1                MS. SHAPIRO:  I am sorry, I didn't

         2     assert the objection.

         3               MR. KLAYMAN:  Assert it.

         4               MS. SHAPIRO:  Objection,

         5     attorney-client privilege and relevancy.  He

         6     is not authorized to disclose and he doesn't

         7     need to disclose the specific conversation he

         8     had with an attorney about this deposition.

         9               MR. KLAYMAN:  Certify it.

        10               BY MR. KLAYMAN:

        11          Q    Did Mr. Ben-Veniste tell you, when

        12     you didn't wanted to answer a question, you

        13     could just say you didn't remember?

        14          A    No, sir.

        15          Q    Who else did you talk with?

        16          A    I mentioned to James Carville, who

        17     I saw had been similarly noticed, or deposed

        18     or served, rather.  It was in the paper this

        19     morning, so a few people may have mentioned

        20     it to me.

        21          Q    Did you discuss your deposition

        22     with anyone at the White House?


         1          A    Not the deposition, no.  The fact

         2     that it was in the newspaper this morning,

         3     which did not come from me, I might add,

         4     several people mentioned that to me.

         5          Q    Did you discuss with anyone in the

         6     White House counsel's office your deposition

         7     here today, or another day?

         8          A    Yes.

         9          Q    Who?

        10          A    Ms. Paxton.

        11          Q    Anyone else?

        12          A    I mentioned it to Mr. Ruff.

        13          Q    Did Mr. Ruff say anything to you

        14     after you mentioned it to him?  I am not

        15     asking what was said.  Did he respond?

        16               MS. SHAPIRO:  Just a moment.  The

        17     witness has answered, yes he had a

        18     conversation.  Beyond that, it would violate

        19     the attorney-client privilege.

        20               MR. KLAYMAN:  The fact that there

        21     was an utterance from Mr. Ruff would violate

        22     the attorney privilege?


         1               MS. SHAPIRO:  Yes, the fact that

         2     whether Mr. Ruff had a response to him, yes.

         3               MR. KLAYMAN:  Certify that.  We

         4     have gone through this kind of thing with

         5     Justice lawyers before.  I would hope that

         6     you would have an opportunity, perhaps at the

         7     next break, to consult with someone.  There

         8     is a law here.

         9               I am not asking for any advice.  I

        10     am just asking for him to a identify whether

        11     Mr. Ruff responded.

        12               When you instruct the witness not

        13     to answer, that is a potential contempt of

        14     court.

        15               MS. SHAPIRO:  I don't need a

        16     lecture on the rules.

        17               MR. KLAYMAN:  I am putting you on

        18     notice that --

        19               MS. SHAPIRO:  Will you, please, let

        20     me finish?

        21               MR. KLAYMAN:  We will move for

        22     sanctions.  I am asking you to correct it.


         1               MS. SHAPIRO:  I am asking you to

         2     let me finish.  I would like, one, to finish

         3     whatever I say before you talk over it.

         4               Two, the rules, specifically, state

         5     that instruction not to answer on the basis

         6     of privilege is appropriate.

         7               If after this deposition you want

         8     to move to compel, we would brief and support

         9     that claim of privilege.

        10               MR. KLAYMAN:  What I am telling you

        11     is that is frivolous.  And I am putting you

        12     on notice if you keep making those kinds of

        13     objections, I will move to have you

        14     sanctioned.

        15               MS. SHAPIRO:  I understand it --

        16               MR. KLAYMAN:  You and your

        17     colleagues.

        18               MS. SHAPIRO:  You can do what you

        19     like. Thank you.

        20               MR. KLAYMAN:  I am asking you at

        21     the next break to get some advice on this,

        22     because I am not asking for anything that


         1     Mr. Ruff said in terms of specifics, but just

         2     whether he responded.  That is not covered by

         3     privilege.

         4               MS. PAXTON:  Responded to what?

         5               MR. KLAYMAN:  To Mr. Begala telling

         6     him that he was being deposed.  Do you want

         7     to reconsider whether he can answer that?

         8               MS. SHAPIRO:  Nor at this point,

         9     no.

        10               MR. KLAYMAN:  Certify it.

        11               BY MR. KLAYMAN:

        12          Q    Did you talk with anyone else at

        13     the White House about your deposition before

        14     Judicial Watch?

        15          A    I don't think so, no.  Again it was

        16     in the paper, so in the hallway a few people

        17     said, I saw in the newspaper that you are

        18     going to be deposed.

        19          Q    Who said that to you?

        20          A    I can't remember.

        21          Q    It happened to today?

        22          A    Yes, just different people said,


         1     hey, either good luck or this is unfair.

         2          Q    You can't remember?

         3          A    Just in the hallway this morning, a

         4     few people.  I can't remember exactly

         5     particular people.  It was not a

         6     conversation.  It was literally passing in

         7     the hall.

         8          Q    What time did this occur today?

         9          A    It was in the newspaper this

        10     morning that I was going do be deposed.  I

        11     think that some folks, as I was walking to my

        12     office said either, good luck or this is not

        13     very fair, or comments of that nature.

        14          Q    Who said it wasn't fair?

        15          A    I don't know.  I mean, I don't

        16     know. I mean, I don't remember.

        17          Q    Do you frequently go down the

        18     hallway, people talk to you and you don't

        19     remember who they are?

