In February of 1964, Bobby Baker appeared as a witness before the Senate Committee on Rules and Administration.  [Citations in square brackets refer to end notes at the bottom of this article]. The hearings were part of an investigation into Baker’s alleged inappropriate business activities while serving as Secretary for the Majority in the Senate.  Edward Bennett Williams, a lawyer with significant experience in representing witnesses before Congressional committees, represented Baker.
Williams’ approach in the Baker case was to focus primarily on Baker’s impending criminal trial, and secondarily on Baker’s reputation. With these priorities in mind, Williams advised Baker to plead the fifth amendment and refuse to answer any questions from the committee. To illustrate Williams’ focus, this paper examines two factors that Williams cited as important  in his advice that Baker should plead the fifth: 1) Perjury, as a threat to Baker’s trial prospects, and 2) Ridicule from the Committee, as a threat to Baker’s reputation. These factors are still important to witnesses who must decide whether to plead the fifth before an investigating Committee.
I. Perjury: A Threat to Baker’s Trial Prospects
The Senate investigation of Baker was essentially a criminal investigation. At the time of the hearings, Baker was already under investigation by the FBI and the IRS,  as well as the Justice Department.  There was a danger that, if Baker testified, he might perjure himself before the committee. Such perjury could lead to additional criminal convictions; each instance of perjury would be a separate charge. 
Williams’ primary objective in representing Baker was to minimize criminal liability. In light of this goal, it made sense for Williams to advise Baker not to testify, because: A) a guilty witness who testifies will either implicate or perjure himself, and B) even an innocent witness risks perjuring himself. These assertions are still true.
A. A Guilty Witness Who Testifies Will Either Implicate or Perjure Himself
A guilty witness who testifies before a committee must either tell the truth, and thereby implicate himself, or commit perjury. The case of Aldo Icardi demonstrates this dilemma. Almost ten years before the Baker hearing, Williams represented Icardi, a defendant in a criminal trial, who was charged with “eight counts of perjury allegedly committed in 1953 before a subcommittee of the Committee on Armed Services of the House of Representatives.” 
An Italian court, without Icardi present, had convicted Icardi of murdering a military officer in 1944, while serving as a soldier in World War II; American courts could not try Icardi for the murder, but the Congressional committee decided to investigate the officer’s death.  Before the subcommittee called Icardi as a witness, the chairman discussed with committee members the possibility of charging Icardi for perjury, if he testified consistently with a false account he had given of the Italian murder.  As Williams later explained: “[The Congressional hearing] was a carefully laid perjury trap. It was a preconceived plan by members of the United States Congress to get Aldo Icardi.” 
Rather than admit responsibility for the murder, Icardi repeated the false account of the murder that he had given prior to the hearings. Following Icardi’s testimony before the Committee, charges of perjury were brought against him.Fortunately for Icardi, the appellate judge agreed with Williams that the Committee had abandoned its proper legislative function and instead sought to gain a criminal conviction of Icardi.  Icardi’s conviction for perjury was overturned.
Like Icardi, Baker was almost surely guilty of the crimes with which the investigating committee accused him. Before Baker appeared before the committee, numerous witnesses had testified to his guilt.  Like Icardi, Baker faced the possibility of perjury charges if he testified before the committee. There is no evidence that the Baker committee sought to trap Baker into committing perjury. However, given the ongoing investigations of Baker at the time he appeared before the committee, and the subsequent criminal trial, it seems very likely that perjury charges would have been brought against him if such charges had been tenable.
Had he chosen to testify before the committee, Baker would have had to choose between admitting his wrongdoing and thus implicating himself in his future criminal trial, or perjuring himself and being prosecuted for additional charges of perjury, as Icardi was. However, whereas Icardi’s perjury convictions were overturned because the investigating committee had exceeded the proper scope of its investigation, Baker’s perjury convictions probably would not have been overturned, because the investigating committee had broad authorization to investigate Baker’s business dealings. 
