51


       1    Florida.  I went through each of the things

       2    he asked for and got like a filing system in

       3    there.  It's not very elaborate or anything

       4    like that.  I don't keep -- you know, we have

       5    anything in there if I've got -- all kinds of

       6    different stuff.

       7         Q    Since you began to work for

       8    Governor Clinton in 1992, have you kept

       9    documents about your involvement with

      10    Governor Clinton and then President Clinton

      11    and the Clinton administration?

      12         A    Not really.

      13         Q    But you kept some, correct?

      14         A    Yeah, some.

      15         Q    Are all of those documents in that

      16    file cabinet or are some stored elsewhere?

      17         A    No.  I mean, everything that I

      18    would have would be in that file cabinet.

      19         Q    You have another residence, do you

      20    not, out in the Shenandoah Valley?

      21         A    I do.

      22         Q    Where is that located?








                                                              52


       1         A    In Warrentown, Virginia.

       2         Q    What's the address?

       3         A    325 Fischer's Road.

       4         Q    You have a little office in that

       5    residence, too, don't you?

       6         A    I wouldn't call it an office.  I'm

       7    not the type of person that really has a -- I

       8    don't have a desk in my office in Washington.

       9    I just don't do that kind of thing.

      10         Q    You don't have a desk in your

      11    office in Washington?

      12         A    I don't, no, sir.

      13         Q    You work on the couch?

      14         A    Yes.

      15         Q    What do you have?  Chairs in there?

      16         A    Well, I got two sofas and I think

      17    there's a couple of chairs, and some people

      18    come in to talk, we just take some chairs

      19    where people that work for me sit.

      20         Q    Do you have a desk out in

      21    Shenandoah valley?

      22         A    No, sir.








                                                              53


       1         Q    Do you have a fax machine?

       2         A    I do.

       3         Q    Sometimes you get faxes there from

       4    your office in Washington, don't you?

       5         A    Sometimes.

       6         Q    Sometimes you get faxes from other

       7    people, correct?

       8         A    Sometimes.

       9         Q    And you have gotten faxes from the

      10    White House there from time to time in

      11    Shenandoah Valley?

      12         A    Maybe, but I doubt it.

      13         Q    And you get faxes in your office or

      14    home on Capitol Hill from The White House

      15    from time to time, don't you?

      16         A    I do.

      17         Q    And you've gotten faxes from Paul

      18    McGowan, George Stephanopolous at both

      19    residences as well, have you not?

      20         A    I don't know.  I would doubt if I

      21    got very much but I obviously couldn't -- you

      22    know, I couldn't say categorically that I did








                                                              54


       1    not.

       2         Q    Where is the paper kept that comes

       3    into your farm?

       4         A    I throw it away or I take it back.

       5    It's usually -- when I get faxes is like

       6    newspaper articles or something even if I get

       7    that and I wouldn't -- most everybody if they

       8    were going to fax me something would fax it

       9    to the office.

      10         Q    Take it back where?

      11         A    To the office.  In other words, I

      12    get mail.  That's where I live, you know, out

      13    there but if I get mail I just take it into

      14    the office.

      15         Q    You cart it into the office on

      16    Capitol Hill?

      17         A    Let me just say if I got any faxes

      18    out there -- I can't tell you that I didn't

      19    because it's possible that somebody faxed me

      20    something.  If they did, 99 percent of the

      21    time I would throw it away.  It would be, you

      22    know, a thing in the paper.








                                                              55


       1              It would be something from Newsweek

       2    or something like that.  If it was something

       3    that required -- like if it was a bill or

       4    something -- it wouldn't be an instance where

       5    somebody would fax that kind of thing to me,

       6    but I don't keep stuff there.  I mean, I'll

       7    be -- you know, I'll be glad to do a due

       8    diligence thing to see, but I know there's

       9    nothing out there.  I just don't -- it's just

      10    not --

      11         Q    What is a due diligence thing?

      12         A    I don't know.  It's just kind of a

      13    word I heard.

      14         Q    Is that what private investigators

      15    do, due diligence?

      16              MS. MARSH:  Objection.

      17         Q    Where do you get that word?

      18         A    I know it from law school

      19    somewhere.  I don't have a file out there or

      20    anything, okay?

      21         Q    But you may have some paper out

      22    there and you didn't search, correct?








                                                              56


       1         A    I haven't been out there.  I

       2    haven't been in town.  I haven't been to the

       3    thing, but I could say I would be more than

       4    delighted to -- I don't have any paper.  I

       5    wouldn't know where to look for a file out

       6    there.

       7         Q    You'd be delighted to do that?

       8         A    Yeah.

       9         Q    Now, in terms of paper that comes

      10    into your Capitol Hill office, have you kept

      11    some from the 1992 campaign?

      12         A    Not really.  I didn't, you know --

      13    I don't have anything in the office from the

      14    '92 campaign.  Most of that stuff is boxed

      15    up, and when I left Little Rock I didn't take

      16    anything with me.

      17         Q    Do you have anything from the 1992

      18    campaign forward that you've kept?  Surely

      19    you must have?

      20              MS. MARSH:  You mean from the end

      21    of the campaign?

      22              BY MR. KLAYMAN:








                                                              57


       1         Q    Your interaction with the Clinton

       2    administration and its friends since then?

       3         A    Yeah.

       4         Q    And where is that kept?

       5         A    In Washington.

       6         Q    So everything would be in the

       7    office up there on Capitol Hill?

       8         A    Mm-hmm.

       9         Q    Any other place where it might be

      10    stored?

