151 1 Q You did have discussions with 2 Hillary Clinton? 3 A At what time? 4 Q After the campaign, after the 5 President took his oath of office? 6 A Yes, sir, from time to time. 7 Q And did you meet with her from time 8 to time? 9 A From time to time. 10 Q Did you meet with her in the 11 presence of Mr. Carville? 12 A I would think so. 13 Q Did you meet with her occasionally 14 in the presence of Mr. Stephanopoulos? 15 A I don't have a specific 16 recollection, but I would think so, yes. 17 Q Did you meet with her in the 18 presence of the President from time to time? 19 A I would think so, yes. I don't 20 have a specific memory, but yes, I would 21 think so. 22 Q And during those meetings, you 152 1 would discuss issues involving the 2 administration? 3 A Yes, sir. 4 Q You now meet with the President and 5 First Lady from time to time, correct? 6 A The President frequently. The 7 First Lady occasionally. 8 Q Have you ever discussed the FBI 9 files matter with the First Lady? 10 A Not to the best of my recollection 11 or knowledge, no, sir. 12 Q Are you saying you haven't? 13 A I have no memory of that 14 whatsoever, that's correct. 15 Q Now, the FBI files matter, that is 16 a very significant matter, is it not, in 17 terms of the allegations? 18 A It is a very serious allegation. 19 Q That is something you would 20 remember, wouldn't you, if you discussed it 21 with the First Lady? 22 A I would think so, but I have no 153 1 memory of that. 2 Q So is your answer no, I have never 3 discussed that with the First Lady? 4 A I just want to be very careful, 5 because this is a formal legal proceeding. I 6 want to tell you I have absolutely no memory 7 of that, nor do I have any memory of 8 discussing it with anybody. 9 Again, it is a story that came up 10 when I lived a long way away and was living a 11 different life and was not advising on those 12 kinds of issues at the time. 13 Q Since you became back to the White 14 House, when was that? 15 A August 11th. 16 Q Have you discussed the FBI files 17 matter with anyone? 18 A Not to my recollection. 19 Q Is the answer no? 20 A Not to my recollection, no, sir. 21 Q The answer is no? 22 A Not to my recollection, sir. 154 1 MS. SHAPIRO: I have to object. 2 MR. KLAYMAN: I don't know if he is 3 saying "I don't remember" or "no." 4 MS. SHAPIRO: May I state my 5 objection? 6 MR. KLAYMAN: Yeah. 7 MS. SHAPIRO: My objection is 8 simply that he can only testify to the best 9 of his knowledge, and you are continuing to 10 ask that type of question, and it is 11 harassment. 12 MR. KLAYMAN: Well, because you 13 see, there is a very clever way of answering 14 questions has developed during the last 15 several years which is, "to the best of my 16 recollection." And then people say whatever 17 they want to say. 18 I am telling you, Mr. Begala, and I 19 think you understand this as a lawyer, that I 20 am not asking you to testify as to anything 21 that you don't remember. But to put the 22 qualifier in is quite unnecessary. 155 1 So I will take a stipulation from 2 counsel that everything is based on what you 3 remember, and therefore you won't have to 4 qualify your answers. 5 Can I take a stipulation on that? 6 MS. SHAPIRO: Yeah. 7 MR. KLAYMAN: Okay. Fine. 8 MS. SHAPIRO: We are willing to 9 make a stipulation that he can only testify 10 to the best of his memory. 11 MR. KLAYMAN: I don't want to hear 12 qualifiers "to best of my memory." 13 MR. ANDERSON: He is answering as 14 best he can. You ask your questions. 15 MR. KLAYMAN: I forget your name. 16 I'm sorry. 17 MR. ANDERSON: David Anderson. 18 MR. KLAYMAN: Mr. Anderson, please, 19 one counsel here. There is one counsel. 20 BY MR. KLAYMAN: 21 Q I am asking you a question. I 22 don't want it with a qualifier. 156 1 A I have to answer it to the best of 2 my recollection. 3 Q And I am stipulating everything you 4 say is to the best of your recollection. So 5 I am asking you to answer without, pursuant 6 to stipulation, those qualifiers. 7 Have you ever discussed the FBI 8 files matter with anyone since you have come 9 back to the White House? 10 A I have no recollection of any such 11 conversations with anyone in the White House 12 since I've come back. 13 Q So the answer is no? 14 A I feel, because I am under oath, 15 that I need to be as accurate as I can. So I 16 wanted to say "to the best of my 17 recollection." If you stipulate that, then, 18 the answer is -- 19 MS. SHAPIRO: We are withdrawing 20 the stipulation, because it clearly is not 21 going to work. The witness can answer the 22 question to the best of his ability and if he 157 1 wants to say "to the best of my 2 recollection," that is accurate. 