Deposition Summary Of: James Hamilton, Attorney (Swidler & Berlin Law Firm, Washington, D.C.) February 2, 1998.

1. Hamilton has no experience in Indian law. He is a litigation and criminal law expert. p.5, line 2-20

2. Swidler & Berlin has no one else in their 175 lawyers who has Indian experience, except Pipestem, who has been out of law school 2 ½ years. p.5, line 21 – p.7, line 7

3. Cherokee Nation hired him due to Wilson Pipestem’s friendship with Kim Teehee. p.7, line 23 – p.8, line 16

4. Hamilton considers the Executive Branch of Cherokee Nation to be his client. p.10, line 25 – p.11, line 12

5. Hamilton refuses to answer question as to whether he could work against Tribal Council if Chief asked him to do so. (privileged) p.15, line 11- p.18, line 21 – p. 19, line 7 – p.24, line 15

6. Hamilton did letter to Babbitt on April 16 that “raised the issue of the need for the BIA to assume law enforcement.” p.32, line 16 APRIL 18 IS WHEN DEER SIGNED LETTER TAKING OVER LAW ENFORCEMENT

7. Hamilton told the BIA that there was jeopardy enough (in his judgment) to take away the law enforcement from Cherokee Nation, but had no factual basis for the claim. p.34, line 4 – p.36, line 2

8. The DEMOCRATIC NATIONAL COMMITTEE people that Pipestem met with (see invoice for May 9) regarding reimbursement to the tribe for Kim Teehee included the DNC’s General Counsel, Joe Sandler.

9. Hamilton said that both Babbitt and the Deputy Secretary of the Interior, Garamendi, are his personal friends. Hamilton had Sunday brunch with Garamendi on May 19 (see invoices) and Cherokee Nation paid for it.

10. Hamilton called John Leshy, Solicitor of U.S. Interior Department, at home on Saturday and Sunday to arrange for Byrd to come back to Washington, D.C. to sign the Babbitt agreement on Monday, August 25. p.42, line 17 – p.43, line 3 (This was same agreement that Byrd had refused to sign on Friday, August22) p.51, line 17 – p.53, line 9

11. Hamilton refuses to say if Chief Byrd authorized him to bill Cherokee Nation for assisting BIA to defend against Cherokee Nation’s Judicial Appeals Tribunal lawsuit against the BIA. p.46, line 23 – p.47, line 4

12. He says he is a specialist in government ethics, as well as criminal law and represents not only the White House, but Don Fowler, former head of Democratic National Committee (DNC). p.100, line 6 – p.104, line 16