301 1 your lie hypothetical, I am not going to 2 accept the hypothetical as real. 3 In other words, the President has 4 said that his testimony, which is under seal 5 and I have never seen, and his comments in 6 the '92 campaign are not inconsistent. I 7 have seen nothing, I have seen suggestion and 8 allegations to the contrary, but I have no 9 knowledge. 10 BY MR. KLAYMAN: 11 Q Suppose I have the deposition and I 12 showed it to you and it said in that 13 deposition -- 14 A Wouldn't that be a violation? 15 Wouldn't that be a violation? 16 MS. SHAPIRO: Objection. 17 THE WITNESS: Wouldn't that be a 18 violation? 19 MR. KLAYMAN: Of what? 20 THE WITNESS: Rule 68? 21 BY MR. KLAYMAN: 22 Q I don't have it, but I say suppose 302 1 I did. It wouldn't be a violation if 2 somebody gave it to me in the proper way. We 3 moved to get that deposition. The judge may 4 grant our request to get it. 5 If I was to show it to you -- 6 A Sealed depositions can just go to 7 people who are not party to -- 8 Q Sure, if it as public record. 9 A Apparently, everybody leaks 10 everything except to me. I have not seen 11 anything of the deposition. I have seen all 12 kinds of wild speculation about it, but I 13 have seen the President say, what I said 14 in '92 and what I said under oath are not 15 inconsistent. 16 MR. KLAYMAN: I am asking a simple 17 question. I want to know what your ethical 18 responsibility is vis-a-vis your 19 responsibility to the President. I am 20 entitled to know, based upon, not just your 21 general course of conduct, but statements 22 here that you do try to do what is right and 303 1 truthful. 2 What I am asking you is simple. 3 Whether you actually saw the deposition and 4 saw in black and white that the President had 5 said I had had an affair with Jennifer 6 Flowers, would you then, on your own, correct 7 that with the media? 8 MS. SHAPIRO: Object to form. 9 THE WITNESS: The hypothetical 10 requires me to assume something that I know 11 is false, that I believe is false. 12 BY MR. KLAYMAN: 13 Q Under law you have to assume it to 14 be true? 15 A Why? 16 Q For purposes of this answer. 17 A I am literally mystified. Why do I 18 have I to assume something as true with all 19 of the information that I have tells me that 20 it is false. 21 Q Are you refusing to answer the 22 question? 304 1 A I am trying to understand the 2 question. 3 Q Are you refusing to answer the 4 question? 5 A I am trying to understand the 6 question. You asked me about a general 7 course of practice, which I am perfectly 8 willing to outline. That is again -- as a 9 general course of practice, any good 10 spokesperson with the press would want to 11 correct the record. 12 If it might indulge myself, if you 13 found out that I told a joke and you went on 14 national television and told them that I 15 committed a felony, would you correct that? 16 Because MSNBC did. 17 Q I am taking the deposition. 18 A I know. You have particular 19 knowledge of this as well. You deal with the 20 press, too. 21 Q Will you answer my question or not? 22 MS. SHAPIRO: Let's calm down and 305 1 stop shouting and let's try to resolve these 2 issues. 3 If you can phrase your question in 4 a way that doesn't improperly pose the 5 question, I think Mr. Begala can answer. 6 MR. KLAYMAN: Either he answers the 7 question or I am moving for sanctions. I 8 will certify this question. Are you telling 9 him not to answer? 10 MS. SHAPIRO: He answered the 11 question. 12 MR. KLAYMAN: He has not answered 13 the question. Certify it, we will be moving 14 for sanctions. I will ask it again. Let's 15 see if he comes up with it now. 16 BY MR. KLAYMAN: 17 Q If, in the course of your duties at 18 the White House, you learned that the 19 President had testified in the Jones case 20 that he did have an affair with Jennifer 21 Flowers, would you feel duty bound to correct 22 that? 306 1 A As a general practice, anyone who 2 deals with the press ought to have a duty to 3 correct the record where there is inaccurate 4 information. 5 Again, I just will not buy the 6 assumption in your question that what I 7 believe to be true is, in fact, false, 8 because I have seen nothing that would lead 9 me to that. 10 Q Have you asked anyone whether, in 11 fact, the President did have an affair with 12 Jennifer Flowers? 13 MS. SHAPIRO: Objection, relevancy. 14 BY MR. KLAYMAN: 15 Q You can respond. 16 A I been asked, I remember in 1992 17 the President saying -- the Governor then -- 18 saying that this woman's allegations were 19 false. 20 Q Have you asked recently, this year? 21 A I cannot remember raising it 22 recently. It is a long time ago this 307 1 allegation was made. 2 Q You can't remember that one either? 