3 BY MR. KLAYMAN: 4 Q So you can't answer yes or no? 5 A Again, I take your point that this 6 is something that I would likely remember, 7 and I have no memory of any such 8 conversations. 9 It is not an issue that I have ever 10 worked on. It is not an issue that I have 11 ever dealt with. 12 Q My question was, you can't answer 13 yes or no? 14 A I myself am in the surreal world 15 where I am sworn under oath in a deposition 16 in a lawsuit because I told a joke, Mr. 17 Klayman. So I hope you will understand, if 18 in the first deposition of my life, I treat 19 it with some gravity, and try as forthrightly 20 as I can to tell you that I have absolutely 21 no memory of that whatsoever. 22 Q My question is, you can't answer 158 1 yes or no; is that correct? 2 A I am telling you to the best of my 3 memory -- we have been over this several 4 times -- it is very important that you know 5 this and the record reflect that I have no 6 memory whatsoever of the use or misuse of FBI 7 files, nor do I recall discussing this matter 8 with anyone in the White House. 9 This is not an issue that I have 10 worked on. It is in part why I am so 11 frustrated to have been called here, based on 12 what was obviously an absurd and farcical 13 joke. 14 Q Have you saying this deposition is 15 an absurd and farcical joke? 16 A No, sir, I am saying that my 17 statement in that speech which prompted your 18 service was absurd and farcical. It was a 19 joke, my statement in that speech. 20 Q My question is -- just give me a 21 simple answer -- you can't answer yes or no 22 to my question? 159 1 A I am telling you to the best of my 2 recollection. This is a topic that I believe 3 I would recall if I ever had a conversation 4 about it, and I recall no such conversations, 5 Mr. Klayman. 6 Q Do you understand my question? 7 MS. SHAPIRO: He's answered your 8 question. 9 BY MR. KLAYMAN: 10 Q I want an answer to my question. 11 You cannot answer either yes or no? Correct? 12 Correct? Correct? 13 A Because -- may I answer? 14 Q I am asking you for a yes or no. 15 A Because I am extraordinarily 16 cognizant of the fact that I am under oath, I 17 want to make sure that I tell you everything 18 to the best of my memory. 19 To the best of my memory, no, sir. 20 Q Is the reason why you can't answer 21 yes or no because you don't want to be pinned 22 down, because you recognize that, according 160 1 to what you understand, it is very hard to 2 hold anyone accountable for perjury if you 3 don't remember? 4 A No, sir. It is because I am 5 searching my memory as very best as I can, 6 and I have no such recollection. 7 MR. KLAYMAN: I will show you what 8 I will ask the court reporter to mark as 9 Exhibit 7. 10 (Begala Deposition Exhibit 11 No. 7 was marked for 12 identification.) 13 BY MR. KLAYMAN: 14 Q This is a document which you 15 produced today, Mr. Begala, is it not? 16 A Yes, sir. 17 Q Where did this document come from 18 in your files? 19 A It was in a file. I don't 20 understand. It was in my office. 21 Q It was in your office? Where was 22 it kept in your office? 161 1 A My assistant kept it. 2 Q Who is your assistant? 3 A Stacey Parker. 4 Q Where does she generally keep 5 files? 6 A I think she keeps them around her 7 desk, in a credenza or behind her desk. I 8 think so; I am not sure. 9 Q Was it in a file folder? 10 A No, sir. 11 Q Who found the document? 12 A The document itself? 13 Q Yes. 14 A I did. 15 Q You went through her files to see 16 if there was anything responsive to this 17 subpoena today? 18 A I went through a particular folder. 19 Q The notice today? You did? 20 A Yes, sir. 21 Q Was there a label on the folder 22 that this document came out of? 162 1 A I can't remember one. 2 Q But you are not sure? 3 A I am not sure. 4 Q I asked for the production of the 5 folder. I would like to see whether at the 6 next break that could be faxed over, the 7 label on that folder. 8 MS. SHAPIRO: Where did you ask for 9 the production of the folder? 10 MR. KLAYMAN: If it contains a 11 notation that may be -- you can take a look 12 at it. It may contain a notation that says 13 "Filegate." It may contain a notation that 14 makes a reference to Filegate. He can't 15 remember. 16 MS. SHAPIRO: Well, can you show me 17 where you asked for it? 18 MR. KLAYMAN: We asked for any and 19 all documents that deal with Filegate. 20 THE WITNESS: I would have noticed 21 if it had -- 22 MR. KLAYMAN: As you know. 163 1 THE WITNESS: It is not a question. 2 I can try to clarify if you like. 3 BY MR. KLAYMAN: 4 Q Please. 