101


       1    the conversation with Mr. Kendall.  What else

       2    was discussed?

       3         A    I don't know.  I just called him to

       4    ask him about this.

       5         Q    Let the record reflect Mr. Gaffney

       6    just passed a note to Ms. Marsh.

       7              MS. MARSH:  Yes, he did, and

       8    Ms. Marsh took it.  You have to put that on

       9    the record, too.

      10              THE WITNESS:  I think the other

      11    thing is that --

      12              MS. MARSH:  Wait till he asks you a

      13    question.

      14              MR. GAFFNEY:  Would you like me to

      15    reenact it for the video?

      16              MR. KLAYMAN:  No, you can reenact

      17    it for the court.

      18              MS. MARSH:  Subject to the

      19    objection that we filed regarding a request

      20    for calendars that's extremely broad, request

      21    number 3.  We filed an objection or served on

      22    an objection on you in regard to that.








                                                              102


       1    Subject to that objection, however,

       2    Mr. Carville has brought to you today what he

       3    has of his calendars and the dates included

       4    in the subpoena that have been redacted to

       5    take out personal information, and he can

       6    produce those as well.

       7              MR. KLAYMAN:  Is there anything

       8    else you're producing today?

       9              MS. MARSH:  No, that's all.

      10              MR. KLAYMAN:  I take it there are

      11    other documents responsive to our subpoena

      12    which are not being produced pursuant to your

      13    so-called objection?

      14              MS. MARSH:  I don't think so.  To

      15    the subpoena?  I don't think so.  The

      16    objections were made just in case there were

      17    supplemental documents that come up later

      18    that fall within some of these broad

      19    categories, but I don't believe there's

      20    anything else.  You can ask him through the

      21    schedule of documents, if you want to, to

      22    see.








                                                              103


       1              MR. KLAYMAN:  Well, we will go

       2    through that and come back to this.  I'll

       3    show you what I'll ask the court reporter to

       4    mark as Exhibit 12.

       5                   (Carville Deposition Exhibit

       6                   No. 12 was marked for

       7                   identification.)

       8              MS. MARSH:  Did you not want him to

       9    go through his calendars and sign those at

      10    the bottom?

      11              MR. KLAYMAN:  We will do that at

      12    the perfect time.

      13              BY MR. KLAYMAN:

      14         Q    I'll show you what I've asked the

      15    court reporter to mark as Exhibit 12.  This

      16    is a press release of Judicial Watch,

      17    "Stephanopolous, Begala and Carville

      18    subpoenaed in Filegate."  Have you seen that

      19    before, Mr. Carville?

      20         A    I have.

      21         Q    Where did you get this document?

      22         A    It was faxed to me by probably -- I








                                                              104


       1    don't know -- somebody with Mary's show,

       2    maybe Ann Clank or Amanda Butler, but I don't

       3    know.

       4         Q    Did you call over there and ask for

       5    a copy of this?

       6         A    No.  I think what happened was I

       7    didn't think the press release beat the

       8    subpoena, or, wait, no, the subpoena --

       9              MS. MARSH:  Don't guess if you

      10    don't know.

      11              THE WITNESS:  Yeah at 2/23 -- I

      12    don't know.  You'd have to look and see when

      13    the dates were, but you faxed it to them and

      14    they faxed it to me.

      15         Q    My question was did you call over

      16    there and ask them did you get any press

      17    releases from Judicial Watch?

      18         A    No.

      19         Q    They faxed it to you on their own?

      20         A    Right.

      21         Q    That's Mary's show?

      22         A    Right.








                                                              105


       1         Q    Mary told her worker to send it to

       2    you?

       3              MS. MARSH:  Objection.

       4              THE WITNESS:  I have no idea.

       5         Q    You sent a copy of this to Begala?

       6         A    I did.

       7         Q    Did you call Begala before you sent

       8    it?

       9         A    I don't know.  I don't know if I --

      10    maybe I was out of town.  If you give me my

      11    calendar I'll see where I was on 2/23.  Maybe

      12    someone at the office did.  Why don't you

      13    hand me my calendars and I can tell you where

      14    I was and if I was in town it's likely I did.

      15    If I'm not it's likely somebody in the office

      16    did.  I don't have a memory as to when it

      17    came over.

      18         Q    And you faxed it the same day to

      19    Begala?

      20         A    It looks like it came in at 9:57

      21    and then there's a fax at 11 -- I can't read

      22    it.  The two dates on the fax seem to be the








                                                              106


       1    23rd of February.

       2         Q    And after it was sent to Begala he

       3    called you?

       4         A    I don't know.  I got to find out

       5    where -- if you let me see my calendar and

       6    see where I was.  I don't know if I sent it.

       7    I don't know if I did or somebody else did.

       8         Q    Mr. Bustion, stand there with him

       9    while he looks through that, if you would.

      10         A    I was at the Sperling -- no, wait.

      11    the 23rd.  That was a Monday.  In all

      12    likelihood I did fax it because I was in

      13    Washington on that day.

      14         Q    You faxed it to Begala?

      15         A    I don't know.

      16              MS. MARSH:  Don't guess.

      17              MR. GAFFNEY:  Mr. Klayman, again, I

      18    object to you questioning the witness about

      19    something you haven't provided to the rest of

      20    counsel.

      21              THE WITNESS:  Let me just say this,

      22    Mr. Klayman, I didn't put it in -- I don't








                                                              107


       1    even know how to work the fax machine but it

       2    may have come over and somebody said look at

       3    this and I said okay well fax it to Paul.  It

       4    would seem to me -- I can't tell you to a

       5    certainty that would happen but that would be

       6    logical, or somebody came and said look at

       7    this, do you want me to fax it to Paul.

