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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