5 A I would feel certain if the file 6 itself had any notations that said anything 7 like "Filegate" or "FBI" or your name or 8 anything like that, I would have noticed that 9 and brought that in as well. 10 I noticed a very obscure reference, 11 you know, in a three-page document, and made 12 sure to turn that over to counsel. I am not 13 entirely certain it is responsive, but I 14 wanted to be as forthright as I could be. 15 MR. KLAYMAN: I am on record, and I 16 am requesting the production of the file 17 folder this came out of. I would like you to 18 check at the break. 19 BY MR. KLAYMAN: 20 Q Are there files at the White House 21 that list Filegate or file matter? 22 A Not that I know of. 164 1 Q Are there files that read Larry 2 Klayman or Judicial Watch? 3 A No, sir, not that I know of. 4 Q Are is there anyone in charge of 5 keeping files on those issues? 6 A No, sir, not that I know of. 7 Q Who prepared this document, 8 Exhibit 7? 9 A I don't know who. 10 Q How did it come to your possession? 11 A It was faxed to me. 12 Q Who faxed it to you? 13 A I don't know. 14 Q There is a fax notation at the top, 15 "November 26, '97, Wednesday, 11:45," and 16 it's page 2. 17 Does that refresh your recollection 18 as to where this document came from? 19 A No, sir. 20 Q Where is the first page of this 21 document? 22 A I don't know, sir. 165 1 Q Did you pull it off before you 2 provided it to counsel for production? 3 A No, sir. 4 Q Did you check your files to see 5 where page 1 may be? 6 A I checked that file. I didn't see 7 anything -- I didn't notice the pagination, 8 but I was quite proud to find a rather 9 obscure reference, and was -- 10 Q You were proud to find it? 11 A Well, in that it proves how 12 forthright that I am trying to be in 13 cooperation with, again, what I think is not 14 a very fair request for my deposition, 15 because it is based on a joke. 16 Q Are you taking issue with the 17 court's ruling. 18 A No, sir, I am taking issue -- I am 19 pointing out, rather, that the fact that I 20 was able to find this ought to be some 21 evidence that I am trying to be as fully 22 cooperative as I can be. 166 1 Q Are you taking an issue with Judge 2 Lamberth? 3 A No, sir, I am not. 4 Q I am going to request that a search 5 be made for page 1 of this document. 6 Obviously, there is a page 1. 7 Now, looking at the first page of 8 this document, read down to entry number 12. 9 A Yes, sir. 10 Q "Bill Klinger's FBI files 11 investigation" refers to the file matter, 12 right, Filegate? 13 A Yes, sir. 14 Q Now, who did you discuss this 15 document with? 16 A I brought it to counsel's attention 17 as soon as I found it. 18 Q Well, this document was sent to you 19 for a purpose, was it is not? 20 A Yes, sir, I'm sure. 21 Q What was the purpose? 22 A I would think it would be part of 167 1 explaining the cost and distraction of a 2 variety of investigations that are going on 3 into this President. It is an important 4 political point, I think, as well as a 5 governmental one: The cost and time that has 6 been expended in what I believe are partisan 7 enterprises to investigate the President. 8 Q Oh, and among the various 9 investigations is the Filegate investigation? 10 A It is listed on there, yes, sir. 11 Q So you would have discussed the 12 Filegate investigation in the context of this 13 document? 14 A No, sir, I would not have pulled 15 that particular one out, because it does not 16 contain any dollar amount, and wasn't a 17 particularly high-profile investigation. 18 MS. SHAPIRO: I'd also object, 19 because you are assuming something that he 20 did not testify to. He testify that he 21 didn't discuss this with anybody, 22 necessarily. 168 1 MR. KLAYMAN: He didn't testify to 2 that, Ms. Shapiro. Please hold your 3 statements, because they are inappropriate as 4 counsel. You can make objections; I have no 5 problems with that. But don't give him 6 testimony, please. 7 We have been through this before in 8 other Justice Department cases, and it is not 9 something which is appropriate. 10 THE WITNESS: I have no doubt that 11 I made the larger point many times, and will 12 again, that this President has been subjected 13 to a remarkable level of investigation. 14 I believe, and it is my opinion, 15 that a good bit of this is driven by partisan 16 motivation. And I certainly believe that a 17 good bit of this is very expensive, and 18 probably not what taxpayers might want to -- 19 BY MR. KLAYMAN: 20 Q That was not my question. If you 21 want to make speeches, perhaps we can have a 22 special session at the end where you can make 169 1 a speech, Mr. Begala. 2 A I am trying to be as helpful as I 3 can be. 4 Q I have no question pending, and I 5 would like to move along here. 6 A Yes, sir. 7 Q Who did you discuss this document 8 with? 9 A I brought it to counsel's attention 10 as soon as I found it. 11 Q Well, when you got it. I am not 12 talking about producing it here. What was 13 the purpose of the document? 