Mr. HORTON. Where are they usually held?

Mrs. KEENE. In a private home.

Mr. HORTON. In the District?

Mrs. KEENE. Yes.

Mr. HORTON. And is this private home the home of one of the members?

Mrs. KEENE. Yes.

Mr. HORTON. Do you always hold it in the same home?

Mrs. KEENE. We have held-usually, I think, our meetings have been held in the same place, but not always.

Mr. HORTON. At these meetings in addition to the business were there reports on the solicitations of funds?

Mrs. KEENE. You can't refer to solicitations for funds because it isn't that active. Our president or our treasurer always reported when we had received contributions in the mail, but I think, as Dr. Kameny told you, we have not really solicited funds in any active way other than the little notice in the

Mr. HORTON. What have you all been doing all these months that you have been meeting? What is the nature of your business?

Mrs. KEENE. We discuss what problems there are to be faced with respect to

Mr. HORTON. Let's talk about one of those problems. Give us specifically one of the problems.

Mrs. KEENE. The fact that a person who is a homosexual has a very hard time finding a job.

Mr. HORTON. Does this usually take some time for discussion on this?

Mrs. KEENE. Of course not just that general subject, but it may be a specific instance, factually what has taken place and what we can do about it. That is the most important thing.

Mr. HORTON. Are refreshments served at these meetings?

Mrs. KEENE. Usually at the end we have punch and cookies, 15

minutes or so.

Mr. HORTON. How long do the meetings usually last, a couple of hours did you say?

Mrs. KEENE. Yes. I have never known one to last more than two and a half hours. I can think of

Mr. HORTON. Have you ever seen or participated in any homosexual acts either during the course of these meetings or subsequent thereto in the private homes?

Mrs. KEENE. No.

Mr. HORTON. Have you ever been present either during these meetings or following these meetings when this has been suggested or talked about?

Mrs. KEENE. Definitely not.

Mr. HORTON. Have you ever been in discussions in any of these meetings about the homosexual act?

Mrs. KEENE. No.

Mr. HORTON. This is never discussed?

Mrs. KEENE. No. I might say that my observation has been that any attempt to discuss it would be very much frowned on.

Mr. HORTON. Who asked you to be an officer of this organization? Mrs. KEENE. I do not remember.

Mr. HORTON. Did you of your own volition attempt to be an officer? Mrs. KEENE. No. Did I actively ask?

Mr. HORTON. Yes.

Mrs. KEENE. No.

Mr. HORTON. Did somebody ask you?

Mrs. KEENE. I was nominated as I recall at a meeting.

Mr. HORTON. Do you know the members of the organization?
Mrs. KEENE. Do I what?

Mr. HORTON. Do you know the members of the organization?
Mrs. KEENE. Well, yes.

Mr. HORTON. You are the secretary?

Mrs. KEENE. No, I am not. I am the vice president.

Mr. HORTON. I am sorry. Do you know the members?

Mrs. KEENE. Yes. Do you mean to recognize them by face?

Mr. HORTON. Yes.

Mrs. KEENE. Yes, some of them. Some of them I am not sure of. Mr. HORTON. Do you know the secretary?

Mrs. KEENE. Yes.

Mr. HORTON. What is his name?

Mrs. KEENE. His name in the society is Bruce Schuyler. That is the name that I know him by.

Mr. HORTON. You mentioned his name in this society. Has he got another name?

Mrs. KEENE. I can't tell you.

Mr. HORTON. Do you know him by any other name?

Mrs. KEENE. I can't answer that.

Mr. HORTON. Have you been instructed by counsel as to how you should respond to questions here today?

Mrs. KEENE. No, I have not.

Mr. HORTON. Do you know Earl Goldring?

Mrs. KEENE. Yes.

Mr. HORTON. Is that an assumed name?

Mrs. KEENE. I cannot answer.

Mr. HORTON. That is the only name you know him by?

Mrs. KEENE. I can't answer that.

Mr. HORTON. Do you know him by another name?

Mrs. KEENE. I beg your pardon?

Mr. HORTON. Do you know him by another name?

