

A. Yes. This was directly prepared by Glen Odell. The reason being that

is says F.A.C.E. environmental coalition press release, which is total

for media release, contact her at 0619, says dot dot dot dot.

Glen didn't have her phone number, put down when they sent me the press

release to copy over. That's why you can tell, and this has not been

colloquialized before.

In other words, I haven't changed the it say around for people that are

there. It is very hard to think Rail-Cycle would use the word exhausted.

So we would have changed this around. That's basically a Rail-Cycle

press release, but under --

Q. Under the name of F.A.C.E.?

A. Yeah.

Q. This is a document that was marked in Mr. Marti's deposition as

plaintiffs exhibit two, and the first page is a letter dated May 31,

1995 from Marv Shaw to Larry Rowe.

And it says following our conversation yesterday enclosed is a copy of

the information submitted by F.A.C.E. to the County of San Bernardino

Board of Supervisors at the May 16, '95 public hearing.

Yesterday you looked at the transcript of that May 16 meeting. What I

wanted to know is whether or not these are petitions that were prepared

by Rail-Cycle then disseminated in the community to get local support

for the dump?

A. These are just -- these are the ones we used for the San Bernardino

meeting, but I betcha if you phoned any one of these people -- a few of

the people and asked them if they remember signing this thing, or what

it was about, what the hell they were signing, because all we did was

tell them to sign it and they signed it. This isn't -- and these are

probably good.

Essex never received these. People -- what we did was hand these to

people and told them to sign it.

Q. You think the signatures are all authentic or some of the signatures

are probably forgeries?

A. Hard to tell on these things.

I mean I don't think I would have signed -- my handwriting is bad. Sure

looks like a lot of them are identical, doesn't it. But I couldn't tell

you that for a fact. This was not something that was all that important.

We used to get these things signed all the time by these people: Here

sign this. Take them to lunch. So I mean it's not like -- wasn't

something we would have --

Q. But it was just more of the same in terms of --

A. Yeah -- so many of those things going on like that, that we did on

daily basis. We had people sign stuff or -- I don't know how many times

I was Jake Marti or Glen was Jake Marti or Ed Paxton or, you know, we

used peoples names all the time to get information and say we were the

people because it had to be like it was coming from the community.

Q. There is another document that was marked at Mr. Marti's deposition

as plaintiffs exhibit four. And it appears to be a letter from Mr. Marti

to Larry Rowe, and then it says route to, then there is a list of

people?

A. Jake Marti never wrote a letter himself during the whole time he has

been out there. If this letter was written, either written by myself or

by Glen Odell or somebody from the office.

I wrote this letter. What happened was Glen wrote it -- this is off my

computer -- Glen wrote the letter, probably went back three or four

different times from the office to Glen until we got it down right. And

then we sent it out. Marti would never write a letter like this.

Q. The thing in the upper right hand corner, that says route to, is that

your stamp?

A. No, that appears to be probably theirs. Route to Bod Rowe, so that's

probably to them.

Ms. Klar: Let me have the reporter mark as Exhibit Lauricella I,

documents, multi-page document that appears to be minutes of a regular

meeting of the Board of Directors of the Mojave Water Agency held on

Tuesday, September 12, 1995.

(Exhibit I was marked for identification.)

By Ms. Klar:

Q. Mr. Lauricella, let me show you what's been marked as Exhibit I, and

ask you if you attended that meeting of the Mojave Water Agency?

A. Sure did, Yes.

Q. Why would you attend that meeting or similar meetings?

A. Because we were trying to cabash the water deal, actually trying to

cabash. Waste Management and Rail-Cycle did not want the MOU for MWA to

go through, we wanted it stopped.

Q. MOU between the Mojave Water District and Cadiz?

A. Right. So to move on the MOU we needed to have people from the local

community who were involved with the water go to the meeting.