Witnesses who are being investigated for crimes they have committed, and nevertheless choose to testify before a Congressional committee face a dilemma: if they tell the truth, their testimony may be used against them in a future trial, but if they lie, they may be charged with perjury. Bobby Baker did not face this dilemma, because Williams advised him to plead the fifth, and thus avoid testifying.
B. An Innocent Witness Risks Perjuring Himself
If Baker had believed himself to be innocent of his alleged crimes, it still would have been risky for Williams to advise him to testify. Even an innocent witness might be tempted to lie or distort the truth to protect others. Had he testified, Baker might have opened himself up to perjury charges by distorting the truth (e.g., to protect Lyndon B. Johnson).
Baker felt a loyalty to Lyndon B. Johnson, the new President, whom he considered to be his political mentor. It was Johnson who, while serving as Senate Majority leader, had created the position of Secretary to the Senate Majority, and had then appointed Baker to the position. Although President Johnson downplayed his relationship to Baker, to avoid connection with Baker’s scandals, behind the scenes, it was the President who had convinced Edward Bennett Williams to represent Bobby Baker.  Beyond any personal connection, Baker, as a Democrat, was united to the President by party affiliation.  Although there are conflicting reports about the intimacy of Baker’s relationship with Johnson, he clearly felt a sense of loyalty to the President.
Had Baker testified, he might have been tempted to lie or distort the truth in order to protect President Johnson from scandal. President Johnson was implicated in at least one of the Baker scandals – involving Don Reynolds’ sale of insurance to Johnson.  As a testifying witness, if Baker had been asked about Johnson’s role in the scandal, he would have had to choose between protecting the President by distorting the truth and protecting his own interest by testifying honestly and avoiding perjury. Thus, there would have been at least a potential for perjury, had Baker testified, even if Baker could have testified honestly without implicating himself.
Baker probably had other reasons to distort the truth. President Johnson was only one of many political allies. Even if he had believed himself to be innocent, Baker might have been tempted to distort the truth to protect other politicians, business associates, or family members. Distorting the truth for any reason could have led to perjury charges. Had Baker been innocent, a decision to testify before the committee would still have created a risk of perjury, because even innocent witnesses risk perjuring themselves.
C. Perjury is Still a Danger to Testifying Witnesses
Perjury continues to be a danger to testifying witnesses. According to 18 U.S.C. § 1621, perjury charges may be upheld against anyone who:
(1) having taken an oath before a competent tribunal, officer, or person, in any case in which a law of the United States authorizes an oath to be administered, that he will testify, declare, depose, or certify truly, or that any written testimony, declaration, deposition, or certificate by him subscribed, is true, willfully and contrary to such oath states or subscribes any material matter which he does not believe to be true; or
(2) in any declaration, certificate, verification, or statement under penalty of perjury as permitted under section 1746 of title 28, United States Code, willfully subscribes as true any material matter which he does not believe to be true; 
Thus, perjury can be committed while testifying before a Congressional Committee, when such testimony is given under oath. This fact has not changed between the Baker case and the present.
Unsworn testimony before a Congressional Committee probably cannot result in perjury charges. In the past, 18 U.S.C. § 1505 and 18 § U.S.C. 1001 have been used to prosecute witnesses who lie to Congress in unsworn testimony. However, the 1991 case of U.S. v. Poindexter,  held that 18 U.S.C. § 1505 may be used only to punish efforts to subvert witnesses, and may not be used to punish witnesses for making false statements in a congressional inquiry. Subsequently, in the 1995 case of Hubbard v. U.S.,  the U.S. Supreme Court overturned U.S. v. Bramblett  and held that 18 U.S.C. § 1001, criminalizing false statements given “in any matter within the jurisdiction of any department or agency of the United States,” does not apply to statements given in a judicial hearing. Hubbard clearly implies that statements given before the legislative branch would not be subject to 18 U.S.C. § 1001, either. As a result of these developments, it seems that unsworn testimony cannot be the basis for perjury charges.
