DISTRICT OF COLUMBIA
       3    CARA LESLIE ALEXANDER    :
            et al.,                  :
       4                 Plaintiffs, :
       5                             :
                        v.           : Civil No. 96-2123 (RCL)
       6                             :
            FEDERAL BUREAU OF        :
       7    INVESTIGATION et al.,    :
       8                 Defendants  :
       9    MICHAEL JOHN GRIMLEY     :
            et al.,                  :
      10                             :
                         Plaintiffs, :
      11                             :
                        v.           : Civil No. 97-1288 (RCL)
      12                             :
            FEDERAL BUREAU OF        :
      13    INVESTIGATION et al.,    :
      14                 Defendants. :
      15                                      Washington, D.C.

      16                                 Thursday, May 7, 1998

      17    Deposition of

      18                 MARI LYNNE ANDERSON

      19    a witness, called for examination by counsel

      20    for Defendants pursuant to notice and

      21    agreement of counsel, beginning at

      22    approximately 9:38 a.m. at the offices of the



       1    United States Department of Justice, 901 E

       2    Street N.W., Washington, D.C., before Joan V.

       3    Cain, notary public in and for the District

       4    of Columbia, when were present on behalf of

       5    the respective parties:

       6    APPEARANCES:  

       7       On behalf of Plaintiffs:

       8          LARRY KLAYMAN, ESQUIRE
                  Judicial Watch
       9          501 School Street S.W., Suite 725
                  Washington, D.C.  20024
      10          (202) 646-5172

               On behalf of Defendants Executive Office of
      12              the President, Federal Bureau of
                  TIMOTHY P. GARREN, ESQUIRE
      14          JAMES J. GILLIGAN, ESQUIRE
                  Federal Programs Branch
      16          Civil Division
                  United States Department of Justice
      17          901 E Street N.W., Room 988
                  Washington, D.C.  20530
      18          (202) 514-5302

      19          JON PIFER, ESQUIRE
                  Federal Bureau of Investigation
      20          935 Pennsylvania Avenue N.W.
                  Washington, D.C.
      21          (202) 514-3358




       1    APPEARANCES (CONT'D):

       2       On behalf of Defendant Hillary Rodham
                  PAUL B. GAFFNEY, ESQUIRE
       4          Williams & Connolly
                  725 Twelfth Street N.W.
       5          Washington, D.C.  20005
                  (202) 434-5803
               On behalf of Defendant Livingstone:
                  DAVID S. COHEN, ESQUIRE
       8          Miller Cassidy Larroca & Lewin, L.L.P.
                  2555 M Street N.W.
       9          Washington, D.C.  20037-1302
                  (202) 833-6503
               On behalf of Defendant Nussbaum:
                  ROBERT B. MAZUR, ESQUIRE
      12          Wachtell Lipton Rosen & Katz
                  51 West 52nd Street
      13          New York, New York  10019-6618
                  (212) 403-1000
               On behalf of The White House:
      16          Special Associate Counsel to the President
                  The White House
      17          Washington, D.C. 20500
                  (202) 456-5079

      20                    *  *  *  *  *





       1                   C O N T E N T S

       2    EXAMINATION BY:                            PAGE

       3       Counsel for Defendants                     8

       4       Counsel for Plaintiffs                   177


       6       Counsel for Defendants                   426


       8    No.  1 - FBI Liaison Request Form            65

       9    No.  2 - Green-Striped Paper                 89

      10    No.  3 - Gemmell Declaration,               104
            No.  4 - White House Operations             157
      12              Personnel List

      13    No.  5 - Senate Judiciary Committee         194
                      Testimony Transcript
            No.  6 - Fact Sheet, Attachment             220
            No.  7 - Redacted FBI Liaison Requests      266
            No.  8 - Visitation Logs                    295
            No.  9 - Letter, Freeh to Livingstone,      333
      18              Attachments

      19    No. 10 - Investigation Report               340

      20    No. 11 - White House Personnel              364
                      Security Files Staff List





       2    No. 12 - Memorandum, Kennedy to Hilty,      369
            No. 13 - Background Investigation           382
       4              Check-Out Log


       6                    *  *  *  *  *



















       1              P R O C E E D I N G S& Connolly, for Mrs. Clinton.

      12              MR. MAZUR:  Robert Mazur for

      13    Bernard Nussbuam.

      14              MS. SHAPIRO:  Elizabeth Shapiro for

      15    the EOP and FBI.

      16              MR. KLAYMAN:  Larry Klayman for

      17    Judicial Watch.

      18              MR. FITTON:  Tom Fitton, legal

      19    assistant for Judicial Watch.

      20              MR. MARINBERG:  Dan Marinberg,

      21    legal assistant for Judicial Watch.

      22              THE VIDEOGRAPHER:  Will the witness



       1    please be sworn?