And so what we did is every other meeting we hauled people down from

Cadiz, put them in a car and drove them down, so many down there, buy

them dinner or whatever, make a day of it, and then have them up here in

front of the MWA and expound how they didn't want any of this to go

through because they were stealing all their water, wasn't going to be

water left.

So the twenty people out there wouldn't have any water left if Cadiz

sold them water. Kind of thing we did all the time. That was over and

over again we did it.

Is this one of the ones that were actually set? I think we were a new

business.

Here it is, new business press for consideration for public hearing. Did

they ever get the public hearing? We did get the public hearing? What's

happened so far? They are still fighting the MOU, right? Because we were

told, I was told that the MOU is actually -- that they succeeded in

actually killing it for all practical purposes.

I cannot believe the money and time that Waste Management and Rail-Cycle

put in this thing to kill that MOU.

What we found out is from a assistant to their general manager Larry

Rowe, she was kind of working behind his back for us. And that's when we

found out the MOU was pretty much a dead issue.

Q. How would she sort of work behind the scenes for you?

A. Any time any paperwork came into Rowe's office or any time anything

happened, we'd get a copy from his assistant to take care of it. Even

though Rowe didn't even know what was coming down, we'd get a call from

his assistant's office. Especially Glen. I have even been in the office

over there.

Also if we needed stuff delivered, I got personal phone numbers from her

for hourly and for all the people that were on the board so we can phone

them and try and persuade them on an emergency to kill the MOU, because

we didn't have enough time to go to the meeting. Wasn't set up, we

needed persuasion ahead of time.

So I got on the phone and pretended I was Jake Marti. And she said

straight out she was a hundred percent for the Waste Management

Rail-Cycle project, and didn't like Larry Rowe and all the terrible

things he did and intimated he was being bought by --

Q. By Cadiz?

A. By Cadiz, yeah.

Q. Let me show you a document that was marked at Mr. Marti's deposition

as plaintiff's exhibit six, and that's a letter dated May 11, 1996

supposedly from Paul Limon to Michael Dombrowski with a cc to Marcia

Terrosi (sic) and Valerie Pilmer.

Have you seen that letter previously?

A. Yeah, this is another one that was done by Glen and I. This was sent:

Dear Mr. Dombrowski -- this went back and forth with Glen Odell.

Q. Take whatever time you need to read it.

A. You know, can we go off the record please?

Ms. Klar: Yes.

(Off the record discussion.)

THE WITNESS: This letter is a letter that was prepared by myself,

actually Glen Odell and several people for Paul Limon to sign, and it

was sent to Mr. Michael Dombrowski, Chairman of the Planning Commission,

which is kind of strange since he had already seen this letter any way

because he helped write the letter. So did Turicchi's (sic) office help

write the letter, so did Glen Odell help write the letter.

This letter, faxed back and forth until we got it exactly right what it

had in it because it was made for the record. This letter was to be

signed, sealed, delivered, for the record, nothing other than that.

The other thing was there were several letters that went along with this

from Turicchi's (sic) office what she is going to do to the planning

commission, what they are going to do about these serious allegations

about the promised housing, what-not.

All these letters had to be kind of earmarked, so they had to mesh

together. So everybody in a period of about a week was sending faxes of

all their letters back and forth.

And in my computer I've got the actual letter of this thing where they

were signed, where I've got notes from Turicchi (sic) on there, and I've

got notes from Turicchi (sic) on there, and I've got notes from

Dombrowski. Everybody knew exactly what was going on.

Q. These were letters, a draft would be sent, for example, to

Dombrowski, he would then make handwritten comments and fax that back to

you and you have a copy of that fax?

A. Or it would go back to Glen and Glen would fax it to me. And I have

copies of those faxes, that's one of the things that's on one of the

hard drives.

But the important part of this was everybody -- and I don't even know --

this is one of the things I really don't know if it's against the law of

just immoral, but what ended up happening is these people, everybody

knows -- everybody is holding up this thing saying this is the first

time Dombrowski got this and that the public is being made aware of it

for the first time.

