201 1 I remember this very clearly, 2 because I was talking on the phone with a 3 reporter when George had called me back. And 4 I hung up on the reporter to talk to George, 5 then got this from him, and called back the 6 reporter and said, "I just talked to George, 7 and he says he was not talking about the 8 White House. He was not talking about us. 9 He was talking about White House allies." 10 The reporter had had the same 11 inaccurate but perfectly understandable 12 interpretation that I had had. So I was glad 13 that I had called George. I was quite 14 serious and angry about it. So would I 15 remember this conversation. 16 Q And what reporter did you talk 17 with? 18 A My recollection is that it was John 19 Harris of the Washington Post. 20 Q What did Mr. Harris ask you 21 specifically? 22 A He asked me about that. I think he 202 1 was doing a story more about George, but this 2 mattered to me. 3 As I have said throughout this day, 4 I draw a bright-line distinction between 5 public policy issues and private lives. This 6 is clearly on -- let me finish -- the wrong 7 side of that. 8 And I will say again, I have no 9 knowledge of any use or misuse of FBI files, 10 nor would -- I can't even say that I have 11 ever encouraged it. I have no knowledge of 12 that whatsoever. 13 Q Before George Stephanopoulos made 14 this statement on ABC, you did know who Ellen 15 Rometsch was, did you not? 16 A No, sir. I remember him saying 17 that or hearing about it the first time, and 18 thinking, "Who is that?" 19 Q You were aware, generally, that 20 there was, historically speaking, a situation 21 where J. Edgar Hoover was using FBI files 22 against congressmen and against President 203 1 Kennedy with regard to alleged affairs. You 2 knew about that? 3 A Yes. I know from history that 4 Hoover spied on Dr. King, Martin Luther King 5 Jr. I had never heard of this -- I can't 6 ever remember hearing about this particular 7 story before. 8 I must say that the part of it that 9 I seized on was the larger point, suggesting 10 the smear campaign. And I was relieved at 11 least that George said, "I didn't mean the 12 White House; I meant White House allies," and 13 he said, "I was very careful to say 14 'allies.'" 15 Q But you now know that the Ellen 16 Rometsch story involves the use of FBI files. 17 You now know that? 18 A I just know what George said on TV, 19 I have not studied up on it since then. 20 Q Have you reviewed a brief that 21 Judicial Watch filed opposing your counsel's 22 efforts to block this deposition? 204 1 A Not carefully. 2 Q Did they give you a copy of it? 3 A They may have. I don't -- 4 Q There was an attachment to that 5 brief which has an excerpt from a book 6 dealing with Ellen Rometsch and FBI files? 7 A I don't know. 8 MS. SHAPIRO: Can I just object? 9 If you are going to question him on an 10 exhibit or document, why don't you show it to 11 him first? 12 MR. KLAYMAN: I will. I am 13 entitled to ask questions the way I want to 14 ask them. And you are entitled to ask 15 cross-examination questions at the end, if 16 you don't think I covered things that you 17 want covered, you can ask questions. 18 MS. SHAPIRO: And I am entitled to 19 object. 20 MR. KLAYMAN: Sure, but not on that 21 basis, because that is not a valid objection. 22 BY MR. KLAYMAN: 205 1 Q Did you study history in high 2 school, Mr. Begala? 3 A Yes. 4 Q You studied the period of the 5 Kennedy administration? 6 A I can't remember what we studied. 7 I took history. 8 Q You took American history? 9 A Yes. 10 Q Did you study history in the 11 university? 12 A Sure. 13 Q What courses did you take? 14 A I took history courses. I can't 15 remember the particulars. I took a terrific 16 course about the First World War. 17 Q American history? 18 A No, that was European history, the 19 First World War. 20 Q Because Ellen Rometsch was from 21 East Germany. 22 A I think she post-dated the First 206 1 World War. 2 Q Was there a course on the role of 3 mistresses in bringing down world leaders or 4 anything like that? 5 A No. I did take some history. I 6 majored in government. If I had to do it 7 over again, I would have taken more history 8 and less government. 9 Q Did you take American history in 10 college? 11 A I think so. Yeah, sure. 12 Q You are an avid reader, are you 13 not? 14 A As much as I can. 15 Q You do enjoy reading history, 16 correct? 17 A Biography and stuff. 18 Q Well, here is kind of a nice book, 19 "The Dark Side of Camelot," by Seymour Hersh? 20 A I have not read that one. 21 Q Have you ever seen this book? 22 A Uh-huh, yes, sir. 207 1 Q You have seen it in the White 2 House, haven't you? 3 A Not that I know of. 4 Q Where have you seen it? 5 A Bookstores. 6 Q Have you ever read part of it? You 7 ever opened it up and read the introduction? 