If the Baker case happened today, Baker would not be helped by these developments in perjury law, because he appeared before the Rules Committee under oath. Had he testified, his testimony would have been the type that is still subject to perjury charges under 18 U.S.C. § 1621. Today, witnesses who are accused of crimes, but nevertheless choose to testify, risk perjury, just as Bobby Baker would have risked perjury had he testified before the Rules Committee. A guilty witness must either implicate or perjure himself, and even an innocent witness risks perjuring himself.
The fact that Williams cited the risk of perjury as a reason for Baker to refuse to testify to the Rules Committee demonstrates Williams’ primary objective in his representation of Baker: to minimize Baker’s criminal liability. The risk of perjury would have been too great had Baker chosen to testify, and each act of perjury could have been another criminal charge.
An argument could be made that Baker’s refusal to testify hurt him in the area of criminal liability, by making it easier for the Justice Department to investigate him and bring charges: His public invocation of the fifth amendment made him appear guilty to the government and to the public, and thus ensured that he would be prosecuted. However, prior to the hearings, Baker was already the subject of a civil suit and several criminal investigations.  It is unlikely that cooperating with the committee would have saved him from criminal prosecution. In defending Baker, Williams from the very beginning worked under the assumption that criminal charges would be brought.  His goal was to minimize those charges, and advising Baker to avoid perjury by pleading the fifth amendment was helpful in achieving that objective.
II. Ridicule from the Committee: A Threat to Baker’s Public Image
As a secondary objective, Williams wanted Baker to avoid public ridicule. In light of this goal, it probably made sense for Williams’ to advise Baker not to testify, because: A) witnesses who remain silent face ridicule, but B) witnesses who testify face additional ridicule.
A. Witnesses Who Remain Silent Face Ridicule
Witnesses who plead the fifth amendment and remain silent before an investigating committee face ridicule in at least two ways: 1) the fact of pleading the fifth amendment creates a public stigma, and 2) non-testifying witnesses can be called to appear before the committee and then subjected to embarrassing questions. Bobby Baker faced ridicule in both of these ways.
1. Pleading the Fifth Creates Public Stigma
The act of pleading the fifth amendment creates a public stigma. This stigma still exists, though it has probably lessened in the past fifty years. During America’s “red scare,” Senator McCarthy and others used the term “fifth-amendment Communist” to describe witnesses who, when questioned about their Communist activities, refused to testify.  The term was used to imply that any alleged Communist who pleaded the fifth amendment was, in fact, a Communist. The same reasoning is seen in criminal trials, where commentators often conclude that a defendant who pleads the fifth must be guilty.  Many laymen accepted this logic, without pausing to consider that witnesses might have reasons other than guilt for pleading the fifth. To many Americans, the plea itself is an admission of guilt.
It is difficult to quantify the public stigma that Baker faced as a result of his decision to plead the fifth amendment. On the one hand, Baker had already been stigmatized by the testimony of other witnesses and by resignation of his Senate position, so perhaps the stigma of pleading the fifth did not affect his reputation much. On the other hand, Baker’s refusal to testify came at a time when the public strongly associated fifth-amendment pleas with guilt, and, following the hearings, Baker’s name did, in fact, become a synonym for government corruption. 
For the purposes of this discussion, it is only important to emphasize that Baker’s refusal to testify did result in some degree of public stigma. The decision to plead the fifth amendment was wise in Baker’s case, for numerous reasons, but it still involved some damage to Baker’s reputation, because of the stigma associated with publicly pleading the fifth amendment.
2. Non-Testifying Witnesses Can be Asked Embarrassing Questions
Whereas a U.S. court of law is bound to follow rules of evidence, including the prohibition of hearsay evidence and limitations on the use of leading questions, congressional committees do not follow such rigid rules of evidence. This fact concerned Williams primarily because of the danger of character attacks that Senators could make against Baker. Non-testifying witnesses can be asked embarrassing questions, and, because they are non-testifying, they cannot respond to these questions.
