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









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         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?









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         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?









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         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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