8 A No, sir. I saw a coverage of it in 9 newsmagazines. Coverage was critical. I am 10 not interested in those kinds of stories, 11 frankly. They -- 12 Q Only if they are about Republicans? 13 A No, honestly, I am nauseated by the 14 whole thing. That is not what I got in 15 politics to do. 16 Q But you did, of course, read the 17 news reports, the excerpts of this? 18 A I read news reports about it that 19 were highly critical. I am an admirer of 20 President Kennedy. 21 Q In Time Magazine? 22 A I can't remember. The popular 208 1 press. I take Time Magazine, so it might 2 have been Time. 3 Q And Newsweek? 4 A It might have been. I take that 5 magazine. U.S. News. I don't remember 6 specifically. 7 Q And, of course, when you read those 8 reports, you did read about Ellen Rometsch, 9 did you not? 10 A Not that I recall. As I said, 11 I'm -- no, I want, because, again, this 12 matters. We don't know each other. 13 I am trying to impress upon you 14 that I am nauseated at those kinds of smears 15 and slurs. 16 Q Which is why you are disappointed 17 that the Democratic National Committee didn't 18 refer more negatively to Larry Klayman? 19 MS. SHAPIRO: Objection. 20 THE WITNESS: I said, as a 21 partisan. I do think they should refer to 22 you as an ideologue or someone with a 209 1 particular issue agenda. No, I am not trying 2 to get you in trouble with your tax status, 3 but whatever it is. You certainly believe in 4 something other than -- 5 BY MR. KLAYMAN: 6 Q Well, you may want to consult with 7 them. I believe they have already 8 accommodated you. 9 A No, I'm not interested in building 10 anti- -- I say again, I don't have anything 11 any personal beef with you. I do think that 12 this is kind of a waste of time, given that 13 all I did was tell a joke. And I say again, 14 I have no knowledge of any use of any FBI 15 files or any misuse. 16 Q I bet you will not tell that joke 17 again. 18 A I may have to tell it on President 19 Bush now, go back to that. 20 Q What, that you reviewed his FBI 21 file? 22 A No, no, no. The original joke, 210 1 which was written for me, was that I met 2 George Bush, the President Bush, and he 3 remarked to me that he had seen me on TV, but 4 now seeing me in person, I was better looking 5 than in the picture in my passport file. 6 Maybe I have to go back to that 7 iteration. 8 MR. KLAYMAN: I will show you what 9 I ask the court reporter to mark as 10 Exhibit 10. 11 (Begala Deposition Exhibit 12 No. 10 was marked for 13 identification.) 14 BY MR. KLAYMAN: 15 Q I'm showing you Exhibit 10. This 16 is the excerpt from "The Dark Side of 17 Camelot" which was attached to our 18 opposition, Judicial Watch's opposition to 19 your counsel's motions for protective order 20 to attempt to block your deposition. 21 Have you seen this before? 22 A Not to my knowledge. 211 1 Q Take an opportunity and just read 2 the two pages that are attached to the cover. 3 MS. SHAPIRO: Let me just restate 4 our objection that this has nothing to do 5 with the matters at hand. You have got the 6 FBI files, and we are now taking testimony 7 about reading habits and popular literature. 8 MR. KLAYMAN: No, it has a lot to 9 do with it, because this refers to FBI files. 10 Why don't you read it too, Ms. Shapiro? 11 BY MR. KLAYMAN: 12 Q Are you ready? 13 A No, sir. 14 Q Looking at the bottom of the page. 15 A The page marked 405? 16 Q 405. Let me just read that into 17 the records so we have a frame of reference: 18 "The final lie about Rometsch and the Senate 19 fell to Bobby Kennedy in his 1964 interview 20 with the Kennedy Library. 'Clark Molenhoff 21 wrote an article that she had been tied up 22 with people in the White House with which 212 1 was, in fact, incorrect,' Kennedy said. 'I 2 looked into the files,' he added, with 3 obvious indignation, and 'she had been tied 4 up with a lot of people at the Capitol. I 5 got all of the information she had and it got 6 to large numbers on both ways, Democrats and 7 Republicans.' His concern, Bobby Kennedy 8 added, was for the reputation of the United 9 States. 'I thought it was very damaging, and 10 I spoke to the President about it. It didn't 11 involve anybody at the White House, but I 12 thought it would just destroy the confidence 13 that the people in the United States had in 14 their government. Some of the senators had 15 Negro girlfriends and all kinds of things 16 which were not very helpful.' 17 "Those concerns, Bobby Kennedy 18 said, led him to urge a meeting between 19 Hoover and the two Senate leaders, Mansfield 20 and Dirksen, 'to explain what was in the 21 files and what information the FBI had. I 22 guess it was a shock to both of them. From 213 1 then on,' Kennedy added, 'there was less 2 attention in the Senate on that aspect of the 3 situation.'" 4 Does that refresh your recollection 5 as to whether you knew, before you talked to 6 George Stephanopoulos after he made that 7 statement on ABC news on February 8, that the 8 Ellen Rometsch story involved FBI files? 