201 1 a study that said that it would be cheaper to 2 not put this thing in the gas tank if -- and 3 pay whatever judgments that you were going to 4 have. Ivy then in 19 -- had that story from 5 1973 till I believe 1981 and then told an 6 attorney for GM by the name of Howard, 7 according to a document, that he in fact was 8 requested to do this by the Oldsmobile people 9 and probably showed it to people, and the 10 article said that Mr. Starr was active in 11 keeping this information from the plaintiffs 12 as a result of the attorney-client privilege. 13 I further understand that that has 14 been -- that incident has been referred to 15 the Justice Department -- the U.S. attorney 16 there referred it to the Justice Department 17 for people to look into. That's my 18 understanding. I can't tell you I'm 100 19 percent right on the facts, but that's my 20 understanding. 21 Q I'll show you what I'll ask the 22 court reporter to mark as Exhibit 15. It's a 202 1 transcript of your appearance on Larry king 2 live on February 23, 1998, at 9:00 p.m. 3 MS. MARSH: Is that an authentic 4 transcript or is that something off the 5 Internet that purports to be a transcript? 6 Mr. Klayman, can you answer my question? I 7 guess not. 8 (Carville Deposition Exhibit 9 No. 14 was marked for 10 identification.) 11 BY MR. KLAYMAN: 12 Q Showing you Exhibit 14 -- 13 MS. MARSH: I'll put an objection 14 on the record as to calling it as a 15 transcript when it appears to be something 16 copied off the Internet or another computer 17 system by someone here at Mr. Klayman's 18 office. 19 MR. KLAYMAN: CNN interactive, 20 that's where it came from, horse's mouth. 21 BY MR. KLAYMAN: 22 Q I ask you to turn to page 5, count 203 1 five from the top. Do you see where it has 2 "King" on the top and then it has your 3 colloquy there? 4 "Do you have some information about 5 star's deputies that we don't know? 6 Carville: Well, I don't know if some people 7 know it. All kinds of people over there that 8 have very -- what I think to be very 9 questionable record. One gentleman over 10 there, Mr. Emmick, I think his name, has 11 spent 259 million going after --" 12 A I said 25 or 9 million. The 13 transcript is incorrect. 14 Q "I'm told and ended up paying a $25 15 fine." In fact, it was more like 25,000, 16 right? 17 A I remember it as 25, but I remember 18 the -- 19 Q "I think there's a thing where one 20 of the people in this office denied people 21 the right to counsel or something. I read in 22 Time magazine this week. It's all right out 204 1 there," and then you go on to say, "I wonder 2 if my question to Mr. Starr is did he conduct 3 an investigation of the people that he hired? 4 Did he know what tactic these people used in 5 the past? Did he conduct any kind of 6 interviews with FBI checks or anything like 7 that? These are very important people. 8 These are people that have great power. They 9 subpoena anybody they want to, run up legal 10 fees. These are very much public figures and 11 it's my opinion that as the public figures we 12 need to know more and more about these folks. 13 We surely know more and more about Mr. Starr. 14 I have just been handed a document before I 15 came over here that indicates Mr. Starr may 16 be part of covering up some documents in a GM 17 case down in South Carolina. I'll be looking 18 into that." 19 A That's correct. 20 Q Who handed you that document, as 21 you referred to on Larry king? 22 A Somebody sent it to me. You know 205 1 what I mean? I don't remember where it came 2 from but it was -- as I remember, I think 3 Kevin pulled it off the -- the thing in 4 Mother Jones is my recollection. 5 Q Who handed it to you, Mr. Carville? 6 A I don't know. 7 Q In fact, Mr. Carville you know who 8 it was, don't you? 9 MS. MARSH: I object to the form of 10 the question. 11 THE WITNESS: It's a public 12 document. I really don't. Probably 13 Mr. Murphy. 14 BY MR. KLAYMAN: 15 Q This interview occurred as recent 16 as February 23, 1998, correct? 17 A Right. 18 Q And you can't remember? 