14 A I don't remember specifically using 15 it, but I certainly have made the larger 16 political point that there are an 17 extraordinary number of investigations going 18 on; that they're extraordinarily expensive; 19 and that I believe there is a partisan axed 20 to grind behind some of them. 21 Q You have also made the statement 22 that Kenneth Starr is corrupt, correct? 170 1 A In the sense that Lord Acton meant. 2 Q Did you make take statement to the 3 press in the sense, too, in the sense that 4 Lord Acton meant? 5 A Yes, sir, absolutely I did. I 6 said -- 7 Q How is Kenneth Starr corrupt? 8 MR. ANDERSON: Would you let him 9 finish his answers, please? 10 MR. KLAYMAN: Would you let her 11 object for you, because there is one counsel 12 here. 13 THE WITNESS: Lord Acton made a 14 famous statement that "Absolute power 15 corrupts absolutely." 16 My own belief is that the 17 independent counsel statute conveys an 18 extraordinary amount of power. I said that 19 it may be that, as Lord Acton meant it, 20 "Absolute power corrupts absolutely." 21 BY MR. KLAYMAN: 22 Q Did you give that statement to the 171 1 press? 2 A Yes, sir, I did. 3 Q Or did you just say, "In my 4 opinion, Ken Starr is corrupt"? 5 A No, sir, I never said that. 6 Q So you have been misquoted? 7 A No, sir, I was quoted -- it was a 8 broadcast interview. It was on "Meet the 9 Press." Later, reporters took that word out 10 of context. 11 I believe that absolutes power 12 corrupts absolutely. I believe the 13 independent counsel has too much power. And 14 I think that he is seen by the American 15 people as someone who uses excessive amounts 16 of power. 17 I this that in the Anglo-American 18 tradition, that that is a frightening 19 spectre. 20 Q Are you that you never commented on 21 the Filegate scandal publicly? 22 A I can't remember. I may have as 172 1 part of a larger sense that Republicans 2 running the Congress or Republicans in other 3 places have a partisan motive in their 4 investigations and attacks on the President. 5 Q Who did you discuss this document 6 with at the White House? 7 A Counsel. 8 Q Anybody other than counsel? 9 A No, sir. Not that I can recall. I 10 want to be careful. 11 Q So you might have discussed it with 12 somebody else? 13 A I might have, but I can't recall. 14 I found it; I took it to counsel's office 15 immediately. I don't recall discussing it 16 with anybody else. 17 MR. KLAYMAN: I will show you what 18 I ask the court reporter to mark as 19 Exhibit 8. 20 (Begala Deposition Exhibit 21 No. 8 was marked for 22 identification.) 173 1 BY MR. KLAYMAN: 2 Q Exhibit 8 is a document which was 3 also produced by you today, Mr. Begala, which 4 contains the heading, "Gingrich Keeps his 5 Promise: Speaker 620 Taxpayer Funded 6 Committees on Democrats." 7 This is a document you produced 8 today, correct? 9 A Yes, sir. 10 Q Where was this document found in 11 your files? 12 A In that same file that the previous 13 document was found. 14 Q What else was in that file? 15 A Mostly it was documents about 16 Arlington National Cemetery. 17 Q Larry Lawrence? 18 A There was a larger issue that had 19 been raised in investigation that had gone on 20 that suggested -- Insight Magazine, is my 21 recollection, suggested that the President 22 had sold burial plots at Arlington Cemetery. 174 1 Part of my job on that job, when 2 issue was raised, was to respond to it in the 3 press. I found these documents in the file 4 that contained mostly issues on Arlington 5 Cemetery. 6 Q How thick is that file, roughly 7 speaking? Maybe you can show the video 8 camera. 9 A Not very -- you know. It looks 10 like it was an inch. I am just guessing. 11 But it not a voluminous file. 12 Q Had you asked your assistant to 13 prepare such a pile? 14 A I can't recall. I may have. I 15 can't recall. 16 Q What other kinds of files does she 17 keep for you? 18 A As I went through the budget 19 process, there were perhaps documents on the 20 budget that she might have saved for me. The 21 issues of the day as they arise are what I 22 tend to deal with. 175 1 I myself don't generate very many 2 documents, but when I attend meetings, again, 3 for example on the budget or the State of the 4 Union, there would be documents generated 5 from that that I would just hand over to her 6 when I was done. 7 Q Do you take notes at meetings? 8 A As general matter, no, sir. 9 Q From time to time? 10 A Not very often, no, sir. 11 Q But from time to time? 12 A I am more of a -- like a "to do" 13 list guy. 14 Q Are you saying you never have taken 15 a note? 16 A No, I am saying that. I am more of 17 a "to do" list guy. 18 Q I'm asking you, have you ever taken 19 notes at meetings? 