251
         1     rights at staff meetings, does she not?

         2          A    In my six months, I can't recall a

         3     time she walked into a staff meeting.  I

         4     don't know what rights she has or what that

         5     means.  But I can't recall a time that --

         6          Q    You consult with her from time to

         7     time currently, don't you, with regard to a

         8     spin that you are giving on a particular

         9     story?

        10          A    Not often.  I see her from time to

        11     time.

        12          Q    On what occasions do you see hear?

        13          A    Social primarily.  I saw her about

        14     ten days ago at a basketball game.  I

        15     obviously saw her for the state dinner.

        16          Q    Was that the basketball game that

        17     Vernon Jordan was with the President at

        18     Georgetown?

        19          A    No, it was at the MCI center.  It

        20     was a Bulls game.  Hillary is from Chicago.

        21          Q    Was there any discussion about

        22     whether it was a good idea to have the two of









                                                             252
         1     them together under the current

         2     circumstances?

         3               MS. SHAPIRO:  Can you hold on a

         4     second please?

         5                    (Counsel conferred with

         6                    witness)

         7               THE WITNESS:  Could you restate the

         8     question for me?

         9               BY MR. KLAYMAN:

        10          Q    Was there any discussion at the

        11     White House as to whether that was wise,

        12     legally, for the two of them to be together

        13     at a Georgetown basketball game?

        14          A    There was some brief discussion.

        15     It was Chicago Washington.

        16          Q    Who engaged in that discussion?

        17          A    I went to the game and one of the

        18     other White House staffers that went was Rahm

        19     Emanuel.  We discussed it very briefly.

        20          Q    In fact both of you thought it was

        21     not a wise idea?

        22               MS. SHAPIRO:  He is not going to go









                                                             253
         1     into the substance --

         2               BY MR. KLAYMAN:

         3          Q    Between the two advisors, not with

         4     regard to the President.

         5               You and Mr. Emanuel both thought

         6     that was not a good idea?

         7               MS. SHAPIRO:  Reiterate an

         8     objection, it has nothing to do with the FBI

         9     files in this matter.

        10               MR. KLAYMAN:  You can respond.

        11               THE WITNESS:  It has nothing to do

        12     with the FBI files.

        13               MR. KLAYMAN:  You can respond.

        14               MS. PAXTON:  If you are going to

        15     start getting off into something very

        16     different, we will slow down this deposition.

        17               MR. KLAYMAN:  It follows the course

        18     of conduct.

        19               MS. PAXTON:   We will need to take

        20     a break.

        21               VIDEOGRAPHER:  We are going off

        22     video record at 3:04.









                                                             254
         1                    (Discussion off the record)

         2               VIDEOGRAPHER:  We are back on video

         3     record at 3:08.

         4               BY MR. KLAYMAN:

         5          Q    Did you and Mr. Emanuel express

         6     your opinion, either one of you or both, that

         7     having a President at the Georgetown

         8     basketball game with Vern Jordan was a bad

         9     idea?

        10          A    I will express my personal opinion,

        11     which at the time, and today is, the heck

        12     with it.  These guys ought to be able to have

        13     a life.  They were not going to do anything

        14     inappropriate.  If Vernon wanted to stop by

        15     and see his friend, that was fine by me.

        16     That was a personal view that I expressed at

        17     that time.

        18          Q    But the two -- you did express

        19     concern with Mr. Emanuel, did you not, that

        20     the two could be sharing testimony at that

        21     meeting, correct, on the Lewinsky matter?

        22          A    No, sir.  The topic came up.  I









                                                             255
         1     said if this guy wants to stop by and say

         2     hello to his friend, they ought to have some

         3     kind of life despite the harassment that they

         4     are subject to.  That is my strong view.

         5               I didn't think it was inappropriate

         6     for a friend to tell a friend hello at a ball

         7     game.

         8          Q    Was the concern expressed that it

         9     could be perceived as an opportunity for the

        10     two of them to communicate, to synchronize

        11     testimony?

        12          A    No, sir.

        13          Q    There was no concern?

        14          A    The concern was more what political

        15     critics would say.  But a brief hello, at a

        16     ball game, between friends of many decades,

        17     standing, ought to be allowed even if in

        18     America at the end of 20th century, the

        19     bizarre world that we live in.

        20               That was my view and obviously out

        21     of sync with your own sense of political

        22     judgment, and it may have been politically









                                                             256
         1     wrong, but I don't regret it.  The guy ought

         2     to have some tiny bit of a life still,

         3     despite that he is President.

         4          Q    But you discussed it with Emanuel?

         5          A    I discussed it longer with you than

         6     I did with Emanuel.  He ought to have a right

         7     to say hello to his pal at the ball game.

         8          Q    He should be allowed to talk about

         9     the testimony in the Lewinsky case?

        10               MS. PAXTON:  Objection.

        11               MS. SHAPIRO:  Objection.

        12               MR. KLAYMAN:  Is that your view?

        13               MR. ANDERSON:  This has nothing to

        14     do with the FBI files --

        15               MR. KLAYMAN:  It deals with the

        16     state of mind, the course of conduct --

        17               MR. ANDERSON:  Whose state of mind?

        18               MR. KLAYMAN:  Maybe your state of

        19     mind, given the way you have been behaving

        20     here.

        21               MR. ANDERSON:  Move on to relevant

        22     things.  This is a time limited deposition.









                                                             257
         1               MR. KLAYMAN:  You are not the

         2     primary counsel here.  I would ask you not to

         3     interrupt.