In 1954, Williams represented Senator Joe McCarthy in Senate hearings. Throughout the McCarthy hearings, Williams’ client was barraged with suggestive and embarrassing questions. The committee spent four days presenting the case against McCarthy; much of the evidence presented consisted of readings of transcripts and letters in which McCarthy had insulted and attacked others.  The hearing was described by Senator Watkins as being “in the nature of a judicial proceeding,”  but it was entirely one-sided. The defense could not present any evidence on its own behalf. The hearings unfairly allowed the “prosecution” complete freedom to present evidence and accusations before a national audience, while the defense could only make its case in private and in writing.
As a non-testifying witness, Baker was open to embarrassing questions, and not even his lawyer could respond verbally to the ridicule. During the hearings, Williams tried repeatedly to make Constitutional arguments in defense of McCarthy, but was prevented from doing so by the committee. When Williams complained that his client was being denied a hearing on relevant legal issues, Senator Watkins answering by stating, “You are not being denied that hearing. You can file your briefs and that will be considered by the committee.”  The committee refused to grant Williams’ request for thirty minutes in which to make his case.  Instead of defending his client in front of the hordes of reporters who attended the hearings, he had to limit his defense to written appeals to the committee.
Williams came away from the McCarthy hearings with a belief that there should be a procedural code for congressional investigations and that, among other things, the code should limit the extent to which defamatory statements and testimony likely to be defamatory could be made public.  With such a rule, witnesses before Congressional committees would at least be protected from the worst types of questioning (i.e., questioning for the purpose of public humiliation). However, no such procedural code has been adopted.
In 1957, during the period between the McCarthy case and the Baker case, the U.S. Supreme Court decided the case of Watkins v. United States.  This case limited the Congressional power to hold investigative hearings by requiring that any Congressional inquiry be in the furtherance of a legitimate task of Congress. Congress could no longer investigate solely for the purpose of exposure. Committees holding hearings were now required to restrict their questioning to the purpose described in their authorizing language.
The Watkins decision did not help Baker’s case, because the Baker hearings did further a legitimate Congressional task – the task of preventing corruption in the Senate. The language of Senate Resolution 212, which authorized the Baker investigation, was written in such a way that the Rules Committee could investigate virtually any aspect of Baker’s business life. Pursuant to Senate Resolution 212, the committee was authorized:
To make a study and investigation with respect to any financial or business interests or activities of any officer or employee or former officer or employee of the Senate, for the purposes of ascertaining –
(1) whether any such interests or activities have involved conflicts of interest or other improprieties; and
(2) whether additional laws, rules, or regulations are necessary or desirable for the purpose of prohibiting or restricting any such interests or activities. 
Baker’s decision to plead the fifth left him open to ridicule from the committee. Chairman Jordan made a public show of Baker’s decision to remain silent. After a day of hearings in which Baker refused to answer any questions, and in which Williams informed the Chairman that Baker would not answer any future questions, Jordan called Baker back for a second day of hearings. Williams objected by stating that:
[I]t is an abuse of the legislative function to call a witness whom the committee knows is going to invoke his constitutional rights and refuse to answer questions on subject matters on which the committee already has full information, and I feel it would serve no useful purpose to call Mr. Baker when the committee was apprised that he would not answer questions because he was under investigation by agencies of the executive branch of the Government. 
Despite Williams’ bold argumentation, the Committee persisted in calling Baker back for another day of questioning, with knowledge that Baker would plead the fifth.
The questions that were placed to Baker expressed the innuendo and gossip that he was trying to avoid by remaining silent. At one point, Senator Scott asked Baker a particularly harsh line of questions, implying that Baker had accepted bribes from businessmen, funneled illegal campaign contributions, and even demanded kickbacks from a Senate page.  Although the questions all fell within the committee’s mandate under Senate Resolution 212, they were not in keeping with the spirit of the Watkins decision, because they were asked solely to embarrass Baker.