       8         Q    And you talked to Paul about this

       9    press release after you faxed it to him,

      10    didn't you?

      11         A    I'm sure I did.  I don't have a

      12    memory of the conversation.

      13         Q    And you told him you'd faxed it to

      14    him, correct?

      15         A    I tell you I don't even remember

      16    what -- either somebody handed it to me.  I

      17    don't -- I don't know the sequence of events

      18    is the truth, but my office faxed it to him,

      19    probably at my direction, and I'm sure that I

      20    spoke to him about it.  It would be highly

      21    unusually irregular if I did not.

      22         Q    And he expressed to you his








                                                              108


       1    knowledge that he got the fax from you,

       2    correct?

       3              MS. MARSH:  Do you remember?

       4              THE WITNESS:  I don't remember.

       5    I'm sure he did.  It just would be hard for

       6    me to imagine a situation where somebody got

       7    a fax that you were going to be subpoenaed

       8    and you didn't fax it to the guy.

       9              BY MR. KLAYMAN:

      10         Q    Mr. Carville --

      11              MR. KLAYMAN:  Mr. Bustion, would

      12    you gather up the exhibits we've marked so

      13    far?

      14              MS. MARSH:  You're not going to ask

      15    him anything else about these exhibits?

      16              MR. KLAYMAN:  I may.

      17              MS. MARSH:  I'd like them left in

      18    front of him if you're going to refer to

      19    them.

      20              MR. KLAYMAN:  No, I'm not referring

      21    to those right now.

      22              BY MR. KLAYMAN:








                                                              109


       1         Q    Where did you go to college?

       2         A    Louisiana State.

       3         Q    And what year did you graduate?

       4         A    '70 from undergraduate and '73 from

       5    law school.

       6         Q    Did you go to any kind of

       7    postgraduate education after that?

       8              MS. MARSH:  After law school?

       9              THE WITNESS:  No, just law school.

      10              BY MR. KLAYMAN:

      11         Q    Did you just state where you went

      12    to undergraduate?

      13         A    Louisiana State, got my

      14    undergraduate degree in '70 and my law degree

      15    in '73.

      16         Q    Did you take any time off in

      17    between?

      18         A    Well, I can explain to you what

      19    happened is I got invited to leave in May of

      20    1966.  I joined the Marine Corps, spent two

      21    years in the Marines, and then came back in

      22    '68 and started school and started back in








                                                              110


       1    June, summer school of '68, and sort of

       2    worked and I taught school the year '69 and

       3    then graduated in undergraduate school in May

       4    of '70, and started law school must have been

       5    in September of 1970 or August or whenever

       6    they started.  I don't remember.

       7         Q    Were you ever convicted of a crime

       8    up to today?

       9              MS. MARSH:  Objection as to

      10    relevance.

      11              THE WITNESS:  A crime?  You know,

      12    traffic ticket.

      13              BY MR. KLAYMAN:

      14         Q    Anything other than that?

      15              MS. MARSH:  Objection.

      16              THE WITNESS:  No.

      17              BY MR. KLAYMAN:

      18         Q    Have you ever gone by the name

      19    Chester?

      20         A    Sure.

      21         Q    Are there any police files with the

      22    name Chester on it where you're referred to?








                                                              111


       1         A    I don't know.

       2         Q    Are there any police files where

       3    your name has been excised from it?

       4              MS. MARSH:  Objection as to

       5    relevance.

       6              BY MR. KLAYMAN:

       7         Q    That you know of?

       8         A    None that I know of.

       9         Q    Down in Louisiana?

      10              MS. MARSH:  Objection.

      11              THE WITNESS:  I don't know but

      12    there may be.  I can't tell you that there's

      13    not.  Yeah, that I know.  I'm 53 years old.

      14         Q    Have you ever served in the

      15    military?

      16         A    Two years in the Marines.

      17         Q    Did you serve your complete tour?

      18         A    Mm-hmm.

      19         Q    You didn't leave early?

      20         A    You know what?  I was arrested one

      21    time.  Let me back up.  I was arrested in

      22    Tijuana when I was in the Marines.








                                                              112


       1         Q    What were you arrested for?

       2         A    Fighting, but what happened was

       3    there were three of us in a bar and we didn't

       4    have $20 and we gave the bartender $20 and he

       5    didn't give us change and he said he didn't

       6    speak English and one of the guys reached

       7    over to give him an English lesson and by

       8    that time the thing broke out and the Tijuana

       9    police came and locked us up.

      10         Q    Were you convicted of a crime?

      11         A    I can tell you what happened is

      12    they notified the base.  Somebody goes and

      13    they notify the base and some friends of ours

      14    came down to Tijuana with the bail money and

      15    then we had to go back -- you know, they sent

      16    us back to Camp Pendleton and the commanding

      17    officer said that we'd had good records and

      18    we didn't even get an Article 15, which is

      19    commanding office nonjudicial punishment, but

      20    I was arrested in Tijuana.  That's the only

      21    time to my knowledge I've been arrested.

      22         Q    Have you been barred from Mexico








                                                              113


       1    from ever coming back?

       2         A    No.

       3              MS. MARSH:  Objection as to

       4    relevance.

       5              THE WITNESS:  I doubt if the record

       6    keeping there was -- 1967 or '68 in Tijuana

       7    was -- in terms of the name Chester, I was

       8    born Chester James Carville Junior, and my

       9    father died in 1978 and it was like -- my

      10    mother always wanted me to be called James

      11    and it was kind of like C. James Carville

      12    Junior, and I'm just not an initial and a

      13    name kind of guy and just became James

      14    Carville.  I'm very proud of my name.

      15         Q    You had to leave the military

      16    early, did you not?