         4               MR. ANDERSON:  You are wasting our

         5     time.

         6               MR. KLAYMAN:  I don't want to get

         7     into kid's games with you, sir.

         8               BY MR. KLAYMAN:

         9          Q    Have you ever heard of someone by

        10     the name of Dennis Casey?

        11          A    Yes, sir, I have heard that name.

        12          Q    When did you first hear of that

        13     name?

        14          A    I think he was around in

        15     Pennsylvania politics, when I was working for

        16     Bob Casey, the former Governor.

        17          Q    Is he related to Bob Casey?

        18          A    Not that I know of.

        19          Q    Is Dennis Casey an honest man, in

        20     your opinion?

        21               MS. SHAPIRO:  Objection to the

        22     relevancy of somebody's reputation, unrelated









                                                             258
         1     to this matter.

         2               BY MR. KLAYMAN:

         3          Q    Are you worked with him?

         4          A    Not that I can remember.

         5          Q    Have you ever had contact with him?

         6          A    Not that I can remember.  I may

         7     have.  I know the name of from Pennsylvania

         8     politics, but I don't recall working with

         9     him.

        10          Q    Does he have a bad reputation in

        11     terms of honesty?

        12          A    I don't want to vouch for his

        13     reputation.

        14               MS. SHAPIRO:  Objection, relevancy.

        15               BY MR. KLAYMAN:

        16          Q    You have worked in Pennsylvania

        17     politics. You talked about Wofford and Casey,

        18     right, so you did come in contact with

        19     Mr. Dennis Casey in that context?

        20          A    I heard the name.  I can't tell you

        21     whether I ever came in contact.  You just

        22     asked me if I heard that name.  I heard that









                                                             259
         1     name in Pennsylvania politics.  I am not

         2     willing to vouch for him in any way because I

         3     would not recognize him if walked in the

         4     door.

         5          Q    Are you ware that he gave testimony

         6     before the Government Reform and Oversight

         7     Committee in the Filegate matter?

         8          A    No, sir, I'm not.

         9          Q    I will show you what I ask the

        10     reporter to mark as Exhibit 11.

        11                    (Begala Deposition Exhibit

        12                    No. 11 was marked for

        13                    identification.)

        14               BY MR. KLAYMAN:

        15          Q    I show you a copy of Exhibit 11

        16     which is the testimony of Dennis Casey of

        17     June 26, 1996 before the Government Reform

        18     and Oversight Committee.

        19               I ask you, Mr. Begala, to take a

        20     look at it.  It is very short, only two

        21     pages.  Read it quickly.

        22          A    Can I ask you who he is and what









                                                             260
         1     his background is?

         2          Q    Read that.

         3          A    This will say that?

         4          Q    Mm-hum.

         5               MS. PAXTON:  Is this the entire

         6     testimony, Mr. Klayman?

         7               MR. KLAYMAN:  To the best of my

         8     knowledge, but I don't know.  I don't think

         9     so, actually, it is an excerpt.

        10               MS. SHAPIRO:  Mr. Klayman, is the

        11     cover page attached?  Are you certain that

        12     that is the correct cover page?

        13               MR. KLAYMAN:  Yes.

        14               MS. SHAPIRO:  Because what is

        15     inside looks to be a deposition, not a

        16     hearing.

        17               MR. KLAYMAN:  They attached certain

        18     testimony.

        19               MS. SHAPIRO:  This is an attachment

        20     to the hearing transcript?

        21               MR. KLAYMAN:  Yes.

        22               BY MR. KLAYMAN:









                                                             261
         1          Q    Does that refresh your recollection

         2     about Dennis Casey?

         3          A    Not much.  I didn't work in

         4     Pennsylvania back in 1984, I was working in

         5     Texas.

         6          Q    Tell me what little bit it

         7     refreshes?

         8          A    I recall a guy, I thought he was a

         9     reporter or commentator or pundit from

        10     western Pennsylvania, Pittsburgh, with the

        11     name of Dennis Casey.  I can't recall

        12     anything else.

        13               He says he is a political

        14     consultant out there.  I have no recollection

        15     of ever working with him or I didn't work in

        16     that campaign, in that state, at that time.

        17          Q    Does it refresh your recollection

        18     with regard to Mr. Livingstone and his

        19     activities in Pennsylvania?

        20          A    No, sir.  I wasn't aware of any of

        21     those things.

        22          Q    Do you know Page Reese?









                                                             262
         1          A    I don't think so.  The name does

         2     not ring a bell.

         3          Q    Dan Calegari, C-a-l-e-g-a-r-i?

         4          A    I remember a Dan Calegari working

         5     for Congressman Gephardt in New Hampshire in

         6     1987, 1988.

         7          Q    On page 471 of the exhibit I just

         8     showed you, it says:  "At that point I

         9     approached my co-director, Dan Calegari," who

        10     I will deviate from the statement for a

        11     moment, is from Hill, New Hampshire, as I

        12     recall.

        13               Is that the Dan Calegari that you

        14     know?

        15          A    It may be the same guy.  I have a

        16     recollection of a guy named Calegari who

        17     worked for Congressman Gephardt in the

        18     presidential campaign.  I thought it was New

        19     Hampshire.  I could be wrong but that is the

        20     recollection I have.

        21          Q    Have you ever heard of Ron Klink,

        22     K-l-i-n-k?









                                                             263
         1          A    I have heard of Congressman Klink.

