1
         1             UNITED STATES DISTRICT COURT
                       FOR THE DISTRICT OF COLUMBIA
         2
               ---------------------------------x
         3     CARA LESLIE ALEXANDER et al.,    :
                                                :
         4                       Plaintiffs,    :
                                                :
         5                      v.              : No. 96-2123-RCL
                                                :
         6     FEDERAL BUREAU OF INVESTIGATION  :
               et al.,                          :
         7                                      :
                                 Defendants.    :
         8     ---------------------------------x

         9                                    Washington, D.C.

        10                              Tuesday, March 3, 1998

        11     Video deposition of

        12                    PAUL E. BEGALA

        13     a witness, called for examination by counsel

        14     for Plaintiffs, pursuant to notice and

        15     agreement of counsel, beginning at

        16     approximately 10:15 a.m., at the offices of

        17     Judicial Watch, 501 School Street S.W.,

        18     Washington, D.C., before Michele M. Howell,

        19     notary public in and for the District of

        20     Columbia, when were present on behalf of the

        21     respective parties:

        22









                                                             2
         1     APPEARANCES:

         2        On behalf of Plaintiffs:

         3           LARRY KLAYMAN, ESQUIRE
                     DON BUSTION, ESQUIRE
         4           TOM FITTON, ESQUIRE
                     Judicial Watch
         5           501 School Street S.W.
                     Washington, D.C.  20024
         6           (202) 646-5172

         7
                  On behalf of Defendants:
         8
                     ELIZABETH J. SHAPIRO, ESQUIRE
         9           DAVID J. ANDERSON, ESQUIRE
                     U.S. Department of Justice
        10           901 E. Street N.W.
                     Washington, D.C.  20630
        11           (202) 616-8202

        12
                  On behalf of Hillary Clinton:
        13
                     MARCIE ZIEGLER, ESQUIRE
        14           Williams & Connolly
                     725 12th Street N.W.
        15           Washington, D.C.  20005
                     (202) 434-5874
        16

        17     ALSO PRESENT:

        18           Sally Patricia Paxton

        19

        20                     *  *  *  *  *

        21

        22









                                                             3
         1                    C O N T E N T S

         2     EXAMINATION BY:                            PAGE

         3        Counsel for Plaintiffs                     6

         4     BEGALA DEPOSITION EXHIBITS:

         5     No.  1 - White House Press Release           26

         6     No.  2 - Judicial Watch Press Release        62

         7     No.  3 - New York Times Report               78

         8     No.  4 - Transcript of Speech                86

         9     No.  5 - February 3, 1998, Press Account    136

        10     No.  6 - Peter Yost Press Account           143

        11     No.  7 - November 26, 1997, Fax             160

        12     No.  8 - Document                           172

        13     No.  9 - Stephanopoulos Transcript          195

        14     No. 10 - Dark Side of Camelot, Excerpt      210

        15     No. 11 - Dennis Casey Testimony             259

        16     No. 12 - Washington Post Article            332

        17     No. 13 - Washington Post Report             339

        18     No. 14 - Begala Affidavit                   351

        19     No. 15 - Monthly Calendar                   379

        20     No. 16 - Memorandum, Livingston to Kennedy  417

        21     No. 17 - EOP Access List                    419

        22                     *  *  *  *  *









                                                             4
         1                P R O C E E D I N G S

         2               VIDEOGRAPHER:  Good morning.  This

         3     is the video deposition of Paul Begala taken

         4     by the counsel for the Plaintiff in the

         5     matter of Cara Leslie Alexander, et al. 

         6     versus Federal Bureau of Investigation, et 

         7     al.  The U.S. District Court for the District

         8     of Columbia, Case Number 96-2123(RCL) held in

         9     the offices of Judicial Watch, 501 School

        10     Street S.W., Washington D.C. on this date,

        11     March 3, 1998, and at the time indicated on

        12     the video screen which is 10:15 a.m.

        13               My name is Sylvanus Holley.  I am

        14     the videographer.  The court reporter today

        15     is Michele Howell from the firm of Beta

        16     Reporting.

        17               Will counsel, please, introduce

        18     themselves?

        19               MR. KLAYMAN:  My name is Larry

        20     Klayman.  I am general counsel of Judicial

        21     Watch.

        22               MR. BUSTION:  Don Bustion, attorney









                                                             5
         1     Judicial Watch.

         2               MR. FITTON:  My name is Tom Fitton,

         3     I am legal assistant for Judicial Watch.

         4               MS. SHAPIRO:  Elizabeth Shapiro,

         5     counsel for Mr. Begala, and Executive Office

         6     of the President.

         7               MR. ANDERSON:  David J. Anderson,

         8     counsel for Mr. Begala and the defendants.

         9               MS. PAXTON:  Sally Paxton with the

        10     White House.

        11               MS. ZIEGLER:  Marcie Ziegler, for

        12     the defendant, Hillary Clinton.

        13               MR. KLAYMAN:  Mr. Anderson, are you

        14     with the government or are you in a private

        15     law firm?

        16               MR. ANDERSON:  FBI.

        17               MS. SHAPIRO:  Working with the

        18     Department of Justice.

        19               MR. KLAYMAN:  You are working with

        20     the Department of Justice?

        21               MR. ANDERSON:  Yes.

        22               MR. KLAYMAN:  Swear the witness.









                                                             6
         1               THE VIDEOGRAPHER:  Would the court

         2     reporter, please, swear in the witness?