3 A I remember the President saying 4 that what he said under oath and said in 1992 5 are not inconsistent. I have seen nothing 6 that would disabuse me of that. 7 Q But you haven't asked recently? 8 A I have been asked by the press -- 9 Q Have you asked recently? 10 A The President has been asked. 11 Q Have you been asked? Have you 12 asked recently whether there was an affair 13 with Monica Lewinsky? 14 MS. SHAPIRO: That was not the 15 question that was asked. 16 BY MR. KLAYMAN: 17 Q I am sorry, Jennifer Flowers. Have 18 you asked recently whether the President had 19 an affair-- 20 A I have been asked. I cannot 21 remember asking anyone because there is a 22 deposition that is under seal that is the 308 1 subject of an enormous amount of speculation. 2 So I am asked about it quite a bit. 3 I remember the President saying, 4 what I said in 1992 and what I said under 5 oath are not inconsistent. I have not seen 6 anything to the contrary. To take your idea 7 should something come up to the contrary, the 8 record ought to be corrected, yes, sir. 9 But I have not seen, I don't want 10 your hypothetical to allow the suggestion or 11 implication that I believe the assumption 12 that you -- 13 Q No one ever asked you to do that. 14 Unfortunately it took half an hour to get the 15 response. 16 A It is very important to me. 17 Q It is a cathartic experience. 18 A It important to me that people 19 understand that you understand that. 20 Q You are aware, aren't you that 21 pleadings have been filed in the Jones case 22 where the President's deposition is quoted 309 1 publicly? Are you aware of that? 2 MR. ANDERSON: Do you want to -- 3 MR. KLAYMAN: This not for you to 4 interrupt my deposition. 5 MS. PAXTON: I would like to confer 6 with counsel, please? 7 MR. KLAYMAN: You are not counsel 8 of record here. 9 MS. SHAPIRO: She is the client. 10 MS. PAXTON: I would like to confer 11 with my counsel. We will take a very brief 12 break. 13 VIDEOGRAPHER: We are going off 14 video record at 3:57. 15 (Discussion off the record) 16 VIDEOGRAPHER: We are back on video 17 record another 4:02. 18 BY MR. KLAYMAN: 19 Q I just asked a simple question. If 20 you were aware that there were pleadings 21 filed in the Jones case on the public record 22 that contained portions of the President's 310 1 deposition? 2 A No, sir. I thought the deposition 3 was under seal. 4 Q Did you ever discuss politics with 5 Craig Livingstone? 6 A Not that I can recall, no, sir. I 7 thought he was on permanent staff of the 8 White House security team. 9 Q Was there a controversy that brewed 10 over the issuance of your temporary pass 11 during the first administration? 12 A Yes, sir. 13 Q What was that controversy about? 14 A My the recollection is that 15 Congressman Wolfe raised an objection that I, 16 and other political consultants, had access 17 to the White House and had not been through 18 an FBI background check. He made reference 19 to the Alger James spy situation and said, we 20 don't know if these people are spies. 21 The press raised questions as to 22 whether we had lobbied. We didn't lobby. 311 1 Obviously we are not spies. 2 I thought, and so did James and the 3 Chief of Staff, that actually Congressman 4 Wolfe made a fair point and we should subject 5 ourselves to FBI background checks. I 6 voluntarily, as did Carville and the others 7 disclose to the press all of our sources of 8 income and clients in the interest of full 9 disclosure. 10 Q In that context, did you ever have 11 any contact with Craig Livingstone or Anthony 12 Marceca? 13 A Not that I remember. Much later 14 when I turned in my pass I may have turned it 15 over to Livingstone, but I don't remember. 16 Q Did you ever talk about the issue 17 of the temporary passes with Hillary Clinton? 18 A With Mrs. Clinton? 19 Q Yes. 20 A Not that I can recall, sir. 21 Q During all of your conversations 22 with her, have you ever heard her use 312 1 Livingstone's name? 2 A Not that I can recall, sir. 3 Q Can't remember? 4 A Not that I can recall. I didn't 5 know the guy very well, so it would be 6 unlikely. 7 Q Who was the one who made the 8 decision to revoke your temporary White House 9 pass? 10 A I think it was Leon Pinetta, Chief 11 of Staff. 12 Q Did you ever discuss Livingstone or 13 Marceca with Leon Pinetta? 14 A Not that I recall. 15 Q You don't remember? 16 A I can't imagine that I did. 17 Q You have discussed the FBI files 18 matters with Leon Pinetta? 19 A Not that I recall. 20 Q Do you recall him giving an apology 21 to the American people over the files matter? 22 A No, sir, but I was living in Texas 313 1 at the time, and I wasn't following it very 2 closely. Nor was I in very close touch with 3 Leon. 4 Q You and I have debated each other 5 on television from time to time, correct? 