201
1 A Yes.
2 Q Who have you talked about it with?
3 A The civil department of the
4 Department of Justice.
5 Q When did you hear from them, even
6 if it predated the six months? When did you
7 first hear from the civil department, as you
8 call it?
9 A I believe it was end of March,
10 beginning of April.
11 Q Of this year?
12 A Yes.
13 Q Who contacted you?
14 A My attorney, Mark Srere.
15 Q And did he then put you in contact
16 with the civil department? Was that
17 Mr. Gilligan he put you in contact with?
18 A I believe it was, but I mainly have
19 dealt with Dianne.
20 Q Dianne who?
21 MR. GILLIGAN: Ms. Spellberg.
22 MS. SPELLBERG: Spellberg.
202
1 BY MR. KLAYMAN:
2 Q Ms. Spellberg, okay. And did there
3 come a point in time when you actually spoke
4 with them about this case?
5 A Yes.
6 Q When was that, the first time?
7 A I believe it was the beginning of
8 April.
9 Q And did you speak with them by
10 phone or was it in person?
11 A In person.
12 Q Did they fly you here to
13 Washington?
14 A Yes.
15 Q Who paid the expense of that?
16 A The civil department did.
17 Q Do you have any kind of attorney
18 agreement with them in writing? Did you
19 retain them in writing?
20 A I don't think you can retain the
21 government.
22 Q Is there any kind of written
203
1 agreement that says they're your lawyer?
2 A I do not believe so, no.
3 Q Did they offer to be your lawyer?
4 A As far as this matter goes, as far
5 as my professional relation with The White
6 House.
7 Q Who made that offer?
8 A I believe that was always the
9 understanding of working at The White House,
10 that any time a dispute would come up in your
11 official capacity, it would be handled by the
12 Department of Justice.
13 Q But you weren't represented when
14 you spoke with the Independent Counsel --
15 MR. GILLIGAN: Mr. Klayman, let me
16 just add a clarification for the record. As
17 I stated early, we represent Ms. Anderson --
18 MR. KLAYMAN: Please do not pollute
19 the testimony. This is inappropriate. I'm
20 entitled to ask her who she understands
21 represents her before you tell her that.
22 I've got motions for sanctions pending. I'd
204
1 hate to have to file supplements.
2 MR. GILLIGAN: As I've asked you
3 before, do not interrupt me when I'm making a
4 statement on the record.
5 MR. KLAYMAN: It was right in the
6 middle of my question. I'm entitled to an
7 answer.
8 MR. GILLIGAN: And I did not --
9 MR. KLAYMAN: I'm entitled to an
10 answer. Please wait.
11 MR. GILLIGAN: Your question is not
12 finished and I'm going to state again for the
13 record, as I stated earlier, we represent
14 this witness in her official capacity.
15 MR. KLAYMAN: Why was that
16 necessary other than trying to influence the
17 testimony? Please certify this highly
18 sanctionable behavior.
19 MR. GILLIGAN: So you say.
20 THE WITNESS: What was the question
21 again, please?
22 BY MR. KLAYMAN:
205
1 Q When you appeared in front of the
2 Independent Counsel and spoke with them, the
3 Justice Department didn't represent you then,
4 did it?
5 A Considering that it was ultimately
6 the Justice Department asking the questions,
7 no. That would have been in conflict.
8 Q You're saying that the Independent
9 Counsel, to the best of your knowledge, is
10 the Justice Department?
11 A I'm saying they are part of -- the
12 attorneys represented themselves as
13 Independent Counsel under the jurisdiction of
14 the Department of Justice.
15 Q So you considered the Independent
16 Counsel to have represented you at the time
17 you spoke with them?
18 A No, I'm saying that it would have
19 been a conflict of interest for them to have
20 said that they would have represented me.
21 What I'm saying, I was a witness and I
22 retained my own attorney.
206
1 Q Did there come a point in time
2 since you've had contact with the Justice
3 Department in March of this year where they
4 told you that they wanted to represent you?
5 A They have never told me that they
6 wanted to represent me. They have told me
7 that in my official capacity as an employee
8 of The White House, they, as my official
9 capacity, represented me, as Mr. Gilligan had
10 stated.
11 Q So they presented that to you as a
12 fait accompli? They didn't ask for your
13 permission? They just said we're
14 representing you?
15 A I'm not sure what your implication
16 is.
17 Q I don't have to have an
18 implication. I'm just asking the question.