20 A What I mean is, if by "notes" you 21 mean a "to do" list, to remember to call Jim 22 Smith about blah blah, sure. But I don't 176 1 write down what people say in meetings. 2 Q You are saying that you have never 3 done that? 4 A I may have, but it is not my 5 practice as a general rule. 6 Q Do you write down your own 7 thoughts? 8 A As a general rule, I don't. I am 9 more of a "to do" list kind of person. 10 Q I am not asking you as a general 11 rule. I am saying, do you ever write down -- 12 A I would hate to rule out, but I am 13 not a big doodler. I am not a big note 14 taker. I prefer "to do" lists. 15 Q Do you ever write down your 16 thoughts? 17 A I may have. I would hate to rule 18 that out. It is not my general practice. 19 Q So in your entire life, you have 20 never written down any thoughts? 21 MS. SHAPIRO: He answered the 22 question. 177 1 BY MR. KLAYMAN: 2 Q You are not sure in your entire 3 life whether you have ever written down one 4 thought? 5 A What I have said is, generally, I 6 do not take notes at meetings. I generally 7 will write down reminders to do certain 8 things. 9 Q And I asked you a simple question, 10 Mr. Begala. Have you ever taken one note of 11 any of your thoughts in your entire life? 12 A Well, I would hate to rule that 13 out. But I do not sit in meetings and write 14 down what I am thinking or what other people 15 are saying. I often will write down tasks 16 that I want to remind myself to do. 17 Q So then, what you are basically 18 telling me is, you don't remember whether you 19 have ever written down one thought in your 20 entire life? 21 A No, sir, I am not. I am saying, my 22 practice in meetings is to make more of a "to 178 1 do" list, rather than write down my own 2 thoughts or the thoughts of others. 3 Q I am not going to give up on this 4 question until you give me a response, and I 5 don't care if I am here for three weeks. 6 A Yes, sir. That is my best 7 response, is that as a practice, I write down 8 the tasks that I want to remind myself to 9 perform. I generally do not -- I don't want 10 to say I have absolutely never, because, 11 again, I am conscious of the fact that I am 12 under oath, so I would hate to rule something 13 out in the absolute. 14 But my general practice is to write 15 down tasks that I remember that I need to do, 16 if I'm in a meeting. 17 Q And have you ever written down one 18 thought on a piece of paper about a meeting, 19 about someone that you have had to -- 20 A I answered that to my best of my 21 ability. 22 MS. SHAPIRO: Objection again. 179 1 That has been asked and answered. 2 BY MR. KLAYMAN: 3 Q Yes or no? 4 A I answered to the best of my 5 ability. 6 MR. KLAYMAN: Certify it. 7 BY MR. KLAYMAN: 8 Q Do you keep your notes filed in any 9 kind of binder or folder? 10 MS. SHAPIRO: Objection. He has 11 not testified about any notes. 12 MR. KLAYMAN: You can respond. 13 I know, because he has refused to 14 answer the question. I am asking another 15 question. 16 THE WITNESS: I am not a note-taker 17 or note-keeper. 18 BY MR. KLAYMAN: 19 Q But you do keep notes, don't you? 20 A Not generally. I may have, for 21 example, edits on a speech draft. I don't 22 know if my assistant keeps them or not. 180 1 Q Where are they kept? 2 A I give them to my assistant. As a 3 general matter, I think she turns them over 4 to records management things that are no 5 longer topical. 6 I do a good bit of editing on 7 speeches, and I do not know if my assistant 8 saves those edits or if she throws them away. 9 They are not particularly -- 10 Q Do you have a computer in your 11 office? 12 A Yes, sir. 13 Q Do you use a computer? 14 A Uh-huh. 15 Q Do you type correspondence on that 16 computer? 17 A Not often, but occasionally. 18 Q Do you type memoranda to file on 19 that computer? 20 A No, I don't type memoranda to file. 21 I will occasionally write a memo, but not 22 very often. 181 1 Q What kind of computer do you have? 2 A A desktop. I don't know the brand. 3 You know, a desktop PC. 4 Q Do you record document creation on 5 floppy disks? 6 A No, sir. 7 Q It's kept on a hard drive? 8 A I think so. 9 Q It goes into a central White House 10 data system? 11 A I don't know. 12 Q Is there someplace you can store 13 the document in some kind of backup system in 14 the White House? 15 A I don't know enough about how the 16 computer system works. 17 Q You do know how to work your 18 computer, correct? 19 A Sure. 20 Q You know how to store a document, 21 correct? 22 A Yes. 182 1 Q Well, how is it stored? 2 A I hit a save button and it is 3 stored somewhere. I don't use disks. 4 Q Are chron files, chronological 5 files, kept in your office? 6 A I don't know what that is. 7 Q Files of everything that you have 8 written or others have written? 9 A I don't understand. 