6 A Yes. 7 Q We debated even when you were down 8 in Texas living there? 9 A Yes. 10 Q So you could keep up to date on 11 what was going on in Washington. 12 A I tried to as best I could. I 13 found my greater strength though was that I 14 wasn't immersed in the minutia of the 15 Beltway. I did a better job, maybe its 16 hubris, but I thought I did a better job 17 being further away and less tied down to 18 every insider angle. 19 Q What newspapers did you read in the 20 ordinary course when you were in Texas? 21 A The Austin American Statesmen, 22 which is my local paper. I read the Dallas 314 1 Morning News, would generally read the New 2 York Times and occasionally, infrequently 3 read the Wall Street Journal. 4 Q You continued to consult with the 5 White House during the period you were down 6 in Texas? 7 A No, sir, I did not. I was a friend 8 of people who worked there, but no, I did not 9 consult with the White House while I was in 10 Texas. 11 Q Have you ever met an FBI agent? 12 A Yes, sir. 13 Q Which one or ones have you met? 14 A I can't remember the names, but I 15 have had security checks. 16 Q In context of your working with the 17 White House, Clinton White House? 18 A Yes, sir. 19 Q Do you remember, have you ever met 20 Gary Aldridge? 21 A Not to my knowledge. 22 Q Did you ever meet Dennis 315 1 Scolengreenie? 2 A Not to my knowledge, no, sir. You 3 asked me that this morning. 4 Q Have you ever discussed with 5 anybody in the White House the issue of Gary 6 Aldridge's book, Unlimited Access? 7 A I remember Stephanopoulos going on 8 TV and criticizing it. I can't remember if I 9 talked to him about it. Again, I was living 10 a long way away. 11 Q Has the issue come up recently at 12 the White House, Gary Aldridge's book? 13 A No, sir, not that I recall. 14 Q Has anyone planning to file a 15 lawsuit again Mr. Aldridge? 16 A Not that I am aware of. No, sir. 17 Q It has been threatened in the past? 18 A That is news to me. 19 Q Do you know Howard Shapiro of FBI 20 fame? 21 A Not that I know of. 22 Q You never met him? 316 1 A Not that I can recall. 2 Q You are not sure, you may have met 3 him? 4 A Again, in the course of public life 5 you meet a lot of people, but I don't 6 remember meeting Howard Shapiro from the FBI. 7 Q Did you ever go into the vault in 8 the office of personnel security? 9 A No, sir. I never heard of any such 10 thing. 11 Q Do you know of anyone who did? 12 A No, sir, I didn't know that there 13 was one. 14 Q Are you aware that Craig 15 Livingstone an Anthony Marceca had a bunch of 16 interns that worked with them? 17 A No, sir, I was not. 18 Q Have you ever met Monica Lewinsky? 19 A No, sir, not to my knowledge. 20 Q How often do you see the President 21 on a weekly basis, currently, roughly 22 speaking? 317 1 A Most business days. 2 Q Once or twice or how many times? 3 A A week or a day? 4 Q A day? 5 A Generally, once or twice a day. 6 Q When do you generally see him the 7 first time during the day? 8 A Before his first public or press 9 appearance. 10 Q What is the purpose of your seeing 11 him? 12 A I am part of a team of people who 13 help prepare him before he makes public and 14 press announcements, speeches, press 15 conferences, those sorts of events. 16 Q What time of the day do you 17 generally meet with him initially? 18 A It varies depending upon what time 19 an event has been scheduled for. 20 Q Is it generally early? 21 A No, no, sir. He is not a morning 22 person. 318 1 Q What time does he generally arrive 2 to work? 3 A He doesn't meet with anybody or us, 4 I don't really know. But we try to schedule 5 news events around 10:00 a.m. to 2:00 p.m. 6 which is a slot which makes it most 7 convenient for the news people covering us. 8 Q The press reports that he gets up 9 at 5:00 a.m. are incorrect? 10 A Oh, I don't know. When I traveled 11 with him, that was not the case. That was 12 six years ago though. 13 Q How long do you meet with him 14 generally in preparing him, just roughly 15 speaking? 16 A Roughly 10 to 15 minutes. 17 Q If you meet with him later in the 18 day, when is that? 19 A Only if there would be some 20 subsequent public event. There are days that 21 we do more than one event in a day. 22 Q What is your working day? When do 319 1 you start? 2 A I start work about 7:30, I come in 3 much earlier so I can run. 4 Q When do you leave generally? 5 A Generally about 7:15, 7:30 in the 6 evening. Some nights, later. 7 Q In your office do you have a 8 television? 