19 A I'm not sure what your question is.
20 Q They advised you they were
21 representing you, correct, the Justice
22 Department?
207
1 A They advised me that there was a
2 civil litigation and that my testimony would
3 help in the matter.
4 Q Who told you your testimony would
5 help end the matter?
6 MR. KLAYMAN: She's already
7 testified to it, Mr. Gilligan.
8 MS. SPELLBERG: She didn't say
9 "end."
10 MR. KLAYMAN: Yes, she did.
11 MR. GILLIGAN: Could I have the
12 question and the answer read back, please?
13 MR. KLAYMAN: I'm asking the
14 questions. I'm not asking for it to be read
15 back.
16 MR. GILLIGAN: I am for purposes of
17 possibly lodging an objection.
18 (The reporter read the record as
19 requested.)
20 THE WITNESS: In the matter.
21 BY MR. KLAYMAN:
22 Q Who advised you that?
208
1 MR. GILLIGAN: I'm going to object
2 to any further questioning. The fact of
3 representation is one thing but questions
4 about the nature of our discussions with this
5 witness tread upon privileged information and
6 I object.
7 MR. KLAYMAN: She waived it. She
8 just testified to that.
9 MR. GILLIGAN: They testified to
10 the fact of representation and that's all.
11 MR. KLAYMAN: Certify it.
12 MR. GILLIGAN: Jim Gilligan.
13 MR. JOSEPH: It's ���� Joseph
14 again.
15 MR. GILLIGAN: Yes, Mr. Joseph.
16 MR. JOSEPH: I'm conferred with an
17 associate Independent Counsel who's more
18 familiar with this matter than I and I
19 suppose we're a little concerned about this
20 in light of the pending criminal
21 investigation, and I'd like to go back and
22 tell him, if I can, what the relevance of
209
1 this particular line of questioning is to the
2 civil action.
3 MR. KLAYMAN: This is Mr. Klayman.
4 The civil action is the civil side of what
5 happened in Filegate. It's a $90 million
6 lawsuit could turn into a class action
7 lawsuit if certified on behalf of people
8 whose files were taken, and we would be very
9 interested and in fact it would be very
10 important to know whether others have been
11 told things different than what is being
12 testified to today about the nature of
13 Ms. Anderson's involvement with Craig
14 Livingstone and others.
15 So, consequently, it's very
16 relevant in our civil suit and that's why I
17 offered that, if there's a problem in our
18 asking questions as to what you had posed to
19 Ms. Anderson, that at a minimum we should be
20 able to ask what she said.
21 And again we're not asking at this
22 point if she said anything before a grand
210
1 jury, just whether she said it to anyone and
2 you're, of course, among the group of people
3 she discussed the facts that are underlying
4 this lawsuit with.
5 MR. GILLIGAN: In a nutshell,
6 impeachment.
7 MR. KLAYMAN: That's not correct
8 for Mr. Gilligan to say. I'm the one asking
9 the questions.
10 MR. GILLIGAN: That's the apparent
11 relevance to us.
12 MR. KLAYMAN: If you want to confer
13 and get back to us, that's fine.
14 MR. JOSEPH: I don't really know
15 what I'm going to be able to do today, but
16 I'll see what I can do.
17 MR. KLAYMAN: Okay.
18 MR. JOSEPH: Right now I object to
19 it but I don't really know what status or
20 standing I have to do that. I'm not familiar
21 with the history of the Filegate matter. I
22 have to confer on that. I already have, but,
211
1 if there's some way you can just hold this in
2 abeyance until I can get an answer, if I can
3 get an answer, I'd appreciate it.
4 MR. KLAYMAN: That's fine. We
5 moved on to other areas hoping that you might
6 be able to get back to us. Thank you.
7 MR. GILLIGAN: Thank you,
8 Mr. Joseph.
9 BY MR. KLAYMAN:
10 Q My question was, Ms. Anderson, that
11 you were advised by the Justice Department
12 that it was representing you in the lawsuit
13 that you're here on today, correct?
14 MR. GILLIGAN: Questions about
15 representation are okay.
16 THE WITNESS: As far as my official
17 capacity went in The White House, yes.
18 BY MR. KLAYMAN:
19 Q And they presented that to you as
20 if that was an established fact, correct?
21 A My understanding is that, since
22 you're suing the government and a few other
212
1 individuals, that it was as part of my
2 actions under the capacity of The White House
3 Office of Personnel Security.
4 Q And they flew you to Washington at
5 their expense?
6 A Yes.
7 Q And how long did you meet with them
8 in Washington and discuss this lawsuit?
