|Testimony of Dorothy Kilgallen on direct
examination by Martin Garbus:
Q. Miss Kilgallen, other than being a housewife, do you have any other
A. I'm a writer and I appear on television.
Q. By whom are you employed?
A. The New York Journal American, 220 South Street.
Q. How long have you been employed by the New York Journal American?
A. Since 1931.
Q. In what capacity are you employed by the Journal American?
A. As a Broadway columnist.
Q. What does that involve?
A. It involves motion pictures, theater criticism, notes about famous
people, occasionally politics. Mostly show business, night clubs, theaters
Q. Do you write a daily column for the Journal American?
A. Six days a week.
Q. Is that column syndicated?
A. It's syndicated by King Features Syndicate.
Q. And where does that column appear as a result of the syndication?
A. It appears in newspapers throughout the country, in various cities
from Maine to Texas and in Canada and in Australia and other places.
Q. And is it part of your duties to attend night clubs, theaters and
A. Yes, it is.
Q. Is it fair to say that during the course of your employment by the
Journal American, or your syndication, you have seen all the major night
clubs, theaters or movie openings during the last ten or fifteen years?
A. That is true.
Q. Have you had occasion to see the defendant Lenny Bruce perform?
A. Yes, I have.
Q. When was that?
A. I saw him first in Chicago. I was visiting friends there and he
was just coming up, I guess, just becoming very popular and they took me
to see him. . . . I was very much impressed.
Mr. Kuh: Excuse me, I ask, with due respect, Miss Kilgallen, that any
criticism at this point--
Judge Murtagh: I will suggest that the witness confine her answer to
the question. We will strike that out.
Q. Did you have occasion before today to read the transcripts that
were previously marked as the State Exhibits numbers 4A and 5A?
A. Yes, I did.
Q. --which relates to performances of Mr. Bruce on April 1, 1964 and
April 7, 1964?
Q. Do you have an opinion, Miss Kilgallen, as to the artistic merit
of the contents of the performances that are set down in the transcripts
marked as People's Exhibits numbers 4A and 5A?
Mr. Kuh: May I, if it please the Court, before that question is answered,
may I have a very brief voir dire on the qualification of Miss Kilgallen
as an expert?
Judge Murtagh: Yes, you may.
Mr. Garbus: May I, before Mr. Kuh goes into the voir dire, qualify
her further, if there is any question at all?
Judge Murtagh: All right, you may.
Q. Miss Kilgallen, have you for the past several years had a radio
program concerning itself with drama and theater criticism?
A. Yes, for seventeen years until a year ago last April.
Q. On what station did it appear?
Q. Are you also a television performer?
A. Yes, but not in a critical sense.
Mr. Garbus: I have no further questions with respect to this witness'
qualification unless it becomes necessary after Mr. Kuh's voir dire.
Voir dire by Richard Kuh:
Q. You wouldn't be offended by my questions. I suggest you may not be
an expert in certain areas. You will answer them candidly and recognize
that you do your job for the newspaper and I do my job in here.
Q. Now, Miss Kilgallen, you have mentioned working for the Journal
American. Is your column called 'Voice of Broadway'?
A. That's right.
Q. Is that essentially a column of chit chat, gossip, information,
viewpoints on a host of things?
A. It involves a host of things, I don't know what you would interpret
as being essential. It's essentially what I think about things and what
appeals to the public.
Q. Somewhat then--I hope you wouldn't find this analogy distasteful--but
your version, if you will, of what Walter Winchell does in a somewhat different
A. He's the daddy of us all.
Q. Now, does the Journal American employ a drama critic besides yourself?
Q. Does it employ someone who reviews new shows at night clubs other
A. They employ various people to do that when they are not sure whether
I will cover it or not. I don't have to cover anything I don't wish to,
but I am the primary person covering it on the Journal when it comes to
Q. And apart from your column of chit chat or call it what we will,
'Voice of Broadway,' do you from time to time leave New York and go elsewhere
on special assignment for matters of weeks and months?
A. That's correct.
Q. And during that period, of course, your work is not concerned with
a critical coverage of theatrical performances?
A. Unless it's a critical coverage of a performance in another city,
which has happened.
Q. . . . Is there an organization of New York City Drama Reviewers?
Q. Are you a voting member of that organization?
A. I don't belong to it at all.
Q. Is there an organization of New York Movie Critics that functions
in a similar fashion?