         3     Whereupon,

         4                    PAUL E. BEGALA

         5     was called as a witness and, having been

         6     first duly sworn, was examined and testified

         7     as follows:

         8               EXAMINATION BY COUNSEL FOR

         9     PLAINTIFFS

        10               BY MR. KLAYMAN:

        11          Q    Mr. Begala, please, state your

        12     name?

        13          A    Paul Begala.

        14          Q    When were you born?

        15          A    May 12, 1961.

        16          Q    Where you attended high school?

        17          A    Sugarland, Texas.

        18          Q    Is that where you were born, in

        19     Texas?

        20          A    No, I was born in New Jersey.

        21          Q    When did you graduate from high

        22     school?









                                                             7
         1          A    1979.

         2          Q    What did you do at that time?

         3          A    I don't understand.

         4          Q    Did you go to college?

         5          A    Yes.

         6          Q    Go into the military?

         7          A    I went on to college.

         8          Q    Where you attended college?

         9          A    University of Texas at Austin.

        10          Q    What did you major in?

        11          A    Government.

        12          Q    When did you graduate from

        13     University of Texas at Austin?

        14          A    1983.

        15          Q    During the time that you were at

        16     the University of Texas, were you ever

        17     subject to any kind of disciplinary

        18     proceedings or anything to that effect?

        19          A    No.

        20          Q    Were you active in politics?

        21          A    Yes.

        22          Q    What did you do at the University









                                                             8
         1     of Texas in that regard?

         2          A    I was a student body president.

         3          Q    Were you a member of any democratic

         4     party organizations?

         5          A    I don't remember.

         6          Q    When you graduated from the

         7     University of Texas, what did you do at that

         8     time?

         9          A    I worked in a political campaign.

        10          Q    What campaign was that?

        11          A    Lloyd Doggett for U.S. Senate.

        12          Q    Is he from Texas?

        13          A    He is, from Austin.

        14          Q    What was your position working for

        15     Lloyd Doggett?

        16          A    I was his travel aide.

        17          Q    Did there come a point in time when

        18     you left Mr. Doggett and went to work for

        19     someone else?

        20          A    We lost the campaign to Senator

        21     Graham.

        22          Q    What happened at that time?









                                                             9
         1          A    I went to law school at the

         2     University of Texas.  I began there and

         3     continued to do campaign work on the side.

         4          Q    Same law school at Austin or

         5     different branch?

         6          A    University of Texas at Austin.

         7          Q    Did you graduate from the

         8     University of Texas at Austin?

         9          A    I did.

        10          Q    In what year?

        11          A    I got my law degree in 1990.

        12          Q    What years did you go to the

        13     University of Texas?

        14          A    From '89 to '90 intermittently,

        15     concluded in 1990.

        16          Q    During that period you didn't

        17     experience any disciplinary problems at the

        18     University of Texas?

        19          A    That's correct.

        20          Q    Did you take the bar exam?

        21          A    I did.

        22          Q    Where did you take it?









                                                             10
         1          A    Pennsylvania.

         2          Q    Did you pass?

         3          A    I did.

         4          Q    What year did you pass the bar

         5     exam?

         6          A    I think 1991, but I am nor sure.

         7          Q    Are you a member of any other state

         8     bar associations?

         9          A    No.

        10          Q    What caused you to take the bar

        11     exam in Pennsylvania?

        12          A    I was living in Northern Virginia

        13     at the time.  It was nearby.  It had a

        14     reputation, frankly, for being easier than

        15     some others.

        16          Q    What caused you to move from Texas

        17     to Northern Virginia?

        18          A    I was offered a job in Washington.

        19          Q    What job were you offered?

        20          A    Working for Congressman Gephardt.

        21          Q    What did you do for Congressman

        22     Gephardt?









                                                             11
         1          A    I was a speech writer.

         2          Q    What year did you begin working for

         3     Congressman Gephardt?

         4          A    In 1989, as a speech writer on

         5     Capitol Hill.

         6          Q    How long did you stay with

         7     Congressman Gephardt?

         8          A    Again, intermittently until 1991.

         9          Q    What happened in 1991?

        10          A    I left Congressman Gephardt's

        11     employ to run a political campaign.

        12          Q    Which political campaign was that?

        13          A    Harris Wofford for the United

        14     States Senate.

        15          Q    This was a campaign for Senate,

        16     correct?

        17          A    Correct.

        18          Q    Mr. Wofford had been the president

        19     of Bryn Mawr College, is that where he came

        20     from?

        21          A    That was one of many previous jobs.

        22     He was appointed to the Senate on the death









                                                             12
         1     of Senator Hines.

         2          Q    What did you do for Mr. Wofford?

         3          A    I was his campaign manager.

         4          Q    Did you have any prior experience

         5     as being a campaign manager before you went

         6     to work for Mr.  Wofford?

         7          A    No, not as a campaign manager.

         8          Q    Up to that point in time, had you

         9     ever met a James Carville?

        10          A    Oh, yeah.

        11          Q    When did you meet James Carville?

        12          A    1983.

        13          Q    What were the circumstances of your

        14     meeting him?

        15          A    He is was hired to be Lloyd

        16     Doggett's campaign manager.

        17          Q    At the time that you accepted this

        18     position as campaign manager for Mr. Wofford,

        19     were you in business with Mr. Carville?