      17         A    No.

      18         Q    Involuntarily, did you not?

      19         A    No.  No, of course not.

      20              MS. MARSH:  Objection as to

      21    relevance.

      22              THE WITNESS:  I had an honorable








                                                              114


       1    discharge.  Went back to Camp Pendleton and

       2    went to boot camp graduation during the

       3    Republican National Convention.

       4              BY MR. KLAYMAN:

       5         Q    When did you first have anything to

       6    do with politics?

       7         A    My grandfather was on the police

       8    jury in Louisiana, so I guess when I was a

       9    little bitty boy I, you know, probably sort

      10    of go around with him and door knock and

      11    everything and the first campaign I ever

      12    worked on was a man named D. Price LeBlanc.

      13    They called him the trading country boy.  And

      14    he ran for the legislature against a man

      15    named Boise 컴컴, and I guess I was 15.

      16    Maybe I was a little bit -- somewhere around

      17    there.  It was 1959.  I was born in '44,

      18    probably just turned 15.  And I would go

      19    around and tear signs down for him or

      20    something, put signs up, take signs up, that

      21    kind of foolishness.

      22         Q    Louisiana in terms of politics








                                                              115


       1    based on your considerable experience, which

       2    we'll get into, is a pretty corrupt state,

       3    isn't it?

       4              MS. MARSH:  Objection as to

       5    relevance and also whether he's an expert on

       6    Louisiana politics.

       7              BY MR. KLAYMAN:

       8         Q    Based on your experience?

       9         A    I love my home state.  I would

      10    prefer to use the word "colorful" as opposed

      11    to corrupt.

      12         Q    Why can't we use the word

      13    "corrupt"?

      14              MS. MARSH:  Objection.

      15              THE WITNESS:  I'll say the politics

      16    in Louisiana are colorful.  I would rather

      17    not compare it to other places that I hadn't

      18    been.

      19              BY MR. KLAYMAN:

      20         Q    Tell me what was the first campaign

      21    you ever worked on as an adult.

      22         A    Probably for a man named 컴컴 Brown








                                                              116


       1    when I was in law school.  You mean worked

       2    on, like, ran for district attorney in Baton

       3    Rouge, and, I mean, you know, like, when I

       4    was in law school I was -- you know, we'd

       5    have, like -- when I was in college I was in

       6    the Young Democrats, and I guess we worked on

       7    the '64.  That would probably be the more --

       8    '64 Presidential race.  I wasn't paid

       9    anything, but, you know, it was sort of a --

      10    we'd pass out stuff.

      11         Q    And what did you do?

      12         A    Not much.  Free Speech Alley at LSU

      13    and we'd go out and argue with the

      14    Republicans and that kind of stuff.  I doubt

      15    if we affected a vote.

      16         Q    What was the next campaign you

      17    worked on?

      18         A    Well, I'm trying to catalog my life

      19    here to '64.  I went in the marines on '66, I

      20    didn't work on any campaigns then.  I got out

      21    in '68.  I didn't do anything in the '72

      22    presidential -- probably '73 East Baton Rouge








                                                              117


       1    parish district attorney.  I worked for a man

       2    named 컴컴 Brown.

       3         Q    And in the course of that campaign

       4    was there an opponent to Mr. 컴컴 Brown?

       5         A    Mm-hmm, good friend of mine.

       6         Q    What's his name?

       7         A    His name is Frank Foile.  He is a

       8    judge.  I think he is still is a judge in

       9    East Baton Rouge parish.  I know he was.

      10         Q    And during that campaign the guy

      11    you worked for, 컴컴 Brown did some research

      12    on his opponent.  That's pretty normal, isn't

      13    it, in a campaign?

      14         A    I'm sure he did.  I was a law

      15    student.  I doubt if I was -- you know, for

      16    sure.

      17         Q    Now, what was the next campaign you

      18    worked on?

      19         A    '73, worked for a man named Jerry

      20    컴컴.  When I got out of law school I went to

      21    a firm called 컴컴 컴컴 컴컴 & 컴컴.  And the

      22    컴컴 of the law firm ran for the Public








                                                              118


       1    Service Commission in Louisiana, which I

       2    think there are only like three or five.  It

       3    was a pretty powerful job in Louisiana.

       4         Q    And you did some opposition

       5    research on that campaign?

       6         A    I doubt if we did very much because

       7    we got our clocks cleaned.  Whatever it was,

       8    it was woefully inadequate.

       9         Q    Tell me in those days how

      10    opposition research was done based on your

      11    experience.

      12         A    I was more of a put up the signs,

      13    drive the candidate around kind of guy.  We

      14    didn't do very much then.  The whole research

      15    apparatus was not anything like it is today

      16    on the Clinton campaign.

      17         Q    What was the next campaign you

      18    worked on?

      19         A    1974.  Probably Billy 컴컴, who ran

      20    for an open congressional seat in the Third

      21    District of Louisiana in 1979.

      22         Q    What was your role in that








                                                              119


       1    campaign?

       2         A    I worked for the media firm that

       3    was doing the spots.

       4         Q    And who was that?

       5         A    It was a firm in Baton Rouge called

       6    컴컴 & 컴컴.