Like any witness who refuses to testify before an investigating committee, Baker was open to ridicule. The fact of pleading the fifth amendment was, in itself, a sort of ridicule, because of the public stigma it created, and the committee created additional ridicule by subjecting Baker to embarrassing questions, when the members of the committee knew that he would not respond. Despite Williams’ justifications for pleading the fifth amendment, Baker’s refusal to testify did result in some exposure to ridicule.
B. Witnesses Who Testify Face Additional Ridicule
If Baker had chosen to testify, he would have opened himself to additional ridicule from the committee. Testifying witnesses are more open to ridicule by an investigating committee than are non-testifying witnesses, in at least two ways: 1) the witnesses might reveal embarrassing information about themselves, and 2) testimony given will lead to more specific and embarrassing questions from the committee.
1. Witnesses Might Reveal Embarrassing Information about Themselves
Because of his guilt, Baker could not have testified honestly without embarrassing himself. While dishonest testimony would probably have led to charges of perjury, honest testimony would probably have led to embarrassing information about Baker, including information about his crimes.
2. Testimony Given Leads to Additional Embarrassing Questions from the Committee
The recent Enron hearings demonstrate the way in which testifying witnesses can be exposed to embarrassing cross-examination questions from investigating committees. Like the Baker hearings, the Enron hearings involved witnesses who were also accused of crimes. Some high officials, such as Andrew Fastow, Enron’s former Chief Financial Officer, invoked their fifth amendment rights, and refrained from testifying. Others, such as Jeffrey Skilling, Enron’s former Chief Executive, chose to testify. Those who refrained from testifying faced the same type of humiliation experience decades earlier by Bobby Baker. Congressmen asked the witnesses embarrassing questions about their financial dealings, knowing that they would not reply. Those who chose to testify faced additional embarrassment in the form of cross-examination questions.
Although Skilling and others apparently intended to clear their names by testifying, their testimony was met with scorn and ridicule. After Skilling testified that he was unaware of the imminent collapse of Enron, a Republican Congressman said:
“People in far inferior positions to you could see cracks
in the walls, feel the tremors, feel the windows rattling. And you
want us to believe that you sat there in your office and had no clue
that this place was about to collapse?” 
A Democratic Congressman then suggested that Skilling’s testimony contradicted earlier testimony as to his involvement in the company’s collapse.  The committee’s ridicule of Skilling was harsher than it would have been if he had simply pled the fifth.
Committee hearings subject testifying witnesses to ridicule by forcing the witnesses to reveal embarrassing information about themselves, and by giving committee members an opportunity to ask specific, embarrassing questions in response to the testimony. Although non-testifying witnesses face some ridicule, also, they do not face these additional types of ridicule.
Because testifying witnesses are more open to ridicule than are non-testifying witnesses, it made sense for Williams to advise Baker that pleading the fifth would reduce the damage to his reputation. Preserving Baker’s reputation was Williams’ secondary goal for Baker. Although that goal could not be achieved perfectly, Baker probably did minimize his exposure to ridicule by following Williams’ advice and refusing to testify.
The two factors examined above, 1) Perjury, as a threat to Baker’s trial prospects, and 2) Ridicule from the Committee, as a threat to Baker’s reputation, illustrate Williams’ approach in representing Baker. Williams primary focus was on Baker’s impending criminal trial, while his secondary focus was on preserving Baker’s reputation. In light of these priorities, it made sense for Williams to advise Baker to plead the fifth.
Bobby Baker was convicted of several criminal charges, including tax evasion and larceny.  However, there were no charges of perjury. Although Baker’s reputation suffered from the Senate hearings and his publicized criminal trial, his reputation was probably hurt less than it would have been, had he testified before the Rules Committee. By following Williams’ advice, Baker avoided possible prosecution for perjury, and minimized his exposure to public ridicule.