9 A One morning.
10 Q And who did you meet with?
11 A Tim Garren, Jim Gilligan, and
12 Dianne Spellberg.
13 Q Did you meet with them after that
14 or talk to them after that about this
15 lawsuit?
16 A Not until I flew up yesterday.
17 Q And how long did you meet with them
18 yesterday or talk to them yesterday?
19 A I believe it was maybe one to two
20 hours.
21 Q And it was those two sets of
22 discussions that helped refresh your memory,
213
1 correct?
2 A No.
3 Q Didn't help you at all?
4 A I'm saying it's not the one that
5 completely refreshed my memory, no.
6 Q What helped refresh your memory?
7 MR. GILLIGAN: I would just
8 instruct the witness not to reveal the
9 substance of any communications she had with
10 lawyers for the Department of Justice.
11 MR. KLAYMAN: She just said you
12 didn't refresh her memory.
13 MR. GILLIGAN: I'm just being
14 cautious, Mr. Klayman.
15 THE WITNESS: The process of going
16 back into what happened while I was at The
17 White House.
18 BY MR. KLAYMAN:
19 Q And how did you go through that
20 process of going back?
21 MR. GILLIGAN: Same instruction.
22 BY MR. KLAYMAN:
214
1 Q That came through the lawyers,
2 right, through sitting down and discussions
3 with them?
4 A That came through the Independent
5 Counsel investigations and whatnot.
6 Q Came from meeting with the
7 Department of Justice in this lawsuit, did it
8 not?
9 A It has culminated in that, yes.
10 Q And when did you meet with the
11 Independent Counsel? What was the date?
12 A I believe I've already said that
13 was in August.
14 Q Of '96?
15 A Yes.
16 Q So it's been going on two years
17 since you met with the Independent Counsel,
18 correct?
19 A It's been that long of a period of
20 time, yes.
21 Q And in fact you met with the
22 Independent Counsel in August of '96 and that
215
1 was a few months before you testified before
2 the Senate, which is Exhibit 5, correct?
3 A Yes.
4 Q So the Independent Counsel, those
5 discussions had already helped you refresh
6 your recollection by the time you testified
7 in the Senate?
8 A To some degree, yes.
9 Q Now, since the date that you
10 testified in the Senate, did you ever speak
11 with Craig Livingstone?
12 A No.
13 Q Did you see Craig Livingstone from
14 that point forward?
15 A On TV.
16 Q Did you see Anthony Marceca or
17 speak with him from October 1, 1996, to the
18 present?
19 A No.
20 Q Did you speak with Ms. Gemmell?
21 A No.
22 Q Anyone that you worked with in the
216
1 Office of Personnel Security?
2 A No.
3 Q So the only people you've talked to
4 are the Independent Counsel and the Justice
5 Department in preparing for your appearance
6 here today, correct?
7 A I've spoken with them on the case
8 and only the two times that I mentioned
9 previously in April and yesterday in
10 preparation for this.
11 Q Right. So there was the
12 Independent Counsel and there were two
13 meetings with the Department of Justice in
14 this particular lawsuit?
15 A And there was the Senate
16 deposition.
17 Q Right. And those are the only
18 opportunities that you've had to refresh your
19 recollection?
20 A They're the only times that I have
21 discussed the case, yes.
22 Q So after the appearance before the
217
1 Senate, the only times that you've discussed
2 the case are with the lawyers of the
3 Department of Justice?
4 A I believe I have stated that, yes.
5 Q And during those discussions with
6 the lawyers of the Department of Justice,
7 they did speak to you, did they not?
8 A I believe it was necessary for
9 communication, yes.
10 Q And they did provide to you their
11 understanding of the facts, did they not?
12 A No.
13 MR. GILLIGAN: Objection.
14 BY MR. KLAYMAN:
15 Q Did you ever meet with any counsel
16 from The White House about the lawsuit that
17 you're here on today?
18 A No.
19 Q Did you ever speak with any counsel
20 from The White House?
21 A No. I'm assuming you mean for this
22 civil case.
218
1 Q Right.
2 A No.
3 Q Are you aware that Ms. Sally Paxton
4 from this room is from the White House?
5 A Yes. I believe she introduced
6 herself as White House counsel.
7 Q When did she introduce herself?
8 Was that today?
9 A When she stated for the record who
10 she was.
11 Q Was that today?
12 A Yes.
13 Q Have you ever seen the complaint in
14 this lawsuit?