10 Q Do you keep photocopies of letters, 11 for instance, that you have written? Backup 12 photocopies? 13 A I don't know. Not that I know of. 14 My assistant might. I don't know. 15 Q Have you ever asked her to do that? 16 A I can't -- not that I remember. 17 Q Well, explain to me. If you write 18 a letter on your computer, is that the way 19 you do it? Or do you dictate it to the 20 assistant? 21 A Not very often. 22 Q How do you write a letter? 183 1 A Actually, I write a lot of 2 handwritten notes: "Good to see you today," 3 or "Thanks for supporting us on this issue." 4 Q But you have written a letter on 5 your computer? 6 A I would think so, yes, sir. 7 Q How does that generally work after 8 it is put on your computer and stored? Who 9 types it out? 10 A General correspondence, my 11 assistant does for me. On occasions, I will 12 write out a letter myself on my computer, but 13 not very often. 14 Q Who prints it out? 15 A If I have written it, I do, or if 16 she has written it, she does. 17 Q And if it is typed out by her, does 18 she bring it in for you to sign? 19 A Yes. 20 Q What happens to that letter? How 21 is it transmitted? Say, if it is mailed, who 22 handles the mailing? 184 1 A I don't know. My assistant does. 2 Q She keeps a photocopy for your 3 records of what was sent? 4 A I don't know that. 5 Q You have never discussed that with 6 her? 7 A No, sir. 8 Q Is it your position that you don't 9 want records of anything that you write? 10 A No. I don't generate a lot of 11 letters. I write, as I say, note cards or 12 cards, thanking people for this or that. But 13 again -- 14 Q Is there any kind of directive in 15 the White House not to create paper or 16 recordations? 17 A I don't know. 18 Q Have you ever seen any such 19 directive? 20 A I can't recall one, no, sir. 21 Q Do you have a shredder in your 22 office? 185 1 A No, sir, I don't. 2 Q Have you ever shredded documents at 3 the White House? 4 A No, sir, I have not. 5 Q Have you ever asked anyone to shred 6 documents? 7 A No, sir, I have not. To the best 8 of my recollection. I want to be careful on 9 that, because I'm under oath. 10 Q Are your handwritten notes 11 photocopied? 12 A My handwritten notes to people? 13 Q When you thank people? 14 A I don't know. They may be. 15 Q Turning to Exhibit 8, who prepared 16 this document? 17 A I don't know. 18 Q How did it come into your 19 possession? 20 A I think it was faxed to me, but I 21 don't know. I don't see fax marks on it. I 22 don't know. It might have been mailed. I 186 1 don't know how it came to me. 2 Q What was this document intended to 3 do? 4 A I would have used this -- I don't 5 have specific recollection, but I would tell 6 you how I would use a document like this: In 7 talking to members of the press or maybe 8 talking to the Democratic loyalists, to be 9 able to make a point, which I find 10 extraordinary, that before he came to power 11 as Speaker, Speaker Gingrich said he was 12 going to assign 20 subcommittees or task 13 forces to investigate the White House. Sure 14 enough, he has. 15 I think that makes a powerful point 16 about the partisan motives of some of these 17 accusations. 18 Q Turn to the last page. It says, 19 "Authorized and paid for by the Democratic 20 National Committee"? 21 A Yes, sir. 22 Q Does that refresh your recollection 187 1 of where you got this document? 2 A It would suggest that it comes from 3 the Democratic National Committee. 4 Q Who sent it to you? 5 A I don't have a recollection of 6 actually receiving this document. But this 7 is the sort of thing I would have used, for 8 example, in defending the President against 9 these attacks on Arlington Cemetery, by 10 saying this is part of a larger pattern of 11 the Republican trying to investigate the 12 President for their partisan ends. 13 Q So your job basically is to spin 14 these investigations? 15 A No -- 16 Q To be able to deflect criticism 17 from all of the Clinton scandals by saying 18 the Republicans and others are spending a lot 19 of money to smear the President? 20 That's your approach, isn't it? 21 A It is not my principal job, but it 22 is one argument that I use. I believe it to 188 1 be true. 2 Q I didn't ask you whether you 3 believed it to be true. I asked you whether 4 that is part of your job? 5 A I do that willingly. I believe 6 that part of the motive of a number of these 7 attacks is deeply partisan. 8 Q But some of the attacks are 9 warranted, are they is not? 10 A I guess anybody is certainly 11 justified in criticizing their President. It 12 is an American tradition. 