1. See,Financial or Business Interests of Officers or Employees of the Senate: Hearing Before the Senate Committee on Rules and Administration, 88th Cong. 1304-62 (1964).
2. The committee intended to investigate numerous scandals involving Baker, including: 1) the deportation of Ellen Rometsch, whom Baker had set up as a sexual partner for various politicians including President Kennedy, 2) the Mortgage Guaranty Insurance Corporation’s business relations with Baker, 3) Baker’s transfers of money to Gertrude Novak, 4) vending contracts (in September of 1963, Capitol Vending Company filed suit against Baker, with charges of abuse of power that led to Baker’s resignation of his Senate position), 5) the growth of Baker’s company, the Serv-U Corporation, 6) unusual payroll practices regarding Baker’s subordinates in the Senate, 7) the Haitian-American Meat Provision Company’s payment to Baker, and 8) the sale of insurance by Don Reynolds, a business associate of Baker’s, to Lyndon Johnson. Carl T. Curtis and Regis Courtemanche, Forty Years Against the Tide: Congress and the Welfare State 247 (1986) (Carl T. Curtis was a Republican member of the Senate Rules Committee that investigated Baker).
3. Robert Gene Baker, Wheeling and Dealing: Confessions of a Capitol Hill Operator 187 (1980).
4. Financial or Business Interests of Officers or Employees of the Senate: Hearing Before the Senate Committee on Rules and Administration, 88th Cong. 1338 (1964).
5. Lyndon Johnson suspected that the Attorney General, Robert F. Kennedy, who had never liked Johnson, was using the Bobby Baker investigation to injure him. C. David Heymann, RFK: A Candid Biography of Robert F. Kennedy 364 (1998).
6. See, e.g., U.S. v. Masters, 484 F.2d 1251 (1973).
7. Edward Bennett Williams, One Man’s Freedom 32 (1962).
8. Edward Bennett Williams, One Man’s Freedom 32-33 (1962).
9. U.S. v. Icardi, 140 F.Supp. 383, 389 (D.D.C.1956).
10. Edward Bennett Williams, One Man’s Freedom 54 (1962).
11. U.S. v. Icardi, 140 F.Supp. 383, 389 (D.D.C.1956)
12. After his criminal convictions in 1967, Baker admitted his guilt. Robert Gene Baker, Wheeling and Dealing: Confessions of a Capitol Hill Operator (1980) (in this work, Baker describes his crimes and admits his guilt).
13. Financial or Business Interests of Officers or Employees of the Senate: Hearing Before the Senate Committee on Rules and Administration, 88th Cong. 1303 (1964).
14. Evan Thomas, The Man to See: Edward Bennett Williams 214 (1991).
15. Even beyond Baker’s loyalty to the President, party affiliation was a significant factor in the Baker hearings. Republicans on the Rules Committee accused Democrats of trying to defeat the committee’s efforts (e.g., by refusing to call certain witnesses), and rumors circulated that the committee’s chairman, B. Everett Jordan, was intentionally trying to protect the Democratic President. Carl T. Curtis and Regis Courtemanche, Forty Years Against the Tide: Congress and the Welfare State 260 (1986); Ben F. Bulla, Textiles and Politics: The Life of B. Everett Jordan 268-269, 279-280 (1992).
16. Don Reynolds, a business associate of Bobby Baker, claimed that he had sold life insurance to Lyndon B. Johnson, who was a senator at the time, and that a condition of the sale was that he give Johnson an illegal kickback out of his commission on the sale; he gave the kickback by buying advertising time on Johnson’s Austin, Texas radio station (he then sold the advertising time at a loss). Carl T. Curtis and Regis Courtemanche, Forty Years Against the Tide: Congress and the Welfare State 251 (1986).
17. 18 U.S.C. § 1621.