      11         A    I would have to ask Todd, you know,

      12    I can't -- I mean, he would --

      13         Q    Todd's the guy that would know?

      14         A    Mm-hmm.

      15         Q    You previously were in business

      16    with Paul Begala, correct?

      17         A    Yes, sir.

      18         Q    Did you ever have a partnership

      19    agreement or anything in writing?

      20         A    I don't think that we ever -- I

      21    think somebody drew one up, and I don't think

      22    we ever signed it or anything like that.  I








                                                              58


       1    think we just kind of operated in a non --

       2         Q    Did you have an office?

       3         A    Yeah.

       4         Q    In Washington?

       5         A    Mm-hmm.

       6         Q    Or elsewhere?

       7         A    Just one in Washington.

       8         Q    Where was your office?

       9         A    329 Maryland Avenue in Northeast.

      10         Q    And who leased that?  Whose name

      11    was on the lease?

      12         A    Me.

      13         Q    Just you?

      14         A    Yeah.

      15         Q    And you must have had file cabinets

      16    in that office, correct?

      17         A    I guess I did.  Yeah, I mean, I'm

      18    sure.

      19         Q    How long did you have that office?

      20         A    From November of '88 -- I used to

      21    live there -- well, actually, no, because it

      22    was in the basement where I lived, and then I








                                                              59


       1    moved upstairs, and I can't tell you -- I

       2    can't remember when I moved upstairs.  It was

       3    all the same building.

       4         Q    Did Begala live there, too?

       5         A    No.

       6         Q    Anybody else?

       7         A    No.

       8         Q    And you had file cabinets there?

       9         A    I don't think we had file cabinets.

      10    I think we had like some things like a

      11    bookcase or something.  I don't know that.  I

      12    really --

      13         Q    Now, did you take the paper that

      14    you stored at that office and take it over to

      15    your newer office?

      16         A    Yeah, we moved over here.  I mean,

      17    maybe they --

      18         Q    And when did you move?

      19         A    I think it was November of '97.

      20         Q    And then you took everything that

      21    you had in files there?

      22         A    Yeah.  Todd, yeah -- yeah.








                                                              60


       1         Q    Todd's the guy?

       2         A    Yeah.

       3         Q    Did Mr. Begala take any paper?

       4         A    He was gone when I moved.  He was

       5    in Texas.

       6         Q    Did he take any paper?

       7         A    Not that I know of.

       8         Q    Clearly Mr. Begala has collected

       9    paper over the years about his involvement

      10    with Governor Clinton and the campaign?

      11              MS. MARSH:  I don't know.

      12              THE WITNESS:  I don't know what

      13    Mr. Begala's done or not done or took or not

      14    took.

      15         Q    You sent him faxes over the years

      16    when he was back in Texas, didn't you?

      17         A    I'm sure I did.

      18         Q    And you sent him letters sometimes?

      19         A    No.

      20         Q    And you sent faxes and other kinds

      21    of written communications to other people

      22    around town, don't you, from time to time?








                                                              61


       1         A    Sure, sometimes I do.  Yeah.

       2         Q    You would have sent some faxes to

       3    George Stephanopolous from time to time,

       4    wouldn't you?

       5         A    It's possible but if it is it's not

       6    very many.  I mean, if there was a --

       7              MS. MARSH:  Can we get some more

       8    water for the witness, please?

       9              BY MR. KLAYMAN:

      10         Q    Want some more water?

      11         A    Yeah.

      12              MR. KLAYMAN:  Do you want a break

      13    or --

      14              MS. MARSH:  No, let's keep going.

      15              BY MR. KLAYMAN:

      16         Q    Have you brought any documents with

      17    you today?

      18              MS. MARSH:  He's brought documents

      19    but they're all covered by the objection.

      20              MR. KLAYMAN:  So you're not

      21    producing any documents?

      22              MS. MARSH:  Not unless you have a








                                                              62


       1    court order.

       2              MR. KLAYMAN:  Well, we will seek

       3    one, Ms. Marsh.

       4              MS. MARSH:  I'm sure you will,

       5    Mr. Klayman.

       6              MR. KLAYMAN:  And our position is

       7    that no such objection was ever served, and

       8    we will be seeking more than that.

       9              MS. MARSH:  No doubt you will.

      10              BY MR. KLAYMAN:

      11         Q    What types of documents did you

      12    bring here today?  Just subject matter?  What

      13    do they relate to?

      14         A    To --

      15              MS. MARSH:  They relate to filegate

      16    and to Judicial Watch.

      17              BY MR. KLAYMAN:

      18         Q    What specifically with regard to

      19    filegate?

      20         A    Well, I don't know --

      21              MS. MARSH:  Let me consult with him

      22    for just a minute.








                                                              63


       1                   (Witness conferred with counsel)

       2              MS. MARSH:  He's willing to waive

       3    the objection to that request, which I

       4    believe on the subpoena was request number

       5    36, and produce to you this file.  And we

       6    need this file back.  So you can mark it and

       7    make copies and have those attached to the

       8    deposition transcript.  That is the original

       9    file.

      10              MR. KLAYMAN:  What documents do you

      11    have with regard to Judicial Watch?

      12              I'll ask that the court reporter

      13    mark as Exhibit 9 the file that says

      14    miscellaneous Gary Aldridge book, Filegate.

      15              MS. PAXTON:  Mr. Klayman, what's

      16    Exhibit 8?

      17              MR. KLAYMAN:  Exhibit 8 is this

      18    file folder.  Exhibit 8 is the map of the

      19    office on Capitol Hill.  Filegate is number 9

      20    and Judicial Watch is Number 10.