15 A No.
16 Q Have you ever seen any what lawyers
17 call discovery responses in this lawsuit?
18 A Not to my knowledge, no.
19 Q Do you know what interrogatories
20 are?
21 A Yes.
22 Q Did you ever see interrogatory
219
1 responses?
2 A No.
3 Q Has anyone showed you any
4 pleadings?
5 A Pleadings?
6 Q Legal briefs?
7 A No.
8 Q So all of the information which you
9 obtained from the lawyers of the Department
10 of Justice came to you orally, by word of
11 mouth?
12 A I'm not sure what information
13 you're talking about that came to me from the
14 Department of Justice. They've asked me what
15 I knew and I answered their questions.
16 Q Did they give you anything in
17 writing, any talking points or anything like
18 that?
19 A No.
20 Q Has it been your experience that
21 your memory gets the better the longer you're
22 away from events that have occurred?
220
1 A No.
2 Q Generally it gets worse, doesn't
3 it?
4 A Yes.
5 MR. KLAYMAN: I'll show you what
6 I'll ask the court reporter to mark as
7 Exhibit 6.
8 (Anderson Deposition Exhibit
9 No. 6 was marked for
10 identification.)
11 BY MR. KLAYMAN:
12 Q Before I ask you that question,
13 they paid for your trip up here today as
14 well, did they not?
15 A Yes.
16 Q And they're paying for your hotel?
17 A My understanding, yes.
18 Q Have they paid any other expenses
19 of yours, the Justice Department?
20 A No.
21 Q Paying for your meals?
22 A Supposed to be.
221
1 Q Paying for your cab fare?
2 A Supposed to be. I have yet to see
3 it, but supposed to be.
4 Q Do you have anything in writing as
5 to how you're supposed to be reimbursement?
6 A No.
7 Q Who promised you to make payment
8 for your expenses?
9 A I believe that would be the lawyers
10 in front of you.
11 Q Which ones?
12 A Dianne, Tim, and Jim.
13 Q Showing you what has been marked as
14 Exhibit 6.
15 MR. GILLIGAN: Do you have
16 additional copies of the document,
17 Mr. Klayman?
18 MR. KLAYMAN: I certainly do. I
19 would never leave you out, Mr. Gilligan.
20 MR. GILLIGAN: It would be no fun
21 that way.
22 BY MR. KLAYMAN:
222
1 Q Have you ever seen this document
2 before? There's a face sheet called
3 Alexander v. FBI, Defendants Third
4 Supplemental Response to Plaintiffs' First
5 Request for Production of Documents, and
6 attached to this is something called a fact
7 sheet, the testimony of Mari Anderson, which
8 comprises Bates numbers 15634, 15635, 15636
9 with attached deposition testimony, and those
10 span Bates number 15637 through and including
11 15645. Have you ever seen this before, in
12 whole or in part?
13 A I've never seen the fact sheet, but
14 I have seen my deposition.
15 Q The markings that are on the
16 deposition portions, 15639 through and
17 including 15645, are those your markings?
18 A No.
19 Q Do you know whose they are?
20 A No.
21 Q Take a look at the fact sheet. You
22 see where certain questions and answers are
223
1 provided?
2 A Yes.
3 Q And why don't you read them? There
4 are just two pages, a little bit more than
5 two pages.
6 Did you discuss these questions and
7 answers when you met with the attorneys for
8 the Justice Department?
9 MR. GILLIGAN: Objection. You're
10 asking a question that would call for an
11 answer that would be violative of the
12 attorney-client privilege.
13 MR. KLAYMAN: This is a matter of
14 public record. It's been produced as a fact
15 sheet testimony of Mari Anderson.
16 MR. GILLIGAN: Ask her about the
17 document, if you will, but do not ask her if
18 it's something she saw when she met with the
19 attorneys.
20 MR. KLAYMAN: Assuming you can even
21 claim attorney-client privilege, it's been
22 waived by having produced this fact sheet
224
1 concerning her testimony.
2 MR. GILLIGAN: That is a complete
3 jumble to me. I'm not claiming the document
4 to be privileged. Yes, we produced it to
5 you. What I'm claiming is whether this
6 document was discussed with the witness
7 during our discussions with her is a matter
8 of privilege, and I instruct the witness not
9 to answer.
10 MR. KLAYMAN: It's not a matter of
11 privilege because I'm not asking her anything
12 going beyond what is already written on this
13 document. I'm just trying to identify
14 whether the questions and answers were
15 discussed. They're already a matter of
16 record.