A. I'm not sure about that.
Q. In any event you are not a member of that organization?
Mr. Kuh: If your Honor please, with great respect for Miss Kilgallen
and the interesting work that she does, I submit that the whole question
of expert testimony in this area is extremely dubious to start with and
I think that is compounded by the fact that Miss Kilgallen is not the Journal
American's expert critic, I think that to call her to give expertise would
be straining something that is already far strained.
Judge Murtagh: The Court quite agrees that perhaps the witness' qualifications
are not what they should be, but will permit the witness to testify.
Mr. Kuh: The people then have, with due respect again, a continuing
objection noted to anything Miss Kilgallen may say from this point on.
Mr. Garbus: I think the record indicated, as your Honor knows, that
she has covered every opening in New York in the field of drama, the theater
and the movies for the last fifteen years....
Direct examination by Martin Garbus:
Q. Do you have an opinion then, Miss Kilgallen, as to the artistic merit
of the contents of Mr. Bruce's performances, the performances as set forth
in People's Exhibits numbers 4A and 5A?
A. Yes, I do.
Q. What is your opinion?
A. I think he's a brilliant satirist, perhaps the most brilliant that
I have even seen and I think his social commentary, whether I agree with
it or not, is extremely valid and important and I have enjoyed his acts
on several occasions. I did not see the one that is in question here, but
I read it. Of course, it is impossible to judge completely without having
heard his voice and seeing his gestures, but I can say that on the occasion
when I saw him I was very impressed with his intelligence, with his material,
with his ability to comment on events of the day straight out of a newspaper,
which was objectively ad- libbed.. . .
Q. And would your answer be the same, Miss Kilgallen, if your answer
were restricted solely to the performances in exhibits--People's Exhibits
4A and 5A?
A. Yes, I believe it would.. . .
Q. With respect to the performances, these transcripts, People's Exhibits
4A and 5A, would you characterize Mr. Bruce as a brilliant comic?. . .
A. I still think that, having read the transcripts, that he is a very
brilliant man and that he has great social awareness, that basically he's
an extremely moral man and is trying to improve the world and trying to
make his audiences think, which, I think is a very good thing and very
moral and to be applauded. . . .
Q. You described Mr. Bruce as a moral man, by virtue of the material
contained in the transcripts identified as People's Exhibits 4A and 5A.
Would you amplify on that a bit? What are the morals that Mr. Bruce is
A. Well, he seems to be concerned with almost every moral issue that
there is. He seems to be concerned with religion, with civil rights, with
the behavior of people in a given situation and he seems to want things
to be better.....
Q. Miss Kilgallen, in the transcripts the words 'mother fucker,' 'shit'
and 'ass' are found, isn't that correct?
Q. Will you please describe for the Court the manner in which those
words are used?
A. Well, I have heard these words--
Mr. Kuh: If your Honor please, excuse me, Miss Kilgallen, I will object
to asking for the manner in which they are used; the manner speaks for
Judge Murtagh: Sustained.
Mr. Kuh: If she's asked for a critical appraisal, I have another objection
Q. Are the words 'cock sucker,' 'fuck,' 'shit' and 'ass' and 'mother
fucker' used in the transcripts?
A. Yes, they are.
Q. In what way are they used?
Judge Murtagh: I think the transcripts speak for themselves, Counsellor.
Mr. Garbus: I don't believe they do.
Judge Murtagh: I don't intend to confine an expert witness . . . but
I suggest you use the witness not merely to reproduce something that is
already in evidence, but rather to add to it if it would be competent.
. . .
Q. Miss Kilgallen, is there an artistic purpose in the use of language
as set forth in transcripts in People's--
A. In my opinion, there is.
Q. In what way?
A. Well, I think that Lenny Bruce, as a night-club performer, employs
these words the way James Baldwin or Tennessee Williams or playwrights
employ them on the Broadway stage for emphasis or because that is the way
that people in a given situation would talk.
Q. Miss Kilgallen, did you see Blues for Mister Charlie?
Q. And are some of those words used in Mr. Bruce's transcripts used
in the play?
A. I believe almost all of them.
Q. Are these words also used in The Carpetbaggers, a book by Harold
Robbins, which is presently being sold?
A. Yes.. . .
Q. Can you tell of any other books that are being distributed that
have the same language?