        20          A    Yes.

        21          Q    When did you first go into business

        22     with Mr. Carville?









                                                             13
         1          A    He and I have done a variety of

         2     campaigns together over the years.

         3          Q    What other campaigns had you done

         4     over the years with him?

         5          A    With him, now Congressman, then

         6     candidate Doggett in 1984.  In 1986, I worked

         7     with James on Bob Casey's campaign for

         8     governor of Pennsylvania.

         9               I worked with James for awhile, for

        10     Wilkinson for governor of Kentucky, I can't

        11     remember the year.

        12               In '88, I worked with James for

        13     Frank Lautenberg, the U.S. Senator from New

        14     Jersey who was up for reelection.

        15               In '90, I worked with James on Zell

        16     Miller's campaign for governor of Georgia.

        17          Q    Any other campaigns that you worked

        18     with James?

        19          A    Not that I recall at the top of my

        20     mind, but we did a variety of campaigns.

        21          Q    Were there any or campaigns up

        22     to 1991, when you went to work as campaign









                                                             14
         1     manager for Mr. Wofford, that you worked on,

         2     with or without James?

         3          A    I worked for Congressman Gephardt,

         4     when he ran for president as his speechwriter

         5     in 1987 and '88.

         6               I have done spot consulting work

         7     and occasional speech for different

         8     candidates.  I think that is about it, but I

         9     don't have my resume in front of me, so I

        10     don't want to --

        11          Q    During the period up to the point

        12     that you we went to work for Mr. Wofford, had

        13     you ever been in charge of any campaign in

        14     gathering information about opponents?

        15          A    No.

        16          Q    Did you work with people who were

        17     in charge with that function?

        18          A    Research department, every campaign

        19     has one.

        20          Q    Let's discuss for, for instance,

        21     the campaign concerning Bob Casey.  Who was

        22     in charge with gathering information about









                                                             15
         1     opponents in that campaign?

         2          A    We didn't have a department that

         3     gathered information about opponents.  We had

         4     research both on Mr. Casey's issues and

         5     positions, and on the opponents's issues and

         6     positions.  At the top of my mind, I cannot

         7     remember who ran that division of the

         8     campaign. It has been almost twelve years.

         9          Q    Were any outside investigators

        10     employed in the Casey campaign?

        11          A    Not that I know of.

        12          Q    Did you ever work on a campaign

        13     after working with Mr. Wofford where outside

        14     investigators were employed?

        15          A    Not that I knew of.

        16          Q    That didn't mean that there weren't

        17     investigators, correct?

        18          A    I can only speak to what I know.  I

        19     never was aware of any.

        20          Q    Up to the point that you went to

        21     work for Mr. Wofford as campaign manager, had

        22     you ever come in contact with a Craig









                                                             16
         1     Livingstone?

         2          A    No.

         3          Q    Are you aware that Craig

         4     Livingstone was involved in Pennsylvania

         5     politics?

         6          A    I have heard that from newspaper

         7     accounts, from press accounts.

         8          Q    At the time that you went to work

         9     for Mr. Wofford, have you ever been in

        10     contact with Mr. Anthony Marceca?

        11          A    No.

        12          Q    Up to the time that you went the

        13     work for Mr. Wofford, had you ever met

        14     President Bill Clinton?

        15          A    No.

        16          Q    I'm talking 1991?

        17          A    Up until the time I went to work

        18     for Senator Wofford.

        19          Q    Same question with regard to

        20     Hillary Clinton?

        21          A    Correct.

        22          Q    You had not met her?









                                                             17
         1          A    Not that I can recall, no.

         2          Q    Aside from Mr. Casey and Mr.

         3     Wofford, had you ever worked for other

         4     Pennsylvania candidates or politicians?

         5          A    No.

         6          Q    Up to that point in time?

         7          A    Right, I have not.

         8          Q    Do you know of anyone who has

         9     worked with Mr. Livingstone or Marceca prior

        10     to time that they joined the White House?

        11          A    No.

        12          Q    Do you know what I meant by that?

        13          A    If you could clarify it.

        14          Q    Up to the point that Livingstone

        15     and Marceca became employees at the White

        16     House, are you aware of them having worked

        17     with other people up?

        18          A    I don't know anything about them,

        19     so no.

        20          Q    Tell me what your duties and

        21     responsibilities were as campaign manager for

        22     Harris Wofford?









                                                             18
         1          A    To manage and direct the campaign,

         2     which included the staff, the scheduling of

         3     the candidate, hiring and supervising

         4     consultants who ran political ads and

         5     conducted polls.  The business of running a

         6     campaign.

         7          Q    Did Harris Wofford have a research

         8     department as well?

         9          A    Um-hum.

        10          Q    Who ran that research department?

        11          A    My recollection is that Eric Berman

        12     ran it.

        13          Q    Who is Eric Berman?

        14          A    He is the guy who ran the research.

        15          Q    Where is he now?

        16          A    I think he is in New York.

        17          Q    What does he do?

        18          A    I think he does public relations,

        19     but I am not sure.

        20          Q    Was anyone else in that research

        21     department with Mr. Berman?

        22          A    I am sure, but I cannot remember









                                                             19
         1     particulars.

         2          Q    Did the Wofford campaign employ any

         3     investigators either in house or out house?