       7         Q    And what did you do for them?

       8         A    Help put together spots, go down

       9    and do the meetings and, you know, was kind

      10    of -- you know, it had kind of moved up from

      11    just sort of being a Gopher to helping the

      12    campaign help produce spots, that kind of

      13    stuff.  We did the -- you ever see those old

      14    weather vane spots we used to get in the

      15    studio, had a gushing wind.  We run against a

      16    guy named Jim Diamond, and I'd sit under the

      17    table and we had this kind of weather vane

      18    thing.  One day he says this the next day he

      19    says this.  I've done a thousand of those.

      20         Q    Did you do some opposition research

      21    in that campaign?

      22         A    Oh, yeah.








                                                              120


       1         Q    How did you collect it?

       2         A    I don't remember.  He was in the

       3    legislature.  I'm sure we went and looked at

       4    his votes and said that he was whatever.  The

       5    biggest negative he had was he was from the

       6    New Orleans area and our guy was not, and it

       7    was, you know, back then the people from New

       8    Orleans vote for people in the New Orleans

       9    area and the people out in the country --

      10    it's not quite like that any more.

      11         Q    In those days --

      12              MS. MARSH:  If we're going to talk

      13    about opposition research can we get a

      14    definition that we all agree on?

      15              BY MR. KLAYMAN:

      16         Q    Get information about the opponent?

      17    That's opposition research, right?

      18         A    Yeah.

      19         Q    And to get information you get it

      20    wherever you can get it, right?

      21         A    No.  I mean, I never have gone

      22    through anybody's trash or followed anybody








                                                              121


       1    around or anything like that -- no, I did.  I

       2    followed a guy around one time.  Pete Dawkins

       3    because he did a thing and we heard that he

       4    was going to go to Winston-Salem for a

       5    fund-raiser and I told the guys, I said I

       6    betcha he's going on an RJR jet.  And so I

       7    sent somebody out to the Trenton airport and

       8    sure enough he got on an RJR jet.

       9         Q    You have hired people to follow

      10    people, haven't you, in the course of

      11    campaigns?

      12         A    No, sir.

      13         Q    And you have hired people or worked

      14    with people to dig up information wherever

      15    you could, correct?

      16         A    No, sir.  I have hired people --

      17    I've certainly hired people to "dig up

      18    information."  I have not "hired people to

      19    dig up information wherever they could."

      20         Q    You told people specifically where

      21    to go look for information or you just said

      22    get me some information about this?








                                                              122


       1         A    No, it depends on the level of

       2    sophistication of the people that you have.

       3    Sometimes starting out in campaigns you'd

       4    have to say, you know, he was on the City

       5    Council.  Go see what his attendance record

       6    was, you know what I mean, get the sort of

       7    campaign contributions things, look at the

       8    votes, depending on what the background of

       9    the candidate was.

      10         Q    Get information from people that

      11    knew the candidate?

      12              MS. MARSH:  What are you asking

      13    him?  Did he ever do that?

      14              BY MR. KLAYMAN:

      15         Q    I'll ask you if you've ever done

      16    that.  Surely you have, haven't you?  Or

      17    people that have worked with you?  You'd be

      18    crazy not to?

      19              MS. MARSH:  One question at a time.

      20              THE WITNESS:  I can't tell you that

      21    I never did it but we generally don't -- to

      22    my knowledge, this is just not sort of a








                                                              123


       1    technique that we use as go and kind of

       2    interview neighbors or something like that.

       3    I can't tell you it didn't happen on a

       4    campaign that I worked on.  Sometimes

       5    campaigns are big things and things happen

       6    that you don't know about.

       7              BY MR. KLAYMAN:

       8         Q    Sometimes on the campaigns you've

       9    worked on you've hired people to look into

      10    court records or hire peopled to talk to

      11    people?

      12         A    I've hired people to look at court

      13    records, I'm sure.

      14         Q    But you hired people to get

      15    information about a particular subject,

      16    right?

      17         A    Sure.

      18         Q    I was watching one of your film

      19    debuts yesterday, War Room.  Did you see that

      20    one?

      21         A    Oh, yeah.

      22         Q    Almost won an academy award for








                                                              124


       1    that one, right?

       2         A    Good movie.

       3         Q    There's a scene in there where

       4    you're talking about allegations that George

       5    Bush's campaign had purchased printing

       6    presses from Brazil, right?

       7         A    Right.

       8         Q    Now, you hired somebody to look

       9    around and try to find that, didn't you?

      10         A    No.  That's not true.  Somebody

      11    called us -- I forgot but it was somebody

      12    down in Brazil said they saw it or somebody

      13    said you're not going to believe this, and,

      14    you know, then I called the press and said

      15    whatever and they sort of went back and forth

      16    but, no, I didn't hire anybody to do that.

      17         Q    You have been involved in campaigns

      18    where the other campaign has spread what

      19    you've considered to be false information?

      20         A    I'm sure.  Everybody in every

      21    campaign I've ever worked in always thinks

      22    the other side spreads false information.








                                                              125


       1         Q    In fact, during that movie you made

       2    several statements that in your view Roger

       3    Ailes was spreading false information about

       4    the Clinton campaign didn't you?

       5              MS. MARSH:  Objection as to

       6    relevance.

       7              THE WITNESS:  I don't remember what

       8    it is -- Roger wasn't even doing the TV in

       9    1992, was he?  I don't think he was working

      10    for Bush.

      11              BY MR. KLAYMAN:

      12         Q    You tell me.

      13         A    That's the best I can remember.  He

      14    didn't work the '92 campaign.

      15         Q    In fact, you made several

      16    statements in that movie, didn't you?

      17              MS. MARSH:  Objection to relevance.

      18              THE WITNESS:  Tell me what the

      19    statement is.  I don't remember every

      20    statement I made in the movie -- you know

      21    what it was?  You're talking about the thing

      22    where they said they're going to come and








                                                              126


       1    they're going to say this, the deal in New

       2    Hampshire and I said something about George

       3    F. 컴컴, who happened to show up at my

       4    wedding, which was kind of embarrassing.

