Some of this chapter is in the book, in the chapter called, "War." The "seven charges" referred to near the start are the allegations made against me in August 2001 by the Siegelman administration, in a letter to the paper's publisher, Howard Bronson. The charges are listed in full on the front of my web-page (go to the right column and scroll down.)
“Aside from the outburst, Mr. Andrews said, Mr. Curran had shown bias by ‘editing’ an ethics complaint filed against Governor Siegelman by a political opponent. Seeking comment, Mr. Curran had faxed the governor’s office a draft of the complaint, bearing two scrawled question marks and some highlighting. When the final complaint was filed, the governor’s staff contended that Mr. Curran had edited it.”
-- From of Oct. 8, 2001, story in the New York Times bearing the headline, “Governors’ Limits on Press Raise Concerns.”
“I therefore request not only that Ziegler’s politically motivated allegations be summarily dismissed, but that the Commission consider investigating the circumstances that led to the filing of the complaint, and that it take all appropriate actions against the responsible parties.”
-- Aug. 1, 2001, letter from Ted Hosp to Ethics Commission Director Jim Sumner, in which the governor’s lawyer asked the commission to consider investigating me for assisting Zeigler with his complaint against Siegelman.
In March 2006, Roll Call, the Washington newspaper devoted to covering Capitol Hill, published a piece about, of all people, Mobile lawyer Jim Zeigler. “Botched-Bill Plaintiff No Stranger to Controversy,” was the headline above a story about a lawsuit filed by Zeigler.
He’d seen where the $39 billion budget reconciliation bill signed in February by President Bush contained a major snafu. Roll Call reported that, “embarrassingly, the language in its House and Senate versions did not match up” and that it “was only a matter of time before someone filed suit to block it.”
As it turned out, the man who decided to stick a finger in the eye of Congress and the White House by filing a federal lawsuit is no stranger to controversy.
Jim Zeigler, a conservative Alabama lawyer and two-time Bush convention delegate, has a long history of antagonizing his state’s political establishment. In interviews with a range of Alabama political insiders, the 57-year-old Zeigler was described as a “gadfly” only slightly more often than he was labeled “a maverick.”
Over the years, Zeigler has filed numerous ethics complaints against an array of state officials and politicians, from city councilman to governor. He’s also represented everyone from protesters who want to post the Ten Commandments in public spaces to a citizens group opposed to private development at a state park.
Of the seven charges presented to Mike and Bronson on Aug. 17, one troubled me more than the others combined. It was the accusation that I conspired with Zeigler in bringing his ethics complaint. File this one under, “No good deed goes unpunished.”
Reading the allegation in the New York Times was the last straw. A charge like that in a newspaper as widely read as the Times posed a threat to my livelihood. (The story, which was quite fair, and also addressed problems between the Minnesota press and then governor Jesse Ventura, and is discussed in the chapter, "War.")
The next day I wrote a letter to Carrie Kurlander, Rip Andrews (both with Siegelman's press office), Hosp (Ted, the governor's general counsel), Siegelman, (chief of staff) Jim Buckalew and (outside legal advisor) Boots Gale, and which I ran by my editors before sending. It didn’t contain a threat of litigation but perhaps implied as much. It must have worked, as the administration never again repeated the charge.
I wrote that Andrews and Kurlander – for this was a last names sort of letter – had “made the Zeigler charges in their roles as spokespersons, and have on some occasions stated to Alabama reporters that I assisted Zeigler in writing the complaint.”
“Last week, Andrews repeated these charges to a reporter for the New York Times. I like to think I could have cleared up these misconceptions on your part had one of you merely taken the time to call or write me. Because you continue to make these charges against me, and in such public forums, this seems like a good time to once again tell you my side of this affair, unsolicited though it is.”
Exhibit one in my defense is, well, Jim Zeigler.
In 1974, at age 25, the former president of the University of Alabama Student Government Association ran for a spot on the Alabama Public Service Commission, and won. This marked him as a young star on the rise. Zeigler, though, was already on the cusp of his legendary losing streak. Halfway through his term, he ran for chairman of the PSC, and lost, as he did in his next race, for the Alabama Supreme Court. His record in statewide elections is now one and seven. (He was, however, twice elected by Republicans to serve as a delegate at the national convention, in 2000 and 2004.)