17 MR. GILLIGAN: That's exactly
18 right.
19 MR. KLAYMAN: I'm not asking for
20 any advice between attorney and client. It's
21 not covered by the attorney-client privilege.
22 I'm just saying was this discussed. I'm
225
1 allowed to identify by date, author, and
2 subject matter generally speaking what's
3 discussed between attorney and client.
4 That's what would be in a privilege log and I
5 could therefore ask whether this document was
6 discussed.
7 MR. GILLIGAN: I suggest actually
8 that you already have an answer to an earlier
9 question which gives you the information you
10 need.
11 BY MR. KLAYMAN:
12 Q Was the information contained in
13 this document discussed?
14 MR. GILLIGAN: Objection.
15 MR. KLAYMAN: All right. Certify
16 it. I'm not going to waste any more time on
17 it.
18 MR. GILLIGAN: Please ask the
19 witness again, as you did earlier, if she's
20 ever seen this document before.
21 BY MR. KLAYMAN:
22 Q I just asked whether the
226
1 information contained in this document was
2 discussed when you met with counsel for the
3 Justice Department?
4 MR. GILLIGAN: Objection. Instruct
5 the witness not to answer.
6 MR. KLAYMAN: Certify it.
7 BY MR. KLAYMAN:
8 Q Have you ever discussed the
9 information contained in this document,
10 Exhibit 6, at any time with persons other
11 than counsel?
12 A Yes -- or other than --
13 Q Other than lawyers?
14 A No.
15 Q Do you know who prepared Exhibit 6?
16 A No.
17 Q Ms. Anderson, assuming this case
18 goes to trial and we believe that it will,
19 will you be available to testify here
20 personally in Washington, D.C.?
21 A It would depend on the time frame.
22 Q Would you make yourself available?
227
1 A Again, it would depend on the time
2 frame.
3 Q Do you know of anything that's
4 scheduled within the next two years at the
5 present time that would prevent you from
6 attending?
7 A That would be class and finals
8 and/or papers and or tests.
9 Q But subject to working with that
10 type of scheduling concern you're willing to
11 return to Washington, D.C.?
12 A If I have the money.
13 Q Will you agree to do that if
14 someone pays your expense?
15 A Yes.
16 Q Let's go back to when you met Craig
17 Livingstone. I believe you testified earlier
18 that Craig Livingstone had worked for Ross
19 Perot?
20 A It was my understanding.
21 Q How did you learn that?
22 A When I called him to see about
228
1 entering the political realm.
2 Q You called him in Dallas? Is that
3 where he was?
4 A No.
5 Q Where was he?
6 A I do not know where he was. I
7 called his -- the number he gave me in D.C.
8 Q And he then called you back?
9 A Yes.
10 Q And you don't know whether he was
11 calling you from D.C. or someplace else?
12 A I do not remember if he was calling
13 me from someplace else.
14 Q I believe you testified you met him
15 in 1988 at the Democratic National Committee
16 Convention in Atlanta?
17 A Yes.
18 Q When he called you back, did you
19 ask him what he was doing for Ross Perot?
20 A No.
21 Q Did you later learn what he was
22 doing for Mr. Perot?
229
1 A Well, he offered to --
2 Q What did he say specifically he was
3 doing?
4 A Advance.
5 Q Did he tell you what that entailed?
6 A Yes.
7 Q And what was that?
8 A That was the setting up of
9 Mr. Perot's meetings in relation to the
10 campaign for President.
11 Q Did he tell you whether he had
12 personal contact with Mr. Perot?
13 A No.
14 Q Did he tell you who he was working
15 with on the Perot campaign, particular names?
16 A No.
17 Q Did you learn after that more about
18 what he had done for Perot?
19 A No.
20 Q During the time that you worked for
21 the Office of Personnel Security, I take it
22 the name Perot came up?
230
1 A No.
2 Q Did you ever see a file of Ross
3 Perot?
4 A No.
5 Q An FBI file?
6 A Not to my recollection.
7 Q Any other kind of file?
8 A I saw many other files but not in
9 relation to Mr. Perot.
10 Q Did he ever mention a Russell
11 Varney to you?
12 A Not that I remember.
13 Q Or Pat Choate?
14 A Not that I remember.
15 Q A Mr. Stockdale? Does that name
16 ring a bell?
17 A Admiral Stockdale?
18 Q Yes.
19 A Only in the sense that when we --
20 as the staff in Little Rock watched the TV
21 airing of the debate where he asked who am I,
22 why am I here.