       2    Whereupon,

       3                    MARI ANDERSON

       4    was called as a witness and, having been

       5    first duly sworn, was examined and testified

       6    as follows:


       8              BY MR. GARREN:

       9         Q    Now, Ms. Anderson, before we get

      10    started today, I'd like to give you just a

      11    few instructions about the process.  Your

      12    deposition is being taken today in this case

      13    entitled Alexander v. FBI.  This deposition

      14    is just an opportunity for the assembled

      15    masses here today to take your testimony

      16    about the matter under oath.  Do you

      17    understand?

      18         A    Yes.

      19         Q    Now, when your deposition is taken,

      20    your testimony will be sworn and under oath.

      21    It can be used in the eventual trial of the

      22    proceeding, so it is very important, since



       1    your testimony is under oath and can be used

       2    in the case, that you answer truthfully and

       3    directly to the questions presented to you.

       4    Do you understand that?

       5         A    Yes.

       6         Q    Now, if you have any questions

       7    about any question put to you, if there's

       8    anything confusing about it, please speak up.

       9         A    I will.

      10         Q    Let us know that you have a

      11    question about it.  Don't speculate about

      12    what it may be that we're trying to ask you.

      13    If you don't understand what we're asking

      14    you, please speak up, and I will be very

      15    happy to rephrase the question or clarify

      16    anything that's confusing to you.

      17    Understand?

      18         A    Yes.

      19         Q    If at any time in the course of the

      20    proceeding you become distracted or you need

      21    to take a break for any reason, please speak

      22    up and we'll take a break.



       1         A    I will.

       2              MR. KLAYMAN:  Before you go on let

       3    me just put a few things on the record as

       4    long as you're in the instructional mode

       5    here.  We have a continuing objection to the

       6    participation of Ms. Paxton in this

       7    proceeding and that's a matter before the

       8    court.  You may proceed.

       9              BY MR. GARREN:

      10         Q    Please state your full name for the

      11    record, Ms. Anderson.

      12         A    Mari Lynne Anderson.

      13         Q    And where do you reside?

      14         A    I reside 9585 Juniper Street,

      15    Apartment 4319, Atlanta, Georgia.

      16         Q    And how long have you resided in

      17    Atlanta, Georgia?

      18         A    How long have I resided in Atlanta,

      19    Georgia, or how long at that residence?

      20         Q    How long have you resided in

      21    Atlanta, Georgia?

      22         A    In Atlanta, Georgia, since the



       1    summer of '95.

       2         Q    You've resided there continuously

       3    since the summer of '95?

       4         A    Yes.

       5         Q    Now, Ms. Anderson, I'd like you to

       6    basically summarize your educational

       7    background beginning with college.

       8         A    Graduated from the University of

       9    Georgia in, I believe, 1991 in June.  I then

      10    went to paralegal school thinking I was going

      11    to be an attorney.  That's not going to

      12    happen.  Then I am now currently enrolled at

      13    Georgia State University.

      14         Q    Now, you mentioned you graduated

      15    from the University of Georgia in 1991.  Did

      16    you receive a degree from the University of

      17    Georgia?

      18         A    Bachelor's of Art in political

      19    science.

      20         Q    And when did you start paralegal

      21    school?

      22         A    After graduation.  I believe it was



       1    in the fall, but I could be mistaken.

       2         Q    The fall after you --

       3         A    The fall of '91, but I could be

       4    mistaken.  I believe it was the fall.

       5         Q    Did you complete paralegal school?

       6         A    With honors.

       7         Q    And where did you go to paralegal

       8    school?

       9         A    I don't remember the name of the

      10    school.  It was the National Paralegal

      11    Institute or something like that.

      12         Q    And where was it located?

      13         A    Atlanta, Georgia.

      14         Q    You mentioned you're currently at

      15    Georgia State University; is that correct?

      16         A    Yes.

      17         Q    And are you in an undergraduate

      18    program there?

      19         A    Currently.

      20         Q    And what's the nature of that

      21    program?

      22         A    Marketing.



       1         Q    And when do you expect to graduate?

       2         A    This coming spring.

       3         Q    Now, let me ask you to summarize

       4    your work history post-graduation from the

       5    University of Georgia.

       6         A    Worked at a law firm, Jenkins &

       7    Eells, since dissolved and then went to

       8    Little Rock.  From there I went to

       9    Washington, D.C., and worked on the inaugural

      10    committee in 1992 and then went to The White

      11    House when the inaugural was finished.

      12         Q    Let's go back through that a little

      13    bit.  When you graduated from University of

      14    Georgia, you worked for a law firm; is that

      15    correct?

      16         A    After the paralegal school.

      17         Q    And what law firm was that?

      18         A    Jenkins & Eells.

      19         Q    And where is that located?

      20         A    It's no longer.  It's now defunct,

      21    but it was in Atlanta, Georgia.

      22         Q    And do you remember generally what



       1    your dates of employment were at Jenkins &

       2    Eells?

       3         A    I have no earthly idea.  I know it

       4    was after my first degree, but I specifically

       5    do not remember.