His second claim to fame is as a serial filer of ethics complaints and taxpayer lawsuits. Citizen Jim struck first in 1983, when he brought an ethics complaint against attorney general Charlie Graddick and sued state auditor Jan Cook. He subsequently became the driving force behind the Taxpayer Defense Fund, which existed to file ethics complaints and taxpayer lawsuits. Others targeted by Zeigler included Attorney General Jimmy Evans and Public Service Commission President Jim Sullivan.
The last time I’d spoken to Zeigler was three years prior, for a story on dueling lawsuits between him and Craig Pittman (at this writing, a state appeals court judge.) It was not a substantial lawsuit, but had, or so I thought, laughs value.
Zeigler had formed a company to settle disputes through mediation rather than costly, time-consuming lawsuits. Pittman operated a mail-order business on the side and entered a partnership to promote Zeigler’s services. The two advocates of sensible dispute resolution got into a scrap over money and sued each another.
“It’s kind of sad that I’m dealing in an area trying to prevent litigation. I’ve named my one-man firm Zeigler Litigation Prevention and yet I’ve got involved in a case myself,” said Zeigler, adding, “You can’t prevent them all.”
Fast forward to July 24, 2001, two days after our first stories on Siegelman’s legal fees. Zeigler faxed a press release to my attention, along with a taxpayer lawsuit demanding that Siegelman refund to the state the legal fees paid him by Cherry Givens.
He declared his intent to file the lawsuit two days later. Paul and I agreed it was either a non-story or, at most, worthy of a graph or two in our next story. I e-mailed Carrie and Rip to inform them of Zeigler’s plans and said we considered it a non-event.
Two days later Zeigler left me a voice mail saying he’d decided against suing Siegelman. He was on his way to Montgomery to file an ethics complaint, a copy of which, he said, had just been faxed to the paper. Far as I can tell, neither citizen’s lawsuits nor ethics complaints have much chance of bearing fruit, but given the choice, an ethics complaint is the smarter call. The administration later sought to link me to this decision that was made, far as I know, solely by the most prolific filer of ethics complaints and taxpayer lawsuits in state history.
An ethics complaint was more of a story than a citizen’s lawsuit, but in large part because of who was filing it, we decided not to make a big deal of it, and to run it on an inside page. Regardless of the strength of a complaint, if brought by Zeigler it’s subject to attack, like a weather report from Chicken Little.
As always when reviewing documents, I read the complaint with pen in hand, circling this, underlining that, scribbling stars, question marks, check marks, what have you. I do this to prevent having to hunt for the important bits when it comes time to write. I made markings on four of the six pages. Those on one page generated the bulk of the case against me.
As previously explained (in a chapter about legal fees paid to Siegelman after he became governor), Cherry Givens was receiving fees South Alabama by way of the Siegelman-authorized state settlement; and from placement on Exhibit S of the national settlement. For the last one, I had reported that Cherry Givens was due an unknown share of a reported $7 million fee to be split among several law firms.
Page four of Zeigler’s complaint alleged that Siegelman used his public position to ensure Cherry Givens placement on Exhibit S. He asserted that “the firm gained $2.8 million” from that.
Lower on the page, Zeigler wrote that the firm “gained $2.8 million” from Siegelman’s “manipulating the $20 million settlement for USA …”
As I pointed out in my October letter to Siegelman, Carrie, Hosp and the others (a letter described in the chapter called, "War"), I “noticed that Zeigler’s complaint included the figure $2.8 million in two different places, and representing two different sums of tobacco related legal fees.”
Upon seeing this, I had circled each $2.8 million, connected them with a line, then scribbled two question marks. (See record below.)
Back to the letter:
Though I think I’m pretty familiar with both the tobacco cases, I have never been told, nor seen it reported elsewhere, that any of the several firms slated to share in what has been estimated as a $7 million fee was to receive $2.8 million or, for that matter, any specific amount. It’s an unknown, at least to me.
Did Zeigler get this from somewhere else? Or did he have it confused with the other $2.8 million? As I've probably stated to you on many previous occasions, I consider it my job not merely to present numbers, facts and comments as presented to me, but to do my best to make sure those numbers, facts and comments are indeed correct. The purpose being: Don't give the reader bad facts.
I needed comment from Zeigler and the governor’s office. I figured Zeigler, driving to Montgomery, would be in cell phone dead zone, so put off calling him. As for Siegelman, how could he or his press folks respond to an ethics complaint they hadn’t seen?