Mrs. KEENE. I don't want to answer that. All that I know him as is Earl Goldring, and I know him through my position in the society, and in no other way.

Mr. HORTON. Have you ever presided at any of the meetings?

Mrs. KEENE. No.

Mr. HORTON. You were present, weren't you, this morning when Mr. Kameny was testifying?

Mrs. KEENE. Yes.

Mr. HORTON. Did you hear him testify about the purpose of the organization, to alter the criminal law in regard to private consenting homosexual acts by adults?

Mrs. KEENE. Yes.

Mr. HORTON. Do you subscribe to that purpose?
Mrs. KEENE. Yes, I do.

Mr. HORTON. Do you subscribe to the purposes as he enunciated them here this morning in his testimony?

Mrs. KEENE. Not perhaps in the words that he used.

Mr. HORTON. Do you think he was accurate in stating the position of the organization with respect to this?

Mrs. KEENE. Insofar as he stated that the purpose of the organization or that one, I might say, hope of the organization was that it would be no longer, that the criminal law would be changed so that it would no longer be a crime for one consenting adult to commit a homosexual act with another consenting adult in private. I think that that is a hope, an aim of the society.

Mr. HORTON. What is your definition of the homosexual?

Mrs. KEENE. Anyone who feels a sexual attraction toward a person of the same sex.

Mr. HORTON. Does this include the homosexual act?

Mrs. KEENE. Well, it includes, of course, a great many people who commit homosexual acts, but, of course, it also includes a great many people who never commit homosexual acts.

Mr. HORTON. Mr. Chairman, I had started the questioning of this witness, and I yield back to the chairman.

Mr. DOWDY. How did you define homosexual again?

Mrs. KEENE. As anyone who feels a sexual attraction toward another person of the same sex.

Mr. Dowdy. I thought you left out the sexual attraction the first time.

Mrs. KEENE. I hope I didn't. I didn't mean to. I think that is a very important part of it.

Mr. Downy. I do, too. It seemed Kameny this morning was wanting to leave that out.

Mrs. KEENE. Well, that was a slip of his tongue then, I think. Mr. DOWDY. Do you distinguish between homosexual and lesbian? Mrs. KEENE. Well, in common terminology a lesbian is a female homosexual.

Mr. Dowdy. There is an organization of lesbians called the Daughters of Bilitis, I believe?

Mrs. KEENE. Yes.

Mr. DowDY. Are you a member of that organization?

Mrs. KEENE. No.

Mr. Downy. Are you a member of any of these international organizations of homosexuals?

Mrs. KEENE. No.

Mr. DOWDY. I had to go to the telephone, but I understand you have declined to answer the question whether you are testifying under your

true name.

Mr. HORTON. May I

Mrs. KEENE. Did you actually ask me that?

Mr. HORTON. I did ask her, Mr. Chairman, about her name, and she said it was Ellen Keene. Then I asked if she was married, and she said "Yes," and she refused to give me the name of her husband. Mr. Dowdy. Is Ellen Keene your name or is it an alias? Mrs. KEENE. That is a question I do not want to answer.

Mr. DOWDY. You know, of course, that we must assume that you are testifying under a false name, or else you wouldn't mind answering.

Mrs. KEENE. Not in the light of the explanations that Mr. Karmeny has given you, no.

Mr. DownY. The same thing applied to him. He said he used his right name.

Mrs. KEENE. But he was talking about other officers of the society. Mr. DowDY. You are talking about only yourself now.

Mrs. KEENE. I am talking about myself as one of those other officers of the society to whom he was referring.

Mr. Dowdy. I don't remember whether he testified that Ellen Keene was your right name or not.

Mrs. KEENE. I don't imagine in the light of his other testimony that he did. As a matter of fact, I am sure he did not.

Mr. HORTON. Mr. Chairman, may I suggest that this witness be sworn and be asked these questions?

Mrs. KEENE. I don't think you can do that.

Mr. DowDY. Did you give us your address?
Mrs. KEENE. No.

Mr. Dowdy. What is your address?

Mrs. KEENE. I do not wish to give you that.
Mr. Dowdy. Are you employed?

Mrs. KEENE. Yes.