       6         Q    And did you do paralegal kind of

       7    work for Jenkins & Eells?

       8         A    I did filing, serving of summonses,

       9    and stuff like that.

      10         Q    You mentioned in 1992 you went to

      11    Little Rock; is that right?

      12         A    Yes.

      13         Q    Why did you go to Little Rock?

      14         A    I thought that I was going -- I was

      15    planning on going to law school and that I

      16    might want to get into politics.

      17         Q    You were contemplating going to law

      18    school in Little Rock?

      19         A    No.  The politics is what I was

      20    contemplating.

      21         Q    Now, did you subsequently work on

      22    the Clinton campaign in 1992?



       1         A    Yes.

       2         Q    Tell me how you obtained a position

       3    with the Clinton campaign in 1992.

       4         A    I obtained a position -- I had a

       5    name, and I went and I called that name and

       6    began volunteering.

       7         Q    And how did you get the name?

       8         A    From Craig Livingstone.

       9         Q    And what was the name that you had?

      10         A    James Day.

      11         Q    Do you remember when you started

      12    volunteering for the campaign?

      13         A    I believe it might have been either

      14    June or July.  Specifically, I'm not certain.

      15    It may have been August.

      16         Q    And did you stay with the campaign

      17    throughout the campaign until the election?

      18         A    Yes.

      19         Q    Now, did you have a paying position

      20    with the Clinton campaign?

      21         A    Not initially.

      22         Q    When, if ever, did you obtain a



       1    paying position?

       2         A    A week before the election.

       3         Q    So, except for the week before the

       4    election, it was all volunteer work; is that

       5    correct?

       6         A    Yes.

       7         Q    What was the nature of the work

       8    that you did for the Clinton campaign?

       9         A    I primarily worked with the advance

      10    office for -- at that time Senator Gore

      11    working with his correspondence and archiving

      12    the day trips, the schedules, and stuff like

      13    that.

      14         Q    Now, you mentioned that you had a

      15    name and you called this James Day; is that

      16    correct?

      17         A    Yes.

      18         Q    And you mentioned that Craig

      19    Livingstone played some role in that?

      20         A    Yes.

      21         Q    Could you explain that further?

      22         A    In 1998 -- I'm sorry, 1988 -- when



       1    I was still an undergrad at the University of

       2    Georgia, I -- when the National Democratic

       3    Convention was in Atlanta, did sort of an

       4    internship there, and they had put me in

       5    Chairman Kirk's office where I had met Craig

       6    Livingstone.  When the convention had ended,

       7    he said if you ever want to get into politics

       8    give me a call and gave me a card and

       9    ultimately I gave him in a call in the summer

      10    of '92.

      11         Q    Where was he at that time?

      12         A    Ross Perot campaign.

      13         Q    Craig Livingstone was working for

      14    the Ross Perot campaign at the time that you

      15    called him?

      16         A    That was my understanding.

      17         Q    And he mentioned someone to you

      18    that you could call to volunteer for the

      19    Clinton campaign?

      20         A    No.

      21         Q    Explain further how that happened.

      22         A    He said he would try and get me on



       1    with the Ross Perot campaign and then

       2    Mr. Perot announced that he was pulling out

       3    of the presidential race and the next time I

       4    talked to Craig he said he was going to

       5    Little Rock and he was going to be doing the

       6    advance school for the Clinton/Gores, and he

       7    would try and get me in.  That did not happen

       8    and he said or, if you want, here's the name

       9    James Day.

      10         Q    And you called Mr. Day?

      11         A    Yes.

      12         Q    And what happened there?

      13         A    He said if I wanted I could -- I

      14    went to Little Rock, and I spoke to him and

      15    he said if I wanted I could do some volunteer

      16    work, but he couldn't promise anything.

      17         Q    Now, after the election in 1992,

      18    where did you next work?

      19         A    After the election I came up to

      20    D.C. and worked for the Airline Pilots

      21    Association for a few days and then worked at

      22    the inaugural committee.



       1         Q    And the Airline Pilots Association,

       2    was that a temporary position?

       3         A    Yes.

       4         Q    And then you mentioned you work for

       5    the inaugural committee; is that right?

       6         A    Yes.

       7         Q    Do you recall when you went to work

       8    for the inaugural committee?

       9         A    Specific date, no, but I believe it

      10    was right before that Thanksgiving.

      11         Q    And did you stay with the inaugural

      12    committee through the inauguration?

      13         A    Yes.

      14         Q    So approximately from right before

      15    Thanksgiving until January 20; is that

      16    correct?

      17         A    No, until mid-February.

      18         Q    And what was the nature of the work

      19    that you did for the inaugural committee?

      20         A    I was staff assistant for the

      21    security office.

      22         Q    Did you work with Mr. Livingstone?



       1         A    Yes.

       2         Q    And what did you do with

       3    Mr. Livingstone?  What kind of work did you

       4    perform with him?