         2          Q    Have you ever worked for him?

         3          A    No, sir.

         4          Q    Have you ever heard of a Billy

         5     Shore?

         6          A    Yes, I know Bill Shore.  He is the

         7     head of Share Our Strength.  He does good

         8     work.

         9          Q    Have you ever worked with him in

        10     conjunction with Pennsylvania politics?

        11          A    No, sir.

        12          Q    Have you ever been worked against

        13     him?

        14          A    Not that I -- well, in '92, when I

        15     worked for Governor Clinton, Billy for a

        16     brief time was running Bob Carey's campaign.

        17     In fact, Billy was one of the people Carville

        18     and I met with when he were trying to decide

        19     which presidential campaign to sign on with.

        20               I have high admiration for Billy

        21     Shore.  I know him and like him.  The other

        22     people I don't know particularly.









                                                             264
         1          Q    When you were consulting in the

         2     Clinton-Gore campaign in 1992, who was

         3     responsible for hiring decisions on that

         4     campaign?

         5          A    I would think it would be the

         6     campaign manager, Dave Wilhelm.

         7          Q    Anyone else?

         8          A    I am sure he had people working

         9     under him.  Carville and I were consultants,

        10     so we didn't hire and fire people on the

        11     campaign stuff.

        12          Q    You were also a consultant I take

        13     it on 1996 campaign?

        14          A    No, sir.  Well, for a brief period

        15     of time.  I left Washington in '95 and did

        16     not work in that campaign.

        17          Q    Have you ever met Dick Morris?

        18          A    Once in 1995.

        19          Q    What was the occasion of meeting

        20     him?

        21          A    Carville and I were pitching a guy,

        22     Bob Del Tufo, a U.S. attorney who wanted to









                                                             265
         1     run for Governor ever New Jersey.  He kind of

         2     dropped out, but I remember Del Tufo.  He is

         3     a good guy.

         4          Q    Is that the only time you talked to

         5     Dick Morris?

         6          A    Yes, sir.  To my knowledge.

         7          Q    Are you aware of anyone in the

         8     White House who talked to Dick Morris about

         9     the Filegate matter?

        10          A    Not to my knowledge, no, sir.  I

        11     don't have any knowledge of the Filegate

        12     matter.

        13          Q    Does the White House have

        14     possession of a copy or the original of the

        15     diary of Shari Rowlands, his girlfriend?

        16          A    I have no idea.

        17          Q    Have you ever heard of such a

        18     diary?

        19          A    I don't know.  I was not working in

        20     that campaign.  I remember a scandal

        21     involving Mr. Morris and a woman by that

        22     name.









                                                             266
         1          Q    Have you ever met William Kennedy,

         2     the White House counsel's office?

         3          A    Yes, I have.

         4          Q    When did you meet him?

         5          A    When he worked at the White House.

         6          Q    Did you ever discuss FBI files with

         7     him?

         8          A    No, sir, not to my knowledge.

         9          Q    Did you ever discuss Livingstone

        10     with him?

        11          A    No, sir, not to my knowledge.

        12          Q    Marceca?

        13          A    Can I -- let me finish my --

        14          Q    I didn't realize you were not

        15     finished.

        16               MS. SHAPIRO:  Mr. Begala is very

        17     soft spoken.  I think you have to pause a

        18     moment to be sure he is finished with his

        19     answer, before you ask your next question.

        20               THE WITNESS:  Not to my knowledge

        21     or recollection.

        22               BY MR. KLAYMAN:









                                                             267
         1          Q    Are you soft spoken?

         2          A    I am taking this enormously

         3     seriously.  I have never been deposed before.

         4     I take it with the utmost gravity.  I like to

         5     have fun and I like to go on TV and do

         6     combat.

         7               I am quite frustrated, though, at

         8     seeing the legal system turned over to what I

         9     think is a political battle.

        10          Q    You are frustrated at people

        11     bringing matters to try to find out whether

        12     there is corruption in government?  Does that

        13     frustrate you?  Are you if in favor of that?

        14          A    Yes.

        15          Q    You believe that there should be

        16     integrity in government?

        17          A    Yes.

        18          Q    Do you believe the President should

        19     tell the truth?

        20          A    I believe the President has told

        21     the truth.

        22          Q    Do you believe the President should









                                                             268
         1     tell the truth?

         2          A    Of course.  And I believe he has.

         3     I am very proud to say that publicly.

         4          Q    Are you saying he has always told

         5     the truth?

         6          A    Certainly to the best of my

         7     knowledge.  We all make mistakes in life.  I

         8     tell my mother-in-law I like her chili when

         9     it is almost inedible.

        10          Q    Are you saying the President is

        11     inedible?

        12          A    Even he couldn't eat my

        13     mother-in-law's chili.  I am sorry, it is

        14     God-awful.

        15               MS. PAXTON:  This is for the

        16     record, Paul.

        17               THE WITNESS:  I know.  I am sorry,

        18     I don't mean to be flip.  Jokes got me here

        19     in the first place.  I need to temper my

        20     tongue.

        21               BY MR. KLAYMAN:

        22          Q    Have you ever appeared in









                                                             269
         1     Politically Incorrect?

         2          A    Not, I have not.  I was invited

         3     once when they were running an ad that mocked

         4     President Reagan for having Alzheimer's.  I

         5     lost my grandfather to that disease.  They

         6     dropped that ad right away.  I had a

         7     particular problem with that.

         8          Q    Have you ever recommended any

         9     candidates for jobs in the White House,

        10     during the Clinton administration?