A. Norman Mailer certainly uses all these in his books, which were
best sellers. James Joyce used them, and Henry Miller, and many other authors
who are regarded as classical--
Mr. Kuh: May it please the Court, I think when we get into the area
of what other particular items words are used in, we can proliferate side
issues. I suggest that Counsel would certainly be free in a brief to say
such-and-such in a book, pages so-and-so, uses these words, but I think
to have an expert tell us what is in what I'm told is a widely circulated
document, certainly is not proper expert testimony and I ask it be stricken.
Judge Murtagh: The Court has indicated it is going to be liberal. We
will allow the testimony, but I suggest to Counsel that it's just about
worthless for you to produce an expert who testifies that a given author
used similar language of that nature.. . .
Mr. Garbus: I will withdraw the question.
Q. On the basis of the transcripts, which you read before you testified,
can you give us your opinion with respect to Mr. Bruce's merit as a performer?
A. I think he's a fine, brilliant performer.
Q. Can you describe, for us, whether there is any form or any unity
to the method of performance which Mr. Bruce has?
A. Yes, his unity, I believe, is social commentary. He goes from one
subject to another, but there is always the thread of the world around
us and what is happening today and what happened today and what might happen
tomorrow, whether he's talking about war or peace or religion or Russia
or New York, there is always a thread and a unity.
Q. Miss Kilgallen, I show you page 6 of People's Exhibit number 5A
which relates to the performance of April 7, 1964, and ask you what comment
Mr. Bruce is making when he discusses the Negro situation?
. . .
A. I think that in this case Mr. Bruce is hopeful that the Negroes
will get a better break. That, because of the civil rights law being passed,
they will have equality. They will sit on juries, where they have never
sat before. They will be judges and they will have equality and this will
come to pass.
Q. Miss Kilgallen, I now refer you to page 11 of People's Exhibit 5A,
which is the performance of April 1, 1964, to that portion beginning with
Mr. Goldwater, relating to a conversation, or a performance of a conversation,
allegedly by Mr. Goldwater with a group of American Negroes, and ask you
what social comment is made by Mr. Bruce from that portion of that exhibit?
A. I think this part of the transcript indicates that Mr. Bruce feels
that Senator Goldwater does not have much rapport with the Negro; that
he's apart from them, as many people are in Arizona. That he doesn't speak
their language and that they can't get through to him, but they do get
through to Mr. Bruce and he is with them. He says it's a different language
and a different culture and I think that's one of the reasons that he employed
the words he did, because that is part of a different culture; not Mr.
Q. Have you heard the word 'mother fucker' used before?
Q. And in this context how is the word used?
A. Sometimes it was used as an epithet, a term of opprobrium and sometimes
I have heard it used among show business people, who sometimes speak rather
frankly and roughly, as a term of endearment.. . .
Cross-Examination by Mr. Kuh:
. . .
Q. All right. Now, feeling free to leaf through the transcripts . .
. can you tell us what other items . . . convince you that Bruce is an
extremely moral man, that he has a valid artistic purpose and what he says
is extremely pertinent?
A. Well, the first thing that he comes to, I'm afraid, is something
where he discusses the law.. . .
Q. Let's deal with pages 1 and 2 and part of page 3 before you get
to the discussion of the law, and tell me what in that portion demonstrates
A. The first two pages, in my opinion, are a build-up to what he's
saying. He's not a one line comedian. . . . . .
Q. Now, you say the first two pages of dialogue is just build-up, and
the social value or the artistic merit really gets going on page 3. Can
you tell me how--I refer to the top of page 2--the phrase, 'shit in your
pants,' and the words, 'cock sucker,' can you tell me, Miss Kilgallen--and
I apologize for using that language, but we can't help it--can you tell
me in what way that is artistic build-up or necessary build-up?
A. Those are not words that I use myself. . . .
Q. You stated those are words you don't use. Can you tell me if the
prevailing portion of the community finds them repugnant in terms of usage
in mixed company, in public performances?
A. I cannot speak for the majority of the community; I can only speak
for myself, but I believe that certain words are valid and are not objectionable
if they are used in the proper context and if they seem right at the time
and if they are said in the proper manner. Some people can be offensive
without using, what we would call, a dirty word. Some people could use
a dirty word and not be offensive.