231
1 Q Was that ever discussed during the
2 time you were in The White House Office of
3 Personnel Security?
4 A Yes.
5 Q When was that discussed?
6 A Specifically, I do not know.
7 Q Do you know why it was discussed?
8 A Yes.
9 Q Why?
10 A We were sort of laughing about it
11 because we thought it was funny that Admiral
12 Stockdale would say who am I, why am I here
13 in the middle of a Vice Presidential debate.
14 Q I asked you the question about The
15 White House Office of Personnel Security.
16 You weren't there until after the election,
17 were you?
18 A And that's what I'm saying. It was
19 after the election.
20 Q So you were discussing what had
21 happened during the election?
22 A Randomly, yes.
232
1 Q Who did you discuss that with?
2 A I believe we were talking at that
3 time, if my memory is correct, with interns.
4 Q Now, you previously this morning --
5 correct me if I'm wrong -- identified some of
6 these interns?
7 A Yes.
8 Q Do you know where some of these
9 interns are today?
10 A No.
11 Q There was one named Melissa, right?
12 A Yes.
13 Q And there was one named Ed Hughes?
14 A Yes.
15 Q And a Ms. Bertucci?
16 A Yes.
17 Q What was her first name?
18 A Erin.
19 Q Lisa Wetzl, which is she located?
20 A Where is she now?
21 Q Right.
22 A Now exactly I do not know, but last
233
1 I heard she was at the Department of Defense.
2 Q Do you know where she's working at
3 Department of Defense?
4 A No.
5 Q Is she working in the press office,
6 by any chance?
7 A I do not know.
8 Q And what are some of the other
9 names that you can remember right now? Was
10 there a Gina?
11 A Gina Gibson.
12 Q Where is she?
13 A I do not know.
14 Q Any other interns?
15 A Anthony Audi, Melissa Eventas, Luis
16 who I do not remember his last name, and I
17 think that covers all of them, and of those I
18 do not know where they are.
19 Q Since you testified before the
20 Senate, have you discussed the Filegate
21 matter with any of these individuals?
22 A No.
234
1 Q Have you seen them?
2 A No.
3 Q Have you ever had contact with
4 Betsy Wright?
5 A No.
6 Q Maggie Williams?
7 A No.
8 Q Harold Ickes?
9 A No.
10 Q Janet N. Wright?
11 A No.
12 Q George Stephanopolous?
13 A No.
14 Q You ever met George Stephanopolous?
15 A Yes.
16 Q When did you meet?
17 A During the campaign in Little Rock.
18 Q That's contact, isn't it?
19 A Not since this came about nor did I
20 discuss this with because I had not begun
21 working for The White House.
22 Q After you began working for The
235
1 White House did you ever speak with
2 Mr. Stephanopolous or anyone on his behalf?
3 A No. On his staff, yes.
4 Q Who?
5 A Heather ����.
6 Q How did you come to speak with her?
7 A Calling her, asking her to say that
8 we needed information in regard to her
9 permanent pass or George's permanent pass.
10 Q Why did you need information about
11 that?
12 A Things that they had not yet done.
13 As I had mentioned, you had to have a tax
14 check, you had to have a background
15 investigation, you had to attend a security
16 briefing, you had to have a personal
17 interview and other stuff, and if there was
18 something missing we contacted them and asked
19 them to please perform that duty.
20 Q Did you ever meet anyone who worked
21 with Mr. Stephanopolous by name of
22 Ms. Lenzner?
236
1 A No.
2 Q Does that name ring a bell?
3 A No.
4 Q Does the name Terry Lenzner ring a
5 bell?
6 A No.
7 Q Have you ever met or talked with a
8 Jack Palladino?
9 A No.
10 Q A Deb Coyle, secretary to Betsy
11 Wright?
12 A Deb Coyle sounds familiar but I'm
13 not sure in which capacity.
14 Q Well, she was the former secretary
15 of Betsy Wright?
16 A Again, the name sounds familiar but
17 I do not know in what capacity.
18 Q You had met Betsy Wright, though,
19 hadn't you?
20 A No.
21 Q Had you ever talked to the
22 secretary of Betsy Wright?
237
1 A Not that I know of.
2 Q A Doug ����?
3 A The name is familiar but I've never
4 met him.
5 Q Political director of The White
6 House?
7 A Yes.
8 Q Anybody in his office?
9 A Yes.
10 Q Who?
11 A Eric -- I'm going to mess up his
12 last name. It's Eric Sununus.