         4          A    No, sir.

         5          Q    Do you know whether Mr. Carville

         6     has ever employed outside investigators in

         7     political campaigns?

         8          A    No, I don't.

         9          Q    How long did you work for Harris

        10     Wofford?

        11          A    Well, I ran his campaign from, my

        12     recollection is May of '91 to the election in

        13     November, and worked on his reelection which

        14     was in 1994.

        15               In between then, I did some

        16     consulting for Senator Wofford in the

        17     Pennsylvania democratic party.

        18          Q    When you worked for Senator

        19     Wofford, were you employed individually or

        20     were you employed by virtue of being a member

        21     of some corporation or company?

        22          A    I was a part of a firm called









                                                             20
         1     Carville and Begala.

         2          Q    When was that firm founded?

         3          A    You know, we never real had

         4     articles of incorporation.  We had never had

         5     a formal signed agreement.  We worked

         6     together on and off since '84.

         7          Q    Did you have an office?

         8          A    Yes.

         9          Q    Where was the office?

        10          A    On Capitol Hill.

        11          Q    What was the address?

        12          A    329 Maryland Avenue.

        13          Q    Is that office still used by

        14     Mr. Carville?

        15          A    No.

        16          Q    What did the lease say on terms of

        17     who rented that space?

        18          A    I don't know.

        19          Q    When did you take that lease out?

        20          A    I didn't, James did.

        21          Q    What year was that?

        22          A    I don't know.









                                                             21
         1          Q    Roughly speaking?

         2          A    I don't remember.  I am sorry.

         3          Q    Presumably, you started the firm

         4     before you went to work for Harris Wofford,

         5     correct?

         6          A    We are very close friends so it was

         7     a very informal -- we had a letterhead that

         8     said Carville and Begala, but we never

         9     executed any papers.  It was a handshake.

        10          Q    Did you have anything written down

        11     as to how compensation would be divided among

        12     the two of you?

        13          A    No.  We had a lawyer once draft a

        14     partnership agreement.  Neither of us took

        15     the time to read it or sign it.  We are just

        16     friends.

        17          Q    Who was the lawyer?

        18          A    An attorney we hired.  Can I take a

        19     moment?

        20                    (Witness conferred with

        21                    counsel)

        22               THE WITNESS:  The lawyer's name was









                                                             22
         1     Victoria Radd.

         2               BY MR. KLAYMAN:

         3          Q    Victoria Rath?

         4          A    Radd.

         5          Q    Where was she located in

         6     Washington, D.C.?

         7          A    Yes.

         8          Q    Is she still in this vicinity?

         9          A    I think so.

        10          Q    Aside from that lease agreement,

        11     have you ever consulted with her on any other

        12     mater?

        13          A    That was not a lease agreement.

        14     She drafted a partnership agreement that we

        15     never used.  I didn't want to embarrass her.

        16     I am sure it was good.  We just never read

        17     it.

        18               Not that I recall.  Yes, I do

        19     recall.  I asked her once to give us advice.

        20               MS. SHAPIRO:  Objection.

        21               MR. KLAYMAN:  The general subject

        22     matter.  I'm not going to ask him the advice









                                                             23
         1     that was given, just the general subject

         2     matter.

         3               THE WITNESS:  The general subject

         4     matter was whether doing a campaign in

         5     another country would require a foreign

         6     agent's registration act.

         7               BY MR. KLAYMAN:

         8          Q    What country was that?

         9          A    Greece.

        10          Q    Did there come a point in time when

        11     you met a George Stephanopoulos?

        12          A    Yes.

        13          Q    When did you meet George

        14     Stephanopoulos?

        15          A    To the best of my recollection,

        16     1989.

        17          Q    How did you meet him?

        18          A    He was hired at then majority

        19     leader Gephardt's office, about the same

        20     time -- that was about the same time Gephardt

        21     became majority leader.

        22          Q    What was Mr. Stephanopoulos hired









                                                             24
         1     to do?

         2          A    To be the floor manager, manager of

         3     the floor personnel.  I don't know the formal

         4     title.  To work the floor of the House for

         5     the majority leader.

         6          Q    Did you work closely with

         7     Mr. Stephanopoulos?

         8          A    Yes.

         9          Q    You got to know him very well?

        10          A    Yes.

        11          Q    Saw him socially?

        12          A    I don't see very many people

        13     socially, but I suppose.

        14          Q    Are you married?

        15          A    Yes.

        16          Q    When were you married?

        17          A    1989.

        18          Q    What is the name of your wife?

        19          A    I find that invasive.  I am happy

        20     to help you, Mr. Klayman, but --

        21          Q    That is a standard question.  I

        22     didn't ask you for your address or anything









                                                             25
         1     like that, just what your wife's name is?

         2               MS. SHAPIRO:  Is it necessary?

         3               MR. KLAYMAN:  Yes.

         4               MS. PAXTON:  Why?

         5               MS. SHAPIRO:  What is it?

         6               MR. KLAYMAN:  It may lead to

         7     relevant evidence.

         8               MS. SHAPIRO:  Like what?  In what

         9     way?

        10               MR. KLAYMAN:  I think it is pretty

        11     apparent, Elizabeth, it is a very innocuous

        12     question.

        13               THE WITNESS:  I do want to be

        14     helpful, but it is a personal question.  If I

        15     am instructed to answer, I will.