      21                   (Carville Deposition Exhibits

      22                   Nos. 8, 9 and 10 were marked for








                                                              64


       1                   identification.)

       2              MR. KLAYMAN:  I'm just going to

       3    identify before we have a copy the documents

       4    which are contained in Exhibit 9.  I'll show

       5    them to you, Mr. Carville.  If you want, if

       6    you can't see them, I'll have them handed

       7    across the desk.

       8              MS. MARSH:  Do you want him just to

       9    read the titles of them?

      10              MR. KLAYMAN:  That will be fine if

      11    Mr. Fitton can be next to him just to make

      12    sure we get everything.

      13              BY MR. KLAYMAN:

      14         Q    I'd like each piece of paper to be

      15    lettered A through whatever it comes out if

      16    you could do that?

      17         A    There's a title page unlimited --

      18    the Gary Aldridge book.

      19              MR. KLAYMAN:  Mark that 9A.

      20              MS. MARSH:  Don't you want the

      21    court reporter to mark it?

      22              MR. KLAYMAN:  That's fine. He can








                                                              65


       1    mark it with his initials next to it.  He can

       2    do it later.  9A with your initials, JC.  And

       3    you can date it.  Date it.

       4              MS. MARSH:  This going to take

       5    forever, Mr. Klayman.

       6              MR. KLAYMAN:  It will not take

       7    forever.  Unfortunately, very little paper

       8    was produced.

       9              THE WITNESS:  What's the date

      10    today?

      11              MR. KLAYMAN:  16th.

      12              BY MR. KLAYMAN:

      13         Q    Next page.

      14         A    Acknowledgments of the Gary

      15    Aldridge book, which is 9B.

      16         Q    9B with your initials and the date.

      17         A    "Gingrich pushes FBI file story."

      18         Q    9C and the date.

      19         A    FBI files look what I found in

      20    mine, an article by Linda Chavez, 9D, initial

      21    and a date.  "Three hundred more files."

      22    Looks like an editorial from The Washington 








                                                              66


       1    Times, 9E.

       2              MS. MARSH:  Initials.

       3              THE WITNESS:  "White House agrees

       4    to say hand over papers."

       5              MS. MARSH:  That's a 2-page

       6    article.  Do you want each page marked

       7    separately?

       8              MR. KLAYMAN:  Yes.

       9              THE WITNESS:  9F.

      10              MS. MARSH:  G.

      11              THE WITNESS:  G.  All right.

      12    Travel office --

      13              MS. MARSH:  Read the title.

      14              THE WITNESS:  "Travel office staff

      15    targeted before firings."  Looks like a

      16    George Archibald story from the Washington 

      17    Times, 9H.

      18              MS. MARSH:  It's two pages.  You

      19    got to do each page.

      20              THE WITNESS:  I'm sorry.  9H still?

      21              MS. MARSH:  No, 9I.  He wants each

      22    separate.








                                                              67


       1              THE WITNESS:  Oh, okay.  All right.

       2    "Inside the Beltway" from Washington Times --

       3              BY MR. KLAYMAN:

       4         Q    What's the date of that?

       5         A    I don't see a date on that.

       6         Q    What's the heading, first article

       7    on the page?

       8         A    "Hoover File," "Family File,"

       9    "Separated at Birth."

      10         Q    All right.  That's fine.  I just

      11    want you to identify it.  What are you

      12    numbering now?

      13              MS. MARSH:  9J.

      14              BY MR. KLAYMAN:

      15         Q    9-J.

      16              MS. MARSH:  Date.

      17              THE WITNESS:  All right.

      18              MS. MARSH:  The second page of it

      19    you got to label K.

      20              BY MR. KLAYMAN:

      21         Q    Second page is 9K, initials and

      22    date.  Next page?








                                                              68


       1         A    Is -- it's a continuation of --

       2         Q    3-page --

       3         A    I guess it must be.  9K -- L?

       4         Q    9L.

       5         A    This is "Inside Politics" again, 9

       6    what, M?  9N.

       7              MS. MARSH:  Tell him what it's

       8    called.

       9              THE WITNESS:  This is "Undercover

      10    Operator" from The Washington Post, "In the

      11    Loop."

      12              BY MR. KLAYMAN:

      13         Q    9N?

      14         A    Yes, 9N.

      15         Q    Next one?

      16         A    9O, "Clinton liberal backers are

      17    testy," Don Lambreau.  This is pages of

      18    statements of William Kennedy, Tony Coelho,

      19    Lloyd M. Cutler, Dee Dee Myers, Janet V.

      20    Green, statement of Ann S. Stock, White House

      21    social secretary and statement of Bob

      22    Lehrman.








                                                              69


       1         Q    Why don't you number each one of

       2    those consecutively?

       3              MS. MARSH:  You're on P.

       4              THE WITNESS:  9P.

       5              MS. MARSH:  Q.

       6              THE WITNESS:  9Q, R, S, T, U, V.

       7              BY MR. KLAYMAN:

       8         Q    Next?

       9         A    "White House improperly obtained

      10    the FBI files of more than 600 people, new

      11    documents show," W.  9X -- what's the date?

      12              MS. MARSH:  Sixteenth.  Read the

      13    title.

      14              THE WITNESS:  "Secret system

      15    computerizes personal data."  9 -- this is

      16    9-Y.

      17              MS. MARSH:  The last article is

      18    three pages long.

      19              THE WITNESS:  Three pages long and

      20    it's, "Secret system computerizes personal

      21    data."