19 A No, I can't. As if I'm going to 20 remember -- it could have been somebody told 21 me about it I might have said pull this thing 22 off. I mean, I don't remember -- who do you 206 1 think -- I mean, who would you suspect would 2 have handed it to me? 3 Q It came from either Mr. Bennett's 4 office or Mr. Kendall's? 5 A Oh, good god. It was in a magazine 6 article. It was in the Miami Herald. This 7 is not something that's sort of a big secret 8 out there. I mean, this is not some kind of 9 a thing that wasn't accessible or available 10 to people. 11 Q Did you provide the GM document to 12 The White House? 13 A No. I mean, I'm sure that they 14 have it anyway. For all I know it could have 15 been somebody in the White House that told me 16 that this thing was up somewhere. Look, if 17 we're going to sit here -- it's fine with me 18 to talk about something that appeared in a 19 magazine, that appeared in a newspaper 20 article. It was there, yes, and I said I had 21 been handed this story. Of course. 22 Q Now, after the campaign of 1992, 207 1 when Governor Clinton was elected to 2 President of the United States, you left the 3 position as head of the war room, correct? 4 A Yes, sir. 5 Q And effective leader of the 6 Clinton-Gore campaign? 7 MS. MARSH: Objection. 8 THE WITNESS: Yeah, it's your 9 characterization. I was certainly one of the 10 senior people in the campaign. 11 Q Are you so modest in your book? 12 MS. MARSH: Mr. Klayman, we've been 13 over this. 14 BY MR. KLAYMAN: 15 Q Mr. Carville, what did you do at 16 that time? 17 A What do you mean, what did I do? 18 Q What did you go do with your life 19 after President Clinton was elected? 20 A Well, let's see. Wrote a book. I 21 got married. I had a kid. I gave speeches 22 and did -- you know, whatever. I was 48 208 1 years old and stayed friendly with -- you 2 know, with the President. 3 Q You continued to provide advice to 4 Mr. and Mrs. Clinton, did you not? 5 A I did. 6 Q And you continued to provide advice 7 to people who worked for them in the White 8 House, correct? 9 A Well, I sure continued to speak to 10 them and remained friends with the people 11 that worked in The White House. 12 Q And you continued to provide advice 13 and keep contact with people on the 14 Democratic National Committee and Democratic 15 party, correct? 16 A Some. I never had a lot of friends 17 over there. Certainly, when David was over 18 there I would go, you know, some. But most 19 of the stuff I did would be at the White 20 House. 21 Q And how much contact did you have 22 with the President ongoing on a weekly basis? 209 1 MS. MARSH: What time period? 2 THE WITNESS: Yeah, that's a hard 3 thing to answer, Mr. Klayman, because it sort 4 of depends because I might -- I had less 5 contact than, like, Mandy or Stan did because 6 I was out writing a book and giving speeches 7 and doing other things. I was on the road a 8 good bit. 9 Q Let's talk about 1993. About how 10 much contact did you have weekly with the 11 President and First Lady? 12 A Oh, probably a couple times a 13 month, but I can't -- you know, I mean we 14 just go back. There's no possible way I 15 could answer that because it would depend on 16 the time frame. 17 Q Did you talk to them by phone? 18 A Well, I'm sure I did. 19 Q The President would call you from 20 time to time? 21 A Yeah, I'm sure he did. 22 Q The First Lady would call you? 210 1 A Less frequently but some. 2 Q You'd meet sometimes? 3 A I did. We would. 4 Q You'd meet at the White House 5 sometimes? 6 A We did. 7 Q And you'd be invited over with your 8 wife Mary Matalin for social occasions at the 9 White House from time to time? 10 A You sure are interested in my wife. 11 The one time in 1993, in November, the 12 President and First Lady before we got 13 married gave us a party. One other time, if 14 you're interested, I could tell you the other 15 time my wife went was George Stephanopolous's 16 going away party. 17 Q I've heard Mary make a statement 18 from time to time that she likes 19 Mrs. Clinton; is that accurate? 20 MS. MARSH: Objection as to 21 relevance. 