        20          A    Casual hallway conversations are

        21     not particularly noteworthy for me.  They

        22     don't make a big impression.  Just hi, how


         1     are you, or good luck today.

         2          Q    You don't look at the person?

         3          A    I am trying to be helpful.

         4          Q    I don't think you are trying to be

         5     helpful.  As long as you are making

         6     gratuitous comments.

         7               MS. SHAPIRO:  Objection.

         8               BY MR. KLAYMAN:

         9          Q    I don't understand how you can't

        10     remember someone greeting you in the hallway

        11     today, and telling you it is not unfair.

        12     That is today.

        13               MS. SHAPIRO:  Is there a question

        14     on the table?

        15               BY MR. KLAYMAN:

        16          Q    Yes, can you tell me who greeted

        17     you and made that comment?

        18               MS. SHAPIRO:  It has been asked and

        19     answered.

        20               MR. KLAYMAN:  Perhaps, his memory

        21     is now refreshed.

        22               MS. SHAPIRO:  Will you, please, let


         1     me finish what I say before you speak over

         2     me?  I think it is only courteous.

         3               THE WITNESS:  I didn't make a note.

         4     It didn't make a big impression.  I am trying

         5     to be --

         6               BY MR. KLAYMAN:

         7          Q    Were they male or female?

         8          A    As I came to work this morning, or

         9     as I walked down the hall this morning,

        10     people might have mentioned, hey, I saw in

        11     the paper that you were going to be deposed.

        12          Q    More than one person?

        13          A    If you ask if I discussed, the

        14     answer is no, I have not with those people.

        15     But they were sort of, hey, how doing?  Good

        16     luck to you.  In the hall this morning.

        17          Q    More than one person?

        18          A    I think.

        19          Q    Were they male or female?

        20          A    I don't remember.  Again --

        21               MS. SHAPIRO:  This is asked and

        22     answered.


         1               BY MR. KLAYMAN:

         2          Q    You don't know whether they are

         3     male or female?

         4               MS. SHAPIRO:  Argumentative.

         5     Irrelevant.  I think we can move on.  He

         6     has --

         7               MR. KLAYMAN:  You may not be the

         8     one who decides whether we move on,

         9     Ms. Shapiro.

        10               MS. SHAPIRO:  Well, I can state

        11     that it has been asked and answered.  And you

        12     are being argumentative, at this point.

        13               BY MR. KLAYMAN:

        14          Q    Were they male or female?

        15               MS. SHAPIRO:  He can only keep

        16     repeating his answer.

        17               MR. KLAYMAN:  I am testing his

        18     memory.  It is a question of credibility.

        19               MS. SHAPIRO:  You are not entitled

        20     to test his memory forever on the same

        21     question.

        22               MR. KLAYMAN:  I never asked the


         1     same question.  I asked male or female.  I am

         2     trying to make it more general for you.

         3               THE WITNESS:  I remember coming out

         4     of the men's room, and I saw Goody Marshall.

         5     Thurgood Marshall.  He expressed that this

         6     was -- I don't remember the exact words.  He

         7     was surprised.  He was amazed.  It was a

         8     passing conversation in the hallway.  I don't

         9     remember with any other specificity.

        10               BY MR. KLAYMAN:

        11          Q    Anyone else you can now remember?

        12          A    No.  When you said male or female,

        13     I just remembered it was the men's room I was

        14     coming out of.  It was one second.

        15          Q    This is Goody Marshall?

        16          A    Thurgood Marshall.

        17          Q    How is the first name spelled?

        18          A    T-h-u-r-g-o-o-d.

        19          Q    The first name?

        20          A    Thurgood.

        21          Q    This is Thurgood marshals's son?

        22          A    This is the only Thurgood Marshall


         1     I know.

         2          Q    What is his position at the White

         3     House?

         4          A    He coordinates cabinet affairs,

         5     assistant to the President for cabinet

         6     affairs.

         7          Q    Anyone else that you remember?

         8          A    No, sir, no.  I have tried very

         9     hard on your prompting to rack my brain.

        10          Q    Have you talked about your

        11     appearing before Judicial Watch with anyone

        12     else, other than what you just mentioned?

        13          A    No, sir, not that I can recall.

        14          Q    Did you have one or more

        15     conversations with Mr. Carville about your

        16     appearance here today?

        17          A    Yes, about may appearance, no.

        18     About the fact that there had been a notice

        19     that we were going to be called or you put

        20     out a press release, yes.

        21          Q    When did the first such

        22     conversation occur?


         1          A    I guess about the time the press

         2     release went out, the day the press release

         3     came out.  I guess this was last week.

         4          Q    How did you learn about the press

         5     release?

         6          A    It was in my in box.

         7          Q    How did it get into your in box?

         8          A    I don't know.  Someone faxed it to

         9     me.

        10          Q    I will show you what I will ask the

        11     court reporter to mark as Exhibit 2.

        12                    (Begala Deposition Exhibit

        13                    No. 2 was marked for

        14                    identification.)

        15               BY MR. KLAYMAN:

        16          Q    Showing you Exhibit 2, Mr. Begala,

        17     is this the press release to which you are

        18     referring?

        19          A    Yeah.  Yes, it seems fair.

        20          Q    The top of this press release shows

        21     the marking that it was faxed from Judicial

        22     Watch to the Mary Matalin show, Mary Matalin.


         1     Does this refresh your recollection as to who

         2     provided you with a copy of the press

         3     release?