9 A Yes. 10 Q Do you have more than one? 11 A No, sir. 12 Q Split screen or anything so you 13 could see all of the those at the same time? 14 A No, just a little, maybe 13 inch. 15 Q What is your favorite show during 16 the day? 17 A I generally watch CNN, but I 18 sometimes watch MSNBC and am surprised by 19 what I see. 20 Q Whenever I am on, you watch. 21 A I happened to catch you. 22 Q Thank you, I appreciate that. 320 1 That is part of your job is to 2 monitor what is being said in the press? 3 A It is important for me to know what 4 is going on TV, I think. 5 Q Since you returned to the White 6 House, have you ever heard of the phrase FBI 7 files from any source inside the White House? 8 A I can't remember conversation about 9 FBI files or their use or misuse. I do know 10 that there is an ongoing controversy. In the 11 last few days I have obviously learned a lot 12 more about it from you. But I can't remember 13 any other conversations about that topic. 14 Q Have you ever discussed opposition 15 research with Mrs. Clinton? 16 A Not that I can recall. 17 Q The President? 18 A I imagine before he was President, 19 for his campaign in 1992. 20 Q During the time that you have been 21 with the White House, beginning this year? 22 A Not that I can recall. But again 321 1 let me -- one more time restate what I mean 2 by that. 3 What I mean is statements and votes 4 and quotes on the public record. That is the 5 opposition research that wins elections and I 6 think that is the opposition research or 7 favorable positive research that advances 8 public issues. 9 I do not like any of the attacks on 10 the people's private lives. I have seen the 11 President subjected to more of that than 12 anybody ever ought to survive or ought to go 13 through and still survive. So I don't want 14 to see anybody else dragged through that. 15 Q So you will never, ever, for the 16 rest of your life in Washington, ever mention 17 any aspects of an adversary's private life? 18 A I try very hard. We all fall 19 short. I try very hard for that. I'm sure 20 you will, if you talk to the people that I 21 work with or reporters that I deal with, I 22 think they will tell you that I don't traffic 322 1 in people's private lives. 2 I work on, I hit very hard, we have 3 been on TV against each other. I believe in 4 rough, tough politics, but I don't like the 5 direction that some people are trying to 6 take -- 7 Q I believe you called me a right 8 wing nut? 9 A Yes, to me that is sort of 10 acceptable hyperbole. It is not about your 11 private life. 12 Q It is all right to call me a nut? 13 A You have probably called me a lot 14 worse. 15 Q I never called you a name. 16 A Yeah right. Ad hominum, you bet. 17 I think the body politic is very resilient, I 18 think we can take that. 19 I do not, though, endorse the kinds 20 of attacks that have been made against the 21 President. 22 Q I guess that is left to Sidney 323 1 Blumenthal to discuss private lives? 2 A Not to my knowledge, no, sir. 3 Q Have you ever discussed opposition 4 research with James Carville during the 5 period after you returned to the White House? 6 A It is a campaign function. Again, 7 by which you mean -- 8 Q Carville made a statement recently 9 that it was time to wage war against 10 Clinton's adversaries, correct? 11 A No, my recollection was he was 12 specific about Ken Starr. 13 Q You discussed that with him, the 14 statement with Ken Starr? 15 A I can't remember discussing it with 16 him. But I remember James saying that. 17 Q What did he say about how he was 18 going to wage war? 19 A He has been very public in his 20 criticisms of Judge Starr. 21 Q You did discuss with him how he was 22 going to wage war, did you not? 324 1 A I don't remember talking that 2 particular phrase with him. He made no 3 secret. You don't have to talk to him to 4 though the criticisms he has about Ken Starr. 5 Q How is he going to wage war? 6 A He has taken to the public air 7 waves. He goes on any number of TV shows. 8 He attended a breakfast with 30 reporters, in 9 the last couple of weeks. By publicly 10 mounting the podium and speaking out. 11 Q Now, he made statements in the last 12 week and a half, mocking Ken Starr's 13 religious beliefs, has he not? 14 A I would rather let James talk about 15 that. 16 Q You have read that, have you not? 17 A I don't know if I would 18 characterize them that way. 19 Q The Style section of the Washington 20 Post? 21 A I don't want to characterize. 22 Q That Ken Starr was going to, in the 325 1 context of his religion, drive all of the 2 fornicators out of Washington? 3 A I don't know if that was about his 4 religion but I think many critics have seen, 5 what the Washington Post reported was Starr's 6 effort to probe into the President's private 7 life, months ago -- six months ago. 8 Q Were you present when Carville made 9 those remarks? 