        16               BY MR. KLAYMAN:

        17          Q    I don't think the name of your wife

        18     is personal.  I am sure it, probably, is

        19     published in White House directories?

        20          A    Not that I know of.

        21          Q    I would think so.

        22               MS. PAXTON:  Let's take a minute.









                                                             26
         1                    (Witness conferred with

         2                    counsel)

         3               VIDEOGRAPHER:  We are going off

         4     video records at 10:31 a.m.

         5               MR. KLAYMAN:  It was pointed out to

         6     me that, in fact, we have a press release

         7     from the White House which lists the name of

         8     your wife, whose name is Diane.

         9               We ask that this be marked as

        10     Exhibit 1 to Mr. Begala's deposition.

        11               MS. SHAPIRO:  Our objection to the

        12     relevancy still stands.  We are not

        13     instructing him not to answer.

        14                    (Begala Deposition Exhibit

        15                    No. 1 was marked for

        16                    identification.)

        17               BY MR. KLAYMAN:

        18          Q    During the period that you worked

        19     for Harris Wofford, did you work for any

        20     other political candidates?

        21          A    Not that I can remember, although

        22     we might have -- I think we had an ongoing









                                                             27
         1     consulting relationship for the Governor of

         2     Georgia, who is Zell Miller.

         3          Q    I take it that Mr. Carville also

         4     worked on the Wofford campaign?

         5          A    Yes, he did.

         6          Q    It was a campaign where health care

         7     became an issue?

         8          A    Right.

         9          Q    It led to later discussions, in the

        10     Clinton administration, about making that an

        11     issue as well?

        12          A    It led to Senator Wofford's

        13     election, which was what I was concerned

        14     about.

        15          Q    What, if anything, did you do in

        16     terms of political campaigns after the first

        17     Wofford campaign?

        18          A    Carville and I were signed on to

        19     consult for Senator Glenn, John Glenn of Ohio

        20     who was up for reelection.

        21               In December of '91, we signed on to

        22     go to work for Governor Clinton, Governor of









                                                             28
         1     Arkansas, presidential campaign.  The Glenn

         2     contract was short-lived -- because we were

         3     too busy with the Clinton contract.

         4          Q    What did you do specifically for

         5     John Glenn?

         6          A    Met with him several times and

         7     talked with him about his upcoming

         8     reelection.  As I said, we wound up ending

         9     the contract because we were too busy with

        10     the Clinton contract.

        11          Q    During the period that you worked

        12     for Senator Glenn, did you ever have any

        13     discussions about the Keating 5 scandal?

        14          A    Not that I can recall.

        15          Q    That doesn't mean that you didn't.

        16     You realize that you are under oath and you

        17     have to tell the whole truth?

        18          A    Yes, sir, that is why I don't want

        19     to guess.

        20               MS. SHAPIRO:  Objection.

        21               BY MR. KLAYMAN:

        22          Q    Are you saying that was a not a









                                                             29
         1     relevant issue in the campaign?

         2          A    I did very little work for him.  I

         3     would have loved to, because I considered him

         4     a man of great integrity.  I was so

         5     overwhelmed with the burdens of the

         6     presidential campaign. I just don't recall

         7     specifically.

         8          Q    Do you know what the Keating 5

         9     scandal is about?

        10          A    Vaguely.

        11          Q    What was it about?

        12          A    Vaguely it was about allegations of

        13     savings and loans.

        14          Q    The payoffs by Charles Keating to

        15     John Glenn in part, correct, as well as some

        16     Republicans?

        17          A    Not that I know of.

        18          Q    For special favors, correct?

        19          A    I have the highest respect for John

        20     Glenn.

        21          Q    I didn't ask you whether you had

        22     high respect for him.  I asked you whether









                                                             30
         1     you knew what the allegations of the scandal

         2     were about?

         3          A    I know vaguely.

         4          Q    Do you consider that to be an

         5     important allegation, a Senator received

         6     payoffs in exchange for favors to the savings

         7     and loan industry?

         8               MS. SHAPIRO:  Objection to the

         9     relevancy.

        10               MR. KLAYMAN:  I want to get to the

        11     witness' state of mind here.

        12               Is that a serious allegation?

        13               THE WITNESS:  It is certainly

        14     serious.

        15               BY MR. KLAYMAN:

        16          Q    That is certainly something that as

        17     someone who worked on the campaign, you would

        18     want to know about?

        19          A    I am sure.  I don't remember if it

        20     became an issue in his '92 reelection. I

        21     didn't wind up working for him, but only

        22     because I got so busy with Bill Clinton.









                                                             31
         1          Q    Was it James Carville who dealt

         2     with that issue on behalf of John Glenn?

         3          A    Not that I recall.

         4               MS. SHAPIRO:  Objection.  Assumes

         5     facts not in evidence.  He has not testified

         6     he knows anything about that issue.

         7               MR. KLAYMAN:  He can respond.

         8               THE WITNESS:  I have.

         9               BY MR. KLAYMAN:

        10          Q    What issues, if any, did you

        11     discuss with Senator Glenn?

        12          A    I can't remember.  It is just a

        13     nascent stage of a reelection effort.  I

        14     can't remember any particulars that we got

        15     into back then.  It was just a campaign --

        16          Q    Are you aware of any sources of

        17     Senator Glenn's campaign contributions?

        18          A    No.

        19          Q    Are you aware that he has taken

        20     money from the Riadys and John Wan?