Well, it's a lie. Everybody that was involved in this thing knew exactly

what was going on and played the public, I don't know if monetarily, but

played them for fools.

The other thing was it wasn't just screwing Cadiz Land Company, it was

also screwing the people of San Bernardino.

And Paul Limon thought he was signing a real letter. In other words, he

thought this was for real. He's a good man and the problem was --

Q. He was duped?

A. He was duped. Not only was he duped -- I get real irate about this

letter. This was the turning point for working for them.

Q. As to the sale of water by Cadiz, did you have --

A. Bottled water.

Q. He give any evidence that Cadiz was selling bottled water?

A. Cadiz had -- at one time had bottled water, bottled during the

election campaign, and there was some bottled water they had bottled

gotten into a few stores to sell at one time.

And Glen wanted me to collect these bottles and have the people from

Cadiz run up and say look, look, they are stealing our water in these

little twelve ounce bottles of water.

You would have to have fifty million trucks to get any significant

amount, but any way he wanted people to stand up in these meetings and

say look, they're stealing our water.

Well, the problem was Cadiz realized they didn't do it on purpose, they

were doing it more of a promotional thing, so when they realized they

didn't have a permit which is nothing against the law, they needed to

get one of their wells listed as a pure well, which they are all pure

any way, but it's a licensing thing.

When they realized they didn't have that, they phoned the few stores

that did have the water and told them he can't sell this stuff and he

pulled it off the shelves.

The problem was Glen needed to have it for the meeting, bit meeting

before the board of supervisors and the planning commission, he needed

to have bottled water.

So I knew some people in Twenty-nine Palms that had stores and some

other people knew some other people. So we went to the back area of the

stores because it had already been pulled off the shelves. And we got

them, and they ran receipts for us -- I didn't, but so people can stand

up and say they bought the bottled water such and such a place.

Q. You actually got the receipt?

A. No, actually the Board of Supervisors got the receipts, but I got the

receipt from the two stores and that little restaurant kind of thing in

Amboy. We made a big deal.

They had me chasing trucks out there, we had flyovers. We did everything

we could to chase these trucks down, because they were going to use if

as a way of saying the company Cadiz was just being contentious, they

were dealing with the county, they were going to steal water one way or

another.

It was all BS. They could have taken truck loads of stuff out and it

wouldn't have affected the -- but it made the people out of Cadiz upset

the actual people that lived out there because they thought they were

being rubbed their noses in by Cadiz Land Company, but they weren't.

Ms. Klar: Why don't we take a break for a few minutes.

(Off the record discussion.)

(Whereupon a short recess was taken.)

Ms. Klar: Let's mark this as next in order.

(Exhibit J was marked for identification.)

By Ms. Klar:

Q. Mr. Lauricella, let me show you what's been marked as Exhibit J, and

ask you whether or not that's a press release that's prepared by either

Waste Management or Rail-Cycle?

A. This is a hand-out.

Q. A hand-out?

A. This probably was handed out from the looks of it, because if you

look at this, states about the group from Needles in Twenty-nine Palms.

This is handed out during the election. This is one of the things that

was put together as a hand-out during the election.

Q. And it was prepared by Waste?

A. Actually that looks like it was prepared by Glen, then sent to me to

co-authorize, then sent to Glen and sent to the legal committee. Almost

positive it was done in blues and yellows, handouts, thousands of them.

Q. This refers to studies, all show one thing: There is no significant

recharge of water to our dessert (sic)aquifer?

A. Right.

Q. Is that a true statement, or is that something that was made up?

A. First of all, there is a recharge rate, we all know there is a

recharge rate. What's in contention is what the recharge rate is.