Q. Can you tell me how the words or the phrase on page 2, 'shit in
your pants,' and in page 2, 'cock sucker,' are used in a way that blend
artistic merit, that demonstrate Mr. Bruce's moral character and that are
A. Mr. Bruce sometimes uses those words almost as a throwaway.
Judge Murtagh: Almost as what?
Witness: A throwaway.
Judge Murtagh: What does that mean?
Witness: That's show-business parlance I'm afraid, your Honor. It's
an offhand thing that you almost don't hear.
Judge Murtagh: How is the fact that words such as that are offhand,
how does that make it proper if it is improper otherwise?
Witness: Well, your Honor, to me words are just words, and if the intent
and the effect is not offensive the words in themselves are not offensive.
. . . It depends on how it's done. I have seen entertainers who didn't
use these words, but were offensive nevertheless, and I can give you examples.
I have criticized them. . . .
Judge Murtagh: Did you hear him on these two occasions?
Witness: No, but knowing his performances I can almost picture the
way he said them.. . .
Q. Are you familiar with any of Bruce's phonograph records?
A. I think I have one.. . .
Q. Now, you mentioned before something about Mr. Bruce's bit--or something--
at the Palladium. Is that on that record?
A. No, I'm not so sure. It's so long since I heard the record I really
Q. Was that bit, so called, about the Palladium, a rather lengthy bit?
Q. Quite lengthy?
A. For him it is.
Q. And except for one word at the very end, which I think is the word
'urination,' . . . except for that, do you know of any other four-letter
words or combinations, and I apologize, Miss Kilgallen, such as 'cock sucker'
throughout this lengthy bit?
A. I don't know it by heart. I only know the general idea and that
I found it very amusing, at least to show people. I don't know whether
it would be to the average audience, but I know Milton Berle laughed a
lot when he heard it.
Q. Thank you. If I tell you that that record contains no vulgarity,
none of the words that Mr. Garbus used so far in examining you, would you
dispute that contention?
A. No, sir; that makes sense.
Q. And so you recognize that Mr. Bruce can be amusing, even to Milton
Berle, without utilizing any of these four-letter words or combination
A. Yes, I'm sure he can, because I think he's a near genius.
Q. You think he's a near genuis?
Q. And if I tell you that all through that record and these others
that I have here, [such words as] 'fuck' were not used at all, . . . would
you say that these records show less genius than the scripts that you have
Mr. London: Objection.
Judge Murtagh: Objection overruled.
Q. Would you say that Bruce is able to get his social satire, his moral
values, his artistic ability across fully and ably and unimpeded without
the use of these words that I think you recognize, you, yourself, you indicated
were not used?
Mr. Garbus: I object to that. This trial is about these transcripts,
not about anything else.
Judge Murtagh: Objection overruled.
A. I don't know whether he can get his meaning across fully, because
some of these words, which are objectionable, as you put it, are terms
that are used by people in real life, and I think to be more graphic he
must use them, just as a playwright or a novelist would use them.
Q. Let me read you this--and I'm reading from page 22 of the April
1st performance--. . . he says, 'That's the way all of us feel, shitty
all the time and low because we're no good cause we run away but nobody
ever stays it's all bullshit none of you mother fuckers ever stayed one
time in your life you never stayed and that's why you can sit and indict.'
Do you feel that that language is necessary to the effectiveness of that
portion of that script?
A. I think he felt it was necessary and perhaps it was. He was expressing
the fear that all humans feel and he was sympathizing with it.
Q. And do you believe that words 'mother fucker' and 'shitty' and so
forth were necessary to that expression, apart from what he might have
felt, was necessary--do you feel that that was necessary, you as a person
who is critical and is here as an expert on criticism?
Mr. Garbus: I would object to that, your Honor.
Judge Murtagh: Objection overruled.
A. I really can't judge that, because I didn't hear the way he said
Q. Well, will you recognize, Miss Kilgallen, that there are at least
an appreciable number of persons in the community who would find that language
A. I'm sure there are.
Q. . . . Can you tell us how the use of this language, not in Mr. Bruce's
eyes, but in your eyes, as a critic, a person who was qualified here as
an expert witness, will you tell us how the use of this sentence, that
I read, is necessary to the artistic unity, if you will, of the Jackie
Kennedy story?. . .
A. I do not underwrite anything that Mr. Bruce may have said. I'm just
saying that what I have read does not offend me.