18. 951 F.2d 369 (D.C. Cir. 1991).
19. 514 U.S. 695 (1995).
20. 348 U.S. 503 (1955).
21. The IRS investigation seemed certain to lead to the criminal prosecution of Bobby Baker. However, had President John F. Kennedy not been assassinated in November of 1963, the Justice Department and FBI investigations might not have led to the criminal prosecution of Bobby Baker. The Attorney General, Robert Kennedy, had an interest in preventing a true investigation of Bobby Baker’s scandals, because Robert Kennedy’s brother, the President, was implicated in the Ellen Rometsch scandal (Baker set Ms. Rometsch up as a sexual partner for the President, but, when her connections to Communist East Germany were discovered, she was deported). Robert Kennedy controlled the Justice Department’s investigation of Baker, and was calling favors with the FBI to limit the bureau’s investigation of Baker. Taylor Branch, Pillar of Fire: America in the King Years, 1963-65 154 (1998). However, after the President was assassinated, Kennedy’s justification for restraining the investigations diminished. The new President, Lyndon Johnson, believed that, far from restraining the investigations, Robert Kennedy actively encouraged the investigations in an attempt to damage Johnson’s career. C. David Heymann, RFK: A Candid Biography of Robert F. Kennedy 364 (1998). Furthermore, even if Congress, the FBI, and the Department of Justice had cancelled their investigations, the IRS investigation would probably still have led to Baker’s conviction for tax evasion.
22. Robert Gene Baker, Wheeling and Dealing: Confessions of a Capitol Hill Operator 187-88 (1980).
23. Seth F. Kreimer, Sunlight, Secrets, and Scarlet Letters: The Tension Between Privacy and Disclosure in Constitutional Law, 140 U.Pa.L.Rev. 1, 111 (1991).
24. Lawyers constantly remind reporters that a defendant’s fifth-amendment plea is not an admission of guilt. See, e.g.,Tom Jackman, Hit-Run Unresolved, Family Undeterred, Washington Post, August 8, 2000, at B1.
25. See, e.g., Joseph S. Clark, Congress: The Sapless Branch 71-72 (1964) (Joseph S. Clark, a Democrat, was a member of the Senate Rules Committee before which Baker appeared).
26. Thomas C. Reeves, The Life and Times of Joe McCarthy: A Biography 649 (1982).
27. McCarthy’s Counsel’s Argument, N.Y. Times, September 1, 1945, at 14 (reprinting a portion of the previous day’s hearings).
28. McCarthy’s Counsel’s Argument, N.Y. Times, September 1, 1945, at 14 (reprinting a portion of the previous day’s hearings).
29. McCarthy’s Counsel’s Argument, N.Y. Times, September 1, 1945, at 14 (reprinting a portion of the previous day’s hearings).
30. Edward Bennett Williams, One Man’s Freedom 84-85 (1962).
31. 354 U.S. 178 (1957).
32. Financial or Business Interests of Officers or Employees of the Senate: Hearing Before the Senate Committee on Rules and Administration, 88th Cong. 1303 (1964).
33. Financial or Business Interests of Officers or Employees of the Senate: Hearing Before the Senate Committee on Rules and Administration, 88th Cong. 1360 (1964).
34. Financial or Business Interests of Officers or Employees of the Senate: Hearing Before the Senate Committee on Rules and Administration, 88th Cong. 1348-51 (1964).
35. William Neikirk, Skilling: I Didn’t Know, Chicago Tribune, February 8, 2002, at 1.
36. William Neikirk, Skilling: I Didn’t Know, Chicago Tribune, February 8, 2002, at 1.
37. The convictions were for two counts of tax evasion, two counts of grand larceny, one count of transportation of stolen money, one count of fraud and false statements, and one count of conspiracy. E. W. Kenworthy, Baker Convicted on 7 of 9 Counts; Plans to Appeal, N.Y. Times, January 30, 1967, at 1.