9 A In fact, it does. It strikes me 10 that I have never heard this story before. 11 Q What part of the story have you not 12 heard? 13 A Any of this. I heard George say 14 this on TV and then others say, "Oh, yeah, 15 she was this spy." I never heard of any of 16 this, and I am struck by this story as a 17 first impression. 18 Q Now, when you talked to George 19 after the interview with ABC, the following 20 day -- 21 A No, it was during that week. I'm 22 not certain that it was on that Monday, but 214 1 it was during that week. 2 Q Did you talk to him more than once? 3 A No. I talked to him with some 4 frequency, but I can't remember what day of 5 the week that was. It was subsequent to the 6 interview, I made a point of talking to him 7 about that comment, because I was angry about 8 it. 9 Q That was the first time you talked 10 to George Stephanopoulos since you rejoined 11 the White House? 12 A Correct. 13 Q In fact, you talked to him at least 14 once a week before that? 15 A Yes, I would say. 16 Q How many times did you generally 17 talk to him per week? 18 A With some frequency. I try to talk 19 to him once a week. He goes on TV every 20 Sunday. 21 Q Why do you talk to him? 22 A He is my friend, first. He is also 215 1 an influential pundit. 2 Q And you want to feed him 3 information that he can use on ABC, correct? 4 A I have actually had no success. I 5 am not trying to be flip. I've had no 6 success in persuading George to be a more 7 aggressive Clinton defender, frankly. 8 So no, I don't feed him information 9 at all. I instead try to implore him and 10 encourage him to defend the President. I 11 have had precious little success. 12 Q You want him to be informed so that 13 he can make an informed commentary on ABC, 14 correct? 15 A Again, what I give George is -- 16 sometimes we talk just about our friendship. 17 Sometimes I do talk to him about nothing that 18 is new. I say, "This is why this won't hurt 19 us," or -- it is my analysis of the 20 situation. And I try to urge him to adopt 21 some of that analysis, and, I must say, with 22 a startling record of failure thus far. 216 1 Q George talks to others in the White 2 House in order to be able to do his 3 commentary on ABC, does he not? 4 A I don't know that. People in the 5 White House are mad at George, candidly. 6 They're angry with him. So I don't know -- 7 Q But he has talked to others, has he 8 not? 9 A You've got to ask George, again. 10 Q And you are aware, from whatever 11 source, that he has talked to Sidney 12 Blumenthal, are you not? 13 A I am not aware of that. I'm not. 14 I talk to George myself with some regularity. 15 He is a close friend. I am determined 16 somehow to survive this current 17 unpleasantness with our friendship intact. 18 And that is one of the reasons I talk to him 19 with some frequency. 20 Q So you are the point person in the 21 House for dealing with George? 22 A I don't -- I would not want that 217 1 mantle. 2 Q But you are? 3 A It's not that formal. I don't know 4 who else he talks to there. 5 Q No one has ever come in to you and 6 said, "I just talked to George, and we had a 7 conversation"? 8 A Not that I can recall. Not that I 9 can recall. I mean, that may have happened, 10 certainly. But it is not like people report 11 to me on their conversation. 12 Q Who did that happen with? 13 A No, I'm saying, I can't rule that 14 out. But people don't come to me and report 15 to me about their conversations with George. 16 Q After George made that statement on 17 ABC News, did you ever talk about that 18 statement with the President? 19 MS. SHAPIRO: I am sorry. This is 20 not -- 21 MR. KLAYMAN: Did you ever talk 22 that statement with the President? 218 1 MS. SHAPIRO: I am instructing him 2 not to answer that question, because he will 3 not testify as to conversations between 4 himself and the President. 5 MR. KLAYMAN: I am allowed to 6 identify the subject matter. I am not asking 7 the substance. 8 MS. SHAPIRO: That is exactly what 9 you are asking. 10 BY MR. KLAYMAN: 11 Q Did you ever talk about that 12 statement with the President? 13 MS. SHAPIRO: That question you can 14 answer. 15 THE WITNESS: Not to my knowledge, 16 no, sir. 17 BY MR. KLAYMAN: 18 Q That means you cannot remember? 19 A I cannot remember ever talking to 20 the President about that, that statement. 21 Q Did you ever talk to Hillary 22 Clinton about that statement? 219 1 A No, sir, I would not have. 2 Q Did you ever talk to anybody else 3 in the White House about George's statement? 4 A I am sure I did. 5 Q Who? 6 THE WITNESS: Am I free to say? 7 BY MR. KLAYMAN: 8 Q Yeah. 9 A I can't remember in particular, but 10 I am sure the rest of the communications 11 team, because it was a very important point 12 to let the press know that George was not 13 saying that we were trying to advance this 14 sort of strategy; that George had 15 purposefully said -- and he said "I wanted to 16 be careful about that, and I said 'White 17 House allies.'" 