       5         A    I was staff assistant and basically

       6    helped other members in the office and

       7    ultimately became responsible for making sure

       8    that those who needed to a pass to the

       9    inaugural headquarters had one, working in

      10    conjunction with the federal police at that

      11    location.

      12         Q    Now, after the inaugural, where did

      13    you next work?

      14         A    The White House.

      15         Q    And what kind of job did you obtain

      16    with The White House?

      17         A    Initially staff assistant.

      18         Q    Staff assistant with what office?

      19         A    White House -- Office of White

      20    House Personnel Security.

      21         Q    And how did you obtain that job?

      22         A    Craig Livingstone offered it to me.



       1         Q    Do you recall approximately when

       2    that offer was made?

       3         A    Approximately the last week that I

       4    was working at the inaugural committee.

       5         Q    And what were your approximate

       6    dates of employment with The White House

       7    Office of Personnel Security?

       8         A    Approximately February of '93

       9    through August/September of '94.

      10         Q    And did you have a job title during

      11    your employment with the Office of Personnel

      12    Security?

      13         A    Executive assistant.

      14         Q    Were you executive assistant

      15    initially when you started with the office?

      16         A    No.

      17         Q    What was your first position?

      18         A    As stated before, staff assistant.

      19         Q    And approximately how long after

      20    you started did you become the executive

      21    assistant?

      22         A     When Nancy Gemmell departed The



       1    White House.

       2         Q    And do you recall approximately

       3    when that was?

       4         A    I believe that was August of '93.

       5         Q    And did you remain executive

       6    assistant until you left the Office of

       7    Personnel Security?

       8         A    Yes.

       9         Q    Now, what was the nature of your

      10    general job duties with the Office of

      11    Personnel Security?

      12         A    Office manager and just

      13    facilitating the processing of White House

      14    employees and those who needed access to The

      15    White House.

      16         Q    And what was your approximate

      17    salary during that period of time, when you

      18    were working with the Office of Personnel

      19    Security?

      20         A    Average I would say was probably

      21    about 28.

      22         Q    28,000?



       1         A    Yes.

       2         Q    A year?

       3         A    Yes.

       4         Q    Now, you mentioned you left in

       5    September of '94; is that correct?

       6         A    Yes.

       7         Q    And why did you leave that

       8    position?

       9         A    I had decided that politics was not

      10    really what I wanted to continue doing with

      11    the rest of my life and nor was security, and

      12    I wanted to move on.

      13         Q    What job did you take after you

      14    left the Office of Personnel Security?

      15         A    After I left the Office of

      16    Personnel Security, I did some advance work

      17    for Senator -- I'm sorry -- Vice President

      18    Gore, and I did that off and on for about a

      19    year after until I figured out what I wanted

      20    to do.

      21         Q    What was the nature of the advance

      22    work that you would do for Vice President



       1    Gore?

       2         A    When there was an event, they would

       3    select a team to go to the various cities to

       4    set up his appearance or what was going to

       5    happen in that city.

       6         Q    And what would you do?

       7         A    Mostly motorcade.

       8         Q    Was this a continuous job that you

       9    had with the Vice President's office, or what

      10    was the nature of how you were assigned work

      11    in that job?

      12         A    It was not continuous.  What would

      13    happen is I would either call them or they

      14    would call me and they would say we have a

      15    trip, can you fit it into your schedule or

      16    can you do this trip?

      17         Q    And how were you paid for that?

      18         A    Per diem.

      19         Q    What do you mean, per diem?

      20         A    It was paid through the National

      21    Democratic Committee, and it would be $30 a

      22    day.



       1         Q    Since you mentioned that you left

       2    the Office of Personnel Security because you

       3    wanted to leave politics and pursue another

       4    line of work, why did you go to work for Vice

       5    President Gore?

       6         A    As I stated earlier, I hadn't yet

       7    figured out what exactly I wanted to do, and

       8    I needed some time to figure that out.

       9         Q    Do you recall approximately how

      10    many trips you made during the period of time

      11    that you were working for Vice President

      12    Gore?

      13         A    No.

      14         Q    Now, you mentioned you worked for

      15    Vice President Gore in that capacity assigned

      16    jobs for approximately a year; is that

      17    correct?

      18         A    Off and on.  It wasn't continuous.

      19         Q    But you did this for how long?

      20    What was the general period of time?

      21         A    Primarily the fall and winter is

      22    when I did that.



       1         Q    What was the next job that you had

       2    after leaving that job?

       3         A    After leaving that job, I moved to

       4    Atlanta and was trying to get on with the

       5    Olympics, which I achieved in 1996.  I

       6    believe it was May.

       7         Q    Do you recall the approximate date

       8    that you went back to Atlanta?

       9         A    That would have been, I believe,

      10    September of '95.

      11         Q    And when you got back to Atlanta,

      12    you pursued a job with the Atlanta Olympic

      13    Committee; is that correct?

      14         A    Yes.

      15         Q    How long did it take you to get a

      16    job with the Atlanta Olympic Committee?