      22              BY MR. KLAYMAN:








                                                              70


       1         Q    You've now numbered everything in

       2    Exhibit 9, correct?

       3         A    Yes, sir.

       4         Q    With your initials, J.C?

       5         A    Yes, sir.

       6         Q    With the date?

       7         A    Yes, sir.

       8         Q    I show you what has been marked as

       9    Exhibit 10 on the folder.  This is the

      10    Judicial Watch file.  I'd like you to do the

      11    same thing, identify each piece of paper and

      12    just start 9A through whatever comes out.

      13              MS. MARSH:  Ten.

      14              THE WITNESS:  10A, "Begala insists

      15    he had no knowledge of FBI files misuse."

      16              MR. KLAYMAN:  You have a loose

      17    article there.  It hasn't been copied there.

      18              MS. MARSH:  Same thing.

      19              BY MR. KLAYMAN:

      20         Q    Same thing as the copy that was

      21    just made, 10A?

      22         A    Yeah, it's the same thing.








                                                              71


       1         Q    Make that 10B.

       2         A    All right.  "Stephanopolous,

       3    Begala, and Carville subpoenaed in filegate."

       4    That would be 10C.  And New Republic October

       5    reprint of an article about Larry Klayman of

       6    October 6, 1997, which is D.

       7         Q    While you're on that, Mr. Carville,

       8    where did you get that?

       9         A    This?

      10         Q    The one you just marked about New 

      11    Republic.

      12         A    It was faxed to me by Dalit

      13    Toledano, who used to work for me as a law

      14    student at NYU law school.

      15         Q    Where does she work now?

      16         A    She's at law school.

      17         Q    At NYU?

      18         A    Yes.

      19         Q    How did she know to fax that to

      20    you?

      21         A    When I got the thing, she has a

      22    Lexis/Nexis, and I said see if you find








                                                              72


       1    anything about a Klayman and fax it down to

       2    me.

       3         Q    Was anything else faxed to you?

       4         A    No.

       5         Q    About Klayman or anyone else?

       6         A    My lawyer faxed it.

       7         Q    Is it a legal document that was

       8    faxed or is it some other type of

       9    documentation?

      10              MS. MARSH:  You can tell him what

      11    it is.

      12              THE WITNESS:  Some court of appeal

      13    decisions.

      14              BY MR. KLAYMAN:

      15         Q    Which ones do you have?

      16              MS. MARSH:  He didn't bring them

      17    here but I can tell you what they are.

      18    There's one from the Court of International

      19    Trade.  There's one from the Second Circuit

      20    and I think one from the Ninth Circuit, if I

      21    recall correctly.

      22              BY MR. KLAYMAN:








                                                              73


       1         Q    When were those faxed to you?

       2         A    I don't remember.

       3         Q    Recently?

       4         A    Yeah.  Yeah.

       5         Q    About a week and a half ago?

       6         A    I don't know.  I don't know.

       7         Q    Which lawyer faxed them to you?

       8    Ms. Marsh?

       9         A    Yes.

      10         Q    And they were faxed within the last

      11    two weeks, correct?

      12         A    Yeah.

      13         Q    And was anything else faxed to you

      14    by Ms. Marsh about Larry Klayman or Judicial

      15    Watch?

      16              MS. MARSH:  Anything that's not

      17    privileged?

      18              MR. KLAYMAN:  He can respond.

      19              THE WITNESS:  No.

      20              BY MR. KLAYMAN:

      21         Q    On this last document here that

      22    you've marked --








                                                              74


       1         A    Where it says more to come?

       2         Q    10D, it says, "For James and Kevin.

       3    More on the way, Dalit."  James, is that you?

       4         A    That's me.

       5              MR. GAFFNEY:  I'm going to make an

       6    objection Mr. Klayman.  You are questioning

       7    the witness regarding exhibits and I don't

       8    have a copy of them.

       9              MR. KLAYMAN:  We're going to make

      10    them right now.

      11              MR. GAFFNEY:  I appreciate it if

      12    you withhold your questions till after we

      13    have the documents.

      14              MR. KLAYMAN:  We'll have a lot more

      15    questions.  We'll have six copies of each

      16    made.

      17              BY MR. KLAYMAN:

      18         Q    Mr. Carville, have you disseminated

      19    those 9th and 2d Circuit opinions to anyone?

      20    Have you given them to anyone that Ms. Marsh

      21    sent to you?

      22         A    No, I don't think so.








                                                              75


       1         Q    Pretty recently, isn't it, that you

       2    got them?

       3         A    Mm-hmm.

       4         Q    So who did you give them to?  Who

       5    did you send them to?

       6         A    I don't think I faxed them to

       7    anybody.

       8              MS. MARSH:  He just said he didn't

       9    sent them to anybody.

      10         Q    Did you mail them to anybody?

      11         A    No.

      12         Q    Did you have anybody hand them to

      13    anybody?

      14         A    No.

      15         Q    Did you mention them to anybody?

      16         A    Yeah.

      17         Q    Who did you mention them to?

      18         A    I mentioned them to David Kendall.

      19         Q    In the last few weeks?

      20         A    Yeah.

      21         Q    Anyone else?

      22         A    Probably Bob Barnett, but I don't








                                                              76


       1    know, and ÄÄÄÄ to Mr. Begala.

       2         Q    Excuse me?

       3         A    To Mr. Begala.

       4         Q    And who else?

       5         A    Probably Mr. Emanuel, probably

       6    Mr. Stephanopolous.

       7         Q    ÄÄÄÄ Emanuel?

       8         A    Mm-hmm.

       9         Q    Mr. Stephanopolous?

      10         A    Mm-hmm.

      11         Q    Anyone else?

      12         A    Highly probable that I did but I

      13    just can't think of anybody right now.