18 So I would hope -- I can't tell you 19 a particular person. I would hope that I 20 would have gone to the other people in the 21 White House who deal with the press and armed 22 them with that same information and defense 220 1 that George had given me. 2 Q Who is in the communications 3 department that you spoke with about this? 4 A I can't remember the specific 5 conversation. I would hope, I would consider 6 that part of my duty, to tell my colleagues. 7 Q Who? In the ordinary course, who 8 would you have spoken with? 9 THE WITNESS: Is that all right for 10 me to say? 11 In the ordinary course, it would 12 have been Ann Lewis, the communications 13 director; and Mike McCurry, the press 14 secretary; Rahm Emanuel, the senior advisor; 15 perhaps Mr. Blumenthal; maybe others on the 16 press and communication staffs. 17 Those are the people who, like me, 18 receive inquiries from the press. There is 19 probably a lot more that do, but in a normal 20 course, you asked me, and again, I would have 21 hoped -- I would have considered that part of 22 my responsibilities. 221 1 Q Now, during the conversation with 2 Mr. Stephanopoulos, you asked him who were 3 those White House allies, did you not? 4 A No, sir, I did not. 5 Q You had no curiosity? 6 A No, I didn't. I was eager to get 7 back on the Washington Post and tell them 8 that George cleared us, and to urge the Post 9 to look at that transcript as well. 10 Q So you have never asked George 11 Stephanopoulos what he meant by White "House 12 allies"? 13 A That's correct, to the best of my 14 recollection and memory. 15 Q So you might have asked him that? 16 A I don't recall asking him that. I 17 remember the conversation with greater 18 clarity than most, because I was under the 19 gun to talk to a reporter. At that -- while 20 I was on the phone with the reporter, George 21 had returned my call. 22 So I remember that with some 222 1 clarity. And I remember the sense of urgency 2 to get back to this reporter, who I think was 3 Harris from the Post, but I'm not really 4 certain. 5 Q Based on your formidable 6 experience, wouldn't it be better to get back 7 with names of people who George did talk to, 8 rather than just issue a blanket denial when 9 you got back to the press? 10 A No, sir. 11 Q Who are the White House's allies? 12 A I don't know who. You have to ask 13 George what he meant by that. But I was 14 eager to get back on the phone with the 15 press, because even in making this -- what I 16 thought was an unhelpful charge, George made 17 a point, he said, of saying "allies" and not 18 "the White House." 19 And that was what I wanted to get 20 back to the press. 21 Q Do you have an immediate supervisor 22 at the White House? Who is your superior? 223 1 A Chief of staff. 2 Q Who is that? 3 A Mr. Bowles. 4 Q Did you discuss George's comment 5 with Mr. Bowles? 6 A Not that I can recall, no, sir. 7 Q Yes or no? 8 A Not that I can recall. I would 9 have -- in the normal course of things -- I 10 don't remember a specific conversation. But 11 in the normal course of things, I would have 12 talked to the people who deal with the press. 13 Mr. Bowles does not deal with the press as a 14 routine matter. I mean, he may have given an 15 interview in his life, but he doesn't deal 16 with the press. 17 Q Did anyone ever talk to Mr. 18 Stephanopoulos about what he meant with the 19 reference "White House allies"? 20 A I know I -- I don't remember 21 following up on that point. 22 Q Do you know of anyone else who did? 224 1 A Not that I know of, I don't. 2 Q Did you ask anyone else to follow 3 up on it? 4 A I did not. 5 Q Did Mr. Bowles? 6 A I don't know that he even was aware 7 of it. 8 Q Was any request made of the White 9 House counsel's office to figure out what was 10 meant by "White House allies"? 11 A Not that I know of. 12 Q Did any order go out to investigate 13 what George meant by White House allies? 14 A No, I don't. 15 Q Did you ask Palladino to figure 16 that out? 17 A I never talked to him. 18 Q Or Lenzner? 19 A I never talked either of those men, 20 I've told you several times. 21 MS. SHAPIRO: Excuse me. Can you 22 please give him time to respond before you 225 1 ask your next question? 2 THE WITNESS: To the best of my 3 knowledge and recollection, I never talked to 4 these people. 5 BY MR. KLAYMAN: 6 Q Do you know whether anyone has been 7 asked to look into this? 8 A No, I don't know that. 9 Q So you are content to allow there 10 to be a bunch of White House allies out there 11 that are spreading what you claim are 12 falsehoods? 13 A I don't know that there are at all. 14 I was just very relieved that George cleared 15 our reputation as a White House. 