         4          A    It was in my in box.  I didn't ask

         5     who sent it.  It was a press release.  It

         6     didn't seem like a particularly private

         7     document to me.

         8          Q    What happened after you observed

         9     this press release in your in box?

        10          A    I rolled my eyes and set it down.

        11          Q    Did you make a call?

        12          A    No.

        13          Q    Did someone call you?  Did

        14     Mr. Carville call you?

        15          A    I talked to Mr. Carville.  I don't

        16     remember.  It wasn't at that exact moment, I

        17     can tell you that.  It came in my in box.  I

        18     looked at it rolled my eyes, and went about

        19     my day.

        20          Q    Did you talk to him in person or on

        21     the phone?

        22          A    On the phone.


         1          Q    Did you call him or did he call

         2     you?

         3          A    I don't recall.

         4          Q    When did that conversation take

         5     place?

         6          A    I think the day that this came out,

         7     or, maybe, the day after.  I don't remember

         8     exactly.  It was timely with the release of

         9     the press release.

        10          Q    What did you and Mr. Carville

        11     discuss during the conversation?

        12          A    Our view, my view -- I will speak

        13     for myself, that it seemed, frankly, absurd

        14     to be subpoenaed for a quip, a joke.

        15          Q    Is that what you think you were

        16     subpoenaed for?

        17          A    Yes, sir.

        18          Q    Nothing else?

        19          A    Yes, sir.

        20          Q    What did Mr. Carville say to you?

        21     I want you to tell me everything he said to

        22     you during that conversation.


         1          A    Best as I can recall, he agreed

         2     that it was absurd.  I don't remember the

         3     exact words that he used.

         4          Q    Did he use profanity?

         5          A    No.  It would not have been very

         6     noteworthy if he had.

         7          Q    Did he call me a twerp?

         8          A    No, sir, he did not.

         9          Q    Only subsequently?

        10          A    Subsequently, we had a second

        11     conversation after you appeared on MSNBC.  It

        12     wasn't about the deposition.

        13          Q    How long did the first conversation

        14     take place?

        15          A    It was not a very long

        16     conversation.

        17          Q    Did he advise you that he had been

        18     subpoenaed?

        19          A    He didn't say he had been

        20     subpoenaed.  He said, he had been asked -- I

        21     don't know the legal formalities, but he had

        22     been asked, and my recollection is that the


         1     date that he had been asked to appear, he

         2     told me, he was going to be out of town.

         3          Q    In fact he told you he wasn't going

         4     to appear, didn't he?

         5          A    No, the thing recorded in the paper

         6     that James was kind of eager to get involved

         7     in the judicial proceedings for reasons known

         8     only to himself.

         9               No, he did say, the particular

        10     date, I think it was March 10, that he was

        11     going to be out of town.

        12          Q    You are aware that he told the

        13     process server, there was an affidavit, that

        14     he wasn't going to appear?

        15          A    No, sir, I am not aware of that.

        16          Q    You are not aware of that?

        17          A    No.

        18          Q    Sworn affidavit, you have never

        19     seen it?

        20          A    No, sir.

        21          Q    What, if anything, did you say to

        22     Mr. Carville about whether you would appear


         1     for a deposition?

         2          A    It didn't come up.

         3          Q    Now, you say that I appeared on

         4     MSNBC.  This was with John Gibson?

         5          A    Yes, sir.

         6          Q    This was last week?

         7          A    Yes, sir.

         8          Q    Is it correct that you called John

         9     Gibson after I made a statement that we were

        10     seeking to take your deposition?

        11          A    No.

        12          Q    You didn't call John Gibson?

        13          A    That's correct.

        14          Q    Who called?

        15          A    I called a producer at MSNBC named

        16     Keenan Block, and protested that you had

        17     accused me falsely of using FBI files in an

        18     improper fashion or in any fashion, and I was

        19     outraged.

        20               I called Mr. Block, because he is a

        21     producer at MSNBC I know, I don't know

        22     Mr. Gibson.  I expressed severe anger and


         1     outrage.  I asked him to pass along that

         2     correction.

         3               I was very angry.  I remember that

         4     very well, because it was Ash Wednesday and I

         5     was getting ready to go to Mass.  I

         6     subsequently left but I did not see, but was

         7     told later that they did correct the record.

         8          Q    Is it not true that MSNBC offered

         9     you an opportunity to come on the air to

        10     correct it itself?

        11          A    I received a page while I was in

        12     Mass that said that.

        13          Q    Mr. Begala, I recollect and the

        14     tape speaks for itself, that immediately

        15     after I made that statement, not the

        16     statement you say but the statement that you

        17     had given a speech saying that you had looked

        18     through FBI files, there was a commercial

        19     break, and when Mr. Gibson came back as

        20     commentator he said, you had called and that,

        21     in fact, he offered you the opportunity to

        22     come on and you said you didn't want to.


         1               Isn't that a correct recitation of

         2     what occurred?

         3          A    No, sir.  I can tell you what

         4     occurred.  What occurred was I called Keenan

         5     Block.  He is a producer of the network.

         6     Actually, I think he produces the Brian

         7     Williams show not the John Gibson show.  I

         8     didn't know that at the time.

         9               I expressed my outrage to him.  He

        10     did not offer me a chance to go on, nor was I

        11     interested.  It was getting, the last Mass of

        12     the day was about to occur at St. Matthews

        13     and Mark and I had an obligation to attend

        14     that, which I did.