        11          A    Yes, sir.

        12          Q    Who did you recommend?

        13          A    Most recently, I remember, Lindsey

        14     Thomas is a former Congressman from Georgia

        15     who was already in the works to be appointed

        16     as some kind of a rivers commission.  He is a

        17     great conservationist and outdoorsman.  I put

        18     in a good word for him.

        19          Q    Did you ever put in a good word for

        20     Mr. Livingstone?

        21          A    No, sir.

        22          Q    Do you know where Mr. Livingstone









                                                             270
         1     is today?

         2          A    No, sir.

         3          Q    Have you become aware that he is in

         4     Laguna Beach, California working for a DNC

         5     donor?

         6          A    No, sir.

         7          Q    You did not know that?

         8          A    No, sir I did not know that.

         9          Q    Do you think whether Mr. Carville

        10     ever recommended Mr. Livingstone for

        11     employment?

        12          A    I don't know.

        13          Q    Do you know whether Mr. Carville

        14     knows Mr. Livingstone?

        15          A    I don't know that.

        16          Q    You don't know one way or the

        17     other?

        18          A    I don't know.

        19          Q    Same question with regard to

        20     Mr. Marceca?

        21          A    Right, I don't know.

        22          Q    Has the First Lady ever discussed









                                                             271
         1     personnel matters with you or anyone else to

         2     your knowledge?

         3          A    Not to my knowledge.  I am trying

         4     to think.  If you could be more specific, I

         5     could try to be more helpful.

         6          Q    Has she ever discussed hiring and

         7     firing anyone with you?

         8          A    I can't recall it, no, sir.  As a

         9     general matter I have not known her to

        10     involve herself in those kinds of decisions.

        11          Q    Did you ever meet Vince Foster?

        12          A    Yes, sir.

        13          Q    When did you meet Vince Foster?

        14          A    When he worked at the White House.

        15          Q    Did you ever have any dealings with

        16     Vince Foster at the White House?

        17          A    I met him.  I didn't work on any

        18     issues with him, that I can recall.

        19          Q    Did you ever discuss anything with

        20     him?

        21          A    I have had conversations with him.

        22          Q    What conversations did you have?









                                                             272
         1          A    I can't recall now.  I mean I

         2     didn't know him very well.

         3          Q    Did you ever discuss

         4     Mr. Livingstone or Mr. Marceca with Vince

         5     Foster?

         6          A    Not to my knowledge.

         7          Q    Did you ever discuss FBI files with

         8     Mr. Foster?

         9          A    No, sir, not to my knowledge.

        10          Q    Is that no or not to your

        11     knowledge?

        12          A    Well, both.

        13          Q    That is one of the rare times you

        14     said no.

        15          A    The story didn't come out until I

        16     was living in Texas and Vince was dead.  So I

        17     am very certain I never discussed it with

        18     Vince because I never even heard about it

        19     until he had been dead for three years.

        20          Q    Did you ever discuss a matter

        21     called Travelgate did with Vince Foster?

        22          A    Not that I can recall.  I remember









                                                             273
         1     from clippings that that was something that

         2     he had worked on.  I remember him being

         3     involved in that.

         4          Q    Did you ever have any discussions

         5     with anyone at the White House or elsewhere

         6     about an FBI investigation of Billy Ray Dale,

         7     the head of the travel office?

         8          A    No, sir.  I remember when that

         9     happened I was traveling the day that that

        10     story broke.  I remember talking to Dee Dee

        11     Myers.  Her saying that there is this huge

        12     story out there because we fired the staff of

        13     the travel office.  I remember thinking,

        14     obviously wrongly in hindsight, why is that a

        15     story?  Why are they writing about that?

        16          Q    Did you ask Dee Dee that?

        17          A    I made the comment it didn't strike

        18     me as a very big story.  I remember that

        19     because I was obviously wrong.

        20          Q    What did Dee Dee Myers tell you

        21     about why that is a big story?

        22          A    She just said believe me, it is a









                                                             274
         1     big story.  I was traveling in upstate New

         2     York.  I didn't work on it.  I remember that

         3     phone conversation because one of the many

         4     times my political judgment has been errant.

         5          Q    What was your position, if any, at

         6     the time that you discussed that with Dee Dee

         7     Myers?  Who were you working --

         8          A    Political consultant.

         9          Q    With access to the White House?

        10          A    Yes, sir.

        11          Q    During that period of time, how

        12     frequently did you visit the White House?

        13          A    I don't remember what time that

        14     was.

        15          Q    Roughly speaking?

        16          A    At the very beginning of the

        17     President's term I went there a good bit,

        18     particularly to help pass the President's

        19     economic plan, sell that to the public.

        20          Q    What was the relative frequency per

        21     week?

        22          A    When I was working on the economic









                                                             275
         1     plan I was there, I would bet, nearly

         2     everyday.

         3          Q    Did there come a point in time when

         4     the frequency of your visits declined?

         5          A    Yes, sir.

         6          Q    When was that?

         7          A    As other obligations to other

         8     clients and elections took me away, in both

         9     '93, when I told you we did a campaign in

        10     Greece, I did Governor Florio's campaign, I

        11     forgot these this morning.  Jim Florio of New

        12     Jersey, I did his campaign in '93 and spent a

        13     good deal of time in New Jersey and not very

        14     much in the White House.

        15               In '94 I worked for Senator Wofford

        16     in Pennsylvania and Governor Miller in

        17     Georgia.  So there were stretches where I was

        18     not around very often.

        19               But, particularly in helping to

        20     sell the public on the President's position

        21     on the economic plan, and the health care

        22     reform proposal, I was there a fair amount.









