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Bardach's article begins with Mas's August 1994 meeting with Clinton: "When Jorge Mas Canosa sauntered out of the White House Cabinet Room on August 19 A following a 90-minute meeting with the President of the United States, he was irrepressibly gleeful. Although the combative, scandal-plagued mega-millionaire has long dominated Miami and, to some degree, Florida politics from the bully pulpit of his coffer-rich Cuban American National Foundation, Mas had just pulled off the coup of his career -- dictating America's new Cuba policy."
From Bardach's deposition:
Hank Adorno: Tell me the source or sources of the factual information which is included in the first paragraph of your story.
Bardach: Some of the sources that I can recall at this moment are the Miami Herald, and the actual facts of the meeting were in the Miami Herald...and somebody I spoke to at the State Department.
Adorno: And who's that?
Bardach: He wishes confidentiality.
Adorno: Was that person at the meeting?
Bardach: I don't know.
Adorno: Did you ask him whether he was at the meeting?
Bardach: I don't recall.... Everybody learned of the meeting very quickly. It spread through the exile community here instantly. And I talked to people at Cambio Cubano about it. [Cambio Cubano is a Cuban-exile group philosophically at odds with CANF.]
Adorno: The Cambio Cubano individuals...were any one, either one of those individuals at the meeting?
Bardach: No, they heard about it through the grapevine.
Adorno: Did you seek to interview any of the individuals that actually attended the meeting, other than Jorge Mas Canosa?
Bardach: No, I relied on the Herald.
Adorno: What do you mean by the word sauntered?
Bardach: You know, walked out, you know, walking but with a bit more of a lilt in the walk.
Adorno: And who described him? You didn't see him walk out, did you?
Bardach: I was told he was very, very pleased with himself.
Adorno: Who told you that?
Bardach: The State Department and the Cambio Cubano people.
Adorno: None of which were at the meeting?
Bardach: I'm not sure about the State Department, so yes, that's the answer.
Other, more controversial passages in Bardach's article relied on similarly vague or biased sources. For example, she claimed that CANF had "pulled off the feat of securing millions of dollars from government grants, funneling the funds through its various umbrellas and PACs, such as the Free Cuba Committee, and then paying much of it out to favored politicians and causes."
From Bardach's deposition:
Adorno: What millions of dollars have they secured from government grants?
Bardach: This is based on the research and published work of John Nichols in the Nation, [a politically liberal weekly], and other published sources.
Adorno: First of all, did you do any independent research to determine what government grants -- meaning did you go to the governmental agencies and speak to them, or did you just get this information from a published source?
Bardach: Published sources.
Adorno: All I'm trying to establish is that you're going to find out almost all of that is incorrect.... Was it your intent in these two sentences to state that CANF, using its nonprofit, tax-exempt status, gets [government] grant money and then somehow funnels it to political causes?
Bardach: Yes, the point being that there have been published articles questioning the nonprofit status of CANF because of its political lobbying, to the extent of its political lobbying. And this is just a reference to all that material that has been written about that aspect of CANF.
Adorno: Do you know whether CANF has an audited financial statement by a Big Six accounting firm?
Bardach: I do not know.
Bardach's reporting technique -- imaginative extrapolation from news accounts -- led to a series of minor errors in her article. For example, she stated that Clinton received almost $300,000 in "Mas-controlled Cuban exile money" after attending a fundraiser at Victor's Cafe. The accurate sum was about half that amount. During her deposition, Bardach admitted she did not speak with Jorge Perez or Paul Cejas, organizers of the event. "I did not investigate who was the fundraiser, who hired the hall, who paid the bills," she said. "All I know is that [Clinton] left with contributions and pledges for a significant amount of money."
"Of which you attribute to Mas, correct?" asked Adorno.
"To Mas's friends and associates," replied Bardach.
Other errors ran the gamut from trivial (the location of Mas's home and placing Joe Carollo in office when he wasn't) to the serious (claiming Mas "dismissed" a Radio Marti executive who in fact resigned, and misstating Mas's position regarding the detention of Cuban balseros).
Still more mistakes were contained in passages characterized as defamatory by Mas and his attorneys. For instance, Bardach described Mas as "a good friend" of anti-Castro terrorist Orlando Bosch, "who served eleven years in a Venezuelan prison for blowing up a civilian Cuban airplane."
As Adorno pointed out during Bardach's deposition, Bosch was acquitted by the Venezuelan Supreme Court because of lack of evidence. "I wasn't even aware of the acquittal at that time," Bardach responded. "I didn't learn about the subtle perambulations that happened later. All I knew at that time was that he had done the jail time. I operated under the assumption that you don't do long sentences unless you are convicted." Bardach admitted she did not review any court records or speak to either Bosch's lawyers or the prosecutors involved.