        15               While I was in Mass, I remember my

        16     pager going off saying Keenan Block called

        17     back and wants you to go on the show.  I

        18     ignored that.

        19          Q    If you had been there, according to

        20     your recitation, would you have gone on the

        21     show?

        22          A    I don't know.  I just called and


         1     expressed my outrage and then I went to

         2     church.

         3          Q    When you talked to Keenan Block,

         4     did you express any opinion about Larry

         5     Klayman or Judicial Watch, or give them any

         6     information about Larry Klayman or Judicial

         7     Watch?

         8          A    I complained to him the joke I told

         9     in the speech, that was a joke.  That my

        10     recollection was, that I had told Mr. Block,

        11     that you had issued a press release that said

        12     it was a joke.  But on the air you had

        13     dropped that part out, I thought in an effort

        14     to smear me.

        15               I made it very clear to Mr. Block

        16     that I was very angry.

        17          Q    Did you say anything about me or

        18     did you say anything about Judicial Watch?

        19          A    That is what I said about you.

        20          Q    Did you say anything else about

        21     Judicial Watch or Larry Klayman?

        22          A    Not that I recall.  I mean, I was


         1     very critical of what you said about me.  I

         2     am still real angry about it.

         3          Q    Did you say anything else about

         4     Larry Klayman or Judicial Watch to Mr. Keenan

         5     Block?

         6               MS. SHAPIRO:  Asked and answered.

         7               BY MR. KLAYMAN:

         8          Q    Yes or no?

         9          A    I was enormously critical of what

        10     you said.

        11          Q    My question is did you say anything

        12     else about Larry Klayman or Judicial Watch?

        13          A    I asked answered it as best as I

        14     can.

        15          Q    It calls for a yes or no, simple

        16     question?

        17          A    To the best of my knowledge.  I

        18     called him.  I expressed my outrage at what

        19     you had said about me.  I asked for some

        20     correction of the record.  I left the office.

        21          Q    That is all you said?

        22          A    That is all I remember.


         1          Q    That is all you remember.  That

         2     doesn't mean that is all you said, that is

         3     all you remember?

         4          A    Right.

         5          Q    You didn't call me an SOB or

         6     anything like that?

         7          A    I don't -- I would hope not.  I

         8     can't swear to that.  I sometimes use foul

         9     language myself.

        10          Q    You have no recollection of doing

        11     that?

        12          A    But I wouldn't rule it out.  I am

        13     not proud of it, but that is part of my

        14     common lexicon.

        15          Q    You didn't say nothing like Larry

        16     Klayman is a Clinton hater and his groups are

        17     Clinton haters?

        18          A    I may -- I wouldn't have said it

        19     about the group.  I may have said it you.  I

        20     don't remember saying it, though.

        21          Q    You may have said it about me

        22     generally?


         1          A    I might have.  I think you are

         2     quite a critic of this administration and

         3     this President.

         4          Q    That doesn't mean I am a Clinton

         5     hater.

         6          A    You can take that up yourself.  You

         7     were on national television accusing me of

         8     criminal, felonious, activity falsely -- and

         9     I believe you knew it was false, Mr. Klayman.

        10          Q    Well, you said it, Mr. Begala.

        11          A    I said it as a joke.

        12          Q    Didn't you say you looked in FBI

        13     files?

        14          A    I told a joke.  The point of the

        15     joke was irony.  The point of the joke was

        16     that it was not true.  In fact its very

        17     falseness conveyed -- excuse me, let me

        18     finish, Mr. Klayman, this matters to me.

        19               The very falseness of the statement

        20     conveys its humor.  It was obvious.  It was

        21     humorous, and it was taken as such by the

        22     crowd, and also by the press in attendance.


         1          Q    Mr. Begala, isn't it true that you

         2     made that statement, even assuming that what

         3     you say is true, to send a message to

         4     perceived Clinton adversaries that they

         5     shouldn't mess with this administration?

         6          A    No, sir.

         7          Q    Because if they do, you have access

         8     to FBI files?

         9          A    No, sir, absolutely not.  In fact,

        10     if I can tell you for a minute, the

        11     derivation of that joke.  I have been telling

        12     a variety, a version of that joke for five

        13     years now, six years.

        14               Originally, a friend of mine wrote

        15     it for me.  It was about George Bush, the

        16     joke, which is not true, I want to say for

        17     the records, is that upon meeting President

        18     Bush, he was quite gracious and said to me,

        19     son, now I have seen you on TV saying these

        20     bad things about me, but now that I see you

        21     in person, you are a lot better looking

        22     person than in your passport file.


         1               I have been telling that joke for a

         2     number of years.  I subsequently updated it

         3     with a similarly absurd scenario.

         4          Q    What is funny, Mr. Begala, about

         5     looking into the FBI files of Republicans?

         6          A    Absolutely nothing.

         7          Q    Then why do you make a joke about

         8     it?

         9          A    Because it is absurd on its face

        10     that I could, in a context of praising,

        11     actually, my friend, my friends's wife, who

        12     is a Republican, pointing out that there are

        13     very good Republicans in this world.

        14               It is an absurd statement designed

        15     to elicit humor.  It is a joke.  It is absurd

        16     in its obvious falseness, and just as absurd

        17     as President Bush rifling passport files.