13 Q Well, investigation as to whether 14 files came from the FBI for improper use, 15 that is warranted, isn't it? 16 A I would think so, yes, sir. Again, 17 I want to say for the record, I don't mean to 18 belabor it, but I have no knowledge of the 19 use or misuse of FBI files. It is a very 20 important thing for you to know. 21 I am trying to be cooperative as 22 you go afield from that. But I don't want 189 1 the lose sight of the central point that I 2 have absolutely no knowledge or recollection 3 of any use or misuse of FBI files at the 4 White House. 5 Q That is a very serious matter, is 6 it not, whether files were used or misused? 7 A Yes, sir, and I say that with all 8 due gravity. 9 Q And you can't say categorically 10 that FBI files were not misused? 11 A I can only say what I know, and I 12 have no knowledge of that. I can't speak to 13 things I don't know. 14 Q But given your lack of knowledge, 15 you can't vouch that, in fact, those FBI 16 files were used illegally? 17 A I can only speak to what I know. 18 That's correct. 19 Q Now, look to number 3, where it 20 says -- 21 A On this item, "Gingrich Keeps His 22 Promise"? 190 1 Q On Exhibit No. 8, it says, item 2 number 3, "McCain, Arizona," the last 3 sentence: "The House Commerce Committee may 4 look into the same allegations, and a private 5 group, Judicial Watch, has filed lawsuits to 6 investigate the Commerce Department." 7 Have you ever commented to the 8 media about Judicial Watch, other than what 9 you testified this morning? 10 A I may have. I don't have any 11 recollection. I didn't notice that until 12 just now. I am a little disappointed that 13 the Democrats didn't characterize you in a 14 more negative fashion, not personally, but as 15 a partisan group, because you are private, 16 but I also think you are partisan. 17 Q I fully suspect you will correct 18 that error. 19 A I might do that. Again, not in a 20 personal sense, but I do think you are 21 partisan. I am too. I am proud of my 22 partisanship. I suspect you are too. 191 1 Q We are not partisan. We are not. 2 But again, I am not testifying. 3 A I know, not yet. 4 Q In terms of FBI files, have you 5 ever seen an FBI file? 6 A Not to my knowledge, no, sir. 7 Q Did you undergo a background 8 investigation by the FBI before you began to 9 work during the Clinton administration as a 10 consultant? 11 A As I was working for -- after Bill 12 Clinton became President and while I was a 13 consultant to the party, yes, sir. 14 Q Do you know who the FBI interviewed 15 in conducting that investigation? Any of 16 your friends or acquaintances or anyone? 17 A Give me just a minute. 18 MS. SHAPIRO: Give us one moment, 19 please. 20 THE WITNESS: Excuse me. 21 (Witness conferred with 22 counsel) 192 1 MS. SHAPIRO: You had a question 2 pending, Mr. Klayman, and I wanted just to 3 make the general statement that because this 4 deposition is not under seal, that if the 5 direction you are going is to ask him about 6 his own background investigation, that I am 7 sure -- 8 MR. KLAYMAN: I am not asking about 9 if information was provided. I was asking 10 who was interviewed by the FBI concerning 11 you, Mr. Begala. 12 MS. SHAPIRO: I understand what the 13 question was. I am just saying generally 14 that the subject of his own background 15 investigation is not something that should be 16 explored in a public deposition, as I am sure 17 you are sensitive. 18 BY MR. KLAYMAN: 19 Q Based on your knowledge. I not 20 asking the FBI; I am not asking for 21 government information. 22 Based on your knowledge, who did 193 1 the FBI talk to about you? 2 A I don't know who they talked to. I 3 gave them names of the people with whom I 4 worked, and I don't know who they did or did 5 not contact. I never followed up. 6 Q Did anyone ever contact you and 7 say, "I just have been talked to by an FBI 8 agent about you, Mr. Begala"? 9 A Yes, sir. 10 Q Who? 11 A A guy who runs a magazine that I 12 did some writing for. 13 Q Who is that? 14 A John Kennedy. 15 Q George Magazine? 16 A Yes, sir. 17 Q Anybody else? 18 A He called me. It was a brief 19 conversation. He said, "Hey, the FBI came 20 by. It was sort of a noteworthy thing." 21 Q Was it to do a background 22 investigation, or did they come by on another 194 1 matter as related to you by John Kennedy Jr.? 2 A He didn't say, as I recall. I 3 presumed that it was because I had listed his 4 name as one of several people who employed 5 me. 6 Q Is that recently, since you 7 rejoined the White House? 8 A Yes, sir. 9 Q Did he tell you what they asked 10 him? 11 A No, sir. 12 Q Did you ask him what they asked 13 him? 14 A No, sir. 15 Q You weren't interested? 16 A No. I think I did pretty good work 17 for the magazine, but I didn't ask him what 18 they had gotten into. 19 Q You were not curious? 20 A No. 21 Q Have you ever seen your own FBI 22 file? 195 1 A No, sir. 2 Q Have you ever asked to see it? 3 A No, sir. 4 Q Have you ever heard of Ellen 5 Rometsch, R-o-m-e-t-s-c-h? 6 A Not recently. 