      17         A    Until May of '96.

      18         Q    What was the nature of the job you

      19    had with Atlanta Olympic Committee?

      20         A    Initially I was bus coordinator and

      21    then became assistant manager for venue and

      22    transportation.



       1         Q    Now, did anyone from The White

       2    House assist you in any way with getting a

       3    job with the Atlanta Olympic Committee?

       4         A    No.

       5         Q    And you worked for the committee

       6    for how long?

       7         A    Until I believe it was mid-August

       8    of '96.

       9         Q    That was right after the Olympics

      10    ended; is that right?

      11         A    Yes.

      12         Q    What did you do after you completed

      13    that job?

      14         A    Answered questions for Independent

      15    Counsel.

      16         Q    What was your next employment?

      17         A    I have none.  Oh, I'm sorry.

      18    Currently, I have an internship with Melissa

      19    Libby & Associates in Atlanta.

      20         Q    After you finished with the Atlanta

      21    Olympic Committee job, shortly thereafter did

      22    you start back to school?



       1         A    In January of '97.

       2         Q    And is that when you started back

       3    to Georgia State University?

       4         A    Yes.

       5         Q    And you're still at Georgia State

       6    University, you testified?

       7         A    Yes.

       8         Q    And do you work part-time while you

       9    go to school?

      10         A    This quarter I am.

      11         Q    And tell me about the nature of

      12    that job.

      13         A    Melissa Libby & Associates, it's an

      14    internship for a public relations firm that

      15    deals with restaurants.

      16         Q    And where is this job located?

      17         A    Atlanta, Georgia.

      18         Q    Now, Ms. Anderson, I want you to

      19    focus your attention on your employment with

      20    The White House Office of Personnel Security.

      21    During your time with the Office of Personnel

      22    Security, who was the director of the office?



       1         A    Craig Livingstone.

       2         Q    You mentioned you were there from

       3    approximately February of '93 till September

       4    of '94; is that correct?

       5         A    Yes.

       6         Q    That's approximately 19 months; is

       7    that right?

       8         A    I don't know the calculation but,

       9    yes.

      10         Q    During that entire time that you

      11    were there, was Craig Livingstone always the

      12    director of the office?

      13         A    Yes.

      14         Q    What was the position you had

      15    initially with the office?

      16         A    Staff assistant.

      17         Q    And then you moved up to another

      18    position?

      19         A    Executive assistant.

      20         Q    And that transition took place

      21    approximately how many months after you

      22    started working there?



       1         A    About seven to eight.  I'm not sure

       2    but I think seven to eight.

       3         Q    During your time with the office,

       4    were there other staff assistants in the

       5    office?

       6         A    Yes.

       7         Q    How many other staff assistants

       8    were usually in the office during your

       9    employment there?

      10         A    On average the whole time or when I

      11    left?

      12         Q    On average the whole time.

      13         A    One.

      14         Q    Now, were there other people

      15    detailed to the office from other agencies

      16    within the federal government?

      17         A    Yes.

      18         Q    How many detailees were in the

      19    office during your tenure in the office?

      20         A    One.

      21         Q    Who was that?

      22         A    Tony Marceca.



       1         Q    Were there interns assigned to the

       2    office during your tenure with the office?

       3         A    Yes.

       4         Q    And during your tenure there how

       5    many interns were assigned to the office?  Do

       6    you recall?

       7         A    Approximately five or six.

       8         Q    Do you recall their names?

       9         A    Melissa Evantas, Anthony Aoudi,

      10    Erin Bertucci, Ed Hughes, Lisa Wetzel, and I

      11    believe that's all.  I can't remember others

      12    -- oh, Gina Gibson.

      13         Q    Were these interns all there at the

      14    same time or did they overlap or how did that

      15    work?

      16         A    They were not all there at the same

      17    time, and there was another one, Luis, but I

      18    don't remember his last name.  But they would

      19    come in quarterly or semester shifts as their

      20    schedules allowed.

      21         Q    Were there volunteers in the office

      22    on occasion during your tenure with the



       1    Office of Personnel Security?

       2         A    Initially.

       3         Q    How many volunteers were there

       4    during your tenure that you can recall?

       5         A    Two.

       6         Q    And who was that?

       7         A    Steve Pollack and the second one

       8    was Kara Gerhardt.

       9         Q    Were they both there at the same

      10    time or were they there at different times?

      11         A    I'm not sure if they were there at

      12    the same time or not.  I know Steve was there

      13    initially.  Maybe Carol worked one day with

      14    him, but she wasn't in the office that much.

      15         Q    Now, considering employees of the

      16    office, the detailees, interns, volunteers,

      17    on average how many people would be assigned

      18    to the office at any given day during your

      19    tenure in the office?

      20         A    On average approximately four.

      21         Q    What would you say was the largest

      22    number of people who were assigned to the



       1    office on any given time during your tenure

       2    with the office?