I e-mailed Carrie, informing her that Zeigler had changed his mind on the lawsuit, was on his way to Montgomery to file an ethics complaint, and had faxed us a copy. I wrote: “I’d be glad to fax you this complaint. In any event, would want to get some kind of comment.”
She took me up on the offer, and I faxed her what was to become the evidence against me.
I waited a couple of hours to call Zeigler, though not long enough. Had I waited a few extra minutes, all this silliness could have been avoided.
When I reached Zeigler, he said he’d just that moment parked his car outside the particular Bronner building that housed the Ethics Commission. I was nearing deadline, and asked if he could answer a few questions while I had him on the phone.
Chief among them: Was the first $2.8 million -- the one described as being paid to Cherry Givens from national tobacco settlement -- correct? Was it possible he got that mixed up with the $2.8 million fee from the University of South Alabama settlement?
Jim said something like, “Oh, you’re right. I’ll have to change that.”
His response registered as trouble. Call it hyper-sensitive or hyper-alert, but I was, had been for months, in a high-pressure situation with the administration. I was, in their eyes, the enemy, and to be discredited if at all possible. I immediately realized that I'd sent Carrie my marked-up copy, and now, prior to filing what would be the official copy, Zeigler was going to change it based on a question I asked.
He said he had a laptop and a portable printer and could fix the complaint right there. I concluded by asking him to call me after he filed it, in the event the Ethics Commission was closed or he got run over crossing the street. The last thing I wanted to do was report an ethics complaint against the governor if one had not been filed.
Our story the next day quoted Zeigler calling his complaint the “first step in the impeachment of Don Siegelman.”
“He will not finish out his first term as governor. What Don Siegelman and his supporters have done is 100 times worse than what Guy Hunt was convicted of,” Zeigler said.
Countered the administration in a statement e-mailed to us that afternoon:
“Mr. Zeigler’s history of antics and frivolous complaints are well documented. To misuse and abuse the process for political purposes is absurd. These false claims are among a long list of deranged acts by a man who believes America is being surrendered to a New World Order and who has stated that the public education system has been taken over by communists.” (See note at bottom.)
Like the pea under the princess, Zeigler’s decision to change the complaint based on my question continued to trouble me. So – another grievous error – late that afternoon I dashed off an e-mail to Hosp in sloppy as opposed to letter form.
Wrote I, verbatim, and in the grip of full-disclosure fever:
Ted...wanted to tell you something to clear something up in case you noticed it. when I faxed y’all copy of zeigler’s filing, it was what he’d faxed me before heading up to Montgomery…he left message for me to call him on cell phone..when i asked him about something I didn’t understand and thought was incorrect, and wanted to make sure in case I reported it…was about the $2.8 million fees to firm on exhibit S and such, which he had on his complaint.
Well, the $2.8 million was from the USA settlement, as you know…he said, hey, your right. He called me back later after he filed it, since I wasn’t going to do story unless I knew it had been filed. He said he had his laptop and changed the thing I pointed out when I asked him, and filed corrected version.
Since y’all have copy I faxed to you, which has a question mark on that spot, and since y’all will see the copy he actually filed, I just didn’t want you think I was conspiring with this guy to assist him on his ethics complaint.
I can promise you that I did not.
Probably it was my paranoia did me in, that they would not have noticed the changes in Zeigler's complaint had I not e-mailed Ted and spelled it out for them.
The allegation that I aided Zeigler first came to our attention on Aug. 17, in the seven sins memo presented to Bronson. In late September, when we decided to publish a story on their allegations, an unfortunate Jeb Schrenk drew the assignment.
Like subjects of all our news stories, I wasn’t permitted to review the piece prior to publication, and like subjects of many stories, I bitched and moaned after reading about myself in the paper. I was chafed by Jeb’s use of the word “draft” to describe the copy of the complaint faxed me by Zeigler. I felt it implied that the complaint was a work in progress when I received it, and whined that use of the "draft" supported the administration’s charge.
In the weeks after the story, the Register’s public records battle with the administration became a much-written about issue statewide. Increasingly, Rip and Carrie focused on the Zeigler allegation to sully me and the paper.
Because of the administration’s focus on the Zeigler case, the editors decided to do another story, this time addressing only that charge. In his back and forth with the administration, Jeb learned of two new incriminating pieces of evidence, the first, as presented here in his story:
Andrews said an e-mail Curran sent Ted Hosp, Siegelman’s legal adviser, also points to Curran’s involvement.