Q. Then you concede, as a critic and as an expert in criticism, that
these words may be unnecessary to this story, that you personally cannot
find a justification for them although you personally do not object--is
that what you are telling us?
Mr. Garbus: I object to the question on the ground it's argumentative,
on the ground it rephrases the witness' testimony in a manner which she
did not give it, on the ground it calls for speculation.
Judge Murtagh: Objection overruled.
A. I believe that if Mr. Bruce in his routine felt it was necessary,
then it was necessary.
Mr. Kuh: I ask that my question be read back for Miss Kilgallen.
Judge Murtagh: So ordered. Read the question back.
[Last question re-read]
A. Sir, as a critic and I know you doubt my qualifications, but--
Mr. Kuh: That's been ruled on by the Court and I accept all of the
rulings of this Court, Miss Kilgallen, on any matter.
A. I could enlarge on them, but that's all right. But as a critic I
have only to tell what I think about an act, I don't have to justify every
word of it.
Judge Murtagh: But you are being asked now to justify it; in other
words, to testify on the soundness of your meaning.
A. Well, I feel it is in Mr. Bruce's style, just as Blues for Mister
Charlie is in James Baldwin's style and Tropic of Cancer is in Henry Miller's
style. He has the right to use the words he feels are fitting and pertinent
and perhaps dramatic.
Q. . . . Are you familiar with the portion of the script of the April
1st performance that deals with sodomy, sex with animals, dogs and cats
and I think hippopotamuses and the SPCA--and then goes on, 'If you came
home and found your husband with a chicken would you belt him, really feel
bad, bad. A chicken, ah it's an odd bed, ah I felt like ah, I'm the last
one to know.' Will you tell us what the artistry, or the social value,
or the merit, or the good is, in the Bruce story of sexual intercourse
with a chicken?
Mr. Garbus: I will object to Mr. Kuh's characterization of Mr. Bruce's
performances. The testimony has already been that this is not a discussion
of sex with animals per se, but rather a social comment made by the use
of these symbols.
Judge Murtagh: Objection overruled.
A. Well, sir, sodomy is in the Bible. If it can be read in churches
I wouldn't rule it out for Mr. Bruce's act, if he cared to comment on it..
Q. Do you recognize beyond the intentions generally some cohesiveness
within each book of the Bible?
A. Well, the Creation is pretty well written.
Q. I'm sure that the Lord is thankful to you for that comment. Now,
would you tell us just what cohesiveness do you see in the Lenny Bruce
script that you hold in your hands?
A. Well, he goes from one subject to another, but it is always commentary
on life, manners, morals.
. . .
Q. Turning to the April 1st transcript . . . may I ask you to look
where the transcript starts, 'because my aunt --mother came home every
day telling me stories about some guy took it out in the park went, yoo
hoo lady, and she hit him with the pocketbook and so--'
A. . . . Yes, I have it.
Q. Now, you mentioned that in judging Bruce's performance it was very
difficult if not impossible to judge solely by reading the script, that
one had to hear his voice and had to see what he did. If I tell you in
that portion of the performance he turned partly away from the audience,
put his hands together and moved the hands, from the region of his pubic
area, upon and down: . . . assuming that state of fact, when that portion
that I have called to your attention to on page 21 was read, dealing apparently
with a man or men exposing themselves before women, if I tell you that
there is testimony that Bruce moved his hands in the area of his pubic
area together and moved them up and down, would you tell me what artistic
value there was in that performance?
A. I couldn't tell you.
Q. Can you tell me what morality on the part of Bruce that that demonstrated?
A. I don't think it would demonstrate morality.
Q. Indeed it would contradict morality?
A. I think so.
Mr. Garbus: I will object to Mr. Kuh's question.
Judge Murtagh: Objection is overruled. You called the witness as an
Q. Did you say you think so?
A. I say I think it would not reflect morality.
Q. Would it contradict, contravene, be the opposite of morality, indeed
A. I think it might.
Q. Is there any question in your mind about that?
A. I didn't see it; I'm just taking your--. . .
Q. Hypothetically, do you think it would be immoral?
A. Yes.. . .
Q. Tell me, putting aside Henry Miller for a moment, do you know any
other contemporary American author who uses these words in the profusion
that Bruce does and uses these stories one after another after another--Roosevelt's
tits, Jackie Kennedy's ass, chicken in bed, urinating from windows. Do
you know any book that goes into, not millions of homes, but hundreds of
thousands of homes, that uses these words in the same profusion, lacking
in story line, lacking in unity?