22 THE WITNESS: It's like I like 211 1 President Bush and Senator Dole. 2 BY MR. KLAYMAN: 3 Q What kind of contact have you and 4 her had together with the First Lady? 5 A Three times. We saw at the party 6 that she and the President gave us when we 7 got married. We saw the First Lady at the 8 going away party for George Stephanopolous, 9 who was a friend of Mary and I's, and we saw 10 the President and First Lady. We went 11 through some receiving line for all of about 12 three seconds at the last state dinner. 13 Other than that I don't think that my wife 14 had, to my knowledge, any contact with the 15 First Lady. 16 Q Now -- 17 A I do everything that I can to try 18 to remain friends and be friends with her 19 friends, also. 20 Q Between 1993 to 1996, who did you 21 have most contact with at the White House? 22 A George. 212 1 Q And how frequently did you have 2 contact with Mr. Stephanopolous during that 3 period? 4 A Close to daily. 5 Q Several times daily? 6 A You know, maybe sometimes more than 7 once daily, maybe sometimes if I was on the 8 road, depends on where I was. 9 Q He's testified and stated publicly 10 that you talked about seven times a day; is 11 that about accurate? 12 MS. MARSH: Objection. His 13 testimony is what it is. 14 THE WITNESS: I'm sure there was 15 days that we -- it could have been a day that 16 we talked seven times a day, but that was 17 kind of pretty unusual for me to talk to 18 anybody seven times a day. I was in 19 regular -- 20 MR. KLAYMAN: Ms. Paxton, please 21 stop -- I observed you're shaking your head, 22 which signals the witness. You're talking on 213 1 the record. You're not even counsel of 2 record. 3 MS. PAXTON: If you're going to 4 yell at me, then I will go on the record. 5 You have no right to make those 6 representations. 7 MR. KLAYMAN: And if you want to 8 train a camera on someone, I suggest you do 9 it on Ms. Paxton. 10 MS. GILES: Stephanopolous 11 deposition transcript speaks for itself. 12 THE WITNESS: George Stephanopolous 13 and I were, are, and continue to be close 14 friends. We talk to each other frequently. 15 BY MR. KLAYMAN: 16 Q During the period 1993 to 1996 17 several times a day, correct? 18 A You know, some days we probably 19 talked several times a day, maybe some days 20 we didn't talk -- I don't know. What I would 21 rather do is just characterize -- we spoke on 22 the phone frequently. 214 1 Q It was close contact? 2 A Yes, we're close friends. 3 Q How long does each conversation 4 generally last? 5 A It varies, as honest an answer I 6 can give you. Not very long. Anybody that 7 knows George, it's I gotta go. My 8 conversations for whatever -- I had -- I'd 9 love to know why -- I would say that anyone 10 that knows Mr. Stephanopolous will remark 11 that his conversations are known for their -- 12 at this time maybe only Mr. Emanuel's are 13 shorter. 14 Q During that period, did you also 15 keep in contact with Mr. Begala? 16 A Sure. He worked in the same office 17 with me. As much as you're going to keep in 18 contact with somebody whose office door is -- 19 Q Where was he located between 1993 20 and 1996? 21 A From 1993 till -- you'd have to 22 look. When did he leave to go to Austin? He 215 1 was located in my office, and it would have 2 been out in Alexandria somewhere. 3 Q When did he leave to go to Austin? 4 A Yeah. I had a going-away party for 5 him, and the baby was born August of '95, as 6 best I can recall. Now, I could be wrong, 7 but you've got his deposition, but if I 8 remember, the baby had just been born, and I 9 had a going-away party for him. 10 Q In your depositions with 11 Mr. Stephanopoulos and Mr. Begala, you would 12 talk to him about politics and what was going 13 on in the Clinton White House, correct, from 14 time to time? 15 A Sure. 16 Q And in fact, you were providing 17 advice with regard to the Clinton 18 administration during that period, correct? 19 A Some, yes, sir. 20 Q And you were paid for that advice, 21 weren't you? 22 A Yes, sir. 216 1 Q How much were you paid for that 2 advice? 3 MS. MARSH: Objection as to 4 relevance. 5 THE WITNESS: You'd have to ask 6 Mr. Begala, but I don't remember. I don't 7 recall. But I could find out for you. 8 BY MR. KLAYMAN: 9 Q Roughly speaking. 10 A I don't recall. I'd rather not 11 guesstimate. I'd rather be factual, and I'd 12 be glad to follow up. 13 Q Did you have a contract? 