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.









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         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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