10 A No, it was, I think at a press 11 conference of some sort. 12 Q Do you approve of making fun of 13 someone's religion? 14 A I don't think James was making fun 15 of someone's religion. He is a religious 16 person himself. We all try our best. I 17 don't want to characterize him, though. 18 Q So if he is making fun of the 19 worship of subpoenas, that is not making fun 20 of religion? 21 A No. I think that there have been 22 too many subpoenas thrown around. I think 326 1 that is a fair criticism. I don't see how 2 that gets to anybody's religious beliefs. 3 Q Did you discuss with James Carville 4 the war against Ken Starr by using 5 investigators? 6 A No, sir. I don't recall any such 7 conversation. 8 Q You may have had one, but you don't 9 remember? 10 A I don't remember ever having one. 11 Again, James' comments have been as public as 12 they can be. This is not a private thing 13 that he is doing. It is a public as it can 14 possibly be. 15 Q It makes it okay because it is 16 public? 17 A It makes its public. I have not 18 heard any discussion -- had any discussion 19 about anything except what he said in public. 20 Q Have you ever met Randy Turk? 21 A The name does not ring a bell. 22 Q Lawyer of Mr. Livingstone? 327 1 A No. 2 Q Gary Cohen, lawyer of 3 Mr. Livingstone? 4 A Not that I can recall, no, sir. 5 Q Have you ever talked to David 6 Watkins? Do you know David Watkins? 7 A David Watkins who used to work in 8 with White House? 9 Q Yes. 10 A I remember him. 11 Q How do you remember him? 12 A I remember he worked in the White 13 House. 14 Q Did you ever meet him? 15 A Yes, sir, I did. 16 Q In what context? 17 A I met him in the '92 campaign. 18 Q What was his job in '92 campaign? 19 A I can't remember. Some 20 administrative function. Carville and I as 21 consultants were not in the direct line of 22 administrating. Campaign, particularly 328 1 presidential, are enormous management 2 undertaking. 3 James and I are better at 4 consulting than managing. So he had some 5 management function, is my recollection. 6 Q Did you ever discuss FBI files with 7 David Watkins? 8 A No, sir, not to my knowledge or 9 recollection at all. 10 Q Are you aware that he has made a 11 statement that Hillary Clinton is the master 12 mind of Filegate or something to that effect? 13 A No, sir, I am not aware any such 14 statement. 15 Q Have you ever met a George 16 Saunders, S-a-u-n-d-e-r-s? 17 A That name does not ring a bell. 18 Q Have you ever met Joanne Hilty, 19 H-i-l-t-y? 20 A The name does not ring a bell. No, 21 sir. 22 Q Do you know Christine Varney? 329 1 A Yes, sir. I do. 2 Q Who is Christine Varney? 3 A She is a commissioner, I think on 4 the Federal Trade Commission. 5 Q Have you ever discussed Craig 6 Livingstone with Christine Varney? 7 A Not to my knowledge or 8 recollection. 9 Q Have you ever discussed FBI files 10 with Christine Varney? 11 A Not to my knowledge or 12 recollection. 13 Q You just don't remember? 14 A I have no recollection of any 15 conversation about the FBI file matter. It 16 was an issue that erupted when I was living a 17 long way away. While I like her, I have not 18 kept up our friendship over the years. 19 Q Do you know whether Ms. Varney has 20 retained Mr. Livingstone as a an employee? 21 A I have no idea. I thought she was 22 on the Federal Trade Commission. 330 1 Q Do you know whether Ms. Varney ever 2 hired or interviewed Mr. Livingstone? 3 A I have no idea. No, sir. 4 Q Do you know Cheryl Mills? 5 A Yes. 6 Q When did you first get to know her? 7 A I guess when she was working in the 8 White House. I can't recall. 9 Q What was her position at the time? 10 A I can't recall. She is in the 11 office of White House counsel now, maybe she 12 was then. I can't remember. 13 Q Did you ever discuss 14 Mr. Livingstone with her? 15 A Not to my knowledge or 16 recollection. 17 Q Did you ever discuss the FBI files 18 matter with her? 19 A Not to my knowledge or 20 recollection. 21 Q You can't remember? 22 A No, I do not recall any 331 1 conversations about the FBI file matter. It 2 was not a matter I worked on and I have no 3 knowledge of the use or misuse of FBI files. 4 Q Do you know who Mari, M-a-r-i, 5 Anderson is? 6 A The name does not ring a bell. 7 Q If I told you that she worked in 8 the Inspector General's office of the 9 Treasury Department, does that refresh your 10 recollection? 11 A No, sir, it does not. 12 Q Are you aware of two FBI agents 13 that she ordered investigated at the Treasury 14 Department? 15 A No, sir, I am not. 16 Q I am sorry. 