                                                             276
         1          Q    Did you ever visit the office of

         2     personnel security since you have been either

         3     a consultant or an employee of the White

         4     House?

         5          A    I can't remember it, no, sir.

         6          Q    Have you ever seen documents in and

         7     around the White House that were labeled FBI

         8     files?

         9          A    No, sir, I never have.  To the best

        10     of my knowledge and recollection.

        11          Q    Have you ever had discussions with

        12     anyone over what documents were taken out of

        13     Vince foster's office after he died?

        14          A    Not that I can remember, sir.

        15          Q    So you may have had discussions?

        16          A    It was political controversy, but

        17     it was not one that I played a particular

        18     leading role in.

        19          Q    Were FBI files taken in his office?

        20          A    I have no idea what, if anything.

        21          Q    Did you hear any rumors to that

        22     effect?









                                                             277
         1               MS. SHAPIRO:  Let him finish his

         2     answer before you ask the next question.

         3               THE WITNESS:  I have no idea what,

         4     if anything, might have been taken out of

         5     Mr. Foster's office after he died.

         6               BY MR. KLAYMAN:

         7          Q    Have you heard anyone say FBI files

         8     were taken out?

         9          A    I can't remember that specifically.

        10          Q    It may have been said?

        11          A    Certainly, lots of things get said.

        12          Q    Who would have said it?

        13               MS. SHAPIRO:  Objection.  He didn't

        14     testify that anybody said it.

        15               THE WITNESS:  I don't know who

        16     might have said it.  I mean -- you might have

        17     said it.

        18               BY MR. KLAYMAN:

        19          Q    Did you ever discuss Vince Foster's

        20     documentation with Bernee Nusbaum?

        21          A    Documentation?  I don't understand.

        22          Q    Documentation in his office on the









                                                             278
         1     day that he died?

         2          A    Not that I can remember, no, sir.

         3          Q    Did you ever discuss it with Maggie

         4     Williams?

         5          A    Not that I can remember, no, sir.

         6          Q    Did you ever discuss Vince Foster

         7     where Maggie Williams after he died?

         8          A    I don't remember specific

         9     conversation, but people at the White House

        10     were very upset after Vince died.

        11               MS. SHAPIRO:  I will insert another

        12     relevancy objection, that we are way off our

        13     field here.

        14               BY MR. KLAYMAN:

        15          Q    Did you ever discuss Mr. Foster

        16     with Hillary Clinton after he died?

        17          A    I can't remember doing so but I

        18     can't rule it out, either.

        19               If I can elaborate.  I was not an

        20     Arkansan, so I was not intimately familiar

        21     with Vince.

        22               I liked him.  I knew him somewhat.









                                                             279
         1     In particularly in the '92 campaign, I was on

         2     the plane, so those few people on the plane I

         3     got to know quite well.  The rest of the

         4     folks in Arkansas, I didn't get to know as

         5     well as others in the campaign may have

         6     because my job was to be 30,000 feet above

         7     the air, above the ground.

         8          Q    Did you ever meet Webb Hubbell?

         9          A    I must have met him in the

        10     campaign, because he was around.  But I don't

        11     remember meeting him this the campaign.

        12          Q    Have you ever discussed whether Web

        13     Hubbell had access to FBI filings?

        14          A    No, sir, not to my knowledge.

        15          Q    You don't remember?

        16          A    I don't remember any such

        17     conversations.

        18          Q    Has the First Lady ever mentioned

        19     Craig Livingstone to you?

        20          A    Not that I can recall, but she may

        21     be in a political context, some of the

        22     charges that have been leveled.  I couldn't









                                                             280
         1     rule it out, but I can't remember a specific

         2     conversation.

         3          Q    What political context?

         4          A    There are political charges that

         5     have been made, including some from you,

         6     about Mr. Livingstone.

         7          Q    Did you discuss that with her?

         8          A    I can't rule it out.  I don't have

         9     a specific recollection but I can't rule it

        10     out.

        11          Q    Most likely you discussed it?

        12          A    I can't rule it out.

        13               MS. SHAPIRO:  Object, you are

        14     mischaracterizing his testimony.

        15               BY MR. KLAYMAN:

        16          Q    Can you rule anything out?

        17          A    Yes, sir.

        18          Q    Can you rule out that aliens landed

        19     in the west?

        20          A    I can rule out any knowledge of any

        21     use or misuse of FBI files by anyone I ever

        22     talked to or worked with.  I have no









                                                             281
         1     knowledge of any use or misuse of FBI files.

         2     It is very important that you understand

         3     that.  I understand that I am on the record

         4     and this is under oath.

         5          Q    Where did you discuss the FBI files

         6     matter with Mrs. Clinton?

         7          A    I don't recall any discussions of

         8     the FBI files matter with Mrs. Clinton.

         9          Q    Did you ever discuss the files

        10     matter with the President?

        11          A    Not to the best of my knowledge.

        12          Q    So you may have?

        13          A    To the best of my knowledge.

        14     Again, if I can repeat, it is an issue that

        15     arose in the press.  So from a political

        16     standpoint, it didn't become a political

        17     issue until the time I was living in Texas.

        18               So I was not in very frequent

        19     contact with the President of the United

        20     States when I was living in Austin, Texas.

        21     So I say with some certainty I have no

        22     recollection of any such conversation.  I









                                                             282
         1     don't think that there ever would have been

         2     one.

         3          Q    But it does arise from time to

         4     time, does it not, the files matter?