14 A I don't know if we had a written 15 contract or not. Most of the stuff -- I was 16 giving a lot of speeches, and again, was 17 working on my book. And I was certainly -- I 18 did not appreciate -- we had a contract with 19 the DNC. 20 I do not know the amount, but I 21 would be more than happy to find out so I can 22 give you an accurate answer, as opposed to an 217 1 estimate. 2 Q You had a contract with the DNC? 3 A That's correct. 4 Q You and Mr. Begala? 5 A Yes, that's my recollection. I say 6 a contract; I mean, I don't know if we had a 7 written contract, but they paid. Let me go 8 back and say they paid us, and we had a 9 verbal agreement with Mr. Wilhelm. 10 Q Did you have a contract with the 11 White House? 12 A No, sir. 13 Q You had a contract with the DNC to 14 provide advice to the White House? 15 A Yes. 16 Q And who has that contract today? 17 A I don't know if there is one. I 18 don't know if it was a written contract. It 19 might have been a verbal thing. It might 20 have been a handshake. Very seldom in my 21 consulting business do I get a written 22 contract. I'm just usually the kind of guy 218 1 that operates on a handshake. 2 Q Who did you enter the contract 3 with? 4 A I don't know. With David Wilhelm. 5 Well, I do. David Wilhelm. 6 Paul did the -- he was -- one of 7 the things he did, he was more of the 8 business manager. And I don't even think we 9 had -- like I said, you would have to ask 10 him. I don't think we ever even signed a 11 partnership agreement. 12 Q Between 1993 and 1996, roughly how 13 much money were you paid under this contract, 14 or any other type of relationship, to provide 15 advice? 16 MS. MARSH: You mean other? He's 17 not going to tell you about his other clients 18 than the President. I mean, there's 19 nothing -- 20 THE WITNESS: I don't have -- I 21 don't have -- 22 BY MR. KLAYMAN: 219 1 Q I'm talking with regard to 2 providing advice about the Clinton 3 administration. 4 A I could find out. I could call 5 Mr. Begala. I could give you an accurate 6 figure. I don't recall, so why would I give 7 you a figure that I don't have any confidence 8 in, when I could find out and call you or 9 write you a letter and say, pursuant to the 10 question you asked, "We were paid this." I 11 just don't -- I don't know. 12 Q More than $100,000? 13 MS. MARSH: Mr. Klayman, he told 14 you he doesn't know. 15 THE WITNESS: Over what period of 16 time? 17 MR. KLAYMAN: Please do not signal 18 an answer to the witness. Certify this. 19 THE WITNESS: I'm not signaling. 20 MS. MARSH: I'm not signaling him 21 the answer. Mr. Klayman, he told you he 22 doesn't know. 220 1 MR. KLAYMAN: And I'm trying to 2 identify how much. 3 BY MR. KLAYMAN: 4 Q More than a hundred thousand? 5 A Again, I don't -- 6 MS. MARSH: Objection. Asked and 7 answered. 8 THE WITNESS: Over what period of 9 time? 10 Q 1993 to 1996. 11 A I'm sure. Actually, the contract 12 was terminated in -- I think it was only for 13 '93 and '94, as I recall. 14 Q More than 200,000? 15 A I don't know. Mr. Klayman, as I 16 said, I would be glad -- why not? I would be 17 more than happy to find out, you know. You 18 had Mr. Begala here. He ran the business. 19 He would be -- the only thing I would do is, 20 I would call and ask him. If you had him 21 here I assume that you asked him and know. I 22 don't know the answer, and if you keep asking 221 1 me the question, I'm going to keep saying I 2 don't know the answer, and I don't know it 3 now, and I'm not going to know it ten minutes 4 from now. 5 Now, you can keep asking me if you 6 want to, but I'm not going to know anything 7 more ten minutes from now than I know now. I 8 don't recall. I want to give you a truthful 9 answer, and I don't know what the truth is. 10 Q During that period, who did you 11 have most contact with in The White House 12 besides Mr. Stephanopoulos? 13 A Ron, Mark Gearan. 14 Q Ron Emanuel? 15 A Mm-hmm. 16 Q Mark Gearan? 17 A Mm-hmm. 18 Q Why did you have contact with Ron 19 Emanuel? 20 A Well, he was a friend of mine. 21 We're close friends. We have been friends 22 since 1991. He comes -- we eat dinner 222 1 together. He's a close, close friend of 2 mine. Why wouldn't I? 3 Q And sometimes you would talk to him 4 to provide advice, correct? 