        21          A    I have no idea.

        22          Q    How did you and Mr. Carville get









                                                             32
         1     involved with the Clinton campaign?  What

         2     lead up to that?  How did you make the

         3     contact?

         4          A    Governor Miller of Georgia called

         5     one day in the fall of '91, and said that his

         6     friend, the Governor of Arkansas, had been in

         7     Atlanta to visit him, was considering a run

         8     for the presidency, and that Governor Miller

         9     had told Governor Clinton that he should talk

        10     to us about working for him.

        11               So, Miller then called us and urged

        12     us to go meet with him.

        13          Q    Up to that point in time, had

        14     either you or Mr. Carville either met

        15     Mr. Clinton and his wife?

        16          A    I don't know with James but I do

        17     not recall meeting Governor Clinton or his

        18     wife prior to that time.

        19          Q    Did you then call Governor Clinton?

        20          A    No, I think he called us, but we

        21     met with him.

        22          Q    Where were you working at the time









                                                             33
         1     that he called you?  On Capitol Hill?

         2          A    We had an office on Capitol Hill.

         3          Q    Is that where he called you?

         4          A    I don't remember.  We might have

         5     been in Pennsylvania.

         6          Q    Did you subsequently meet with

         7     Governor Clinton?

         8          A    We did.

         9          Q    Where did you meet with him?

        10          A    In Washington.

        11          Q    He came to see you?

        12          A    He was in Washington on other

        13     business.

        14          Q    Did he come with anyone?  Was he

        15     present with Hillary Clinton?

        16          A    He was not with Mrs. Clinton.

        17          Q    Was he with anyone else?

        18          A    I can't remember precisely.

        19          Q    Where did you meet him?

        20          A    At a hotel he was staying in.

        21          Q    What was discussed?

        22               MS. SHAPIRO:  Can we take a moment,









                                                             34
         1     please?

         2               MR. KLAYMAN:  For what?

         3               MS. SHAPIRO:  Because I am

         4     considering inserting an objection and I

         5     would like to take a moment to discuss it

         6     before making a formal decision.

         7               MS. PAXTON:  Why don't we step

         8     outside?

         9               VIDEOGRAPHER:  We are going off

        10     video record at 10:38.

        11                    (Discussion off the record)

        12               VIDEOGRAPHER:  We are back on video

        13     record at 10:41.

        14               BY MR. KLAYMAN:

        15          Q    What was raised by Mr. Clinton

        16     during that meeting?

        17          A    I was struck that he raised the

        18     issues and ideas that he wanted to run on,

        19     not the strategy that he could win on.

        20               Carville and I, at the time, were

        21     talking to several people over the next few

        22     months, talking to several people thinking









                                                             35
         1     about running for President.

         2               I was struck this guy did not talk

         3     strategy with strategists, he talked

         4     substance.

         5          Q    Just briefly, I don't want to

         6     belabor it, it what was the general nature of

         7     the different substance that he raised with

         8     you?

         9          A    He talked about his ideas to revive

        10     the economy and to mend the social fabric.  I

        11     remember that because those are the two

        12     things that he talks about, he talked about

        13     at every occasion in that campaign.

        14               I was struck that he was focused on

        15     ideas and not strategy.  Strategists are,

        16     often, sort of just not dealt with about

        17     substance.

        18          Q    He, obviously, discussed with you

        19     who his likely opponents would be, correct?

        20          A    Not that I recall, that was what

        21     was so striking.  Most politicians when they

        22     meet with a guy like me first time talk about









                                                             36
         1     strategy.  I think, I can place in the top

         2     three in New Hampshire, then I can win in

         3     California.  I don't remember any of that.

         4               I was struck by that he was talking

         5     about ideas and substance.  I was impressed.

         6          Q    Where did the meeting take place?

         7          A    In a hotel lobby.

         8          Q    Which hotel?

         9          A    I can't remember.

        10          Q    How long was the meeting?

        11          A    Maybe a couple of hours, I don't

        12     remember.

        13          Q    At that point in time, you and

        14     Mr. Carville had already developed a

        15     reputation as good democratic party political

        16     consultants, correct?

        17          A    Probably, not much of one.  Clinton

        18     had never heard of us.

        19          Q    But the success with Wofford

        20     obviously was a big success.

        21          A    This was before Wofford's election.

        22          Q    This was before Wofford?









                                                             37
         1          A    This was while we were working on

         2     that campaign.

         3          Q    During the first campaign?

         4          A    I remember clearly, my final

         5     comment to him was that the best thing we can

         6     do to help anybody elect is to not go to work

         7     for you, is to help Harris Wofford get

         8     elected to Senate.  That is the only thing we

         9     were thinking about.

        10          Q    That is because that was a test

        11     campaign?

        12          A    That was because that was the only

        13     client that we had.  We never put

        14     in ÄÄÄÄ consequence.  We had to win that

        15     particular race in order to serve that client

        16     well.

        17          Q    Who was it that Wofford ran against

        18     the first time?

        19          A    Governor Thornberg.

        20          Q    Did there come a point in time

        21     where you had a later meeting or conversation

        22     with Mr. Clinton, or anyone associated with









                                                             38
         1     Mr. Clinton, about handling his political

         2     campaign for President?

         3          A    Um-hum.

         4          Q    When did that occur?

         5          A    After Senator Wofford's election,

         6     which was November of '91.