Rail-Cycle wants to say the recharge rate is something like two hundred

acre feet per year. On the high side they want to say there's twenty

thousand acre feet per year. Looking at the stuff I've looked at, if you

look back, the whole thing probably is in the neighborhood of seven

thousand to ten thousand acres per year. And I'm not a geologist or

hydrologist, but I do know that Rail-Cycle's contention that there is no

recharge rate, significant recharge rate is BS because their own report

shows there is a recharge rate. That's all open contention, independent

what time of the year, what the rain fall is that year, whether it's com

ing out to the Fenner Gap, whether it's coming out different areas.

Q. Now let me show you a document that was marked as plaintiff's exhibit

seven at the Marti deposition, and ask you whether or not this is a

document you've seen before?

A. I haven't seen this before. This is a public hearing, this is just

the comments from the public hearing. I haven't seen this. Or if I have,

I don't remember.

Q. Here is another document that was marked at Mr. Marti's deposition as

plaintiff's exhibit two. This says for immediate release June 6, 1996.

My question is: Have you seen it before and is that another press

release prepared by either Waste or Rail-Cycle?

A. This is produced by Rail-Cycle. No, this is one that was produced by

Rail-Cycle, was sent to the Daily Bulletin -- yeah, obviously this is

not who signed it, signed by John Morgan, Paul Limon one of those people

would make this up. It had not come directly from Waste Management.

And since I was there during these meetings, I'm sure this was actually

done on my computer. I did that.

Q. And it was shown to Mr. Odell before it went out?

A. Yeah, everything was shown to Mr. Odell. None of that would have

passed.

Q. Tell me just generally what the chain of command was as you

understood it? Did you do anything without authorization from Mr. Odell?

A. No, nothing was done without authorization. Anything that had to be

done out there of any major significance or minor significance for that

matter had to first go through Glen and Glen okay'd it, because he

didn't want to have any embarrassing problems out there.

I mean right down to giving, when we gave four thousand dollars or two

thousand dollars to the -- what's that group, business people that get

together in the communities?

Q. Chamber of Commerce?

A. Chamber of Commerce, we gave that to Twenty-nine Palms' Chamber of

Commerce. I was told go ahead and offer money to Chamber of Commerce

where they had problems, even little things like that, where there was

some problems, I had to immediately get back to Glen on the cellular

phone and contact him.

It was going back and forth.

I went to a meeting of Eagle Mountain where our competitors were Eagle

Mountain, I had to keep in constant contact during the period of time I

was in the meeting, with Glen Odell so he could understand what's going

on and so I can make comments as though they were coming from me, but

they were coming from Glen Odell.

Q. When the contribution was made to the Chamber of Commerce, was that

made by the local group or was that made by Rail-Cycle?

A. Made by Rail-Cycle.

Q. And the Chamber of Commerce knew it was made by Rail-Cycle?

A. Yes. They turned it down.

Q. They turned it down?

A. Yes.

Q. This was another document that was marked at Mr. Marti's deposition,

it's plaintiff's exhibit nine.

Is this one of the letters that either you or Mr. Odell prepared and

then you colloquialized for Mr. Limon's signature?

A. Must be one of the last ones I did. Yeah. This was the one that was

-- this is the one that Glen did and I redid. Date is just before I was

picked up.

Q. You were picked up on --

A. October 15th.

MS. KLAR: Let me ask the reporter to mark as exhibit K, a letter dated

October 10, 1996 supposedly signed by Paul Limon to Mr. Dombrowski.

(Exhibit K was marked for identification.)

BY MS. KLAR:

Q. Mr. Lauricella, let me ask you to look at that letter that's been

marked as Exhibit K and ask if that's a document you've seen prior to

today?

A. Yeah, this is a letter I wrote as part of Glen Odell. What happened,

this is the one Glen Odell wanted them to write and wanted Paul Limon to

sign as if it were coming from him as a chairman.

This is also my letterhead for BVEC, B-V-E-C, that's the letterhead that

we used so this came off my computer.