      14              MS. MARSH:  I can give you copies,

      15    Mr. Klayman, that I have, and I can represent

      16    to you and Mr. Carville can confirm that

      17    these are exactly what he got from me of

      18    these opinions, if you'd like to have them

      19    marked.

      20              MR. KLAYMAN:  Let's mark them as

      21    Exhibit 10.

      22              MS. MARSH:  Eleven.








                                                              77


       1              MR. KLAYMAN:  Eleven.

       2              MS. MARSH:  Do you want to mark

       3    each one separately or altogether?

       4              MR. KLAYMAN:  Altogether.  Let me

       5    see them first, please.  One is opinion Wire 

       6    Rope Importers' Association v. United States,

       7    slip op 9486, May 26,1994.  Another one is

       8    Baldwin Hardware v. Franksu, 78 Fed. 3d. 550,

       9    and the last one is United States Court of

      10    Appeals for the Second Circuit, 1998 U.S.

      11    Appeals Lexis 2595 printed in full format.

      12    We'll ask that these be marked as Exhibit 11

      13    and we'll staple them together and make

      14    copies.

      15              MS. MARSH:  And I need those back,

      16    please, as with the other exhibits.

      17                   (Carville Deposition Exhibit

      18                   No. 11 was marked for

      19                   identification.)

      20              BY MR. KLAYMAN:

      21         Q    Mr. Carville, why did you mention

      22    these opinions to Mr. Kendall, Mr. Barnett,








                                                              78


       1    Mr. Begala, Mr. Stephanopolous, and everyone

       2    else you've just named?

       3         A    Just thought they would be

       4    interesting.

       5         Q    Your purpose was to have them

       6    disseminated to the media and to others, was

       7    it not?

       8         A    No, if I wanted to disseminate them

       9    to the media I would have disseminated them

      10    by the media.

      11         Q    You were told by one or more of

      12    those individuals that they were going to

      13    disseminate that information?

      14         A    No.  They figured if I wanted to I

      15    would.  I don't know that they did or didn't,

      16    you know, but they're public record.

      17         Q    Did you also provide information

      18    about these decisions which are Exhibit 11 to

      19    the Democratic National Committee.

      20              MR. GAFFNEY:  I'm going to object

      21    once again, Mr. Klayman, to your questioning

      22    of a witness without providing copies of an








                                                              79


       1    exhibit.

       2              MR. KLAYMAN:  You were reading them

       3    the other day.

       4              MR. GAFFNEY:   I don't care whether

       5    I was reading them the other day or not.  Are

       6    you going to continue to question a witness

       7    about exhibits that you haven't provided --

       8              MR. KLAYMAN:  I just identified

       9    them you know what they are.  I'll be happy

      10    to give you a copy.

      11              MR. GAFFNEY:  I would appreciate it

      12    if you withhold the questioning till you

      13    provide me a copy.

      14              MR. KLAYMAN:  Do you want to see

      15    them right now?

      16              MR. GAFFNEY:  Well, I'd like you to

      17    provide the opportunity for the other counsel

      18    to review them if you're going to be asking

      19    questions.

      20              BY MR. KLAYMAN:

      21         Q    Did you talk to Mr. Gaffney about

      22    those decisions, Exhibit 11?








                                                              80


       1         A    No, sir.

       2         Q    Just Mr. Kendall?

       3         A    And maybe Mr. Barnett.

       4         Q    You are aware that Mr. Gaffney

       5    works with Mr. Kendall and Mr. Barnett?

       6         A    I am.

       7         Q    Your purpose in letting these

       8    people know about it so they could smear

       9    Larry Klayman and Judicial Watch?

      10              MS. MARSH:  Objection.

      11              THE WITNESS:  No.  My purpose was I

      12    called Mr. Kendall and I said how common is

      13    this kind of thing.  He said it was very

      14    rare, and I think there was a judge by the

      15    name of Winter on the court of appeals that

      16    used to teach him in law school.  Mr. Kendall

      17    told me that Judge Winter was a pretty

      18    conservative guy, and he told that trial

      19    judge atta boy, and he said it is not a very

      20    common thing that a court of appeals would

      21    write an opinion upholding sanctions from a

      22    trial court.








                                                              81


       1              BY MR. KLAYMAN:

       2         Q    Did Mr. Kendall tell you whether

       3    that opinion was under court seal?  In other

       4    words --

       5              MR. GAFFNEY:  Objection.  Assumes

       6    facts not in evidence.

       7              BY MR. KLAYMAN:

       8         Q    You can respond.

       9              MR. GAFFNEY:  As you know,

      10    Mr. Klayman, that order is not under court

      11    seal.

      12              BY MR. KLAYMAN:

      13         Q    You can respond.

      14         A    He did not.  I assume somebody got

      15    it out of the Federal Reporter or whatever.

      16         Q    Did Mr. Kendall tell you that Larry

      17    Klayman had sought to keep that opinion under

      18    court seal until all the appeals were heard?

      19         A    He didn't.

      20         Q    Did he tell you that?

      21         A    No.

      22         Q    Did he tell you that in fact there








                                                              82


       1    was an order entered in that case of last

       2    year which sealed the files?

       3              MS. MARSH:  Is that the order

       4    that's been vacated?

       5              BY MR. KLAYMAN:

       6         Q    You can respond.

       7         A    No, he didn't tell me.  I don't

       8    know nothing about that.