       5         Q    And you basically said that Ailes

       6    was going to come up there and spread false

       7    information?

       8         A    Right.

       9         Q    That sometimes happens in

      10    campaigns, doesn't it, in your view?

      11         A    Yeah.

      12         Q    And in fact to be prepared you got

      13    to be prepared to fight back, don't you?

      14    That's why you had the war room?

      15              MS. MARSH:  Objection as to

      16    relevance, also as to vagueness.

      17              BY MR. KLAYMAN:

      18         Q    Right?

      19         A    Yeah.

      20         Q    And the way you fight back is by

      21    spreading false information about your

      22    opponent, correct?








                                                              127


       1         A    I'd like to think that we spread

       2    accurate information but, you know --

       3         Q    Sometimes it happens?

       4              MS. MARSH:  You mean generally on

       5    any campaign or on what he's been on.

       6              MR. KLAYMAN:  He can respond.

       7              MS. MARSH:  You've got to clarify.

       8    Any campaign?

       9              THE WITNESS:  As I understand the

      10    question, sometimes in campaigns false

      11    information gets spread.  Is that the

      12    question?  Yeah.

      13              BY MR. KLAYMAN:

      14         Q    And sometimes you've been

      15    associated with campaigns that have spread

      16    false information?

      17         A    You have to give me an example what

      18    you're talking about and I could respond to

      19    it, but people have said the information that

      20    we've spread is false but we didn't think it

      21    was -- I don't know of a time where I spread

      22    information that I knew it was false, but,








                                                              128


       1    no, there's not a -- you know,

       2    interpretations of different things.  Okay?

       3    Somebody would say that you voted against --

       4    I mean, there are a lot of these things.  You

       5    vote against nutrition programs.  It might be

       6    part of a larger budget or budget

       7    reconciliation act, et cetera.  A lot of this

       8    stuff is just not -- you know, is not clear.

       9    It's not just totally clear.  I don't know of

      10    any situation that it was -- you know, that

      11    I've spread anything that I knew was false.

      12         Q    Sometimes things happen so fast you

      13    don't worry whether it's true or correct?

      14         A    No.  I'll tell you what I've found,

      15    Mr. Klayman, and we have said this for a long

      16    time is we actually like the more aggressive

      17    coverage of campaigns and the truth boxes, et

      18    cetera, et cetera because we think it forces

      19    the discipline in campaigns that tend to have

      20    better research do better, but, I mean,

      21    that's not to say we haven't been -- you

      22    know, you don't get criticized.  A political








                                                              129


       1    campaign, people make charges, charges go

       2    back and forth, et cetera, et cetera.  That's

       3    the nature of what happens in political

       4    campaigns.

       5         Q    And sometimes false information

       6    gets out, correct?

       7         A    Again --

       8              MS. MARSH:  Objection as to

       9    relevance.

      10              BY MR. KLAYMAN:

      11         Q    Let me give you an example.

      12         A    All right, go ahead.

      13         Q    Jennifer Flowers, that's an

      14    example, isn't it?

      15              MS. MARSH:  Of what.

      16              BY MR. KLAYMAN:

      17         Q    False information that your

      18    campaign disseminated that the governor

      19    didn't have an affair with her?

      20         A    I don't think he did.

      21         Q    Your idea of an affair is only if

      22    you have sex more than once?








                                                              130


       1              MS. MARSH:  Objection as to

       2    relevance.  What's the relevance of this of

       3    what his idea of a love affair is?  What's

       4    the relevance of that to the case about the

       5    FBI.

       6              MR. KLAYMAN:  I'm getting the way

       7    he functions.

       8              MS. MARSH:  Regarding sex?  What

       9    does that have to do with FBI filegate?

      10              MR. KLAYMAN:  His truthfulness and

      11    veracity.

      12              THE WITNESS:  I understand from an

      13    article in Time magazine is that he said that

      14    they groped one time in 1977.  Groping does

      15    not fit my definition of sex but maybe it

      16    fits somebody else's.

      17              BY MR. KLAYMAN:

      18         Q    You've seen his deposition

      19    recently, haven't you?

      20         A    I have not seen his deposition but

      21    I saw an account of it on the web site at

      22    Time magazine where they said for purposes of








                                                              131


       1    sex it shall be defined -- and I'll give you

       2    the exact thing, the touching of such and

       3    such area and such and such area.  You know,

       4    in the buttocks and they said did you have

       5    ever have sex with Jennifer Flowers and from

       6    what I'm told the President said yes, I was

       7    in a nightclub in Little Rock in 1977 that

       8    they were groping.  I don't call that sex but

       9    I'll defer if somebody else has a different

      10    opinion what it is but that's what I was told

      11    was in there.

      12         Q    You did make statements, did you

      13    not, during the presidential campaign in 1992

      14    that Governor Clinton did not have an affair

      15    or sex with Jennifer Flowers, correct?

      16              MS. MARSH:  Objection as to

      17    relevance.

      18              THE WITNESS:  I did.  I still

      19    believe that.  But I think I put it in my

      20    book that I didn't think.

      21         Q    Now, if you were to see

      22    Mr. Clinton's deposition and it now says that








                                                              132


       1    he had sex one time, would you want to make a

       2    public statement saying I didn't mean to

       3    mislead lead the people at that time?

       4              MS. MARSH:  Objection.  I want to

       5    object to the question as no relevance to the

       6    matters that are at issue in this case.  It's

       7    extremely hypothetical and suppositional.