17 Have you ever heard of Valerie 18 Lowe? 19 A The name does not ring a bell. 20 Q I inserted names. If I were to 21 tell you she worked in the Inspector 22 General's office of the Treasury Department, 332 1 would that refresh your recollection? 2 A No, sir. 3 Q Are you aware of two FBI agent that 4 were involved in the Filegate matter being 5 investigated at Treasury? 6 A No, sir, I was not aware of that. 7 Q I will show you what I will ask the 8 court reporter to mark as Exhibit 12. 9 (Begala Deposition Exhibit 10 No. 12 was marked for 11 identification.) 12 BY MR. KLAYMAN: 13 Q Showing you Exhibit 12, this is an 14 article from the Washington Post, Steven Barr 15 is the author dated January 17, 1998. Take 16 an opportunity to read that quickly. 17 A Yes, sir. 18 Q Does that refresh your recollection 19 about whether you know a Valerie Lowe or have 20 ever talked with her? 21 A No, sir. 22 Q Know of her existence on earth? 333 1 A I can never remember hearing about 2 her before. 3 Q Have you ever heard about an FBI or 4 Secret Service agent by the name of John 5 Libonati, L-i-b-o-n-a-t-i? 6 A No, sir. The name does not ring a 7 bell. 8 Q Another Secret Service agent by the 9 name of Jeffrey Undercoffer, 10 U-n-d-e-r-c-o-f-f-e-r? 11 A No, sir, the name does not ring a 12 bell. 13 Q What is Public Strategies, Inc.? 14 A PR -- a strategic communication 15 firm, they would prefer to be called rather 16 than PR. A strategic communication firm in 17 Austin, Texas. 18 Q Until recently joining the White 19 House, in August, 1997, is that where you 20 worked? 21 A Yes, sir. 22 Q Did you also teach school at 334 1 University of Texas? 2 A I taught journalism, believe it or 3 not, at the University of Texas. 4 Q Did you teach your students to 5 correct the record if they had inaccurate 6 information? 7 A We discussed a number of ethical 8 conundrum, including, I can't remember that 9 particular topic, but any number of things. 10 And I team taught with a career 11 reporter of great distinction, so the 12 students would get both sides of the 13 practical press politics relationship. 14 Q Who was that team reporter? 15 A Dave McNeely. 16 Q Where does he work? 17 A The Austin American Statesman, he 18 is their chief political writer. 19 Q How is that spelled? 20 A M-c-N-e-e-l-y. 21 Q Did you ever discuss the Clinton 22 White House? 335 1 A Yes, sir. In our class we talked 2 about issues of the day which invariably 3 revolved around the '96 campaign and press 4 coverage thereof. 5 Q Were any of the classes which you 6 taught taped? 7 A I don't know. Perhaps. 8 Q Do you know whether the White House 9 has a taping system in common areas? 10 A Not to my knowledge. No, sir. 11 Q Do you know whether there is a 12 video surveillance system in the White House? 13 A Not to my knowledge, no, sir. 14 Q Has anyone asked that question 15 recently, to the best of your knowledge? 16 A No, sir, not to the best of my 17 knowledge. 18 Q I am starting to talk like you to 19 the best of your knowledge. After this is 20 over I am not going to be able to ask a 21 question without, to the best of your 22 knowledge. 336 1 A I am trying to be as perfectly 2 accurate as I can. 3 Q Who owns Public Strategies, Inc.? 4 A Jack Martin. 5 Q Who is Jack Martin? 6 A The guy who owns the company. I 7 don't mean to be flip. There are a few other 8 small -- 5 percent or so, but Jack owns, to 9 my knowledge, 85 percent of it. He is a very 10 successful businessman in Austin. 11 Q Have you ever discussed the Clinton 12 White House with Jack Martin? 13 A Yes, sir. 14 Q Have you ever discussed the FBI 15 files matter with him? 16 A No, sir. Not to my knowledge or 17 recollection. 18 Q Did you recount your experiences 19 from time to time with Jack Martin at the 20 Clinton White House? 21 A From time to time. He is an 22 experienced political person himself. 337 1 Q Are you still in contact with him? 2 A Occasionally. 3 Q Does he call you from time to time 4 at the White House? 5 A Once or twice in the last six 6 months. 7 Q Do you tell him what is going on? 8 A Just, he calls and checks in. He 9 is a friend of mine, former colleague. 10 Q Is this firm dedicated to helping 11 Democrats as opposed to others? 12 A No, sir. They do no political 13 work. Many of the senior people there worked 14 for President Bush. That is one of the 15 reasons I do say there are some good 16 Republicans out there, because some of the 17 senior people in that firm were senior people 18 in the Bush White House. I came to find them 19 to be people of very high integrity. 20 Q Besides Mary Matalin, who are the 21 good Republicans. 22 A I can name you a few. David Bates, 338 1 Fred McLure, Jean Johnson Phillips. Three 2 top people either with Governor Bush, or 3 Bates and McLure's case, President Bush. 4 Q Was Bob Barr on of the good 5 Republicans? 