         5          A    No, sir, not on my radar screen.  I

         6     don't know if it is good or bad, but there is

         7     enough other things, both of a substantive

         8     matter but also of a political matter that

         9     occupy my time.

        10          Q    Are you aware the First Lady

        11     recently received a subpoena from the

        12     Government Reform and Oversight Committee for

        13     documents?

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

        15          Q    You are not aware of that issue?

        16          A    I am not.

        17          Q    Do you have anyone else who has?

        18          A    Who has what?

        19          Q    Dealt with this issue of the

        20     subpoena from the Government Reform Oversight

        21     Committee?

        22          A    No, sir.  It is not an issue is









                                                             283
         1     that I have worked on.

         2               VIDEOGRAPHER:  We are going off

         3     video record at 3:32.

         4                    (Discussion off the record)

         5               VIDEOGRAPHER:  We are going back on

         6     video record at 3:33.

         7               BY MR. KLAYMAN:

         8          Q    Mr. Begala, as special assistant

         9     counselor to the President, what are your

        10     duties as special assistant?

        11          A    Actually assistant.

        12          Q    What is the distinction between

        13     assistant to the President and counselor to

        14     the President?

        15          A    That is a very good question.  I am

        16     teased often about the number of counselors

        17     that the President has because it is a rather

        18     grandiose title.

        19          Q    You have two roles?

        20          A    No, sir.  It is just a nice title

        21     created for David Gurgin, that is another

        22     joke, but this happens to be true that I know









                                                             284
         1     of, it was created when Mr. Gurgin was

         2     brought on to the White House, sort of an

         3     added flourish.  It is a subject of some

         4     derisive commentary and humor among my

         5     colleagues.

         6          Q    You actually filled David Gurgin's

         7     shoes in that role?

         8          A    I don't know that David or I would

         9     say that.  But it is analogous.

        10          Q    That was his slot?

        11          A    I don't know.  It has been a long

        12     time since David left.  So it is not like I

        13     was hired to replace him.  It was an

        14     analogous sort of role where I am trying to

        15     take the President's policy initiatives and

        16     present them to the public in a way that the

        17     public finds compelling and frankly that the

        18     news media will cover or report on which you

        19     know is a difficult thing to do.

        20          Q    In addition to policy, you are also

        21     dealing with the public over the scandals,

        22     correct?









                                                             285
         1          A    It has fallen to me to do so, in

         2     part because I have some experience of going

         3     on television and in part, I hope, because

         4     people in the press know that I am credible

         5     and honest when I say I believe the President

         6     has not done anything wrong.

         7          Q    In fact you told the press, made

         8     public pronouncements that this is what you

         9     do best, spinning these issues.

        10               Is that correct?

        11          A    No, sir.  I hope I haven't said

        12     that because that is more arrogant than I

        13     ought to be.

        14               It is something that I have

        15     experience with, unfortunately, because this

        16     President, even as long back as have I known

        17     him, has been subject to what I think are

        18     very unfair, personal attacks.  That is one

        19     of the reasons that I think I have such a

        20     strong belief that people ought to focus on

        21     the public record.

        22               Because as a matter of strategy as









                                                             286
         1     well as morality, I have seen Bill Clinton

         2     attacked for allegations of his private life.

         3     Yet he wins and wins and wins.  You think

         4     that the political marketplace would not

         5     reward, does not reward that type of behavior

         6     so people would learn.

         7               So I have, by dint of experience,

         8     learned that the best way to answer these

         9     issues actually is to talk about the public

        10     record, the things that you are working on

        11     and doing.

        12          Q    When you worked on in the 1992

        13     campaign, did you formulate a strategy to

        14     deal with Jennifer Flowers?  Did you

        15     participate in that?

        16          A    I participated in that.

        17          Q    What did you do?

        18          A    We fought like hell, excuse me

        19     language, that is actually the phrase that I

        20     remember the Governor using.  We fought back

        21     hard.  We were not going to just take its

        22     lying down.  He had a set of ideas that he









                                                             287
         1     believed in.  He said over and over, if I

         2     make this about my your life and not mine, we

         3     will both come out of this better.

         4               I still believe that is why the

         5     American people support this President.

         6          Q    You helped formulate the public

         7     pronouncements that Bill Clinton had not had

         8     an affair with Jennifer flowers?

         9          A    To the best of my recollection he

        10     said had her allegations were not true.

        11          Q    You helped formulate that?

        12          A    I helped explicate it, I helped

        13     broadcast it.  The formulation obviously came

        14     from the Governor.

        15          Q    Are you aware of the testimony that

        16     President Clinton gave to the lawyers in the

        17     Paula Jones case?  Are you aware of what is

        18     in the testimony?

        19               MS. SHAPIRO:  Objection.  This

        20     witness cannot answer questions about any

        21     about matter that is currently before the

        22     grand jury in a separate investigation.









                                                             288
         1               MR. KLAYMAN:  Why is that?

         2               MS. SHAPIRO:  Because there is a

         3     separate grand jury investigation with

         4     respect to that.

         5               MR. KLAYMAN:  Why can't he answer

         6     questions.

         7               MS. SHAPIRO:  Because there is --

         8     there are questions of privilege he is not

         9     authorized to waive.

        10               MR. KLAYMAN:  I just asked whether

        11     he was aware, not where it came from, if he

        12     was aware of what had been testified to in

        13     the Jones case with regard to Jennifer

        14     Flowers.

        15               MS. SHAPIRO:  Could you repeat

        16     that?