        18               I did not -- President Bush never

        19     said that.  That is a joke.  It is an absurd

        20     and absurdly false statement, so completely

        21     false as to elicit laughter.

        22               I have to tell you that joke kills.


         1     I have been telling it for six years, I got

         2     to tell you. It works every time.

         3          Q    I believe it kills.

         4          A    It is a very funny joke.

         5          Q    It sends a message to people who

         6     are adversaries, don't mess with us?

         7          A    No, sir, absolutely not.  It is a

         8     good joke, a funny joke, written by a

         9     professional joke writer or screenwriter, or

        10     again originally about President Bush and it

        11     is so absurdly false -- that it gets a laugh.

        12          Q    The last several weeks, you have

        13     issued a statement, publicly, have you not,

        14     that it is time for the White House to

        15     investigate the investigators, correct?

        16          A    No, sir.

        17          Q    It is time to investigate the

        18     investigators?  You have said that, haven't

        19     you?

        20          A    I have called for an investigation

        21     of leaks, but not by the White House.

        22          Q    You said it is time to investigate


         1     the investigators?

         2          A    I don't remember that statement.  I

         3     remember being extraordinarily critical of an

         4     ongoing series of leaks that I do believe

         5     merit investigation.

         6          Q    Was that a joke too?

         7          A    No, sir.

         8          Q    Time to investigate the

         9     investigators?

        10          A    No, I don't remember saying that

        11     exact phrase --

        12               MS. SHAPIRO:  Objection.  He didn't

        13     say that he ever said, investigate the

        14     investigators.

        15               MR. ANDERSON:  We have now been

        16     here one hour you have not asked Mr. Begala

        17     one question about his knowledge of the FBI

        18     matters.

        19               MR. KLAYMAN:  I don't think you

        20     have been here at all, because that is

        21     exactly what I am asking about.

        22               MR. ANDERSON:  The record will


         1     show.

         2               MR. KLAYMAN:  I will show you what

         3     I will ask the court reporter to mark as

         4     Exhibit 3.

         5                    (Begala Deposition Exhibit

         6                    No. 3 was marked for

         7                    identification.)

         8               BY MR. KLAYMAN:

         9          Q    Exhibit 3 is a report from the New

        10     York Times dated February 9, 1998 by James

        11     Benet, entitled:  Washington Memo from

        12     Whispered Secrets a Clamorous Debate.

        13               Looking at the middle of the page,

        14     third paragraph down:  "The stakes of this

        15     theorizing are rising.  On Sunday, Paul

        16     Begala, a senior advisor to Clinton stepped

        17     up to the White House assault on Kenneth

        18     Starr, the independent counsel, denouncing

        19     him for "leaks and lies, and declaring, "it

        20     is time to investigate the investigators."

        21               Does that refresh your recollection

        22     as to whether you made that statement?


         1          A    Um-hum.

         2          Q    You made that statement?

         3          A    I don't -- I see the news clipping.

         4     Again, I have been quite public in calling

         5     for an independent investigation of leaks

         6     that have come out in the last few months.

         7          Q    Now, Kenneth Starr, you are aware,

         8     is a previous attorney with the U.S.

         9     Department of Justice, correct?

        10          A    Yes.  Solicitor general, yes.

        11          Q    You are aware that, when you become

        12     an employee of the Department of Justice, the

        13     FBI conducts a background investigation,

        14     correct?

        15          A    I would imagine that, yes.

        16          Q    You are also aware that, as part of

        17     that background investigation, the FBI has a

        18     file on Ken Starr, correct?

        19          A    I am not aware of that, but --

        20          Q    You are a lawyer, correct?

        21          A    I have never practiced, but I have

        22     a law degree.


         1          Q    You are aware the FBI keeps files

         2     when they do a background investigation?

         3          A    I would think so.

         4          Q    They have one on you, too, correct?

         5          A    I think so.

         6          Q    Therefore, you when say it is time

         7     to investigate the investigators, one way you

         8     could do that was to obtain Ken Starr's FBI

         9     file, correct?

        10          A    No, sir.  Absolutely not.

        11          Q    Why can't you do that?

        12          A    What I said and what I meant was we

        13     need an independent investigation of the

        14     leaks that had been so prevalent at that

        15     time.  I still believe it is necessary.

        16          Q    When you conduct an investigation

        17     of Ken Starr, why can't you get his FBI file?

        18          A    I don't conduct investigations.  I

        19     called for an independent investigation,

        20     investigation of a campaign of leaks.

        21          Q    But one way you could investigate

        22     him is to get his FBI file?


         1          A    No, sir.

         2          Q    Why not?

         3          A    I don't do investigations.

         4          Q    I am talking about others who do

         5     investigations?

         6          A    I did not at all suggest means or

         7     methods.  I suggested an independent -- I

         8     still believe we need an independent

         9     investigation of -- let me finish, sir -- of

        10     what I believe is, has been an orchestrated

        11     campaign of leaks.

        12          Q    When you take the two statements

        13     together, that I reviewed the FBI files, it

        14     is just a joke, Your Honor, you are talking

        15     about Judge Lamberth, right?

        16          A    No, sir, I was not.  I don't know

        17     if I'd ever heard of him.