       3         A    Maybe six.

       4         Q    And what was the least number that

       5    was ever there during your tenure with the

       6    office?

       7         A    Three.

       8         Q    Now, I want you to basically

       9    describe the physical structure in which the

      10    Office of Personnel Security was located.

      11    Where was the office?

      12         A    Ground floor of the Old Executive

      13    Office Building.

      14         Q    And basically, what was the size of

      15    the office?  Describe the office.

      16         A    The office was approximately 20 by

      17    20 feet.  It had six desks, maybe initially

      18    the old Wang computer and then another

      19    desktop computer, initially.  Ultimately,

      20    there was an additional computer.

      21         Q    Was there a vault room attached to

      22    the office?



       1         A    Yes, there was.  It was a sealed

       2    skiff that only office members had the

       3    combination to, office staff.

       4         Q    And how would you enter the vault?

       5    Could you enter the vault without going into

       6    the Office of Personnel Security?

       7         A    No.

       8         Q    So you had to enter it from inside

       9    the Office of Personnel Security; is that

      10    correct?

      11         A    Yes.

      12         Q    How large is the vault, during your

      13    tenure there?

      14         A    With or without the ferris wheel

      15    files?

      16         Q    Without the ferris wheel files.

      17         A    I would say a little bit smaller

      18    than the office, maybe 18 by 18.

      19         Q    And how much of that distance did

      20    ferris wheel files take up?

      21         A    I would say probably a third.

      22         Q    Did people during your tenure in



       1    the office, that is, the employees assigned

       2    to the office, have separate offices within

       3    the Office of Personnel Security?

       4         A    No.

       5         Q    Did people have separate cubicles?

       6         A    There were no physical cubicles,

       7    but there were partitions.

       8         Q    Describe the partitions that

       9    existed?

      10         A    Basically, they were about four by

      11    six feet tall blocks that were just put in

      12    front of the desks, my desk and Craig's desk,

      13    so that my desk -- when you opened the door,

      14    it swung inward and my desk was the desk that

      15    you would see, so we put up a partition

      16    there, and we put up a partition in front of

      17    Craig's desk so that he could have some

      18    privacy.

      19         Q    Was your desk located inside a

      20    cubicle?

      21         A    No, it was located behind the

      22    partition.



       1         Q    Was Mr. Livingstone's desk located

       2    inside a cubicle?

       3         A    No.

       4         Q    Now, from your desk in the Office

       5    of Personnel Security, could you see other

       6    people in the office?

       7         A    Yes.

       8         Q    What other desks could you see in

       9    the office?

      10         A    I could see Ed Hughes's desk and

      11    Tony Marceca's desk.  I could see Craig's

      12    desk -- I could see half of the office.  I

      13    could not see Lisa's desk.

      14         Q    So on a daily basis when you're

      15    sitting at your desk you could look across

      16    the room and see Mr. Livingstone?

      17         A    Yes.

      18         Q    Is that also true with respect to

      19    Mr. Marceca?

      20         A    Yes.

      21         Q    What was the distance between your

      22    desk and Mr. Livingstone's desk,



       1    approximately?

       2         A    I would say approximately ten feet.

       3         Q    And approximately what was the

       4    distance between your desk and Mr. Marceca's

       5    desk when he was in the office?

       6         A    Four to five feet, but I'm not

       7    exactly sure of the distance.

       8         Q    Now, were Mr. Livingstone and

       9    Mr. Marceca within earshot so that you could

      10    hear them where they were at their desk?

      11         A    The whole office was in earshot of

      12    everybody.

      13         Q    When Mr. Livingstone was on the

      14    telephone, could you hear him on the

      15    telephone?

      16         A    Yes.

      17         Q    Was that also true with

      18    Mr. Marceca?

      19         A    Yes.

      20         Q    Was it a fairly regular experience

      21    in the office that you could overhear each

      22    other talking on the telephone?



       1              MR. KLAYMAN:  Objection.  Leading.

       2              BY MR. GARREN:

       3         Q    You can answer the question.

       4         A    Yes.

       5         Q    Would you say that there was much

       6    opportunity for privacy in the office during

       7    your tenure there?

       8         A    No.

       9              MR. KLAYMAN:  Objection.  Vague and

      10    ambiguous.

      11              BY MR. GARREN:

      12         Q    During your tenure in the office,

      13    did everyone employed by the office have

      14    separate telephone lines?

      15         A    No.

      16         Q    Tell me the nature of the telephone

      17    lines that existed in the office during your

      18    tenure there.

      19         A    Initially, probably the first year

      20    that I worked there, we had those Nixonian-

      21    age phones where they were the old phones

      22    that had the big inch-diameter cord coming



       1    out of the back that you had to do the -- you

       2    had to press down the button to pick up the

       3    line, and the little light would go on.

       4              To put somebody on hold, you had

       5    the big red button, and there were only two

       6    lines that went to every phone in the office.