       9         Q    Did he tell you that the matter is

      10    subject for a petition for rehearing in front

      11    of the same court?

      12         A    No, he did not.

      13         Q    Did he tell you the matter can be

      14    appealed to the Supreme Court?

      15         A    He didn't have to tell me that.  I

      16    assumed that it could be.  I can tell you

      17    right now I hadn't practiced law in a long

      18    time, and I called and said did the Supreme

      19    Court accept it, but what the heck, what do I

      20    know?

      21         Q    Did he tell you that the judge who

      22    issued the sanctions, Denny Chin, that he was








                                                              83


       1    an appointee of the Clinton administration?

       2         A    I can read the opinion and know

       3    that.

       4         Q    Did Mr. Kendall tell you that?

       5         A    I don't remember but it would be

       6    superfluous.

       7         Q    Did he tell you that the judge's

       8    name was found in the files of John Huang?

       9         A    No.  He did say that Winter was a

      10    highly respected guy.  I remember that.

      11         Q    I didn't ask you about Winter.

      12         A    I'm just telling you he told me.

      13    You keep asking me things he didn't tell me.

      14    I just thought I'd tell you something he told

      15    me.

      16              MR. GAFFNEY:  Mr. Klayman I would

      17    like to object to the extent and I can't tell

      18    from your questioning that the order you are

      19    referring to is simply the order from Judge

      20    Chin and you're not suggesting that there was

      21    an order prohibiting the dissemination of the

      22    two other opinions which imposed sanctions on








                                                              84


       1    you; am I correct in that?

       2              MR. KLAYMAN:  We'll deal with the

       3    legal issues at a later date.

       4              MR. GAFFNEY:  I just want to be

       5    clear.

       6              MR. KLAYMAN:  We'll deal with them

       7    in court.  That's where we'll deal with them.

       8              BY MR. KLAYMAN:

       9         Q    You know John Huang, don't you?

      10         A    I don't think I do.

      11         Q    Did you ever meet him?

      12         A    If you ever ask me if I ever met

      13    someone I'll tell you that I meet a lot of

      14    people that I don't remember but if I had met

      15    John Huang I would be surprised.  I would say

      16    that.

      17         Q    You know John Huang, don't you?

      18         A    Sure.

      19         Q    And you knew he was working at the

      20    Commerce Department?

      21         A    I did.

      22         Q    And you knew that he moved over to








                                                              85


       1    the DNC to handle campaign contributions?

       2         A    I did.

       3         Q    And you are aware that John Huang

       4    was responsible for recommending Asian

       5    American appointees in the Clinton

       6    administration do you not?

       7         A    No, I don't know that.

       8         Q    You've seen reports, have you not,

       9    in New York times and Los Angeles times

      10    that --

      11         A    I don't recall that -- I mean, if

      12    you told me they're there, I wouldn't be

      13    surprised at all, but I don't recall reading

      14    that and all that I know is about this Judge

      15    Winter.

      16         Q    Well, you were close to the Clinton

      17    administration, were you not, and you still

      18    are, aren't you?

      19         A    I have friends over there but I

      20    never knew John Huang.

      21         Q    And you have friends at the

      22    Democratic national committee?








                                                              86


       1         A    Not very many.

       2         Q    But you have some?

       3         A    Boy, who's left over there?  I'm

       4    sure I do have some.  I just don't know who's

       5    over there any more.

       6         Q    And you are aware that John Huang

       7    recommended Denny Chin to the bench, aren't

       8    you?

       9         A    I'm not aware that.

      10         Q    Judge Denny Chin was recommended by

      11    John Huang.  You know that, don't you?

      12         A    I don't know that.  The only thing

      13    I know of is judge Winter's highly thought of

      14    person according to Mr. Kendall, that he was

      15    his law teacher so I don't know how this

      16    judge got to be on a district court or who

      17    recommended him or anything else.

      18         Q    Are you aware that there were

      19    articles written in the Los Angeles Times and

      20    New York Times that said John Huang decide

      21    who would be appointed in the Asian American

      22    community to judgeships and other things?








                                                              87


       1         A    I'm not aware of that.  The only

       2    thing Mr. Kendall told me was that Judge

       3    Winter was considered to be a top-flight

       4    jurist.

       5              MS. GILES:  I object to this whole

       6    line of questioning has having no relevance

       7    to the FBI files.

       8              BY MR. KLAYMAN:

       9         Q    It does have relevance to documents

      10    that were produced, and it does have

      11    relevance and you know what that relevance

      12    is?

      13         A    What is it?  I'd just be curious to

      14    know what a public opinion from the court has

      15    got to do with the FBI files.

      16         Q    Maybe you'll learn someday.  I'm

      17    asking the questions.

      18         A    I understand.

      19         Q    You are aware that Larry Klayman

      20    and Judicial Watch were the individuals and

      21    groups that discovered John Huang in its case

      22    against the Commerce Department?








                                                              88


       1         A    I am.

       2         Q    And you did see me on the news back

       3    in October and November of 1997 when we took

       4    the deposition of John Huang, did you not?

       5         A    I might have.  I don't remember.

       6         Q    You've talked to me from time to

       7    time with your wife Mary, haven't you?

       8         A    I think I did a show with you.

       9         Q    Right, around the time of John

      10    Huang?

      11         A    You and I talked other than that

      12    time on the show?

      13         Q    That wasn't my question.

      14         A    I recall doing -- I think it was a

      15    Burden of Proof show that you were on and I

      16    recall that you sent my wife a fruit basket

      17    for the holidays.