        18          Q    You were aware, when you made the

        19     statement, that there was a class action

        20     lawsuit filed by Judicial Watch against the

        21     White House?

        22          A    Not, not really.  Maybe, in the


         1     vague sense I may have read a news article

         2     about it.  No.  That is not what I was

         3     referring to.  I was trying to tell a joke.

         4          Q    Who was Your Honor?

         5          A    I was telling a joke.  I was making

         6     a point of the fact that there was a camera

         7     in the room and again, telling a joke, again,

         8     absurd in its obvious falseness, Mr. Klayman.

         9          Q    Are you denying that the White

        10     House procured FBI files, contrary to FBI

        11     procedures in the past, during the Clinton

        12     administration?  Are you denying that

        13     statement?

        14          A    I don't have any knowledge of that.

        15          Q    Have you read about that in the

        16     newspaper?

        17          A    I read stories about FBI files.

        18          Q    Are you aware that director Louie

        19     Freeh called it an egregious violation of

        20     privacy without justification?

        21          A    I am not aware of that.

        22          Q    You are a very knowledgeable man,


         1     are you not?

         2               MS. SHAPIRO:  Objection, completely

         3     vague question.

         4               BY MR. KLAYMAN:

         5          Q    He can respond?

         6          A    I know what I know.

         7          Q    Part of your duties and

         8     responsibilities, both before you became a

         9     member of the White House staff and after, is

        10     to know what is going on in the political and

        11     governmental world, is it not?

        12          A    When this story broke, I was living

        13     in Texas, and I was doing corporate work and

        14     teaching.  And I didn't follow the story very

        15     closely.

        16          Q    Are you saying, to this day, you

        17     have no knowledge of any kind that FBI files

        18     were procured incorrectly, to use a neutral

        19     phrase, from the FBI by the White House?

        20          A    I have seen news articles to that

        21     effect.  But beyond that, I have no knowledge

        22     whatsoever.


         1          Q    Have you ever discussed the

         2     Filegate matter with anyone at the White

         3     House?

         4          A    No, sir.

         5          Q    Not one person?

         6          A    No, sir.

         7          Q    Have you ever discussed the

         8     Filegate matter with anyone else?

         9          A    Not that I remember, no.

        10          Q    I see, you don't remember.  You are

        11     not saying no?

        12          A    It as very broad question.

        13               MS. SHAPIRO:  Objection.  He can

        14     only testify as to what he remembers.

        15               MR. KLAYMAN:  Then he doesn't have

        16     to say.

        17               THE WITNESS:  It may have been when

        18     I read the article, I may have commented on

        19     it, but I doubt it.  Because again I was

        20     living a life where I was teaching and doing

        21     corporate work.  Those kinds of Washington

        22     stories were very far from my existence at


         1     the time.  I don't remember commenting on it.

         2               BY MR. KLAYMAN:

         3          Q    So, you are saying categorically

         4     that you never discussed the Filegate matter

         5     with anyone?  You just read an article, you

         6     never discussed it with anyone?

         7               MS. SHAPIRO:  Asked and answered.

         8               THE WITNESS:  To the best of my

         9     knowledge and recollection.

        10               BY MR. KLAYMAN:

        11          Q    No?

        12          A    Right.

        13          Q    Did you watch the O.J. Simpson case

        14     on TV?

        15          A    Occasionally.

        16          Q    Remember when they asked the

        17     question of Mark Ferman, whether he ever used

        18     the N word and he said no?

        19          A    Yes.

        20               MS. SHAPIRO:  Objection, relevancy.

        21               BY MR. KLAYMAN:

        22          Q    Are you aware of the ramifications


         1     when it turned out in fact he had?  Are you

         2     aware of that?

         3               MS. SHAPIRO:  Objection.  You can

         4     answer the question.

         5               THE WITNESS:  I remember the case.

         6               MR. KLAYMAN:  I will show you what

         7     I asked the court reporter to mark as

         8     Exhibit 4.

         9                    (Begala Deposition Exhibit

        10                    No. 4 was marked for

        11                    identification.)

        12               MR. KLAYMAN:  Showing you

        13     Exhibit 4, Mr. Begala, this was a transcript

        14     prepared by your counsel to the U.S.

        15     Department of Justice of your speech in Miami

        16     to the Democratic Business Council.

        17               MS. SHAPIRO:  Objection, you are

        18     stating facts not testified to.

        19               MR. KLAYMAN:  It says U.S.

        20     Department of Justice.

        21               MS. SHAPIRO:  That doesn't mean

        22     that U.S.  Department of Justice prepared it.


         1     You need to ask him if he knows who prepared

         2     it.

         3               BY MR. KLAYMAN:

         4          Q    Do you know who prepared it?

         5          A    No, sir, I don't.

         6          Q    Have you seen this transcript

         7     before?

         8          A    I have seen a transcript of this

         9     speech.

        10          Q    Was it this transcript?

        11          A    It might be.  This actually does

        12     look a little bit different. Maybe because it

        13     starts on page two --

        14          Q    Look at page 4.

        15          A    Page 4.  Yes, sir.

        16          Q    Look down towards the lower part of

        17     the page where it says Begala, right above

        18     it, it says laughter?

        19          A    Yes, sir.

        20          Q    It says Begala:  So, like, that was

        21     like one of my first lessons that Bill

        22     Clinton taught me and James and Mary


         1     particularly have taught me that there are

         2     some good reasons Republicans out there --

         3               MS. SHAPIRO:  Objection, that is

         4     not what it says.