16 Q Have you ever known George 17 Stephanopoulos to lie? 18 A No. I'm trying to think. No. 19 Q Is he someone that fantasizes 20 frequently? 21 MS. SHAPIRO: About? 22 BY MR. KLAYMAN: 226 1 Q About facts, based on your 2 experience in knowing him? 3 MS. SHAPIRO: I object to the -- 4 THE WITNESS: I am not certain -- 5 BY MR. KLAYMAN: 6 Q Does he make things up? 7 A No, sir. 8 Q Is he an honest and honorable 9 person? 10 A Yes, sir. 11 Q Is he someone you can trust? 12 A Yes. 13 Q So if he said that White House 14 allies were discussing an Ellen Rometsch 15 strategy, based on your experience, you would 16 believe George, wouldn't you? 17 A I was just so angry about the 18 comment that I was so very eager, then, to 19 get back to the press when George said, "I 20 did not mean the White House, and I took care 21 to say that." 22 Q My question was, if George -- 227 1 A When he pointed me to that word 2 "allies," I got the transcript, and he was 3 right. 4 Q Let me read the phrase again. "I 5 agree with that, and there is a different 6 long-term strategy which I think would be far 7 more explosive. White House allies are 8 already starting to whisper about what I will 9 call the Ellen Rometsch strategy." 10 A Right. 11 Q Now, do you have any reason to 12 doubt Mr. Stephanopoulos in terms of his 13 truthfulness in making that statement? 14 A No, sir. I would say that, as you 15 raise this point, I was struck in the 16 newspaper in the last day or two to see Bill 17 Bennett, the former Secretary of Education, 18 making a similar sort of point. 19 I actually disagree with that. In 20 fact, in a speech that you have a copy of, I 21 go out of my way to say that I don't think 22 this politics of personal destruction is the 228 1 way of the future, the way a lot of 2 pessimists do. Apparently, Bill Bennett 3 does, according to the paper. 4 But my own view is that the 5 Republicans are going to reinvent themselves 6 about issues and ideas. 7 Q I didn't ask that question. 8 A No, but you asked about White House 9 allies, and Mr. Bennett -- Secretary Bennet 10 is not -- I am trying to be as forthcoming as 11 I can. 12 Q No, you're not. No, you're not. 13 A Yes, I am, Mr. Klayman. 14 Q I asked a particular question. I 15 just asked for a simple response. 16 Do you have any reason to doubt the 17 truthfulness and veracity of the statement I 18 just read to you by George Stephanopoulos? 19 A I was just so relieved -- no, in 20 short. And, yes, I was very relieved when he 21 pointed out, truthfully, which was surprising 22 to me, that it said "allies." And when it 229 1 did, I relayed that to the press, because it 2 clears our reputation. 3 And, frankly, in this world we live 4 in, that was much as I wanted or needed or 5 hoped for, because I can not control what 6 Bill Bennett or anybody else says. 7 Q So based upon your experience with 8 George Stephanopoulos, who you know to be an 9 honest man, you now believe that White House 10 allies are starting to whisper about what has 11 been called an Ellen Rometsch strategy? 12 MS. SHAPIRO: I object to 13 mischaracterizing your testimony. 14 BY MR. KLAYMAN: 15 Q You believe that, don't you? 16 A No, I think that is a 17 mischaracterization of my testimony. I 18 believe that the White House is not doing any 19 such thing, and I was relieved when George 20 said so. 21 And I will stress again that I have 22 no knowledge whatsoever of the use or misuse 230 1 of FBI files, which was the reason that I was 2 called here in the first place. 3 Q But you believe that if George made 4 that statement that the White House allies 5 were discussing -- 6 A I feel like I have answered that. 7 Q -- an Ellen Rometsch strategy, you 8 believe that, based on what George told you? 9 A I don't know of any who have. But 10 I know that Secretary Bennett was quoted in 11 the newspaper, which is sometimes unreliable. 12 I was struck by Secretary Bennett opining 13 in -- 14 Q Secretary Bennett? 15 A Bill Bennett, the Secretary of 16 Education under President Reagan. 17 Q Is he a White House ally? 18 A No, I don't think so. That is why 19 I was struck by -- I don't think he was doing 20 it in any sense of allegiance to the White 21 House. 22 Q Let me ask the question simply, Mr. 231 1 Begala. 2 A Well, let me finish answering. 3 Q It is nonresponsive. I don't see 4 the point. 5 A No, it's not. You are asking what 6 people are saying about people's private 7 lives. 8 Q I didn't ask about Bill Bennett. 9 He is not a White House ally. 10 Do you believe, based upon what Mr. 11 Stephanopoulos said, given your experience 12 with him, and your stated testimony that he 13 is honest, that White House allies are 14 talking about an Ellen Rometsch strategy? 15 MS. SHAPIRO: Object, because this 16 question has been asked and answered numerous 17 times. 