After Zeigler filed the complaint, Curran sent the e-mail explaining that Zeigler amended his complaint. The change dealt with the $2.8 million figure. Curran said he sent the e-mail to assure the administration, which had already received the copy with Curran’s notes, that he did not intend to help Zeigler.
Curran’s e-mail references the $2.8 million figure and states Zeigler “called me back later after he filed it. ... He said he had his laptop and changed the thing.”
Andrews said Curran’s comment about the laptop is not consistent with the fact that the notes (corrections) Zeigler made were handwritten.
They were saying that the order of the sentences in my e-mail to Ted proved the conspiracy or in any event, supported it. I can only suppose that in my haste, the bit about Zeigler changing the complaint on his laptop entered my brain after the part about him calling to report that he’d filed the complaint. The sole purpose of the second conversation was for Zeigler to confirm he’d filed the complaint. It lasted, maybe, five seconds. He didn’t say anything about the manner in which he’d corrected the complaint. I certainly didn't ask, or, for that matter, give half a damn.
As it turned out, Zeigler had changed the incorrect first “$2.8 million” by hand, not with computer and printer, as he’d told me he intended do and as I’d told Ted that he'd done. Therefore, I lied.
Their theory failed to explain why my co-conspirator would call me after filing the complaint to report that he’d made the changes with computer and printer if he’d done so by hand. Nor did it suggest a motive for me to declare that Zeigler made the change with a printer if he did so by hand; or how I could be so stupid as to tell Ted the complaint he had in his hands was changed with a printer if I knew otherwise.
I'll grant them this victory: They’d proved that in my e-mail to Ted I’d presented two inconsequential events out of order, and one – based upon my assumption that Zeigler changed the $2.8 million with a printer -- was incorrect.
The whole thing was maddeningly convoluted, as it is here, trying to explain it.
In my letter following the New York Times article, I told Team Siegelman that I “continue to be mystified as to the significance of the manner in which it was changed, be it by laptop/printer or handwriting.”
For our story, Jeb called Zeigler and, I like to think, shattered this aspect of the conspiracy.
“Zeigler,” wrote Jeb, “said he had planned to make the changes on his laptop and that’s what he told Curran before filing the complaint. But after talking with Curran, Zeigler said he realized his printer wouldn’t work without a power source, so he made the changes by hand.”
More problematic was another new clue. Someone in or associated with the administration, a sleuth of Holmesian powers of observation and deduction, had proved beyond a shadow of a doubt that I’d assisted Zeigler.
This ace detective, apparently with magnifying glass in hand, noticed something on the final page of Zeigler’s complaint. At the top of the page, the typed word “four” was crossed out in the sentence: “I expect to call the following witnesses to prove the four ethics violations against Don Siegelman.” (See records below.)
Above the crossed out “four” was a “five” – spelled out and handwritten.
The administration had at least two copies of the complaint -- the “pre-edited” version I’d sent them with my scratchings; and a copy of the actual complaint, or in any event one of the copies delivered to Montgomery for dispensation by Zeigler.
When Jeb called to say we’d be doing a story on the Zeigler-Me conspiracy, the Siegelman press office faxed him the goods: The last page from the marked-up copy I’d sent them and the same page from one of the other copies.
Jeb was told to examine the differences in the two fives. And they were different, though not, mind you, in appearance. It was obvious or should have been to anyone not legally blind that both came from the same hand. The discrepancy regarded the placement of the “five” over the crossed out four. One was about a half-centimeter to the left of the other.
Thus, the charge: While Curran was editing the complaint he noticed that the four should have been a five, crossed out the four, and wrote a five above it. He alerted Zeigler to this error and Zeigler, in his own hand, changed the fours to fives on his other copies, including the one bound for the Ethics Commission.
Our story reporting the complaint didn't mention the number of charges against Siegelman. It was an ethics complaint. Probably only Zeigler, as a lawyer, would break such a thing down to “charges.” Four, five, two or twenty, it didn’t matter to me nor, it’s my guess, the ethics commission. Utterly irrelevant.
But I was, as I later acknowledged in my letter to the Siegelman gang, without ready explanation for this teeny-tiny disparity. “I knew immediately it wasn’t my handwriting, and that it was obvious that the same person who crossed out one four and wrote five was the same person who did the same thing on the other copy. Otherwise, I admit, I was flummoxed. Why would the complaint faxed to me from him and which I subsequently faxed to you have slightly different markings?”