6 A I don't know Congressman Barr. I 7 am not a fan of his however. 8 Q Henry Hyde? 9 A I have met Henry Hyde just once and 10 I was very impressed with him. 11 Q I guess you are a fan of Newt 12 Gingrich? 13 A You have to admire his skill, but I 14 do not agree with his ideology. 15 Q His skill to weasel his way out of 16 difficulty? 17 A No, sir, but for him I don't think 18 they could have recaptured the House, the 19 Republicans. I admire talent. 20 MR. KLAYMAN: I will show you what 21 I ask the court reporter to mark as 22 Exhibit 13. 339 1 (Begala Deposition Exhibit 2 No. 13 was marked for 3 identification.) 4 BY MR. KLAYMAN: 5 Q I will show you Exhibit 13. We 6 will staple it later. 7 Look at the last page. James 8 Carville Just Itching for a Subpoena. 9 This is a report that is contained 10 in Exhibit 13 from The Reliable Source of the 11 Washington Post, February 27, 1998. I am 12 reading the last page. 13 "James Carville has had a bad case 14 of subpoena envy. The former political 15 consultant for President Clinton has been the 16 leading basher of Ken Starr for years, but 17 who gets the subpoena for mud slinging? 18 White House aide Sidney Blumenthal. It is 19 not fair. 20 "So Carville has practically been 21 begging Starr for a subpoena of his own. On 22 Tuesday he mocked Starr's worship practices 340 1 during the reporter's breakfast chortling 2 about the prosecutor listening to him and 3 praying to `wash all of the sodomized and 4 fornicators out of town'." 5 You are aware Mr. Carville made 6 those statements? 7 A I am. 8 Q Do you approve of them? 9 A It is not for me to pass judgment 10 on James. 11 Q Would you make a statement like 12 that? 13 A I probably would not. 14 Q He is mocking Starr's worship 15 practices? 16 A I don't think so. He is pointing 17 out something that I do find chilling, and I 18 have commented on. Six months ago the 19 Washington Post reporter, Bob Woodward, that 20 Starr was investigating, had Bill Clinton's 21 private life. His sex life and the sex life 22 of innocent Americans. 341 1 I find that deeply problematic and 2 troubling. I think James is trying to call 3 attention to an unfair inquisition into 4 people's private lives. 5 Q What does that have to do with 6 Starr's worship practices? 7 A You ought to ask James, he is, 8 believe me, more capable than I am, of 9 defending himself. 10 Q You would not do that, would you? 11 A It is different strategies. 12 Q I am trying to figure out -- 13 A He is trying to calling attention 14 to what I think is a very important issue. 15 Six months before anybody had heard the 16 current accusations Bob Woodward reported, 17 and he may be wrong, but Bob reported, and it 18 was unchallenged, that Starr and his 19 investigators were prying into people's 20 private lives. 21 I do not approve of that any more 22 than prying into anybody's private life. I 342 1 think James is trying to call attention to it 2 there. He is doing it is in the classic 3 Carvillian fashion. It gets attention. 4 Q Did you know, before James, I guess 5 it is Carville not Bond -- did you know he 6 was going to make this statement? 7 A No, sir, I did not. I assure you 8 he had no idea he was going that make it 9 until it fled out of his mouth. I have been 10 in business with him 12 or 13 years and -- 11 Q Is he on retainer? 12 A Not that I know of. 13 Q He might be? 14 A I would doubt it, I would doubt it. 15 Q Has the White House issued any 16 statement disclaiming Carville's mocking of 17 Starr's religious practices? 18 A Not that I know of. 19 Q Has that been discussed? 20 A No, sir, not that I know of. 21 Q Are you aware that Carville has 22 called me a little twerp? 343 1 A That is more fair. You know, he 2 ought to be able to, I am for name calling. 3 I am not going to sanctimonious. I do it 4 myself. I think people out to be robust and 5 have a thick skin. 6 Q Did you agree I am a little twerp? 7 A I am under oath. 8 Q In which case you should be 9 emboldened to answer? 10 A I am under oath. 11 Q What did you do for the Democratic 12 National Committee between January of '93 and 13 August of '95? 14 A A variety of tasks. Principally 15 advised the President and his political aides 16 on politics. 17 Q Were you in any way involved in 18 fundraising? 19 A I attended fundraisers or would 20 speak at them but did not solicit 21 contributions. 22 Q Did you deal at all with Marvin 344 1 Rosen? 2 A I met him. 3 Q You mean recently in Miami when you 4 were down there talking about FBI files? 5 A I did not talk to him in Miami when 6 I was making jokes that were absurd in their 7 falsity. 