18 MR. KLAYMAN: It has not been 19 answered. Please answer it. 20 MS. SHAPIRO: I believe he has 21 given you an answer. 22 BY MR. KLAYMAN: 232 1 Q Please answer? 2 A I have answered it to the best of 3 my ability. 4 Q So you believe that that is 5 occurring, based upon your experience with 6 George Stephanopoulos? 7 A I have answered that question to 8 the best of my ability. I know of no use or 9 misuse of FBI files by anyone. And I say 10 that knowing that I am under oath. 11 Q But you are not doubting Mr. 12 Stephanopoulos? 13 A I am saying I know of no use or 14 misuse of FBI files. 15 Q Are you doubting what Mr. 16 Stephanopoulos said? 17 A I'm answering -- 18 Q Answer the question. 19 MS. SHAPIRO: He answered the 20 question. 21 BY MR. KLAYMAN: 22 Q Answer the question. Are you 233 1 doubting what Mr. Stephanopoulos said? 2 A I am answering to the best of my 3 ability. 4 Q Yes or no, are you doubting what 5 Mr. Stephanopoulos said? 6 MS. SHAPIRO: I object that you are 7 harassing the witness. You have asked him 8 multiple times this same question. 9 MR. KLAYMAN: I am not harassing 10 him. My demeanor is quite clear on the 11 record. 12 MS. SHAPIRO: And I don't 13 appreciate you talking over me when I am 14 trying to object. 15 MR. KLAYMAN: Well, just make your 16 objection. Just object. 17 MS. SHAPIRO: How can I when you 18 are speaking over me? 19 MR. KLAYMAN: Because you are going 20 over and over. 21 MS. SHAPIRO: I am identifying my 22 objection. 234 1 BY MR. KLAYMAN: 2 Q Let me ask the question again, Mr. 3 Begala. 4 MS. SHAPIRO: Asked and answered, 5 again. 6 BY MR. KLAYMAN: 7 Q Do you have any reason to doubt Mr. 8 Stephanopoulos's truthfulness and veracity 9 when he says allies in the White House are 10 pursuing an Ellen Rometsch strategy? 11 A I have no knowledge of the use or 12 misuse of the FBI files by anyone. 13 Q Yes or no? 14 MS. SHAPIRO: Okay. I think that 15 has been asked and answered, and I think we 16 should move on. 17 MR. KLAYMAN: I am not moving on. 18 I am not moving on. We will go over it. I 19 don't care if we have to go over it for three 20 hours. I'm going to get an answer. 21 THE WITNESS: I have no idea 22 what -- who or what George refers to as 235 1 "White House allies." 2 BY MR. KLAYMAN: 3 Q Do you believe that George 4 Stephanopoulos was lying when he said this? 5 A I can vouch as a general 6 proposition to George's truthfulness and 7 veracity, and I am happy to do so, if that is 8 where you are leading. But I -- 9 MS. SHAPIRO: I object to the 10 relevance of his credibility. 11 THE WITNESS: I can only testify to 12 what I know, though, Mr. Klayman, and what I 13 know is absolutely no knowledge of any use or 14 misuse of FBI files. 15 BY MR. KLAYMAN: 16 Q Do you have any reason to doubt the 17 truthfulness of Mr. Stephanopoulos's 18 statement? 19 A I said to the extent which I have 20 worked with George, which is for a number of 21 years in close contact, he is a person whose 22 word you can count on. 236 1 I do not, however, have any 2 knowledge of any use or misuse of FBI files. 3 That is the reason I was brought here, and 4 that is the important testimony that I am 5 trying to convey to you. 6 Q So you don't doubt the truthfulness 7 of his statement? 8 MS. SHAPIRO: But that has been 9 asked and answered, Mr. Klayman. 10 MR. KLAYMAN: Yes or no, it has 11 not. 12 BY MR. KLAYMAN: 13 Q Answer the question, please. 14 MS. PAXTON: Let's take a break. 15 MS. SHAPIRO: Let's take a break. 16 (Recess) 17 MS. SHAPIRO: Mr. Klayman, I think 18 you had a question that you have been asking 19 repeatedly. I will let you ask the question 20 one more time, and I'm going to allow the 21 witness to answer it one more time. 22 Then I think you need to certify 237 1 it, or do whatever you do, and move on, 2 because this is a-time limited deposition. 3 MR. KLAYMAN: Well, what do is try 4 to get an answer. 5 BY MR. KLAYMAN: 6 Q Mr. Begala, do you have any reason 7 to doubt the truthfulness of Mr. 8 Stephanopoulos' statement? 9 A While I can generally vouch, as 10 someone who knows him well, for George's 11 character, truthfulness, veracity, I cannot 12 speak to the accuracy or inaccuracy of the 13 statement, because I have no knowledge of it. 14 I have no knowledge of any use or misuse of 15 FBI files, either. 16 Q But you have never known George 17 Stephanopoulos to lie? 18 MS. SHAPIRO: I object. 19 MR. KLAYMAN: It is a different 20 question. I'm entitled to it. 21 BY MR. KLAYMAN: 22 Q Have you ever known him to lie? 238 1 A No. No. I am happy to vouch for 2 his character, integrity, truthfulness, 3 veracity. 4 To the best of my ability in a 5 general proposition. But I am not, under 6 oath, Mr. Klayman, going to be put in a 7 position to testify to the accuracy or 8 inaccuracy of something that someone else 9 said on a TV show. That is not my obligation 10 here. 11 Q Mr. Begala, is there a method, to 12 the best of your knowledge, of obtaining FBI 13 files outside of having them requisitioned by 14 the White House? 