         7          Q    Where did that conversation take

         8     place?  And how did it take place?

         9          A    I don't recall.

        10          Q    Was it by telephone or in person?

        11          A    I don't remember.

        12          Q    But you know you had one?

        13          A    I am sure.

        14          Q    Who was present during the

        15     conversation, who participated?

        16          A    I remember talking to David

        17     Wilhelm, who was the Governor's campaign

        18     manager, and then later meeting with the

        19     Governor, agreeing to go to work for him.

        20          Q    Up to that point in time, including

        21     that point in time, had you ever talked with

        22     Hillary Clinton?









                                                             39
         1          A    No.

         2          Q    Was there anyone else besides

         3     Mr. Wilhelm and the governor that you met

         4     with or talked with?

         5          A    Stephanopoulos had signed on with

         6     him.

         7          Q    Excuse me?

         8          A    George Stephanopoulos was working

         9     for Governor Clinton at the time.

        10          Q    You talked with him before that

        11     second conversation with President Clinton?

        12          A    I think so.

        13          Q    Where did you talk to

        14     Stephanopoulos?

        15          A    My recollection is Washington.

        16          Q    Was it over lunch?  Was it a series

        17     of telephone conversations?  How much contact

        18     was there?

        19          A    I don't remember.  I remember

        20     talking to him George, being impressed with

        21     him.  I do want to help, I mean, let me

        22     finish.









                                                             40
         1          Q    Sure.

         2          A    George was very impressed with him.

         3     He urged me to go to work for him.

         4          Q    During those conversations, surely

         5     you must have discussed the potential

         6     opponents of the Governor for President?

         7          A    I can't remember that.  At that

         8     time, I was meeting with some of his

         9     potential opponents, so I wasn't eager to be

        10     swapping information.

        11          Q    What potential opponents were you

        12     meeting with?

        13          A    Senator Harkin, Senator Carey of

        14     Nebraska.  I think that is all.

        15          Q    Were they approaching you in terms

        16     of possibly hiring you and James Carville?

        17          A    Yes.

        18          Q    Was Governor Clinton aware that you

        19     were talking with others?

        20          A    I don't know.  I would guess,

        21     because I think it was in the paper, but I

        22     don't remember.









                                                             41
         1          Q    Did there come a point in time when

         2     you had another conversation with Governor

         3     Clinton and anyone associated with Governor

         4     Clinton?

         5          A    Sure.

         6          Q    When was that?

         7          A    If you can be more specific.  I

         8     went to work for him.

         9          Q    See, I can't tell because only you

        10     know.  When did you have the next

        11     conversation, roughly speaking?

        12          A    I started working for him on

        13     December 1 of 1991.

        14          Q    You and Mr. Carville?

        15          A    Right, as a firm.

        16          Q    Did you have a series of meetings

        17     up to that point in time?

        18          A    I think, I remember one other time

        19     talking to him.  It was more James and I

        20     talking to each other about who we wanted to

        21     work for.

        22          Q    What did you and James discuss in









                                                             42
         1     terms of who you wanted to work for?

         2          A    James was deeply impressed with Bob

         3     Carey, I was very impressed with Senator

         4     Harkin.  In the end both of us were most

         5     impressed with Governor Clinton.

         6          Q    Is that because he had the greatest

         7     potential to win in your eyes?

         8          A    I don't know that.  Certainly that

         9     played a role in it.  But also, he had, in my

        10     eyes, the right message.  That is what I care

        11     most about in the campaigns, what a candidate

        12     says, what he or she stands for and runs on.

        13          Q    In evaluating whether you wanted to

        14     work for Governor Clinton to run for

        15     President in 1992, clearly you must have

        16     discussed what the pros and cons of his

        17     candidacy were, correct?

        18          A    With whom?

        19          Q    With Governor Clinton?

        20          A    I will repeat, I remember being

        21     struck that he seemed to be more interested

        22     in talking about substance than strategy.









                                                             43
         1          Q    As a political campaign consultant,

         2     is it not your business to know whether a

         3     political candidate has what we call

         4     skeletons in their closet that may prevent

         5     them from ultimately being elected?

         6          A    Not when I am about to go to work

         7     for them.  It is not a very good way to get a

         8     job.

         9          Q    Isn't it the case that you would do

        10     research, at least a nexus search or some

        11     kind of research to see if this potential

        12     candidate, before you accept a position on

        13     their campaign, would have skeletons that

        14     could bring them down before they could be

        15     elected?

        16          A    That is not how James an I operate.

        17     We were more visceral, more emotional.  We

        18     only wanted to work for a very few people.

        19               We did not take on lots of clients.

        20     We limited ourselves, purposely, to only a

        21     very few who we really believed in.  So, we

        22     more operated, with the consensus between the









                                                             44
         1     two of us, on who we really wanted to work

         2     for.

         3               Neither of us began the process of

         4     wanting to work in a presidential campaign,

         5     frankly.

         6          Q    Are you saying that you did no

         7     research on Governor Clinton before you

         8     decided to work for him?

         9          A    I can't remember doing any nexus

        10     searches or anything of that sort.