Mr. DowDY. Who do you work for?

Mrs. KEENE. I do not wish to tell you.

Mr. DOWDY. Even if we pressed the question you would still refuse to answer?

Mrs. KEENE. Under the circumstances, yes, I believe so. Of course, this is something that I had not anticipated being asked, as I told you earlier. I did not expect to testify, and I have not had a chance to think about it, but I believe that this would

Mr. DOWDY. You testified about these homosexual acts in private circumstances. Do you go along with Kameny's testimony that it is in private if you have an audience-if your audience, regardless of how large, is not making too much noise?

Mrs. KEENE. I think that is a question of one's own interpretation. and whether one approves of it or not is again a matter of personal preference.

To my mind I would have to say "No," I don't think it is private, but on the other hand I would have to say that someone else could interpret it as being different.

Mr. DowDY. If he was testifying the beliefs of the society, you would concede that his definition

Mrs. KEENE. That he was testifying what?

Mr. Dowdy. He was testifying as president of the society, so you would concede to his definition of what privacy is?

Mrs. KEENE. No, because I don't think he was expressing an opinion of the society. He was expressing a personal opinion. The society has never even discussed that aspect of it.

Mr. Dowdy. Do you have any questions, Mr. Huddleston, Mr. Sisk? That is all. Thank you.

Mr. HORTON. Could I ask the witness a question please?

Mrs. KEENE. Yes.

Mr. HORTON. Are you employed?

Mrs. KEENE. Yes.

Mr. HORTON. Where are you employed?

Mrs. KEENE. I do not wish to tell

you.

Mr. HORTON. Are you employed by the Federal Government?
Mrs. KEENE. No, I am not.

Mr. HORTON. Are you employed here in the District of Columbia?
Mrs. KEENE. Further than that I will not answer.

Mr. HORTON. I say, are you employed in the District of Columbia? Mrs. KEENE. I will not answer where I am employed.

Mr. HORTON. That is all.

Mr. Dowdy. Where does your husband work?

Mrs. KEENE. I don't wish to answer that.

Mr. Dowdy. Is he a member of the society?

Mrs. KEENE. No.

Mr. DOWDY. Does he know you are a member of the society?

Mrs. KEENE. Yes.

Mr. Dowdy. He approves of it?

Mrs. KEENE. I assume so, yes.

Mr. DOWDY. Thank you.

Now Prof. Monroe H. Freedman.

Where are you employed, or are you taking the fifth on us, too?

STATEMENT OF MONROE H. FREEDMAN, NATIONAL CAPITAL AREA CIVIL LIBERTIES UNION

Mr. FREEDMAN. I did not understand that other witnesses were, sir. Mr. Dowdy. That is what it amounted to.

Mr. FREEDMAN. I am a member of the bar, and I am a professor of law at George Washington University Law School. I am here in my capacity as chairman of the Freedom of Communications Committee of the National Capital Area Civil Liberties Union.

Mr. Dowdy. I believe this morning you declined to answer whether you were a member of this Mattachine Society.

Mr. FREEDMAN. Yes, sir.

Mr. DowDY. Are you a member or do you decline to say?
Mr. FREEDMAN. I decline to say, sir.

Mr. DowDY. Are you testifying under your true name?

Mr. FREEDMAN. Yes, I am, sir.

Mr. Dowdy. Do you know any reason why these other people wouldn't.

Mr. FREEDMAN. It is their understanding apparently, and it seems to me there is reason to believe it, that they could be subjected to persecution because of homosexuality or because someone might rightly or wrongly believe that they are homosexuals.

Mr. DowDY. Is that the reason you refuse to answer the question?
Mr. FREEDMAN. Which question are you referring to, sir?
Mr. Dowdy. Whether you are a member of the society.

Mr. FREEDMAN. No. I am a rather conservative person and oldfashioned about my private life, and except, insofar as it is relevant to these proceedings, I would prefer to keep my private life and my private associations private.

Mr. DowDY. You know when you answer questions about a thing, it is well to know your connection with it, so you know whether there is bias or prejudice in the remarks you make. Are you testifying as a lawyer for this organization?