      18         Q    And you agree I've been on your

      19    show several times, correct?

      20         A    I haven't heard you but she said

      21    that you've been on the show.  I asked her

      22    why did you send her --








                                                              89


       1         Q    She knows me, doesn't she?

       2         A    Yes.  I mean, you sent us -- you

       3    sent her -- I guess you didn't send me -- but

       4    you sent her some kind of fruit basket for

       5    the holidays.  You don't go around sending

       6    something to strangers.

       7         Q    Is that why you called me a little

       8    twerp?  You didn't get a fruit basket?

       9              MS. MARSH:  Objection.  Not a real

      10    question.

      11         Q    Still mad about that?

      12         A    I'm not mad about the fruit basket.

      13         Q    If I'd send it to you you wouldn't

      14    have called me a little twerp?

      15         A    No, I ate it.  We share things in

      16    common.

      17              MS. MARSH:  Objection.

      18              BY MR. KLAYMAN:

      19         Q    Mr. Carville, you are aware that

      20    John Huang still remains under investigation,

      21    are you not?

      22              MS. MARSH:  I'm going to put an








                                                              90


       1    objection on the record to all questions

       2    about John Huang.

       3              BY MR. KLAYMAN:

       4         Q    You can respond.

       5         A    Let me just tell you something.  I

       6    don't know John Huang.  I assume that he's

       7    still under investigation.  To the best of my

       8    knowledge, I have never met John Huang.  I

       9    know I've never spoken to him on the phone or

      10    had any communication with him whatsoever,

      11    but, if you say he's still under

      12    investigation, he's still under

      13    investigation.

      14         Q    Now, assume the facts I told you

      15    are true, that this judge's name was found in

      16    the files of John Huang.

      17              MS. MARSH:  Which judge?

      18         Q    Judge Denny Chin?

      19         A    Based on what Mr. Kendall told me

      20    that I have eminent respect for and that

      21    three courts of appeal judges with the same

      22    jurist like this to write that kind of








                                                              91


       1    opinion, you ask me how I feel if one judge

       2    wrote something, I guess that needs to be --

       3    I did not read that to be a complimentary

       4    opinion is what my opinion is.

       5         Q    You read that one to be

       6    uncomplimentary, correct, the one about me?

       7         A    Yeah, I did.

       8         Q    And about my colleague

       9    Mr. Orfanedes, correct?

      10         A    Yeah.  I didn't pay attention --

      11         Q    But you didn't read the one that

      12    was issued about you last Friday by Judge

      13    Lamberth to be uncomplimentary, did you?

      14              MS. MARSH:  Objection.  Asked and

      15    answered.

      16              BY MR. KLAYMAN:

      17         Q    That one was fine, right?

      18              MS. MARSH:  Objection.  That's

      19    argumentative.

      20              BY MR. KLAYMAN:

      21         Q    Let's take the hypothetical,

      22    Mr. Carville.








                                                              92


       1         A    No, let's don't take the

       2    hypothetical.

       3         Q    You're going to have to answer the

       4    question.

       5              MS. MARSH:  Maybe he is.  Maybe he

       6    isn't.

       7              BY MR. KLAYMAN:

       8         Q    Let us assume that this judge's

       9    name was found in the files of John Huang.

      10    Let us assume that he was recommended for

      11    appointment to the bench by John Huang and

      12    the Clinton administration.  Under those

      13    circumstances, you're a lawyer, is there

      14    anything wrong in asking the judge whether he

      15    has some association with John Huang?

      16              MS. MARSH:  Wait.  Let me put an

      17    objection on the record before you answer.

      18    James, let me put the objection on the record

      19    first.  Don't fight with me.

      20              MR. KLAYMAN:  He's a big boy.

      21              MS. MARSH:  He's a lawyer here and

      22    I am I'm entitled to put an objection on the








                                                              93


       1    record.  I object to the question.  I object

       2    to the assumptions that it makes.  I object

       3    to you asking Mr. Carville as a lawyer.  He's

       4    not called as a lawyer today.  He can answer

       5    you as James Carville, but this question is

       6    irrelevant and assumes facts not in evidence.

       7              MR. GAFFNEY:  I would also like to

       8    object Mr. Klayman as representing a party to

       9    this litigation.  I object to relevance of

      10    this question.  I cannot see, moreover, it

      11    leading to the admissibility of relevant

      12    evidence as to what he thinks about the judge

      13    who imposed these sanctions on you.

      14              BY MR. KLAYMAN:

      15         Q    You can respond.

      16         A    I could tell you what the fact is.

      17    The fact is that I think it was three judges

      18    on the Court of Appeals for the 2d Circuit.

      19    One of them that a highly respected attorney

      20    told me was a highly respected judge.  I have

      21    no reason to doubt the other two are not

      22    highly respected judge.  Reviewed the record








                                                              94


       1    in this case.  I assume everybody had a

       2    chance to submit everything and it was a

       3    public document that my lawyer sent me and I

       4    spoke to people about it, but my

       5    understanding is that it -- let me see the

       6    thing.

       7              Can I see that thing a second?

       8    Thank you.  Hand it here.  It's been a while

       9    since I've been in law school.  Is it the top

      10    one?  I assume that this is some kind of a

      11    U.S. appellate Lex1s 2595 or something.  I

      12    assume it's some kind of public record.  I

      13    don't think anybody got it from anywhere

      14    that -- Judge Winter, Judge Altimari, and

      15    Cabranes, opinion by Winter.  I assume that's

      16    a public thing.  I mean, I didn't know that I

      17    was -- that there's anything nefarious about

      18    me talking to people about this.