Q. Was that the letter that went to Mr. Dombrwoski?

A. Went to Mr. Dombrwoski, I would imagine Mr. Dombrwoski saw this a lot

before this, this is one of the ones that went back and forth.

Q. That was a common occurence that correspondence would be changed in

draft form to the percipient before the draft was sent?

A. That's correct. Mr. Dombrwoski asked for this letter to be sent.

Q. Did he tell you why?

A. I think it was going to kick start something that was going on. The

idea was to try to get the planning commission to set -- he needed

something so they could se a meeting to have your CUP polled, and to do

that we had to kick up enough dust so he could say: Look, this is from a

small community. That was his suggestion.

Q. Let me show you another document that was marked of Mr. Marti's

deposition which is a transcription of tape from the County of San

Bernardino Planning Commission meeting on October 10, 1996.

Have you seen this transcript prior to today?

A. I had seen the raw speeches because we wrote this, but I haven't seen

the transcript.

Q. When you say the speeches, are you talking about the speeches that

were made by Mr. Marti and Andrea Plimen?

A. Right, where is the water thing, this is where they hold up the

water, they hold up the little bottle of water here, this is the

meeting. This is the last meeting I went to.

Q. Was the issue of the conditional use permit something that was

discussed?

A. In fact I sat in this meeting, it was a big hall, Planning Commission

meets in, same thing as the Board of Supervisor meets in.

I made sure Tony was there and actually Jessie were there too, my wife

was there. But they sat on the other side of the group, made us sit here

on one side, Glen Odell and myself and one of their lawyers, I believe

sat on this side, almost like we didn't know what was going on.

But we had just written all these speeches and all, we were there to

make sure Dombrowski did the part he was supposed to do, which is start

questioning for the conditional use permit since he already knew this

because we sent these speeches to him originally.

But part of the hearing let me read that again, or let me hear that

again, it was funny because I was up there laughing with Glen about it,

because the speeches he's reading, they are reading to him and he's the

one that help write them.

Q. All of this was sent in advance?

A. He knew exactly what was going on.

Q. So the whole presentation was all staged?

A. It was all staged, yep. If you read this thing it's funny, because

he's acting like oh -- and I have these speeches in the computer with

all the different corrections on them.

(Off the record discussion.)

BY MS. KLAR:

Q. Mr. Lauricella, you have on several occasions mentioned that you have

information on computers that would facilitate your testimony.

Can you briefly describe the type of information and how this

information would help you if it was made available to you?

A. We have all the information during the time that I worked as a

consultant with Waste Management. There's two things I kept: One was

those hard copies of everything I did, which seemed to somehow

disappeared the night of my arrest, a lot of this stuff disappeared; and

the other thing I kept on was three to four secured systems, computer

systems, along with three or four secured websites and ASCII code.

It would be easy for me to get the information dates, times off those

systems if I could get access to the computer disks, the hard drives and

break down this stuff to be able to bring out what's on there.

Until we get this, it's hard for me to give you dates and times. The

stuff we talked about today, I guarantee it's just a little part of the

stuff that was done. I can sit here and probably write a book and tell

you all the different things we did to Cadiz Land Company.

But unless I have something I can go in chronological order how it went,

it's going to be hard for me to remember all the stuff. I mean there's

things on there where we paid off certain members of the field workers,

you know, to cause problems.

Or the time that we had the field workers running off out in the valley

in one hundred twenty degree heat telling them Migro is calling, then

get the newspapers down there and everybody down there to tell them: See

how Cadiz treats their help.

Without the dates or times, doesn't really make a lot of sense, and only

way I can do that is get ahold of the computer disks.

So that's what we're waiting for, and to be able to get on the website

and pull the information down.

Q. There is a report called, The Boyle Report, and my understanding is

that the original Boyle report confirmed Cadiz' estimate of the recharge

rates and water levels.

Is it your understanding that that report was altered at Rail-Cycle's

direction?