7 Q When did you hear about that? 8 A When George Stephanopoulos made a 9 comment about her on TV. 10 Q Were you watching that day? 11 A Yes, I was, I think I was. If I 12 wasn't watching, I was made aware of it 13 shortly thereafter. I think I was watching. 14 MR. KLAYMAN: I show you what I 15 will ask the court reporter to mark as 16 Exhibit No. 9. 17 (Begala Deposition Exhibit 18 No. 9 was marked for 19 identification.) 20 BY MR. KLAYMAN: 21 Q I show you Exhibit 9. This is a 22 transcript of Mr. Stephanopoulos' appearance 196 1 on "This Week with Cokie and Sam" on ABC, 2 February 8, 1998. 3 MS. SHAPIRO: What number exhibit 4 is this? 5 MR. KLAYMAN: Number 9. 6 (Discussion off the record) 7 BY MR. KLAYMAN: 8 Q Turn to page 2 of this transcript, 9 reading from George Stephanopoulos, about 10 half way down. Excuse me, starting with Sam 11 Donaldson: "We know what the White House 12 tactics are. I mean, they have been almost 13 open about it. Attack the press, and perhaps 14 with good reason, attack the independent 15 counsel, perhaps for some good reason, and 16 stonewall on the central issue, which is the 17 President of the United States. And if he 18 has nothing to hide, why is he hiding?" 19 George Stephanopoulos: "I agree 20 with that. And there is a different 21 long-term strategy which I think would be far 22 more explosive. White House allies are 197 1 already starting to whisper about what I will 2 call the Ellen Rometsch strategy." 3 Sam Donaldson: "I remember her." 4 George Stephanopoulos: "You 5 remember her?" 6 Sam Donaldson: "Yes." 7 George Stephanopoulos: "She was a 8 girlfriend of John F. Kennedy who also 9 happened to be an East German spy, and Robert 10 Kennedy was charged with getting her out of 11 the country and also getting J. Edgar Hoover 12 to go to the Congress and say, 'Don't you 13 investigate this, because you if you do, we 14 are going to open up everybody's closets.' 15 And I think that in the long run, they have a 16 deterrent strategy on getting a lot of..." 17 George Will: "Monica Lewinsky is a 18 East German spy?" 19 Sam Donaldson: "No, but that is a 20 good point. Are you suggesting for a moment 21 that what they are beginning to say is that 22 if you investigate this too much, we will put 198 1 all of your dirty linen right on the table? 2 Every member of the Senate, every member of 3 the press corps." 4 George Stephanopoulos: 5 "Absolutely. The President said he would 6 never resign, and I think some around him are 7 willing to take everybody down with him." 8 Sam Donaldson: "Well, may I just 9 say, let the games begin." 10 George Will: "It is called 11 mutually assured destruction in strategic 12 language." 13 Cokie Roberts: "Or MAD, M-A-D." 14 You heard Mr. Stephanopoulos make 15 those comments? 16 A Yes, sir. 17 Q Had you ever discussed Ellen 18 Rometsch with George Stephanopoulos before he 19 made that appearance? 20 A No, sir. 21 Q Have you ever discussed with George 22 Stephanopoulos J. Edgar Hoover and his 199 1 obtaining FBI files about Kennedy and members 2 of Congress? 3 A No, sir. I called him after that 4 appearance, however, and talked to him about 5 that comment. 6 Q You called him immediately after 7 that? 8 A No, it would have been the next day 9 or during the next week. 10 Q Where did you call him from? Your 11 office in the White House? 12 A Yes, sir. 13 Q How long was the conversation? 14 A Brief, but -- I don't know, but 15 George doesn't stay on the phone a long time. 16 Q And what did you say to George? 17 A I was outraged. I was very angry, 18 because I was getting calls from reporters 19 suggesting this, saying, "You guys are trying 20 to do this." 21 Q Do what, to use FBI files? 22 A They didn't say "FBI files." The 200 1 reporter said, "You guys are" -- "George says 2 you guys are interested in trying to smear 3 your opponents." 4 I called George. It was after that 5 TV show during that next week. I can't 6 remember the day. But I remember the 7 conversation with some clarity, because I was 8 quite angry about it. 9 I said, "George, you know, this is 10 not true." First off, everybody in the press 11 corps know that George and I are friends, so 12 I was the likely person to get these calls. 13 And so I was particularly incensed that 14 people would think that I would do something 15 like that. 16 And George said, "Get the 17 transcript. It says 'White House allies.'" 18 And I said, "Well, that is not what 19 I heard. That is not what people heard. 20 People heard you say 'White House.'" 21 And he said, "Get the transcript. 22 'White House allies.'"
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