13 Q Sununu?
14 A Sununus. That's why I said I would
15 mess it up.
16 Q How is that spelled?
17 A S-e-n-u-s, I believe, I'm not sure
18 of the pronunciation --
19 MR. GILLIGAN: I think you might be
20 missing a sill bell.
21 THE WITNESS: I very well could be.
22 BY MR. KLAYMAN:
238
1 Q What did he do? What did
2 Mr. Sununus do at the time?
3 A At the time that I spoke to him he
4 was working in office of presidential
5 personnel.
6 Q And why did you have contact with
7 him?
8 A Passing in the hall. We were
9 friends.
10 Q Did you ever deal with him on
11 professional matters?
12 A No.
13 Q Paul Begala?
14 A No.
15 Q Anybody on his staff that you know
16 of?
17 A No.
18 Q James Carville?
19 A No.
20 Q I'm talking about ever having
21 contact with these people. You're aware of
22 that, right?
239
1 A No, I thought we were saying in
2 relation to this matter.
3 Q No, I'm talking about ever.
4 A James Carville in Little Rock, I
5 would go to the war meetings at night.
6 Q Why were you going to war meetings?
7 A I was a volunteer in the campaign
8 office.
9 Q During the time that you were a
10 volunteer in the campaign office, did you
11 ever hear anyone discuss during these war
12 meetings individuals or entities that had
13 criticized Governor Clinton?
14 A No.
15 Q Was there ever anyone discussed as
16 to who had criticized the governor who needed
17 to be investigated?
18 A No.
19 Q Did you ever hear anything like
20 that in the White House, we need to
21 investigate this person?
22 A No.
240
1 Q Capricia Marshall?
2 A Do I know her?
3 Q Yes.
4 A No.
5 Q Have you ever heard anyone say
6 during the time that you were with The White
7 House or thereafter we need to investigate
8 this particular person?
9 A In relation to the fact that they
10 had made a criticism of the --
11 Q No, with regard to anything?
12 A We had to investigate people who
13 were current employees of The White House.
14 Q Who do you remember needed to be
15 investigated?
16 A Any member -- current member of The
17 White House who had access or a pass.
18 Q Does the name Linda Tripp ring a
19 bell?
20 A It does now.
21 Q Was that one of the persons that
22 needed to be investigated?
241
1 A I don't remember at that time if
2 she was or not.
3 Q Nancy Erin Wright?
4 A I believe she is one of the
5 president's advisors.
6 Q Have you ever had any contact with
7 her?
8 A No.
9 Q Vince Foster?
10 A No.
11 Q I'm talking about any time.
12 A At any time.
13 Q Ann Lewis?
14 A Familiar. I'm not sure if I had
15 contact with her or not.
16 Q Do you know who she is?
17 A I know who she is.
18 Q Anybody from her office?
19 A I don't believe so.
20 Q Bernie Nussbuam?
21 A He was the head of the office under
22 which I fell, but I don't remember speaking
242
1 to him other than turning something into his
2 office.
3 Q Did you ever meet anybody from his
4 staff?
5 A Yes.
6 Q Who?
7 A Julie Mixell, I believe, is the
8 name that's popping up.
9 Q How is that spelled?
10 A I'm not sure but I believe it might
11 be M-i-x-e-l-l.
12 Q And under what circumstances did
13 you have contact with Ms. Mixell?
14 A Running something over to her
15 office or her calling about one of -- some
16 various matter that fell under office of
17 presidential personnel -- I'm sorry -- White
18 House personnel security.
19 Q Did you run an FBI file over to
20 that office?
21 A I do not remember.
22 Q Do you remember what context it was
243
1 that you went over to that office? What was
2 the matter you were working on generally?
3 A No.
4 Q Anybody else from Mr. Nussbuam's
5 office?
6 A Not to my memory.
7 Q Have you ever met a David Cohen?
8 THE WITNESS: Would that be you?
9 MR. KLAYMAN: That's him.
10 MR. COHEN: I'm one of them. There
11 are a lot of them.
12 THE WITNESS: I met him today.
13 BY MR. KLAYMAN:
14 Q Did you ever meet him before?
15 A No.
16 Q Did anyone ever have contact with
17 the Office of Personnel Security while you
18 were there by the name of David Cohen?
19 A I believe, maybe, but I can't
20 remember 100 percent.
21 Q What causes you to think that
22 perhaps that occurred?
244
1 A I do know that when the matter
2 first arose of some type of investigation in
3 Whitewater and when they started talking
4 about Vince Foster Craig had retained an
5 attorney and his name -- I'm not sure if it
6 was Mr. Cohen or someone else.