        17               BY MR. KLAYMAN:

        18          Q    Are you aware of what was testified

        19     to by the President in the Jones case

        20     concerning Jennifer Flowers?

        21               MS. PAXTON:  What possible

        22     relevance is this to the FBI files matter?









                                                             289
         1               MR. KLAYMAN:  Deals with his

         2     credibility.

         3               MS. PAXTON:  Who?

         4               MR. KLAYMAN:  Mr. Begala.

         5               MS. PAXTON:  How?

         6               MR. KLAYMAN:  I am not going to

         7     tell you on the record.  I know you would

         8     love to know.

         9               MS. PAXTON:  If you can connect

        10     them up, I don't see it is relevant.

        11               MR. KLAYMAN:  I will give you a

        12     break hear.  I don't generally do this but,

        13     because I want to be courteous, I will do it

        14     for you this one last time.

        15               Obviously it has been reported that

        16     the President testified that he did have an

        17     affair with Jennifer Flowers.  Mr. Begala was

        18     spewing forth information on the President's

        19     behalf in 1992 denying it.  That is the

        20     relevance, in terms of his own credibility.

        21               MS. SHAPIRO:  We object on the

        22     grounds of relevance.  We don't think that is









                                                             290
         1     any kind of a valid kind of reason for taking

         2     his testimony.  But he can answer the

         3     question.

         4               BY MR. KLAYMAN:

         5          Q    Are you aware of what the President

         6     testified to with regard to Jennifer Flowers

         7     in the Jones case?

         8          A    I have no first hand knowledge of

         9     the President's testimony.  I have read press

        10     accounts.  Those press accounts actually

        11     have, that I have seen, I remember something

        12     in Time magazine, that said, what the

        13     President had said, which is that he told the

        14     truth in 1992 and he told the truth more

        15     recently under oath, and I am comfortable

        16     with that.

        17          Q    The two statements are A, I didn't

        18     have an affair, and B, I did have an affair.

        19          A    That is not my understanding of the

        20     press coverage.

        21          Q    If you were to learn that the

        22     President did have an affair with Jennifer









                                                             291
         1     Flowers --

         2               MS. SHAPIRO:  Object, hypothetical.

         3               BY MR. KLAYMAN:

         4          Q    Would you, based on your experience

         5     and based on your public position, correct it

         6     on the record, with the press?

         7               MS. SHAPIRO:  Objection,

         8     hypothetical.

         9               THE WITNESS:  Based on my

        10     experience with the press, I never deal with

        11     hypotheticals.  I have learned --

        12               BY MR. KLAYMAN:

        13          Q    I am asking you a hypothetical

        14     myself.  You are in a court proceeding now.

        15               MS. PAXTON:  He is not required to

        16     answer hypotheticals.

        17               BY MR. KLAYMAN:

        18          Q    What I'm testing, Mr. Begala, is

        19     your truthfulness and veracity.

        20               MS. PAXTON:  You are testing his

        21     ability to guess and he is not required under

        22     oath to guess.









                                                             292
         1               BY MR. KLAYMAN:

         2          Q    Let's assume that it was determined

         3     that President Clinton, based on his own

         4     testimony, did have an affair with Jennifer

         5     Flowers.

         6               By virtue of your position as

         7     assistant to the President and counselor to

         8     the President who deals with the press, would

         9     you feel duty bound to correct that with the

        10     press?

        11               MS. PAXTON:  Again, that question

        12     is objectionable.  You are asking him to

        13     answer a hypothetical --

        14               MR. KLAYMAN:  You are not counsel

        15     of record, Ms. Paxton.  Please do not

        16     interrupt.

        17               MS. SHAPIRO:  I assert the same

        18     relevancy objection that he is not required

        19     to answer hypotheticals.  Your role is to ask

        20     him questions about his knowledge.

        21               MR. KLAYMAN:  My role is also to

        22     test whether what we have here is a person









                                                             293
         1     who, as an ordinary course, either tells the

         2     truth or corrects things when he find out

         3     what the truth is.

         4               BY MR. KLAYMAN:

         5          Q    I want to know, Mr. Begala, if you

         6     learned that the President testified that

         7     there was an affair with Jennifer Flowers,

         8     would you feel duty bound by virtue of your

         9     public position to correct that with the

        10     press?

        11          A    I have no knowledge of the

        12     President's testimony.  I have seen news

        13     coverage, and I have seen public statements

        14     from the President, that he testified

        15     truthfully a few months ago, whenever that

        16     testimony was, that -- let me finish, that he

        17     spoke truthfully in 1992.

        18               I am not free to speculate about

        19     what feelings and emotions I might have if

        20     something else happened.  I am just not able

        21     to do that.

        22          Q    I am asking you to assume for









                                                             294
         1     purposes of this question, this is a legal

         2     proceeding, not spinning the press --

         3               MS. SHAPIRO:  This is an improper

         4     question for an a legal proceeding.

         5               MR. KLAYMAN:  It is not an improper

         6     question.

         7               MS. PAXTON:  It is an improper

         8     question.

         9               MR. KLAYMAN:  Please do not

        10     interrupt.  Be fortunate that you are sitting

        11     here.  Please do not interrupt.  There is

        12     counsel here.  You are not counsel of record.

        13     Taxpayers money is not to be used to defend

        14     Mr. Begala out of the White House.  So please

        15     sit here and allow counsel, who is in charge

        16     of that task, to do it, Ms. Shapiro.

        17               MS. SHAPIRO:  I am inserting an

        18     objection to an improper form of question.