A. Sir, I can't give you any lacking in story line, but I can give
you books that have sold by the millions and have been on the bestseller
list in The New York Times for more than a year. One of them is Norman
Mailer's The Naked and the Dead. He uses every word you can think of..
[The witness also mentioned Deer Park by Norman Mailer, From
Here to Eternity by James Jones, and The Carpetbaggers by Harold
Q. The books to which you have referred, and I will not take the time
to review them one by one, do they each have a story?
Q. Does the Bruce dialogue-monologue have any story?
A. It's not meant to have.
Q. The books, in pursuing their story line, have certain dialogues
on the parts of their characters?
Q. And are the words, to which you refer, used almost exclusively,
if not exclusively, as part of this dialogue, in order to depict certain
A. No, I wouldn't say that. They are used in a certain stream of consciousness
effect in description.
Q. Stream of consciousness of some of the characters that they are
describing, is that correct?
A. That's right. Just as Lenny Bruce, in a sense, does a stream of
consciousness in his acts.
Q. Of Lenny Bruce?
A. Of Lenny Bruce or someone he's talking about. If he's talking about
someone he feels has been persecuted, he's using their language.
Q. I wouldn't take much time, but we did discuss before Lenny Bruce's
use of the words 'mother fucker' at his audience. Can you tell me when
James Jones or Norman Mailer or Arthur Miller has called his audience 'mother
Mr. Garbus: Your Honor, may I object? We are talking about books against
monologue. It's completely an irrelevant question.
Judge Murtagh: We will allow it. Objection overruled.
A. I can't tell you anything verbatim from the books, because I read
them a couple of years ago or more. I would imagine--this would be my best
guess--that they did not call their audiences anything. There's another
book called The Naked Lunch which I couldn't even finish reading, but it's
published, and I think the author should be in jail and he used--
Q. Unfortunately we can't do everything at once, Miss Kilgallen. Are
you judging the non-obscene quality and the artistic quality of Bruce by
the fact that The Naked Lunch is a book which, as of this date, is sold
in the community?
A. No, I'm not. I just mentioned it because you asked me for some books.
Q. And The Naked Lunch is a book you found impossible to read, is that
A. Yes, I found it revolting.
Q. What was revolting about it?
A. Just the way it was written.
Mr.Garbus: Objection, your Honor.
Judge Murtagh: Objection overruled.
A. It seemed to use words for shock value, not for any valid reason,
and I object to that.
Q. And when Lenny Bruce--I ask you to turn to the April 1st tape .
. . and read the portion starting--'tits and ass, that's what is the attraction,
is just tits and ass and tits and ass'--and goes on all through the page,
and ask you if you find some shock value in that?
A. No, I don't think it's particularly shocking, it's just a word..
Q. Do you, in your column, use the words tits and ass?
Q. You know exactly what Lenny Bruce was talking about?
A. Yes. . . . I think there he's being critical of the monotony of
what is on view in Las Vegas.
Q. And you find that the constant repetition of these words is necessary
to express that monotony?
A. I think he felt that it was.
Q. . . . Do you know of any other current entertainer or writer who
makes the same non-erotic use of erotic and vulgar words, or is this a
hallmark you meet with Bruce alone?
A. It is not unique with him. Members of a so-called Hollywood rat
pack, such as Frank Sinatra and Dean Martin, have been known to use such
phrases in Las Vegas, in Lake Tahoe, in other night clubs where they had
obviously an adult audience and they were all clowning around together.
. . . These are words that they use in conversation among themselves and
have been known to use on the stage.
Q. . . . Do you think that it is condoned by the average New Yorker
and the community to use vulgarity for vulgarity's sake and vulgarity alone
for shock alone?
A. No, I do not.
Q. You say Frank Sinatra and others have been known, on occasions in
Las Vegas, to use such words, is that correct?
A. Yes.. . .
Q. Would you say either Frank Sinatra or anyone else in their public
performance uses these words and these stories and these allusions to an
extent remotely resembling the extent, the frequency, the volume in which
Mr. Bruce does?
A. Not to the extent or frequency. They use them. . .