Jeb and I still laugh at what I did next. I grabbed a pen and started writing fives. “See, mine are in cursive! I don’t print! Look!”
Paranoid that Jeb might think me trying to write them differently, I bolted to my desk and ransacked my notes looking for prior examples of my fives-manship, found something and showed it to him.
But Jeb, steeled as he rightly was against efforts by me to steer the story this way or that, stuck with his guns. He said he wasn’t in a position to declare that the “fives” were in my handwriting or not.
Well then, I said, I’ll find a damn handwriting expert. I called a lawyer in Mobile known for working on complicated litigation. Yes, he said, he occasionally used a hand-writing expert. The guy lives in Atlanta and charges thousands of dollars. I punted on the handwriting expert defense.
I saw no choice but to call Zeigler and ask him to solve the riddle, which he did. After printing out several copies of the complaint, he’d noticed that the five should be a four. He decided it was a minor change, and fixed it by hand rather than re-print the complaints. In other words, the handwritten “editing” on that portion of the complaint occurred before he faxed it to me.
I told Jeb, who turned out to be the real Sherlock Holmes.
"Do you still have your copy of the ethics complaint, the one that you faxed to the governor’s office?” he asked.
Jeb explained that the five on my copy should be mimeographed, since it was copied by the fax machine. But all the other markings on my copy, including the devious circles around the two $2.8 millions, would be in my virgin blue ball-point ink.
There was a flipside. If the five on my copy was in virgin ink, I was toast. That would show I’d changed it myself. I knew I hadn’t, but also knew I had to prove it. I raced to my desk. I was tossing papers about, not believing I couldn’t find it and sure that Jeb would suppose I couldn’t because I didn’t want to. We eventually located the original in Mike Marshall’s office.
“Sure enough,” as I later wrote Carrie, Hosp, et.al., “it showed my un-copied ballpoint markings, clearly in ballpoint ink, and showed that the crossed out four with the handwritten five was in mimeographed form, such as a copy from a fax machine. In other words, there was some hand-writing -- the crossed out four and the hand-written five -- when the complaint came to me that day.”
I concluded with a self-righteous flourish:
I hope this explanation has satisfied your concerns about my so-called role in the filing of the Zeigler complaint.
In the future, prior to making public allegations against me, I would ask you to provide me with the opportunity to respond. As a reporter, I make every effort to get the responses of people I’m writing about. It may be, though, that the ethical rules that govern political public relations are different, and that from now on, I need to be aware of that.
Because of the widespread dissemination by the administration of the charge that I conspired with Jim, his continued activities on the Siegelman front -- at least two citizens lawsuits, another ethics complaint, and multiple press releases, though some related to Birmingham News stories -- caused me some discomfort. For that I couldn’t blame him. He was just being Jim, doing what he’d been doing for 30 years.
In mid-August, two weeks or so after he filed the legal fees complaint, he amended and re-filed it and sent me a copy. Attached was a letter. “If you are not able to use it, I would then send it to AP, who is following this story, but I thought it only right to give it to you exclusively if you find it usable. Also, your level of understanding of this story exceeds everybody’s, including mine.”
As a courtesy, I called Jim to tell I would not be reporting on it. He acknowledged that his real motive in amending the complaint and seeking coverage was to keep the heat on the Ethics Commission, which he didn't trust.
About a year after the Zeigler matter, my father and I were driving down Old Shell Road in Mobile when we broke out laughing. There, at the intersection of Old Shell and McGregor was Uncle Sam, erecting a political sign.
Under all that red white and blue regalia, top hat and fake white beard, was the one and only, Jim Zeigler.
Four years later, while rummaging through the Siegelman archives, I came across a letter from Hosp to ethics director Jim Sumner. It was dated Aug. 1, 2001, two weeks before the administration’s seven-sins letter to Bronson, and about two months before our first story on their accusations.
Ted laid out the Zeigler-Curran conspiracy and included as attachments documents with which I was long familiar. (See letter below.)
Exhibit A was the press release and lawsuit Zeigler had planned to file. Hosp was able to provide this to Sumner because I’d faxed it to Rip, as it happened, a few hours before my telephone tirade. Because Zeigler never filed the lawsuit, the administration hadn’t seen it. Rip had e-mailed to ask if I could send it to him, which I did without second thought, and including the accompanying “press release.”
In hindsight, it appears that they'd started building their case against me before I blew up at Rip.