       7         Q    So there were only two incoming

       8    lines with separate telephone numbers when

       9    you first began working in the office?

      10         A    If I remember correctly, yes.

      11         Q    Did that change later?

      12         A    Yes.

      13         Q    Describe how it changed?

      14         A    Ultimately, The White House

      15    received a new phone system.  I believe it

      16    was AT&T.  I'm not sure.  And it was -- I

      17    don't remember how many lines we had coming

      18    into the office.  I believe it might have

      19    been four; it could have been more, and we

      20    all had voice mail.

      21         Q    Approximately how long after you

      22    started at the office did that change take



       1    place?

       2         A    About a year later, maybe earlier,

       3    maybe later.

       4         Q    So for the first year when you were

       5    in the office there were only two telephone

       6    lines going into the office; is that correct?

       7         A    Approximately, yeah.

       8         Q    Now, let me ask you about

       9    Mr. Livingstone.  You mentioned that

      10    Mr. Livingstone was the director of the

      11    Office of Personnel Security throughout your

      12    tenure there; is that accurate?

      13         A    Yes.

      14         Q    When did you first meet

      15    Mr. Livingstone?

      16         A    As I stated before, when I did an

      17    internship type thing in 1988 at the Atlanta

      18    -- the National Convention of the Democratic

      19    Committee in Atlanta.

      20         Q    And how well did you get to know

      21    Mr. Livingstone during that period of time?

      22         A    Not very well.  We were in and out



       1    of the same office.

       2         Q    Was he much more than an

       3    acquaintance during that period of time?

       4              MR. KLAYMAN:  Objection.  Vague and

       5    ambiguous.

       6              THE WITNESS:  No.

       7              BY MR. GARREN:

       8         Q    Now, you mentioned that at a later

       9    date, in 1992, when you decided that you

      10    wanted to volunteer for the Clinton campaign,

      11    that you gave Mr. Livingstone a telephone

      12    call; is that correct?

      13         A    Yes.

      14         Q    Now, between those times, that is,

      15    between the time that you worked for the

      16    Democratic National Committee in 1988 and the

      17    time when you called Mr. Livingstone in 1992,

      18    were you in routine contact with

      19    Mr. Livingstone?

      20              MR. KLAYMAN:  Objection.  Vague and

      21    ambiguous.

      22              THE WITNESS:  No.



       1              BY MR. GARREN:

       2         Q    How often between 1988 Democratic

       3    National Convention in Atlanta and 1992 would

       4    you say that you spoke to Mr. Livingstone?

       5         A    None, to my memory.

       6         Q    So the first contact that you had

       7    with Mr. Livingstone after the Democratic

       8    convention in 1988 was your contact in 1992

       9    about volunteering for the Clinton campaign;

      10    is that right?

      11         A    Yes.

      12         Q    Now, was Mr. Livingstone your

      13    immediate supervisor in the Office of

      14    Personnel Security?

      15         A    Yes.

      16         Q    You mentioned at some point,

      17    approximately August of '93, you became the

      18    executive assistant in the office; is that

      19    correct?

      20         A    Yes.

      21         Q    When you became the executive

      22    assistant in the office, were you the



       1    number-two person in the office?

       2         A    Yes.

       3         Q    If Mr. Livingstone was out of the

       4    office, were you the boss in the office?

       5         A    Quasi, yes.

       6         Q    During your time with the Office of

       7    Personnel Security, did you work closely with

       8    Mr. Livingstone?

       9         A    Define "closely."

      10         Q    Did you work with him generally on

      11    a daily basis?

      12         A    In the same office, yes.

      13         Q    And did you feel that you were in a

      14    good position to observe his work activities

      15    in the office?

      16              MR. KLAYMAN:  Objection.  Vague and

      17    ambiguous.  Lacks foundation.


      19              BY MR. GARREN:

      20         Q    You can answer the question.

      21         A    Yes.

      22         Q    At any time during your work in the



       1    Office of Personnel Security, did you see or

       2    hear anything that suggested to you that

       3    Mr. Livingstone might be involved in some

       4    sort of political conspiracy to obtain

       5    confidential information on prior

       6    administration employees?

       7              MR. KLAYMAN:  Objection.

       8    Multi-compound question.  Lacks foundation.

       9    Vague and ambiguous.  Leading.

      10              BY MR. GARREN:

      11         Q    And you can answer the question.

      12         A    No.

      13              MR. KLAYMAN:  Other than that, it's

      14    a great question.

      15              MR. GARREN:  I'm glad you liked the

      16    question.

      17              BY MR. GARREN:

      18         Q    At any time during your tenure with

      19    the Office of Personnel Security, did you

      20    hear or see anything that suggested to you

      21    that Mr. Livingstone had any desire or

      22    intention to misuse the personnel security



       1    files held by the Office of Personnel

       2    Security?

       3              MR. KLAYMAN:  Objection.  Vague and

       4    ambiguous.  Lacks foundation.  Leading and

       5    vague.