A. That's correct.

Q. How do you know that was altered at Rail-Cycle's direction?

A. Because I remember when -- excuse the French, when all shit hit the

fan when they did the report, and it didn't come out the way they wanted

to and that's when it got altered.

Rail-Cycle is real famous for changing reports around. They make a big

deal about how the report is going to be the way they wanted, this is

actually what's going happen. They run it all the way to the very end,

and then when the report doesn't come out that way, it mysteriously gets

canned or comes out completely different than the day it came out. And,

you know, that's in one of those reports.

Just kind of like the simple little water reports we did for the people

up there. You know it looked real good, oh, water rate was going to drop

ten feet in two years. That's an impossibility.

But when their actual report shows the water rate was rising, then all

of a sudden we had to make it sound like it's going the other way. And

that's when we changed it around.

Q. And you did that with Mr. Odell's knowledge and consent?

A. Oh, yeah. I would not deliver any of the reports without his. He's

the one that suggested it, had to be. In fact, he was so upset about it

he didn't want to see -- in the computer there's the raw figures and he

didn't want the people out there to see the raw figures because they

would have probably figured out the water level was going up instead of

down.

Q. Are you familiar with the name Garth Morgan?

A. I certainly am.

Q. Who is Garth Morgan?

A. Garth Morgan used to be their consultant in that area before I got

there.

Q. Do you know, or do you believe that he would have copies of the

original Boyle report?

A. Well, I believe that he might have had copies of the original report.

I don't believe that he probably would have them any more. I would think

by this time he himself would have probably gotten rid of them.

Q. Has a reporter by the name of Fitzsimmons tried to interview you?

A. Several times.

Q. Have you directly or indirectly gotten any response from Waste or

Rail-Cycle when they learned that she was trying to interview you?

A. They were not happy about it.

Q. Who communicated that message to you?

A. That was both Muehl and --

Q. Madison?

A. Madison.

Q. Now did you ever have discussions with Mr. Odell about why it was

necessary to engage in these various activities if -- and why Waste

could not do things honestly and openly in connection with their

activities in Cadiz?

A. Million dollar question, actually 250 million dollar question. This

is going to be a little long and winded, but maybe it will explain

what's going on.

I've done a lot of illegal things in my life, you probably know my

background and everything. When I came on with this company I knew there

were some things that were going to be kind of a little iffy, because

that's what I was told. I didn't think I would be doing anything

illegal, I really didn't. I thought kind of like putting a spin on

things, we are going to put a spin on this and do it the way we want.

Reality of the situation is that landfill site could not have gone in.

Started with the problems with the earthquake, the fault. It should not

have gone in and they knew that.

And they couldn't hold the close scrutinization, have it scrutinized, so

what they kept doing is they would lie if nobody really looked really

close at it, and nobody did look really close at it.

If you look at the history of this thing, there is a couple little green

people, you know what I'm saying, little greens out there waving their

things.

Q. Environmentalists?

A. Environmentalists waving their little flag, but nothing standing in

the way of actually putting it in. If you look at where it's at, it's

another middle of no where.

If you buy twenty people or convince thirty people out there, then you

can put your land fill in out there, who cares. Actually the people of

San Bernardino, people took payments everything, payments of one sort of

another so Rosie didn't care.

So they put it together and didn't care until they ran into Cadiz Land

Company. Then Cadiz Land Company said wait a minute, wait a minute, for

whatever reason we got to take a look at this thing a little further,

whether because it's not a financial deal that's going to work for us or

whatever it is.

And they thought at that point they would still be able to bowl it over.

They thought nobody is going to look that closely. This is Waste

Management, this is Russ Engineering, this is -- shit, we spent two and

a half million dollars on an EIR, nobody is going to look into this. And

they did.

So they just kept compounding one lie after another lie, after another

lie. Is it a corporate culture for Waste Management? Look at their

history, probably is.