8 Q Have you ever been met John Wong? 9 A Not to my knowledge. 10 Q You are not sure? 11 A Not to my knowledge. I have no 12 recollection of meeting him. 13 Q Did you ever meet Charlie Trie? 14 A Not to my knowledge. 15 Q Johnny Chung? 16 A Not to my knowledge. 17 Q You state that you were special 18 government employee while you assisted in 19 efforts to pass the President's economic 20 plan. 21 What is a special government 22 employee in your opinion? 345 1 A In my opinion is someone who 2 directs employees of the White House or has 3 some management or line authority, who has a 4 phone and/or a desk someplace where he or she 5 works. That is a distinction that I was 6 told, as opposed to a consultant which I have 7 generally been. 8 There were a few weeks where my 9 involvement was so heavy, that counsel's 10 office at the time thought it would be best 11 that I be designated as a special government 12 employee. 13 Q As a special government employee, 14 who told you that you should be designated as 15 a special government employee? 16 A White House counsel at the time, 17 one of the deputy councils. 18 Q Was it Hillary Clinton? 19 A My recollection was its was Beth 20 Noland. 21 Q Does Hillary Clinton, based upon 22 your experience with her, consider herself to 346 1 be a special government employee? 2 A I have no idea. I have never had 3 that conversation. This was in furtherance 4 of the President's economic plans which is 5 not something Mrs. Clinton was front and 6 center on. 7 Q You state in your affidavit, 8 paragraph 5, "in fact, I have no information 9 to suggest that any individual in the White 10 House has used FBI background files for any 11 improper purpose." 12 A Yes, sir. 13 Q Did you write that yourself? 14 A I reviewed it and signed it. 15 Q Who wrote it? 16 A I don't know. 17 Q Who handed it to you to sign? 18 A Ms. Paxton from counsel's office. 19 Q Did you ask her who wrote it? 20 A No, sir. 21 Q Did you meet with anyone in the 22 counsel's office before this affidavit was 347 1 prepared? 2 A Yes, sir. 3 Q Who was that? 4 A Ms. Paxton. 5 Q When did you meet with her? 6 A Last day or two when that was -- 7 after you served notice, before I came here. 8 Yesterday. Before that, when we executed the 9 affidavit. 10 Q Where did your meeting take place? 11 A In her office. 12 Q Where is that, in the White House? 13 A In the Old Executive Office 14 building. 15 Q How long did you meet for? 16 A I can't recall. I went over that 17 at some -- I mean I wanted to make sure that 18 this did reflect my knowledge. Again I will 19 say it and I signed an oath. I don't have 20 any knowledge of the use or misuse of the FBI 21 files. 22 Q I am just staying on these issues, 348 1 we will get to that. 2 A That is what you asked about. 3 Q You said it 100 times. 4 A It is very important, because that 5 is what I have been called here for. 6 Q It's on the record. I know you 7 know nothing, that is what you claim. I am 8 asking a different question. 9 How long did you meet with 10 Ms. Paxton, that first meeting? 11 A I can't recall. 12 Q Was anyone else present? 13 A No. 14 Q What happened after that, in terms 15 of the affidavit? 16 A It was drafted and presented to me 17 subsequent to that. 18 Q When it was presented to you, who 19 did you meet with? 20 A Ms. Paxton. 21 Q How long was the meeting? 22 A Less than an hour. I can't recall. 349 1 Q Were there any changes suggested to 2 the affidavit? 3 A I remember making changes. I can't 4 tell you what they were, but I remember 5 making some changes. 6 Q What happened at that point? 7 A Someone incorporated them and it 8 was brought back to me. 9 Q Did you make notes of your meeting 10 with Ms. Paxton? 11 A No. 12 Q Did you make notes of either 13 meeting with Ms. Paxton, the first one or the 14 second one when the affidavit was presented 15 to you? 16 A No. 17 Q Was Ms. Paxton making notes? 18 A Not that I recall. 19 Q This was a few days ago? Are you 20 telling me you can't remember if she had a 21 noted pad? 22 A I don't think she was, but I don't 350 1 remember. 2 Q Did you see her with a pen in her 3 hand? 4 A She had an affidavit in front of 5 her and I was going over it with her 6 saying -- 7 (Pause) 8 BY MR. KLAYMAN: 9 Q Did you take notes during these 10 meetings with Ms. Paxton? 11 A No, sir. 12 Q Did you make any kind of notations 13 on the affidavit? 14 A I may well have, or she may have. 15 Q Have you kept drafts of those 16 affidavits? 17 A I have not. 18 Q Who has the drafts? 19 A I left them in her office. 20 Q Who brought you back the affidavit? 21 A I don't know. 22 Q When you signed it? Was it
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of this Deposition