       8    It's asking if he sees a deposition and it

       9    says certain things.  No one knows what's in

      10    that deposition.  I haven't seen it.

      11              BY MR. KLAYMAN:

      12         Q    What did you do to check out that

      13    that was true, that there was never an affair

      14    and there was never sex during 1992?

      15              MS. MARSH:  Objection as for

      16    relevance.

      17              MR. KLAYMAN:  You can respond.

      18              THE WITNESS:  Just used my common

      19    sense.  If somebody edits -- you know, if

      20    I've got newspaper reports that he didn't

      21    even recognize the voice on the telephone and

      22    there's something like supposedly 12 edits in








                                                              133


       1    this so-called tape and that's what he said,

       2    I don't think that he did.  That's all I can

       3    tell you.  I didn't do any -- how would I

       4    know?

       5              BY MR. KLAYMAN:

       6         Q    Now, during the campaign, you call

       7    kept a file on Jennifer Flowers, didn't you?

       8              MS. MARSH:  Objection as to

       9    relevance and who's "y'all"?

      10         Q    The campaign.  I figured

      11    Mr. Carville would understand that.  You know

      12    what y'all means?

      13              MS. MARSH:  It could mean the

      14    campaign.  It could mean Mr. Carville.

      15              BY MR. KLAYMAN:

      16         Q    The campaign.

      17         A    I'm sure that we had -- I'm sure

      18    that there must have been.  I don't have -- I

      19    don't know if I saw the file.

      20              MS. MARSH:  Don't guess.

      21              THE WITNESS:  I don't know, but I'm

      22    sure I would expect that we did.








                                                              134


       1              BY MR. KLAYMAN:

       2         Q    And you had people out there doing

       3    research about Jennifer Flowers, didn't you?

       4              MS. MARSH:  Objection as to

       5    relevance.

       6              THE WITNESS:  Not me.  I'm not

       7    telling you there wasn't but I'm telling you

       8    I didn't --

       9              BY MR. KLAYMAN:

      10         Q    Did Betsy Wright play a role in

      11    doing research on Jennifer Flowers?

      12              MS. MARSH:  Objection as to

      13    relevance.

      14              THE WITNESS:  I knew about that

      15    when I read it in the paper, and if the

      16    article in the paper's accurate then they

      17    did.

      18              BY MR. KLAYMAN:

      19         Q    You didn't know about that?

      20         A    No, sir.

      21         Q    Now, you were director of that

      22    campaign?








                                                              135


       1         A    No.

       2         Q    What was your title?

       3         A    Hold on just a second.  I did not

       4    become -- what I did is, whatever you call

       5    it, I ran the war room.  I did not assume

       6    that position until late June of --

       7         Q    What position?

       8         A    The war room or whatever you wanted

       9    to call it.  I did the communications

      10    research, that thing.  Okay?  Between the

      11    time I went to work for Governor Clinton

      12    December 1 and then I was on the road

      13    doing -- you know, doing shows and stuff like

      14    that.  I never -- I could tell you that I

      15    don't know -- I didn't know anybody.  I don't

      16    even know if I actually know a private

      17    investigator, to tell you the truth, but at

      18    any rate I didn't know anything about this

      19    till I read it in the paper and I can't

      20    remember when I did.

      21         Q    What was your official title at

      22    various stages of the 1992 Clinton campaign?








                                                              136


       1         A    Consultant to the Clinton campaign?

       2              BY MR. KLAYMAN:

       3         Q    You were widely regarded as the

       4    number one guy for campaign strategy, right?

       5              MS. MARSH:  Objection.

       6              THE WITNESS:  No, I wouldn't

       7    characterize it that way.  I certainly was

       8    one of the senior people in the campaign,

       9    particularly after late June of 1992.

      10              BY MR. KLAYMAN:

      11         Q    And it would have been your job to

      12    know if there are private investigators out

      13    there on Jennifer Flowers, correct?

      14              MS. MARSH:  Objection as to

      15    relevance.

      16              THE WITNESS:  No.  I mean, by the

      17    time I took over Jennifer Flowers was so far

      18    gone -- let me explain to you.  When I

      19    assumed the more senior position in the

      20    campaign it was June and nobody was talking

      21    about Jennifer Flowers any more.  We had

      22    whole other fish to fry here.








                                                              137


       1         Q    They were talking about bimbos

       2    generally, weren't they?

       3              MS. MARSH:  Objection as to

       4    relevance.

       5              THE WITNESS:  You'd have to ask

       6    Miss Wright.

       7              BY MR. KLAYMAN:

       8         Q    There was more than one woman who

       9    was of concern to the campaign, was there

      10    not?

      11              MS. MARSH:  Objection as to

      12    relevance.

      13              THE WITNESS:  You'd have to ask

      14    Ms. Wright?

      15              BY MR. KLAYMAN:

      16         Q    You knew it was a concern that

      17    there were women potentially out there and

      18    could embarrass Governor Clinton during the

      19    '92 campaign, correct?

      20              MS. MARSH:  Objection as to

      21    relevance.  Don't guess.

      22              THE WITNESS:  I certainly knew








                                                              138


       1    about Jennifer Flowers.  When she came out it

       2    was hardly a secret.  I did not -- I was

       3    not -- this is not something that I dealt

       4    with in terms of -- I didn't know anything

       5    about these so-called private investigators

       6    until -- I guess I read about it in the

       7    newspaper.

       8              BY MR. KLAYMAN:

       9         Q    Mr. Carville, are they giving you

      10    too much credit for being in control of the

      11    campaign?

