"I did not in March 1997, promise Larry Klayman that I would pay him for any medical or other expenses he might incur on behalf of my mother Yetta Goldberg," she stated in a sworn affidavit. "On the contrary," she continued, "on that occasion, Larry Klayman was verbally abusive to me and to my aunt (Yetta Goldberg's sister), which forced us to leave his house and go to a hotel for the night. Moreover, on this occasion, Larry Klayman's wife, Stephanie Klayman, was crying while Larry Klayman was screaming at my aunt and me."