3 You have made a -- a contribution or donation to the
4 UCI, have you not?
5 A. I have, yeah.
6 Q. Do you know when that was made?
7 A. Some years ago. I don't recall exactly.
8 Q. Well, 2000, for example?
9 A. I don't know.
10 Q. Was it -- was there anything that occasioned
11 that, that you recall? Like I'm doing it because of X
12 or Y or Z?
13 A. I'm doing it to -- to fund the fight against
15 Q. And what -- what made you -- what triggered
16 that? I mean, was there any particular event?
17 A. The only event, or the only idea is that I'm
18 in support of that fight, just like I've done on other
20 Q. Why UCI? I mean, why give the money to UCI?
21 A. Because they're our governing body.
22 Q. Okay. How much did you give?
23 A. I think 25,000.
24 Q. You say you think. Do you --
25 A. Yeah, I say I think because I'm not 100
1 percent sure.
2 Q. Would it be within a range of that, though,
3 if you're -- I mean, it wouldn't be like --
4 A. Well, it wouldn't be --
5 Q. -- 200,000 --
6 A. No.
7 Q. -- or 150,000?
8 A. No.
9 Q. I mean, it could be 30 or 40, or it could be
10 20, is what I'm asking.
11 A. It could be. I don't think it's that. But
12 I think it's no more than 30.
13 Q. Was it by personal check?
14 A. I don't remember.
15 Q. Did you tell UCI you were going to make it
16 before you did?
17 A. I don't recall, but I don't think so. I
18 don't know.
19 Q. You gave $25,000, or approximately $25,000
20 to the UCI, but you don't remember if you told them
21 beforehand that you were sending them a check?
22 A. I don't recall.
23 Q. Had you ever given any money to UCI before?
24 A. No.
25 Q. Have you ever given any money since?
1 A. I have pledged money since, but I don't
2 think I've done it yet.
3 Q. When did you pledge money?
4 A. I don't remember. Between now and then.
5 Q. No. I meant when did you make the pledge?
6 A. Between now and then. I don't recall
8 Q. Well --
9 MR. HERMAN: Between now and then,
10 meaning between the time you gave them the 25,000 --
11 THE WITNESS: Right.
12 MR. HERMAN: -- and now?
13 Q. (BY MR. TILLOTSON) Oh, okay. Between
14 now -- now and then, which I guess would be tomorrow.
15 Okay. So some --
16 A. It's still a fight I believe in --
17 Q. Okay. I'm not --
18 A. -- so I would still make the donation.
19 Q. I'm not attacking your -- the fight. I'm
20 asking you --
21 A. And if you have a different suggestion on
22 where to donate the money.
23 Q. Is there any other organization that -- that
24 is involved in anti-doping?
25 A. Well, you have a lot of organizations, WADA,
1 USADA, USOC, USA Cycling. You could pick all of
3 Q. So there were other -- I mean, there --
4 there are at least other organizations you could have
6 A. Yeah.
7 Q. Okay. Do you know what UCI did with the
9 A. I don't know.
10 Q. Who did you give the money to?
11 A. Well, if you sent a check or a wire, I don't
12 know who received it, but...
13 Q. I mean, like -- is it literally like one day
14 the UCI guy comes in, opens up the mail, and there's a
15 check from you for $25,000?
16 A. I mean, I don't know. I wasn't in the mail
18 Q. Okay. But did you let anyone know this is
20 A. I told you, I don't remember.
21 Q. Okay. Have you spoken to anyone at UCI
22 regarding your donation?
23 A. Yeah.
24 Q. Who?
25 A. I have spoken to Alain Rumpf, Hein
1 Verbruggen, perhaps others.
2 Q. Do you know what they've done with the
4 A. I just told you, I don't know.
5 Q. Okay. Like they didn't buy some specific
6 equipment or something with it that you're aware of?
7 It wasn't earmarked --
8 A. Which part of I don't know do you not
10 Q. So you have no idea why you gave $25,000 to
11 UCI at all. And you don't even know if you called
12 anyone before --
13 A. I don't know.
14 Q. Let me finish my question.
15 MR. HERMAN: Hang on. Hang on a
16 second. Finish your question, if it is a question.
17 Q. (BY MR. TILLOTSON) You have no idea who you
18 called, and just -- you just sent a check for $25,000
19 to the UCI. You can't remember why you did it, or who
20 you talked to, or what it was for.
21 A. You asked me again what have they done with
22 the money, and I said I don't know.
23 Q. Okay. But you've spoken to two people.
24 Have they discussed with you what they plan on doing
25 with the funds in any way, or what they hope to do
1 with the funds?
2 A. Not that I recall.
3 Q. When did you -- did you ever tell the public
4 that you had made that donation?
5 A. Hein Verbruggen told them at some point, and
6 I confirmed that.
7 Q. Was there a reason why you didn't publicly
8 announce your donation to UCI?
9 A. The same reason that I don't -- my fight
10 against doping is not a public fight. So the same
11 reason that before the 2003 Tour de France, which was
12 fairly well publicized, I sent a private email to
13 Mr. Verbruggen, Mr. Schattenberg, Mr. LeBlanc, Daniel
14 Baal, everybody involved in the Tour and cycling, and
15 said, we have to keep up this fight, which then became
16 public, a public email after Daniel Baal put it in his
18 Personally -- now, this is going --
19 this is going to shock you, but my style is different
20 than David Walsh's. My approach has been more of an
21 internal one, to support clean racing, to support
22 clean sport. My idea of the best tactic is not to
23 slander and defame everybody, and bite the hand that
24 feeds you, and **** in the soup; but my fight and my
25 commitment has always been there.
1 Q. Were you concerned at all when you made your
2 contribution to the UCI that other cyclists or members
3 of the cycling public might take it the wrong way?
4 A. No.
5 Q. Are you aware of any other professional
6 cyclists who's given money to UCI?
7 A. I don't know. I'm not aware. Personally, I
8 think there should be -- I think everybody should
9 contribute to the fund.
10 Q. How does UCI get its money? Do you know?
11 A. I have no idea.
12 Q. Okay.
13 A. Honestly, I don't know.
14 Q. That part of "I don't know" I understood.
15 Believe me.