        19               MR. KLAYMAN:  But you don't have a

        20     right to ask him not to answer --

        21               MS. SHAPIRO:  Under the Federal

        22     rules of civil procedure, only experts can









                                                             295
         1     answer hypothetical questions.

         2               MR. KLAYMAN:  This is not a trial.

         3     If it comes to a trial the judge will be able

         4     to rule on your objection.  I am entitled to

         5     an answer right now.

         6               BY MR. KLAYMAN:

         7          Q    My question is, Mr. Begala; it is a

         8     given that the President did not tell the

         9     truth, that he had no affair with --

        10          A    No, sir, I can't accept that

        11     assumption.  I cannot accept an assumption

        12     that I believe and know to be false.

        13          Q    Let's take the President out of it.

        14     Let's take Lewinsky out of it.  Let's take

        15     Flowers out of it.

        16               Let's talk about in the course of

        17     your duties at the White House, if you

        18     learned that material information was

        19     provided to press which later turned out to

        20     be untrue, and that information could have a

        21     negative effect on the presidency, would you

        22     correct it yourself with the press?









                                                             296
         1          A    That is a hypothetical.

         2               MS. SHAPIRO:  Give us one moment to

         3     see if we will instruct the witness or not.

         4               VIDEOGRAPHER:  We are going off

         5     video record at 3:43.

         6                    (Discussion off the record)

         7               VIDEOGRAPHER:  We are back on video

         8     record at 3:48.

         9               MS. SHAPIRO:  I think we can avoid

        10     problems over hypotheticals.  I will let the

        11     witness answer questions that go to his

        12     general practice.  If you can formulate the

        13     question in that way.

        14               BY MR. KLAYMAN:

        15          Q    If, in the course of your duties

        16     and responsibilities at the White House, you

        17     learned that material information which you

        18     provided to the press was incorrect, and if a

        19     correction of that information would harm the

        20     presidency, would you still release it to the

        21     press?

        22          A    The presidency as an institution?









                                                             297
         1          Q    The President.

         2               MS. SHAPIRO:  Object to the

         3     hypothetical.  I'm not sure -- was there an

         4     agreement that you would phrase this --

         5               MR. KLAYMAN:  I am not going to

         6     stipulate to you on a question.

         7               MS. SHAPIRO:  It is an objection to

         8     the form of the question.

         9               MR. KLAYMAN:  All of these things

        10     as you may or may not know Ms. Shapiro, if my

        11     question is improperly phrased or improper

        12     legally, it will never come into evidence at

        13     any trial.  You have that right.

        14               The only objection you have to

        15     register right now is objection as to form.

        16     Your objection as to substance under the

        17     Federal Rules of Civil Procedure are

        18     preserved.

        19               This is discovery.  I am entitled

        20     to get his state of mind, his course of

        21     conduct and those types of things.

        22               MS. ZIEGLER:  That is a form









                                                             298
         1     objection, just for the record.  She was

         2     objecting.  That is a proper objection she

         3     needs to make now.

         4               MR. KLAYMAN:  That is fine, make

         5     it.

         6               MS. SHAPIRO:  We can avoid disputes

         7     about this sort of thing and in cooperation

         8     if you can phrase your questions in terms of

         9     general practice.

        10               MR. KLAYMAN:  I am.  But I will ask

        11     the questions that I want to not the way you

        12     want.

        13               BY MR. KLAYMAN:

        14          Q    If the this course of your duties

        15     and responsibilities in the White House, you

        16     learned of information that has been provided

        17     to the press that turns out to be inaccurate;

        18     do you feel duty bound to correct that with

        19     the press?

        20          A    As a matter of general conduct,

        21     yes.  Any good press person would want to

        22     maintain his or her own credibility and









                                                             299
         1     integrity and the public's right to accurate

         2     information.

         3          Q    You would make that correction even

         4     if it had a negative impact on the President?

         5          A    Over time, it is worse, far more

         6     negative impact, is if inaccurate information

         7     is out there, so yes.  As the general course

         8     of practice, yes.

         9          Q    Has anyone ever directed you at the

        10     White House not to make a correction of

        11     inaccurate information?

        12          A    Not that I can recall, no, sir.

        13          Q    So you don't know one way or the

        14     other?  You can't remember?

        15          A    I am saying to the best of my

        16     recollection, the answer is no.

        17          Q    Why is it when I ask you tough

        18     question all of the sudden the best of your

        19     recollection pops into the question?

        20          A    Because I am acutely aware I am

        21     under oath.  I wanted to be as completely and

        22     fully accurate as I can be while still being









                                                             300
         1     cooperative.

         2          Q    When you say to the best of your

         3     recollection, does that mean your mind can

         4     temporarily go blank?

         5          A    No.  It mean at this moment in time

         6     I am searching my memory and cannot recall a

         7     single time anyone has asked me to do so.  I

         8     think that is only fair that I am under oath.

         9          Q    If you were to learn that, in fact,

        10     Governor Clinton did have an affair with

        11     Jennifer Flowers, would you feel duty bound

        12     to correct that, currently?

        13               MS. SHAPIRO:  Objection,

        14     hypothetical.  Relevancy.

        15               BY MR. KLAYMAN:

        16          Q    Yes or no?

        17               MS. SHAPIRO:  Answer as to your

        18     general practice.

        19               THE WITNESS:  As a general

        20     practice, if inaccurate information is out

        21     there, part of my obligation is to correct

        22     it.  I would say in the instance you used for

 

 

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