         5               BY MR. KLAYMAN:

         6          Q    That there are some good -- I will

         7     read it again.

         8               "So, like, that was like one of my

         9     first lessons that Bill Clinton taught me,

        10     and James and Mary particularly have taught

        11     me, that there are some good Republicans out

        12     there, which is not something I would have

        13     known just from reading their FBI files."

        14     Laughter.  "You know, I mean, that was just a

        15     joke Your Honor."  That is what you said at

        16     the Democratic Business council?

        17          A    That was a joke I told there.

        18     Again, the point being that one of my best

        19     friends had married a Republican forcing me

        20     to confront the reality that Mary is a good

        21     person and she is a diehard Republican.  And

        22     sometimes -- I am speaking to a partisan


         1     group -- I am trying to make the point that

         2     even the most diehard Democrat has to

         3     acknowledge that there are some very good

         4     Republicans out there.

         5          Q    That may be something we can agree

         6     on with regard to Mary Matalin.

         7          A    I love Mary.  I am the godfather of

         8     her baby.  She is a nice person.

         9          Q    I am asking you this question, what

        10     did you mean by, that was a joke, Your Honor?

        11          A    I was trying to get another laugh

        12     out of it.  It was just a cheap line.  It was

        13     also to stress it was so obviously, absurdly

        14     a joke.  Just another follow on cheap line

        15     joke.

        16          Q    You are referring to Judge Royce

        17     Lamberth?

        18          A    No, sir.  I don't know that I ever

        19     heard of him.  I mean, I might have heard of

        20     him --

        21          Q    Well, he is the judge who is in

        22     charge --


         1               MS. SHAPIRO:  Let him finish his

         2     answer.

         3               MR. KLAYMAN:  Finish.

         4               THE WITNESS:  That is not what I

         5     referring to.

         6               BY MR. KLAYMAN:

         7          Q    The judge who is in charge of the

         8     Filegate class action lawsuit in court?

         9          A    That certainly was not on my mind.

        10     I was not aware of his work or this suit at

        11     the time I gave the speech.  It was an

        12     absurdly and certainly a false joke, the

        13     derivation of which was a play on President

        14     Bush, equally untrue, and I hope nobody

        15     thinks President Bush did anything wrong

        16     either.

        17               MS. SHAPIRO:  I object on the

        18     characterization of that as a class action

        19     lawsuit, because class action has not been

        20     granted in this case.

        21               MR. KLAYMAN:  I think, the court is

        22     aware of the status of the case.  It was


         1     filed as a class action.

         2               BY MR. KLAYMAN:

         3          Q    Mr. Begala, do you have any

         4     knowledge of FBI files that were obtained by

         5     the White House, that are subject of this

         6     case, ever having been returned to FBI?

         7          A    I have no knowledge of that case at

         8     all, sir.

         9          Q    So, as far as you know, they may

        10     still be there?

        11          A    I have no knowledge of that case.

        12     It is why I was frustrated being served with

        13     a subpoena.

        14          Q    You say you discussed with James

        15     Carville more than one time your

        16     participation in this lawsuit and his?

        17          A    The fact that he and I had been

        18     served and, also, I talked with him about

        19     your appearance on MSNBC.

        20          Q    Tell me when was the next time you

        21     talked to him?

        22          A    I don't remember the date but maybe


         1     the date after you appeared on MSNBC, which

         2     would have been a Thursday.  I don't know the

         3     date of the month.

         4          Q    Did he call you or you call him?

         5          A    I don't recall.

         6          Q    What was discussed?  What did you

         7     say?

         8          A    I told him what you had said on

         9     MSNBC.  I told him that you had stated,

        10     without telling anyone that it was a joke,

        11     bald faced --

        12          Q    I don't view it at as joke.

        13          A    An allegation --

        14               MR. ANDERSON:  Would you let him

        15     finish his answer?

        16               THE WITNESS:  You also state it as

        17     a joke in your own press release.

        18               BY MR. KLAYMAN:

        19          Q    I said you claimed it was a joke?

        20          A    If I may finish, I pointed out to

        21     him that you had pretended that a joke that I

        22     had made, that I believe you knew was false,


         1     that you had knowledge of the falsity of the

         2     statement, yet you went on national

         3     television and accused me of a serious

         4     felonious act.  I was pretty angry about it.

         5          Q    What did he say?

         6          A    He said I should sue you.

         7          Q    What else did he say?

         8          A    He said you should talk to my

         9     lawyer.

        10          Q    Who is his lawyer?

        11          A    Bill McDaniel.

        12          Q    Did you talk to his lawyer?

        13          A    Yes, I did.

        14          Q    When did you talk to Mr. McDaniel?

        15          A    The day subsequent to that.

        16          Q    How long did you talk to

        17     Mr. McDaniel?

        18          A    I had lunch with him.

        19          Q    At what point, did you talk with

        20     Carville again?

        21          A    I don't remember.  We talk with

        22     some frequency.  We are close friends.


         1          Q    Have you talked to him again about

         2     this case?

         3          A    Yes, I think -- about this question

         4     that he is quite hot for me to sue you.  He

         5     has urged me to do that many times.

         6          Q    Many times.  What other times did

         7     he urge you to do it?

         8          A    Just in the last few days, just

         9     again and again. James is a very relentless

        10     man.

        11          Q    How many times did you talk to him

        12     in the last few days?