       6              BY MR. GARREN:

       7         Q    Do you understand the question?

       8         A    Yes.

       9         Q    And what's your answer to the

      10    question?

      11         A    No.  I'm assuming you were asking

      12    me if I saw any signs of a conspiracy?

      13         Q    The first question was did you see

      14    any signs of a conspiracy?

      15         A    No.

      16              MR. KLAYMAN:  Same objection.

      17              BY MR. GARREN:

      18         Q    The second question is did you ever

      19    see any signs that Mr. Livingstone intended

      20    or desired to misuse the security files of

      21    the office?

      22              MR. KLAYMAN:  Same objection.



       1              THE WITNESS:  No.  Same answer.

       2              BY MR. GARREN:

       3         Q    Now, Ms. Anderson, are you aware of

       4    Mr. Livingstone or any member of his family

       5    having any type of friendship with the First

       6    Lady?

       7         A    No.

       8              MR. KLAYMAN:  Objection.  Vague and

       9    ambiguous.  Lacks foundation.

      10              THE WITNESS:  No.

      11              BY MR. GARREN:

      12         Q    Did Mr. Livingstone at any time

      13    ever suggest to you that he had any type of

      14    personal friendship or relationship with the

      15    First Lady?

      16              MR. KLAYMAN:  Objection.  Leading.

      17    Vague and ambiguous.  Lacks foundation.

      18              BY MR. GARREN:

      19         Q    You can answer.

      20         A    No.

      21         Q    During your tenure with the Office

      22    of Personnel Security, Ms. Anderson, were you



       1    aware of the First Lady ever expressing any

       2    interest whatsoever in the work of the Office

       3    of Personnel Security?

       4         A    No.

       5              MR. KLAYMAN:  Objection.  Leading.

       6              THE WITNESS:  No.

       7              MR. KLAYMAN:  And vague and

       8    ambiguous.

       9              BY MR. GARREN:

      10         Q    To your knowledge, did the First

      11    Lady at any time during your tenure with the

      12    office ever come to the office?

      13              MR. KLAYMAN:  Objection.  Leading.

      14    Vague and ambiguous.  Imprecise as to time.

      15              BY MR. GARREN:

      16         Q    You can answer.

      17         A    No.

      18         Q    Well, let's make sure it's clear as

      19    to time.  During your tenure with the Office

      20    of Personnel Security, are you aware of the

      21    First Lady ever coming to the Office of

      22    Personnel Security?



       1              MR. KLAYMAN:  Objection.  Same

       2    objection.

       3              BY MR. GARREN:

       4         Q    You can answer the question.

       5         A    Between February of '93 to August

       6    of '94, no.

       7         Q    During your tenure with the Office

       8    of Personnel Security, were you aware of

       9    anything suggesting that Mr. Livingstone

      10    might have personally communicated in any

      11    fashion with the First Lady?

      12              MR. KLAYMAN:  Objection.  Vague and

      13    ambiguous.  Lacks foundation.

      14              THE WITNESS:  No.

      15              MR. KLAYMAN:  And leading.

      16              BY MR. GARREN:

      17         Q    Now let me turn your attention to

      18    Tony Marceca.  Do you know Mr. Marceca?

      19         A    Yes.

      20         Q    When did you first meet him?

      21         A    I first met Mr. Marceca when I

      22    began work for the inaugural committee.



       1         Q    Did you work with Mr. Marceca

       2    during the inaugural committee?

       3         A    I worked in the same office with

       4    him.

       5         Q    Do you know the kind of work that

       6    he performed in the inaugural committee?

       7         A    Vaguely.

       8         Q    What do you know about that?

       9         A    He did the -- he worked with the

      10    command center that was set up for the

      11    inaugural and what exactly he did, I'm not

      12    sure.

      13         Q    Did the two of you work together at

      14    any time on any kind of project or

      15    assignment?

      16         A    No.

      17         Q    Were you aware at the time that you

      18    worked for the inaugural committee that

      19    Mr. Marceca was employed by the Defense

      20    Department?

      21         A    Yes.

      22         Q    Did you know what he did for the



       1    Defense Department?

       2         A    I believe he was in the criminal

       3    investigations.

       4         Q    And how did you learn that?

       5         A    He told me.

       6         Q    What did he tell you that you can

       7    recall about his work at the Defense

       8    Department?

       9         A    That he worked in the criminal

      10    investigations unit.

      11         Q    You can't remember anything else he

      12    said?

      13         A    No.

      14         Q    Now, did you later learn at some

      15    point about efforts to have Mr. Marceca

      16    detailed to the Office of Personnel Security?

      17              MR. KLAYMAN:  Objection.  Leading.

      18    Provides facts not in evidence.  Vague and

      19    ambiguous.

      20              BY MR. GARREN:

      21         Q    You can answer the question.

      22         A    What exactly is the question?


Next Section
of this Deposition