7 Q Did you ever meet Mr. Cohen before
8 today?
9 A No.
10 Q Had you ever talked with him on the
11 phone?
12 A Yes.
13 Q Right after Craig Livingstone had
14 retained him, to the best of your knowledge?
15 A Yes.
16 Q And how many times did you talk to
17 Mr. Cohen?
18 A I do not know.
19 Q More than once?
20 A If he called and left a message,
21 yes.
22 Q Did you ever talk to him about the
245
1 FBI files matter?
2 A Yes.
3 Q And what did he say to you?
4 A He asked me what I remembered of
5 it.
6 Q Was this done by phone or in
7 person?
8 A Phone.
9 Q And this occurred shortly after the
10 matter became public, back in 1996?
11 A I believe.
12 Q Did he ask you anything else?
13 A No.
14 Q And what did you tell him?
15 A I told him what I could remember of
16 it.
17 Q And that was?
18 A That in order for the project we
19 had to order a Secret Service list and that
20 it was that list that we worked off to
21 determine who needed an update.
22 Q What else did you tell him?
246
1 A That was it.
2 Q Did you provide any documents to
3 him?
4 A No, it was only over the phone and
5 I had no documents.
6 Q I take it he asked to meet with
7 you?
8 A No.
9 Q Did you promise your support to
10 help him and Craig?
11 A No.
12 Q Did you ever speak or meet a Randy
13 Turk?
14 A I don't believe so but I don't
15 remember.
16 Q Does that name ring a bell?
17 A It's familiar but I'm not sure why.
18 I believe he was one of Craig's original
19 attorneys, maybe? I'm not sure. He's a
20 lawyer. I know that.
21 Q Did you ever speak with any counsel
22 of Anthony Marceca concerning the Filegate
247
1 matter?
2 A I do not believe so.
3 Q Have you ever had any contact with
4 a Mickey Kantor?
5 A No.
6 Q Anybody from his office?
7 A Yes.
8 Q Who?
9 A I'm not sure but it would have been
10 in relations to the U.S. Trade Office and one
11 of his members needing access to The White
12 House.
13 Q Which member needed access?
14 A I do not remember.
15 Q Anything with regard to the FBI
16 Filegate matter?
17 A No.
18 Q Have you ever had any contact with
19 Bruce Lindsey?
20 A No.
21 Q Anybody from his office?
22 A I am not sure.
248
1 Q Any contact with regard to the FBI
2 Filegate matter?
3 A No.
4 Q When was the first time you met
5 William Kennedy?
6 A When I began working at The White
7 House under the offices of White House
8 personnel.
9 Q Did you ever discuss the FBI
10 Filegate matter after it became public with
11 Mr. Kennedy?
12 A No.
13 Q Anybody from his office?
14 A No.
15 Q Now, Linda Tripp worked for
16 Mr. Kennedy, did she not?
17 A I do not know.
18 Q Did you ever meet her?
19 A I do not remember.
20 Q Do you remember meeting anybody in
21 Mr. Kennedy's office.
22 A Yes.
249
1 Q Who?
2 A Ed ����, Clarissa ����, Beth Nolan,
3 Cliff ����and I can't remember the
4 secretary's name, but there were two.
5 Q And have you ever discussed the FBI
6 files matter with any of these people?
7 A No.
8 Q Kathryn Cornelius?
9 A Yes.
10 Q When did you meet her or talk to
11 her?
12 A The first time I met her was when I
13 was working in Little Rock, but I just knew
14 who she was, and then I remember meeting her
15 again when I started working at The White
16 House.
17 Q What was the nature of the contact
18 in Little Rock?
19 A She would be in the smoking room.
20 I would be going in to get a Diet Coke.
21 Q You ever talk to her about anything
22 of substance?
250
1 A No.
2 Q And what did you talk to her about
3 in The White House?
4 A Hi, how are you? Just things like
5 that, nothing of substance.
6 Q Anybody in her office that you had
7 contact with, ever?
8 A No.
9 Q David Watkins?
10 A Yes.
11 Q When did you meet David Watkins?
12 A When I began working at The White
13 House of office security.
14 Q And why did you come into contact
15 with Mr. Watkins?
16 A Because he was the assistant or
17 special assistant -- I can't remember. I
18 believe he was assistant to the president for
19 White House administration or operations.
20 Q And what was it about being in that
21 position that brought you in contact with
22 him?
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