1 1 UNITED STATES DISTRICT COURT DISTRICT OF COLUMBIA 2 -------------------------x 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 : -------------------------x 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. : -------------------------x 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 2 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 11 On behalf of Defendants Executive Office of 12 the President, Federal Bureau of Investigation: 13 TIMOTHY P. GARREN, ESQUIRE 14 JAMES J. GILLIGAN, ESQUIRE ELIZABETH J. SHAPIRO, ESQUIRE 15 DIANNE SPELLBERG, 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 22 3 1 APPEARANCES (CONT'D): 2 On behalf of Defendant Hillary Rodham Clinton: 3 PAUL B. GAFFNEY, ESQUIRE 4 Williams & Connolly 725 Twelfth Street N.W. 5 Washington, D.C. 20005 (202) 434-5803 6 On behalf of Defendant Livingstone: 7 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 10 On behalf of Defendant Nussbaum: 11 ROBERT B. MAZUR, ESQUIRE 12 Wachtell Lipton Rosen & Katz 51 West 52nd Street 13 New York, New York 10019-6618 (212) 403-1000 14 On behalf of The White House: 15 SALLY PATRICIA PAXTON, ESQUIRE 16 Special Associate Counsel to the President The White House 17 Washington, D.C. 20500 (202) 456-5079 18 19 20 * * * * * 21 22 4 1 C O N T E N T S 2 EXAMINATION BY: PAGE 3 Counsel for Defendants 8 4 Counsel for Plaintiffs 177 5 FURTHER EXAMINATION BY: 6 Counsel for Defendants 426 7 ANDERSON DEPOSITION EXHIBITS: 8 No. 1 - FBI Liaison Request Form 65 9 No. 2 - Green-Striped Paper 89 10 No. 3 - Gemmell Declaration, 104 Attachment 11 No. 4 - White House Operations 157 12 Personnel List 13 No. 5 - Senate Judiciary Committee 194 Testimony Transcript 14 No. 6 - Fact Sheet, Attachment 220 15 No. 7 - Redacted FBI Liaison Requests 266 16 No. 8 - Visitation Logs 295 17 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 21 22 5 1 ANDERSON DEPOSITION EXHIBITS (CONT'D): PAGE 2 No. 12 - Memorandum, Kennedy to Hilty, 369 Attachment 3 No. 13 - Background Investigation 382 4 Check-Out Log 5 6 * * * * * 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 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 8 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: 7 EXAMINATION BY COUNSEL FOR DEFENDANTS 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 9 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. 10 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 11 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 12 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. 13 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 14 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? 15 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 16 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 17 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 18 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. 19 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? 20 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. 21 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 22 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? 23 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 24 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. 25 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. 26 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. 27 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? 28 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? 29 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? 30 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. 31 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 32 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 33 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? 34 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 35 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. 36 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, 37 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? 38 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 39 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 40 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 41 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. 42 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 43 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. 18 19 BY MR. GARREN: 20 Q You can answer the question. 21 A Yes. 22 Q At any time during your work in the 44 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 45 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. 46 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 47 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? 48 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. 49 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 50 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?
of this Deposition