Do I think they do it legally if they can't do it legally. Sure. But

they couldn't do it legally and they know it, and they are going to have

to lie and everybody involved in that project. All on white horses, it's

a great thing, and behind their back they are dealing.

Whether it was my little cog thing back there that I did, or somebody

back in Chicago, they are all involved. It's a big profit for them.

Q. In terms of the ultimate objective, was the ultimate objective just

the landfill or were you told there were other plans for the area?

A. First of all the landfill is gong to be obsolete in ten years. They

know that. They don't even have enough trash to supply the fill now.

Basically there's a whole project: You got the material recycling

facility, those are money in different areas.

There's a big shake up between Burlington Northern Santa Fe right now.

They are taking Burlington Northern Santa Fe for some bucks on this

thing. Everybody knows the landfill site is a hundred year project, but

if it lives for ten years out there, it would be surprising.

So no, they want it for the water out there, they've always wanted the

water. They want to build out there. It's a corridor. They own the rail,

it's a railroad corridor and it's a highway corridor.

I've been in here now, so I don't know what the idea is for the hundred

thousand population town, but somebody has got a finger into it because

they own all the land out there.

And that was the big joke. They were going to have Glen Acres out there

and become very wealthy. It was a big joke. Yeah, the landfill site is a

minor part of it. They can put in light industrial out there, who is to

stand in their way?

Once they beat up Cadiz Land Company, sunk them, then who else? If you

guys hadn't purchased Sun World and Sun World hadn't become such a

player in the market, there was a good chance they could have done it.

They were working real hard on it.

Q. One of the objectives of Mr. Odell, as I understand it, was to queer

the Sun World deal so it could not go forward?

A. Yeah, Sun World deal was supposed to be -- that was one of the things

that got his in the ringer, because it should have been cleared and he

couldn't do it.

He had problems with it. Had the money for, I think , the ten million

dollars or twenty million dollars in the initial thing, something like

that, had that been done in the United States, we would have been

cleared the field. But had it been done offshore, we couldn't do it.

MS. KLAR: Let's go off the record.

(Off the record discussion.)

MS. KLAR: We're done.

(Whereupon he (sic) sworn statement of Joseph Lauricella was concluded

at 12:20 p.m.)

STATE OF CALIFORNIA) ) ss.COUNTY OF SANTA CLARA )

I, the undersigned, declare under penalty of perjury that I have read

the foregoing transcript, and I have made any corrections, additions, or

deletions that I was desirous of making; that the foregoing is a true

and correct transcript of my testimony contained therein.

Executed this 28th day of August, 1997, at San Jose , California.

/Signed/ JOSEPH ERNEST LAURICELLA

REPORTER'S CERTIFICATE

I, Sharen H. Dains, CSR No. 2040, Certified Shorthand Reporter certify:

That the foregoing proceedings were taken before me at the time and

place therein set forth, at which time the witness was put under oath by

me;

That the testimony of the witness and all objections made at the time of

the examination were recorded stenographically by me and were thereafter

transcribed;

That the foregoing is a true and correct transcript of my shorthand

notes so taken.

I further certify that I am not a relative or employee of any attorney

or of any of the parties, nor financially interested in the action.

I declare under the penalty of perjury under the laws of the State of

California that the foregoing is true and correct.

Dated this 4th day of August, 1997.

/Signed/ SHAREN H. DAINS, C.S.R., CM License No. C-2040

REPORTER'S CERTIFICATION OF CERTIFIED COPY

I, Sharen H. Dains, CSR No. 2040 Certified Shorthand Reporter in the

State of California, certify that the foregoing pages 1 through 68

constitute a true and correct copy of the original sworn statement of

JOSEPH LAURICELLA, taken on August 2, 1997.

I declare under penalty of perjury under the laws of the State of

California that the foregoing is true and correct.

Dated this 4th day of August, 1997.

/Signed/ SHAREN H. DAINS, CSR, CM License No. C-2040