15 A I have no knowledge of FBI files, 16 how they are properly or improperly obtained. 17 With the exception of my background check, I 18 have never had any dealings with the FBI, or 19 the background checks they have called me 20 about other people who I was acquainted with. 21 Q Do you know any way that White 22 House allies can get ahold of FBI files? 239 1 A I do not. No, sir. 2 Q In fact, FBI files either have to 3 come from the FBI, or they have to be 4 requisitioned from the White House; correct? 5 A I will take you at your word. I 6 have no idea. I have no knowledge of how the 7 FBI works and no knowledge of use or misuse 8 of FBI files. None whatsoever. 9 I told a darn good joke that has 10 landed me here. But beyond that, I have no 11 knowledge of FBI files issues. 12 Q Have you ever met Craig 13 Livingstone? 14 A I think I have met him. 15 Q When did you meet him? 16 A I think in the early years of the 17 Clinton -- the first Clinton term. 18 Q How did you meet him? 19 A Stopping by the White House. I 20 don't recall a particular moment. 21 Q What was the context of meeting 22 him? 240 1 A I never had a meeting with him. I 2 have seen his picture on TV and in the 3 papers, and I recognized him as someone that 4 I had seen around. 5 Q When did you meet him? 6 A I recognized him from TV broadcasts 7 and the papers as someone I had seen around 8 the White House, at the White House. So I 9 guess I probably would have met him at the 10 White House. 11 Q Did you know what his position was 12 when you met him? 13 A No, sir. I thought he was part of 14 the permanent White House career security 15 staff. 16 Q You thought he was parts of the 17 permanent career security staff? How did you 18 learn that? 19 A I didn't. I was clearly wrong, 20 from the facts I've read in the newspapers. 21 But that was the impression that I had in my 22 memory. 241 1 Q But what led you to that 2 impression? 3 A He seemed to be working on 4 security-type issues. 5 Q During the '92 campaign, were you 6 aware that he frequently played the part of 7 Chicken George? 8 A No, sir, I was not aware of that. 9 Q Were you aware of Chicken George? 10 A I don't know if that's -- I was 11 aware of Chicken George. I didn't know that 12 that was true, that he played Chicken George. 13 Every person tries to claim that particular 14 respect -- 15 Q Whose idea was Chicken George? 16 A My recollection -- I used to know 17 this, because these little things matter in 18 people's careers, believe it or not. I can't 19 remember the guy's name now who tries to take 20 credit for the idea. I can't remember the 21 guy's name, I am sorry. But that is one of 22 those odd little things that people have 242 1 fought about. 2 My role in the campaign, again, was 3 to travel with the candidate. So I was not 4 very aware of what was going on in the 5 opposition to the candidate. 6 Q Was that Carville's idea, Chicken 7 George? 8 A No. Someone else claims the credit 9 for it, and I cannot remember his name. I'm 10 sorry. There was a time that was 11 hotly-debated issue among the bizarre little 12 circle of we pathetic career campaign people. 13 I can't remember the guy's name. It was a 14 guy. I just can't remember his name. 15 Q Have you started to write any book 16 about the Clinton administration? 17 A No, sir, I have not. 18 Q Have you put any thoughts on paper 19 about it? 20 A No, I have not, sir. I remember 21 Josh Steinberg getting in a lot of trouble 22 some time ago for -- 243 1 Q For writing something that was 2 untrue? 3 A No, it was just like notes or 4 something. I just remember Steinberg. I 5 don't think he was writing -- 6 Q He is the guy who disclaimed what 7 he wrote in his diary. 8 A That may be. I just remember 9 vaguely that situation. I have not been 10 fully happy with some of the books that have 11 been written about -- let me finish. 12 I have not been fully happy with 13 some of the books that have been written 14 about the President. 15 Q Is anybody in the White House 16 currently writing a book that you know of 17 about the administration? 18 A Not that I know of. 19 Q Is George Stephanopoulos? 20 A Oh, yes, he is. He is not at the 21 White House, of course. He is at ABC, 22 commentating. 244 1 Q He is writing a book? 2 A Yes, sir. 3 Q He has told you that? 4 A Yes, sir. 5 Q Do you know what publishing house 6 he is using? 7 A No, sir. 8 Q What is his book about? 9 A I would guess it is about his time 10 with Bill Clinton on the campaign and at the 11 White House. 12 Q Does he have a literary agent? 13 A I am sure he does. I don't know 14 who it might be, but -- I don't know. 15 Q Does it concern you that George is 16 writing a book at the same time that you are 17 talking to him? 18 MS. SHAPIRO: Again, I want to -- 19 BY MR. KLAYMAN: 20 Q Has that been a concern of the 21 White House? 