I don’t recall the pretext the little turd used to request the un-filed lawsuit, though I'm sure I would have had he told the truth.
Ted noted in his letter to Sumner that Zeigler’s press release was directed to me and me only. I assume he directed it to me because I’d written the damn story it was based on. I'd wager a princely sum that he sent similar press releases to and only to the reporters at the Birmingham News when he filed compaints and or citizen lawsuits based on their stories.
The conspiracy deepened when Hosp told Sumner it appeared that, “Mr. Zeigler originally intended to file a taxpayer lawsuit against the Governor, but later was convinced for some reason to file an ethics complaint instead.”
Convinced for some reason? It didn’t take a semantics expert to translate that one into, “Curran talked Zeigler into filing an ethics complaint.”
Hosp reported that the governor’s office received a copy of Zeigler’s complaint from me several hours before it was filed; and that it contained “two markings on it that I ask you to pay particular attention to.” These were of course my question marks next to the two $2.8 millions on the one page and the hand-written fives on the other.
The “five” on the complaint delivered to the ethics commission was “clearly in different handwriting from the version we received from Mr. Curran,” said Ted, be he blind or bluffing, take your pick.
From there, he ratcheted things up. The governor’s lawyer declared that since I’d “received, reviewed and edited the complaint, it further seems likely that this complaint should have been filed by Mr. Curran himself.”
Then: “As you know, it is a violation of the ethics laws to ‘file a complaint for another person … in order to circumvent’ the ethics laws.”
“In conclusion, based on the documents attached, I do not see any possible conclusion other than Mr. Curran actively participated in the filing of Mr. Zeigler’s ethics complaint by editing that document to make it consistent with Mr. Curran’s mistaken understanding of the facts.”
Having made his case, Hosp asked Sumner to dismiss Zeigler’s complaint and instead consider investigating the circumstances behind the filing and “take all appropriate actions against the responsible parties.”
I’d known they’d tried to get me fired, but never could I have imagined them requesting an ethics investigation of me. A reporter investigated by the Alabama Ethics Commission? It was past bizarre.
Here was Ted Hosp, who far as I was concerned helped enable the whole scheme. He had signed the secret $20 million South Alabama settlement on Siegelman’s behalf, as if doing so relieved Siegelman of responsibility for an arrangement to route $2.8 million in state money to the same firm that was at the same time in negotiations with Siegelman that were to lead to payments of almost $1 million to the governor.
If Ted didn’t know in December 1999 about the whopping sum going to Siegelman from Cherry Givens, he did by the time he wrote the letter to Sumner. He knew it because the Associated Press reported Siegelman’s ethics filings in June, and because I’d written my stories the week before his letter.
Ted should have been turning in his boss to the authorities. A second option: Resigning because he could no longer tolerate being a party to those activities and many others. Instead, he sought an ethics investigation of me.
Reading Hosp’s letter years later in the quiet archives room, I thought to myself: “Ted, you can kiss my ass.”
Zeigler called me after the Siegelman administration accused him of saying that the public education system had been taken over by communists. He said something to this effect: "Well, heck, my wife is a principal at a public school."
I gulped, and asked if his wife was one and the same as Jackie Zeigler, the principal at Mary B. Austin, the elementary school attended by my son Jerry. The answer was yes. I told my editor and we deemed it unnecessary to reveal this to Team Siegelman. At the time, Jackie had been there maybe one year and I'd had no cause to go the pincipal's office, much less meet her husband.
I would come to know Jackie later, when my daughter, Eva, attended Mary B., and was a classmate of the Zeiglers' cute daughter, Maggie, During those years I had the pleasure to see Jim at a number of school events and birthday parties.
His wife, I will add, is an extraordinary principal. Now, moving on to the documents referred to in the chapter...
The following is the page from the complaint faxed to me by Zeigler and which I made notes, or rather, circles, lines and question marks, after which I ever-so-kindly faxed it to Siegelman's press office. This became the chief piece of evidence in support of the administration's charge that I helped edit the complaint prior to Zeigler filing it.
This next record is the final page of Zeigler's complaint, where he changed four to five. The first one is the copy faxed to me by Zeigler which I then faxed to Siegelman's press office. The handwritten notes are all mine with one exception -- the crossed out four and the five written above it. Below this is one of the copies of the complaint taken to Montgomery by Zeigler, without my notations but with the four crossed out and changed to the telltale five.
Below, the other copy.