        11          Q    I just gave that as an example.

        12          A    I am sure the popular press, but I

        13     had a chance to talk to him, so I didn't -- I

        14     don't remember doing any other research and,

        15     frankly, Zell Miller is someone who is quite

        16     a hero to me.  He was urging us to work for

        17     Bill Clinton.

        18          Q    Are you saying that on all the

        19     campaigns that you worked on, you never asked

        20     the candidate whether there are skeletons in

        21     their closet?  Whether there are political

        22     enemies that may seek to destroy them?









                                                             45
         1          A    No.

         2          Q    You never asked them that question?

         3          A    I am not saying that.

         4          Q    Who have you asked that question

         5     that you worked for, or questions similar to

         6     that?

         7          A    When I am trying to get a job, I

         8     don't try to get the candidate to say bad

         9     things about himself or herself.

        10          Q    Here in the presidential campaign,

        11     let's back up.

        12               Who have you discussed issues such

        13     as skeletons with, of all of the people that

        14     you have represented, you or James Carville,

        15     to the best of your knowledge?

        16          A    If you could define skeletons, that

        17     would be useful.

        18          Q    Jennifer Flowers, something like

        19     that?

        20          A    It didn't come up until the

        21     tabloids or the --

        22          Q    The issues involving possible









                                                             46
         1     payoffs to public officials?  Issues

         2     involving affairs?  Issues involving military

         3     war records?  I mean, I am just giving you

         4     some examples.

         5               Clearly, you must have discussed

         6     these kinds of things with the candidates

         7     that you have represented over the years?

         8     Are you saying that you didn't?

         9          A    No, I am not saying I didn't.  In

        10     any campaign, you try to make sure that you

        11     know what your strengths and your weaknesses

        12     are.

        13          Q    Who did you discuss such things

        14     with who you represented over the years?  I

        15     am not limiting them just to those

        16     categories.  I group them together as

        17     skeletons and political adversaries that may

        18     attack the candidate to try to inhibit his

        19     candidacy or her candidacy?

        20          A    I would try to talk to the

        21     candidate about shortcomings in his or her

        22     record.









                                                             47
         1               My own view, in my own experience,

         2     is that votes and quotes, as I call it,

         3     speeches, public acts, are always much more

         4     of interest to voters than what you have

         5     described as skeletons.

         6               So, I make it is my business to be

         7     sure that I know a good bit about my

         8     candidate's record and, yes, at times, I

         9     guess, I have learned about or asked about

        10     other things as well.

        11               But it is not my focus.

        12          Q    I understand.  My question was,

        13     names?  Who have you discussed these things

        14     with over the years?

        15          A    Again, by these things, you mean

        16     the potential things that people might attack

        17     you on?

        18          Q    Right.

        19          A    Again, it is much more general --

        20          Q    I am asking you for names of

        21     candidates?

        22          A    I would suspect most of the people









                                                             48
         1     that I have worked with have talked to me

         2     about things that they might have been

         3     attacked on.

         4          Q    Including Governor Clinton?

         5          A    Yes.

         6          Q    Up to the point that you were

         7     retained by Governor Clinton, did you discuss

         8     with Governor Clinton, or anyone associated

         9     with Governor Clinton, things that he might

        10     be attacked on?

        11          A    Not that I recall.

        12          Q    Does that mean no?

        13          A    Not that I recall.

        14          Q    Does that mean no or yes?

        15               MS. SHAPIRO:  Asked and answered,

        16     not that he recalls.

        17               BY MR. KLAYMAN:

        18          Q    Does that mean your memory has gone

        19     blank, is that what that means?

        20          A    I recall no such discussions.

        21          Q    Prior to this deposition today,

        22     have you spoken with anyone about being









                                                             49
         1     deposed by Judicial Watch?

         2          A    Yes.

         3          Q    Who have you spoken with?

         4          A    The attorneys.

         5          Q    Which attorneys?

         6          A    The two women present.  I have

         7     talked to a couple other lawyers.

         8          Q    What other lawyers?

         9          A    Do I have to mention the names?

        10          Q    Yes, you do.

        11          A    I talked to a friend of mine who is

        12     a lawyer, Richard Ben-Veniste.

        13          Q    Just general subject matter, did he

        14     give you advice?

        15          A    It was, maybe, just a one minute

        16     phone conversation.

        17          Q    What was the nature of that

        18     conversation?

        19          A    He was not favorably impressed with

        20     the fact that I had been called here.

        21          Q    What did he say specifically?

        22               MS. SHAPIRO:  Objection.









                                                             50
         1               MR. KLAYMAN:  That is not advice,

         2     so there is no attorney-client privilege,

         3     that he is not favorably impressed.

         4               BY MR. KLAYMAN:

         5          Q    What did he say specifically?

         6               MS. SHAPIRO:  He is not authorized

         7     to disclose the specifics of discussions he

         8     had between himself and counsel.

         9               MR. KLAYMAN:  This is a statement

        10     by Mr. Ben-Veniste, not by him.  He has

        11     already revealed that Mr. Ben-Veniste was not

        12     favorably impressed.

        13               MS. SHAPIRO:  That's right.  He

        14     doesn't need to discuss.

        15               BY MR. KLAYMAN:

        16          Q    Did Mr. Ben-Veniste tell you how

        17     you could --

        18               MS. SHAPIRO:  May I assert my

        19     objection before you interrupt?

        20               MR. KLAYMAN:  Please, feel free.

        21               BY MR. KLAYMAN:

        22          Q    Did Mr. Ben-Veniste tell you --

 

 

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