      19         Q    And in fact you talked to a lot of

      20    people about it, correct?

      21         A    Well, not all of them were talked

      22    to about it.  I probably talked to some more








                                                              95


       1    about it.

       2         Q    Who else?

       3         A    Again, I told you the ones I can

       4    remember, but I'm sure I probably talked to

       5    more people than I did.

       6         Q    Well, tell me who else.

       7         A    The ones I told are the ones I can

       8    remember.

       9         Q    During that conversation with

      10    Mr. Kendall did you ever ask whether anyone

      11    at his law firm had ever been sanctioned?

      12         A    No, I didn't.

      13         Q    Did you ever do a check on that,

      14    Nexis search?

      15              MS. MARSH:  Objection as to

      16    relevance.

      17              THE WITNESS:  No, but if they were

      18    deposing me I might.

      19         Q    Did you watch the O. J. Simpson

      20    trial?

      21         A    Not very much.

      22              MS. MARSH:  Objection.








                                                              96


       1         Q    Remember how many times Marcia

       2    Clark and Johnny Cochran and company were

       3    sanctioned?

       4              MS. MARSH:  Objection.

       5              THE WITNESS:  Let me just say right

       6    here this is an appeal from the 2d Circuit.

       7    I don't know about Marcia Clark or anybody

       8    else before three judges unanimously saying

       9    we affirm, but if you do let me know.  But,

      10    again, if Johnny Cochran or Marcia Clark were

      11    deposing me, and my lawyer sent me something

      12    where they were sanctioned, I probably would

      13    talk about it.

      14              BY MR. KLAYMAN:

      15         Q    And in fact your practice has been

      16    to take anything that you could find and

      17    disseminate that about any perceived

      18    adversaries of the Clinton administration,

      19    correct?

      20              MS. MARSH:  Objection.

      21              THE WITNESS:  No.

      22         Q    In fact, what you master in,








                                                              97


       1    Mr. Carville, is to spread anything you can

       2    about adversaries of the Clinton

       3    administration?

       4              MS. MARSH:  Objection.

       5         Q    That's part of what you do, right?

       6         A    First of all, what I "spread" here

       7    was an appellate court decision.  I mean, I

       8    don't know what could be a more public thing

       9    which you can Shepardize the thing, you know

      10    what I mean?  You can get the key number and

      11    all that kind of stuff.  It's all that kind

      12    of -- this is not some little, you know,

      13    secret document here.

      14         Q    Well, it's nice to know that you

      15    still remember the fact that you're a lawyer.

      16    That's good.  That's good.  We've established

      17    that now, good.

      18         A    But, yeah, and what's this Baldwin 

      19    Hardware case?

      20         Q    I'll ask the questions and we will

      21    get back to these documents, but let me ask

      22    you now whether you've ever done these kinds








                                                              98


       1    of Nexis searches on people like Ken Starr.

       2    You ever do that?

       3         A    Sure.  I mean, I haven't done it --

       4         Q    You've done them on judges, too,

       5    haven't you?

       6         A    Well, Ken Starr was a judge.

       7         Q    Have you done one on the judge in

       8    this case?

       9         A    No.

      10         Q    Have you done one on other judges?

      11              MS. MARSH:  A Nexis search?

      12              THE WITNESS:  I would doubt it but

      13    if you can illuminate me.

      14              BY MR. KLAYMAN:

      15         Q    You were involved, weren't you, in

      16    setting strategy with the Democrats with

      17    regard to Judge Bork's nomination?

      18              MS. MARSH:  Objection as to

      19    relevance.

      20              THE WITNESS:  None.

      21         Q    Judge Clarence Thomas, you never

      22    had any input?








                                                              99


       1              MS. MARSH:  Objection as to

       2    relevance.

       3              THE WITNESS:  No -- wait a minute.

       4    If I remember correctly, when Judge Thomas

       5    was up for confirmation I was working for --

       6    do you remember I was working for Senator

       7    Wofford then, but I never did any -- I mean,

       8    I wasn't -- I wasn't involved in that.  No.

       9    In fact, I've been to Justice Thomas' house.

      10         Q    This Judicial Watch file that we

      11    just went over, which is Exhibit 11, was any

      12    of the information in there disseminated to

      13    any hosts on TV talk shows?

      14         A    No.

      15         Q    You don't know if anybody else did

      16    that you informed about it, do you?

      17         A    I don't think I informed anybody.

      18    Only thing is I faxed a copy of your press

      19    release about our deposition to Mr. Begala.

      20         Q    You don't know what other people

      21    did once you told them about this stuff, do

      22    you?








                                                              100


       1         A    Do I know what other people did?

       2         Q    Did with the information.

       3         A    I didn't tell anybody -- excuse me,

       4    I'm sorry.  I didn't tell anybody anything

       5    Judicial Watch that I know of other than

       6    Mr. Begala.

       7         Q    I'm talking about these court

       8    decisions that I've just shown you.  You

       9    don't know what other people did with them,

      10    do you?

      11         A    No.

      12         Q    Now, let's get that exhibit back

      13    and we'll make some copies.  Did you discuss

      14    these decisions with your wife?

      15         A    I'm sure I did.  I assume I did.

      16         Q    Did you ever discuss these

      17    decisions with Bob Bennett?

      18              MS. MARSH:  I think he said he did.

      19              THE WITNESS:  No.  I said Barnett.

      20    I don't think I discussed it with Bennett.

      21              BY MR. KLAYMAN:

      22         Q    Tell me what else you said during

 

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