      12              MS. MARSH:  Objection.

      13    Argumentative.

      14              BY MR. KLAYMAN:

      15         Q    The media?

      16              MS. MARSH:  Objection.

      17              THE WITNESS:  I don't know.  I

      18    certainly wasn't in control of what Betsy

      19    Wright did in terms of that.  I think I had

      20    other responsibilities.

      21              MS. GILES:  I object to this whole

      22    line of inquiry as having no conceivable








                                                              139


       1    relevance to the FBI files that are subject

       2    matter of this litigation.

       3              BY MR. KLAYMAN:

       4         Q    You ever heard of Little Rock

       5    lawyer by the name of Samuel Jones?

       6         A    No.

       7         Q    Wright Lindsey & Jennings?

       8         A    No.

       9         Q    That law firm?

      10         A    If it's Bruce Lindsey's law firm, I

      11    guess I would --

      12         Q    Do you meet Sam Jones from that law

      13    firm?

      14         A    Not to my knowledge, no.

      15              MR. KLAYMAN:  Let's take a little

      16    break, resume in a few minutes.

      17              VIDEOGRAPHER:  Going off video

      18    record at 12:12.

      19                   (Recess)

      20              VIDEOGRAPHER:  We're back on video

      21    record at 12:19.

      22              BY MR. KLAYMAN:








                                                              140


       1         Q    Just let the record reflect we've

       2    gone two hours at this point because we broke

       3    at 12:15.

       4              Mr. Carville, it isn't your

       5    practice, is it not, to keep files on

       6    individuals who may be a threat to a

       7    candidate?

       8         A    Illuminate me a little bit.

       9         Q    Well, like Jennifer Flowers.

      10         A    You know, Mr. Klayman, again, if

      11    you're -- I don't ever recall seeing a "file"

      12    on Jennifer Flowers.

      13         Q    I understand what your testimony

      14    was but I'm asking you, and it's different

      15    than what I just asked --

      16              MS. MARSH:  Mr. Klayman, we don't

      17    need those remarks.

      18              BY MR. KLAYMAN:

      19         Q    Now that I've highlighted the issue

      20    but I'm asking whether it has happened in the

      21    course of campaigns that you've kept files on

      22    individuals that have had unkind things to








                                                              141


       1    say about your candidate.  Surely that must

       2    have happened?

       3         A    I mean, we keep a wealth of

       4    material.  If we're running -- I mean, give

       5    me an example.  Look, if I'm running a race

       6    and it's against an incumbent --

       7         Q    Let's take the '92 campaign.  You

       8    had a file on governor Jerry Brown, didn't

       9    you?

      10              MS. MARSH:  Objection as to

      11    relevance.

      12              THE WITNESS:  Yeah, I doubt it.  I

      13    mean, I'm sure that we had -- somebody did --

      14    you know, he was for the flat tax.  You know,

      15    what was the impact of the flat tax, et

      16    cetera, et cetera, but there was no -- you

      17    keep using this world, you know, file or

      18    something.  We certainly have research.

      19         Q    And you put it in one place,

      20    generally don't you?

      21         A    Yeah, hopefully.

      22         Q    And you put that in a file, right?








                                                              142


       1    Isn't that normal?

       2         A    Well, it's usually in a -- you

       3    know, probably like a looseleaf binder but

       4    sometimes -- now they put them in manila --

       5    most of these kids use computers.  Most of

       6    it's in a computer, to tell you the truth.

       7    Probably wasn't like that when I first

       8    started but now they just sit there and --

       9         Q    People you work with now use

      10    computers?

      11         A    Yeah.

      12         Q    What they have is computer files

      13    where they have the information on candidate

      14    one area or an opponent or somebody has

      15    something to say?

      16         A    I expect they do.  Like I say, I

      17    can't operate a computer, so I couldn't tell

      18    you what's in one.

      19         Q    During the 1929 campaign you had

      20    those kinds of organized files or looseleaf

      21    binders, whatever you want to call them?

      22         A    I think it was all in computer and








                                                              143


       1    if I was -- you know, most of the time they

       2    just -- you know, I didn't see the files like

       3    that.  It was mostly all sort of computer

       4    stuff.  I'm sure we had clip files and that

       5    kind of thing.  I know they had clips but

       6    again with Lexis, Nexis, you don't have the

       7    same -- when I started, you don't have the

       8    same kind of clips and sort of

       9    cross-references, et cetera, et cetera, today

      10    that you did even in 19 -- you know, in the

      11    mid-80s because -- I don't know how they do

      12    it but they punch in the stuff and it sort of

      13    punches out.

      14         Q    Is there somebody in your office

      15    now who knows how to punch stuff in and punch

      16    it out on a computer?

      17         A    Kevin, and I think Todd knows.

      18         Q    So he keeps computer files?

      19         A    Yeah.  We look through them.

      20         Q    Who's "we"?

      21         A    Kevin and I.  I sat right there and

      22    said let's look through the file, everything








                                                              144


       1    in the subpoena.  I sure did.

       2         Q    During 1992 the campaign had a file

       3    on 컴컴 Browning, didn't they?

       4              MS. MARSH:  Objection as to

       5    relevance.

       6              THE WITNESS:  I have no idea who

       7    she is.

       8              BY MR. KLAYMAN:

       9         Q    Would it refresh your recollection

      10    if it's been reported she's one of the people

      11    that the President has had a sexual

      12    relationship with?

      13         A    May be, but it don't refresh my

      14    recollection.  First time I've heard of it?