22 MS. SHAPIRO: Was that objection 245 1 noted? 2 MR. KLAYMAN: Well, I don't know. 3 What is your objection? 4 MS. SHAPIRO: Relevancy. It is 5 hard to hear it when you are talking over it. 6 THE WITNESS: Not at a high level. 7 Again, I will say again that I have not been 8 very pleased with some of the books that have 9 been written about the Clinton 10 administration. 11 BY MR. KLAYMAN: 12 Q What is the name of the book? 13 A George's book? 14 Q Yeah. 15 A I don't know. 16 Q Is it about FBI files? 17 A Not that I know of, no, sir. 18 Q Is anyone else writing a book that 19 you know of on the Clinton administration? 20 A Not that I know of, no, sir. 21 Q Did you ever meet Anthony Marceca? 22 A No, sir, not that I can ever 246 1 recall. 2 Q You are not sure? 3 A Again, I want to -- I have no 4 recollection of meeting him. 5 Q Have you ever talked with Bernard 6 Nusbaum about the hiring of Livingstone? 7 A No, sir, not to my knowledge or 8 recollection. 9 Q So you may have? 10 A I have no recollection of that. I 11 didn't meet Livingstone until after he worked 12 there, so it would be safe bet to say that I 13 never talked to Nusbaum about his hiring. 14 Q Have you ever talked to Special 15 Agent Scullabrini? 16 A Not to my knowledge. I don't 17 remember any conversation. 18 Q Have you ever seen a memorandum 19 where Scullabrini wrote about an interview 20 with Nusbaum where he says that Livingstone 21 was hired on the strong recommendation of 22 Hillary Clinton? 247 1 A I have never seen such a memo, no, 2 sir. 3 Q Have you aware that Hillary was 4 interviewed by Ken Starr for a reported nine 5 minutes over the Filegate matter a month or 6 so ago? 7 A No, sir. I have a vague knowledge 8 that from time to time, she has been 9 interviewed. I didn't know of all of those 10 particulars. 11 Q I mean questioned under oath. Are 12 you aware of that? 13 A I remember her going to a grand 14 jury. I don't know if that is occasion you 15 are referring to. 16 Q Were you or anyone else that you 17 worked with in charge of explaining to the 18 press the reason that Hillary was being 19 questioned by Ken Starr under oath concerning 20 Filegate? 21 A No, sir. I don't remember the 22 events, so I don't remember being asked to 248 1 comment on it. 2 Q Based upon your experience with the 3 Clinton White House, what is Hillary 4 Clinton's role in that White House? 5 A Based on my experience, she is 6 obviously the First Lady. 7 Q Does she have duties and 8 responsibilities, to the best of your 9 knowledge? 10 A Yes, sir, like all First Ladies. 11 Q And what are her duties and 12 responsibilities? 13 A I am not -- you know, I don't work 14 all of that closely with her and her staff. 15 I have a general sense, which, if you want, I 16 can try to share with you. But I would not 17 take that as definitive. 18 Q Well, I am just asking you what you 19 know. 20 A My understanding is that she 21 supervises the residence, the social office, 22 is the hostess of large events like state 249 1 dinners. She also has particular policy 2 concerns on issues of children and families, 3 child care and health care in particular. 4 Q Is she someone who is the 5 equivalent, based on her reputation in the 6 White House, of the president of the company, 7 in that she manages the day-to-day operations 8 of the White House? She is the person who 9 ultimately would decide how the White House 10 runs? 11 A If by "the White House" you mean 12 the residence, I would say probably, although 13 there is the social office and the usher's 14 office. If you mean by the White House the 15 west wing and the policy staff, if I am 16 allowed to discuss that, I will be happy to. 17 MS. PAXTON: Generally. 18 THE WITNESS: Then generally, no, 19 based on my experience in corporate life and 20 my months at the White House. No, I wouldn't 21 analogize her to that function in the west 22 wing. 250 1 BY MR. KLAYMAN: 2 Q You are aware of reports that 3 Hillary Clinton is the person who ordered the 4 firing of the travel office staff? 5 A I have read reports generally about 6 that issue. 7 Q That is consistent with her role in 8 the White House, isn't it? She does have 9 that kind of authority, does she not? 10 A My sense is not -- that is not the 11 case. I mean, I can remember Nancy Reagan as 12 First Lady getting the credit or the blame or 13 firing the Chief of Staff. I can remember 14 Mrs. Bush in the Bush White House getting the 15 claim for the firing -- 16 Q I didn't ask about them. 17 A No, I am trying to think through 18 the role of First Lady. I don't remember -- 19 I remember controversies about the travel 20 office. I don't have any firsthand knowledge 21 about it, however. 22 Q Mrs. Clinton does have walk in
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