        13          A    Several times.

        14          Q    Did James talk about his own

        15     deposition?

        16          A    No.  Except that the first time

        17     saying that he was going to be out of town

        18     that day.  That is all I remember.

        19          Q    Was Mr. McDaniel going to represent

        20     him in terms of the deposition of this case?

        21     Do you have knowledge of that?

        22          A    He seemed to indicate that to me.


         1          Q    Where is Mr. Bill McDaniel located?

         2          A    I think his firm is in Baltimore.

         3          Q    Have you ever talked to Mary

         4     Matalin about your participation in this

         5     case?

         6          A    No, sir.

         7          Q    Do you know whether the press

         8     release was given by Mary Matalin, the one

         9     identified as Exhibit 3, was that given by

        10     Mary Matalin to James Carville?

        11          A    I don't know.

        12          Q    Has he told you that?

        13          A    I don't know, he has not told me

        14     anything about the press release.

        15          Q    Where was it faxed from?

        16          A    I don't know.

        17          Q    How did it get into your in box?

        18               MS. SHAPIRO:  That has been asked

        19     and answered.

        20               MR. KLAYMAN:  Maybe, he remembers

        21     now.

        22               THE WITNESS:  I didn't see anybody


         1     put it in there.  It sat in my in box.

         2     Maybe, when I came back from my office.

         3               BY MR. KLAYMAN:

         4          Q    Do you regularly get press releases

         5     from Mary Matalin?

         6          A    No, not regularly, I wouldn't say.

         7          Q    Does Mary Matalin share information

         8     with you about Republicans?

         9          A    No.

        10          Q    Or James?

        11          A    We are friends, we talk.  I don't

        12     know what you mean by share information.

        13          Q    If you need some information about

        14     a Republican or Clinton adversary, have you

        15     ever asked Mary for that information?

        16          A    No, sir.

        17          Q    Have you ever been present in the

        18     White House, either in terms of a

        19     professional or a personal gathering where

        20     Mary Matalin and James Carville were present?

        21          A    Yes, sir.

        22          Q    Where was that?


         1          A    State dinner for Prime Minister

         2     Blair.

         3          Q    Have you ever watched a movie with

         4     Mary Matalin and James Carville in the White

         5     House?

         6          A    In the White House?  Not that I

         7     recall.

         8          Q    Have they ever done that?

         9          A    I have no idea.  You have to ask

        10     them.

        11          Q    Let's go back to the issue of who

        12     you talked to about your subpoena.  In

        13     addition to Mr. Carville, who else other than

        14     the people you mentioned?

        15          A    I mentioned the lawyers.  I,

        16     obviously, mentioned it to my wife.  I think

        17     that is it.  But I am not sure.

        18          Q    At the time that you were

        19     consulting with Governor Clinton as to

        20     whether to take his campaign on with James

        21     Carville, did there come a point in time when

        22     a formal agreement was entered into between


         1     your firm, Carville and Begala, and Clinton?

         2          A    Yes, sir.

         3          Q    Was that agreement put in writing?

         4          A    I don't remember.

         5          Q    Who would have it, if it exists?

         6          A    No, I don't know.  James might.

         7     Our firm, if I can elaborate, was very small.

         8     We had very few clients.  Most of our

         9     relationships with our clients were handshake

        10     deals as well.

        11               I have been very fortunate that I

        12     have worked for candidates and politicians

        13     who are people of honor.

        14          Q    How much were you paid to handle

        15     that campaign?

        16          A    Our fee began, my recollection is,

        17     I might be wrong, my recollection is, our fee

        18     was $15,000 a month until the Democratic

        19     Convention when the governor was nominated;

        20     and then for the remainder of the campaign,

        21     my recollection is it was $25,000 a months

        22     for the remainder of the campaign.


         1          Q    What were your duties and

         2     responsibilities in taking on this

         3     assignment, you and James Carville?

         4          A    James and I were strategists for

         5     the campaign.

         6          Q    Were either of you campaign

         7     managers?

         8          A    No, sir.

         9          Q    Who was the campaign manager?

        10          A    David Wilhelm.

        11          Q    As part of your responsibilities

        12     and duties as strategists, what specifically

        13     were you to do?

        14          A    To set the strategy.  To work with

        15     the other consultants and staff.  To help set

        16     the direction of the campaign.

        17          Q    You were to know whether political

        18     adversaries were going to attack the

        19     President on particular issues, were you not?

        20     That was part of your duties and

        21     responsibilities?

        22          A    Can you clarify that?  I don't want


         1     to suggest that I had any ability to foresee

         2     the future.  Generally, when you go into a

         3     campaign, people are going to criticize.

         4          Q    Let's get to the point.  At what

         5     point, did you discuss with Bill Clinton or

         6     anyone else the adversaries that he faced in

         7     the primary campaign to become the nominee of

         8     the democratic party?

         9          A    My recollection it would have been

        10     after we were hired on.

        11          Q    Did that occur in person?

        12          A    To the best of my recollection,

        13     yes.

        14          Q    Where did it occur?

        15          A    Probably, in Little Rock.

        16          Q    Who was present during that

        17     meeting?

        18          A    You know, James and I, I can't

        19     remember.  It is not like it was a particular

        20     meeting.  There was an ongoing effort to make

        21     sure that we knew what we were running on,

        22     what we were for and how we would advance



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