      15              BY MR. KLAYMAN:

      16         Q    Mary Jo Jenkins?

      17              MS. MARSH:  Objection.

      18              THE WITNESS:  (Shaking head)

      19              BY MR. KLAYMAN:

      20         Q    You all had a file for her?

      21         A    If I never heard of her how can I

      22    tell you we had a file on her or not?








                                                              145


       1         Q    Beth Colson?

       2              MS. MARSH:  Objection.

       3              THE WITNESS:  Never heard of her.

       4    I heard of -- no.  Give me the names again.

       5              BY MR. KLAYMAN:

       6         Q    Beth Colson?

       7         A    No.

       8         Q    Mary Joe Jenkins?

       9         A    No.

      10         Q    Dolly Kyle Browning?

      11         A    No.

      12         Q    Just so we're clear and then we'll

      13    move on, are you telling me that the

      14    statements being made by various media

      15    organizations and others that then governor

      16    Clinton had had affairs or had sexual

      17    relations with a number of women weren't of

      18    concern to you, James Carville, in terms of

      19    your duties and responsibilities as head of

      20    the war room in the Clinton campaign in 1992?

      21              MS. MARSH:  Objection as to

      22    relevance.








                                                              146


       1              THE WITNESS:  I wouldn't say it

       2    wasn't a concern.  It just wasn't -- Betsy

       3    did that part of the campaign.  That was the

       4    thing that she dealt with, and that kind of

       5    information, I mean, is just something that I

       6    would not -- that I was sort of involved in.

       7    We were doing other things and it wasn't --

       8    by the time that the war room probably got up

       9    and running right after the Democratic

      10    national convention and by that time it was

      11    not that big of a concern, frankly.  It was

      12    earlier in the campaign.

      13              BY MR. KLAYMAN:

      14         Q    I take it you and Begala took jobs

      15    as consultants with the campaign?

      16         A    Right.

      17         Q    When was that?

      18         A    December 1, 1991.

      19         Q    And what were your duties and

      20    responsibilities from that point forward up

      21    to the point that you became head of the war

      22    room?








                                                              147


       1         A    It varied.  Certainly in New

       2    Hampshire we were all up there and traveled

       3    with the candidate and after New Hampshire I

       4    went to Georgia to help with the Georgia

       5    primary, and I can't remember --

       6    sequentially, I think South Carolina came a

       7    little before that and Georgia was a part of

       8    Super Tuesday, but I remember after the New

       9    Hampshire primary I went down to Georgia.

      10              And then from there ended up in

      11    Illinois, I think, and 컴컴 was running

      12    the -- we had people from different states.

      13    컴컴 was sort of running the Illinois

      14    primary.  We were up there helping.  And then

      15    from there, I think we moved on to New York,

      16    and then --

      17         Q    I'm not asking where you moved on.

      18    But what were your duties --

      19         A    I was trying to help get a state

      20    organized and working with the people seeing

      21    about getting a media buy.  You know what I

      22    mean?  Who was going to be for us?  Who was








                                                              148


       1    going to be against us?  Scheduling.  I

       2    remember trying to get what ed boards you go

       3    to, that kind of thing and by that time -- by

       4    the time that we had -- by the time of the

       5    New York primary was over, what happened was

       6    is that we went to -- if you read my book and

       7    I'm just trying to be as accurate as I can on

       8    the dates -- sometime in early May, remember,

       9    Jerry Brown was still running, and Stan

      10    Greenburg and I and maybe it was Manny

      11    Grunwald, I'm not sure, went to see -- talked

      12    to Mickey Cantor, said, look, in all

      13    likelihood we're going to win this nomination

      14    but we want to work on something and we

      15    called it the Manhattan Project, which

      16    related to how to improve voter attitudes

      17    toward the President.  And we did a lot of

      18    research, focus policies, et cetera, et

      19    cetera and because of the primary process at

      20    that time, we were not doing that well in the

      21    general election, but, if you read my book, I

      22    would trust my memory more to the exactitude








                                                              149


       1    of that in All's Fair when it was a lot fresh

       2    in my memory.

       3         Q    The name of the book is All's Fair?

       4         A    Right.

       5         Q    Now, but up to the point, like,

       6    from New Hampshire onward, your job was to be

       7    among other things one of the spinners that

       8    would be able to communicate with the media

       9    about the governor, right?

      10              MS. MARSH:  Objection as to

      11    relevance and as to the term "spinners."

      12              BY MR. KLAYMAN:

      13         Q    Your job was to be in charge of

      14    what was being disseminated?

      15         A    You know, we went from sort of

      16    primary to primary and some primaries I was

      17    more involved than other primaries.  I was

      18    more involved in the Georgia primary than I

      19    was in the Florida primary.  I was more

      20    involved in the New York primary than I was

      21    in the Connecticut primary.  It's just a hard

      22    thing to characterize it as sort of one thing








                                                              150


       1    because it changed as the campaign went on.

       2         Q    You certainly had to know, in terms

       3    of your communications with the media, about

       4    the problems that the governor was claimed to

       5    have had with women, correct?

       6              MS. MARSH:  Objection as to

       7    relevance.

       8              THE WITNESS:  Well, I certainly

       9    knew about Jennifer Flowers.

      10              BY MR. KLAYMAN:

      11         Q    Who did Betsy Wright report to in

      12    the campaign?

      13         A    The governor.

      14         Q    She also reported to you, did she

      15    not?

      16         A    On the Arkansas record stuff.  She

      17    did not report to me on anything to do with

      18    women, but, yes, on what was the unemployment

      19    rate, what was the such and, you know what I

      20    mean?  If they say what happened -- remember,

      21    the great 124 tax increase brouhaha, yes.

      22    Yes, she definitely did report to me on that,

 

 

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