5 A Yeah. More often than not, I'd 6 listen to him -- you know, what people sort 7 of do when they're under the kind of pressure 8 he's got. I think so. I think more than 9 advice, I was probably just some kind of a 10 sounding board. 11 Q What was his position then? 12 A I don't remember. I could tell you 13 where his office was. I think he was -- you 14 know, he worked on -- as I recall, he would 15 work on things like NAFTA, and he worked on 16 the crime bill and that kind of stuff. But 17 it would be better to ask -- I mean, I don't 18 know what his title, if he was assistant to 19 the President. I mean, I have no idea what 20 all these titles mean. 21 Q Mark Gearan, what was his title at 22 that time? 223 1 A At one time, he was the 2 communications director, or the press 3 secretary. I think he was the communications 4 director. 5 Q And you talked to him so you could 6 provide information and advice as well, 7 correct? 8 A Yeah. I didn't talk to him near as 9 much as I talked to Ron. If I talked to him, 10 he is a pretty -- well, he still is a friend 11 of mine. I don't see him. Where is Mark? 12 He's in the Peace Corps now or somewhere like 13 that. 14 Q You talk to Leon Panetta from time 15 to time? 16 A Not a lot. 17 Q But from time to time? 18 A Infrequently, but some. 19 Q To give advice? 20 A The few times that I talked to 21 Leon, Leon said, "The President asked me to 22 call you about something." 224 1 Q You talked to Mac McClarty from 2 time to time? 3 A Periodically, but not often. 4 Q Do you give him advice and 5 information? 6 A Perhaps. You know, I can't 7 remember the exact nature of the 8 conversation. 9 Q You talked to Bruce Lindsey from 10 time to time? 11 A Pretty infrequently, but I've run 12 into him. 13 Q You did talk to him from time to 14 time? 15 A Yeah, I've run into him. 16 Q Did you give him advice and 17 information? 18 A I can't say I didn't, but I 19 don't -- 20 Q Harold Ickes? 21 A Certainly he's a friend of mine. I 22 talk to him from time to time. 225 1 Q And you talked to him from time to 2 time between 1993 and 1996 to give him advice 3 and information concerning the Clinton 4 administration? 5 A Was Harold? I don't think he was 6 there in 1993, Larry -- or Mr. Klayman, I 7 should say. I don't know. If you could jog 8 my memory. But he's certainly a friend of 9 mine, a good friend of mine. 10 Q Did you know Ron Brown? 11 A Yes, I sure do. 12 Q You talked to him from time to 13 time, didn't you? 14 A Not very often. 15 MS. GILES: Objection as to 16 relevance. 17 MS. MARSH: Same objection. 18 Continuing objection to all questions 19 regarding Ron Brown. 20 THE WITNESS: He's a friend of 21 mine, or was a friend of mine. 22 BY MR. KLAYMAN: 226 1 Q You talked to him to give him 2 advice and information? 3 A No. I talked to him during the 4 campaign. I talked to him two, three, four 5 times a week, I guess. 6 Q During the '92 campaign? 7 A Yes. He was the chairman of the 8 Democratic National Committee. But when he 9 was Commerce Secretary, I don't know if I 10 ever called him. 11 But he certainly -- I mean, he 12 certainly was a friend of mine. 13 Q Do you get along with Leon Panetta? 14 A Yeah. I mean, I respect Leon, but 15 I'm not -- we're not -- I have a lot of 16 respect for him. I saw him some time ago, 17 flying out to San Francisco. I think he did 18 a good job for the President. But I don't 19 have a social relationship with Mr. Panetta. 20 Q There's no impediment on him being 21 called by you or him calling you? 22 MS. MARSH: Impediment? 227 1 THE WITNESS: No. 2 BY MR. KLAYMAN: 3 Q Personal, business, or anything? I 4 mean, you can call each other when you want 5 to? There's no animosity between you? 6 A No. No. Certainly not on my part. 7 As I say, I have a lot of respect for 8 Mr. Panetta, you know? I think he did a 9 really good job for the President. But I'm 10 not -- as opposed to some of the people that 11 you were asking me about, who I'm social 12 friends with, I've never been a social friend 13 of Mr. Panetta's. 14 Q Before this deposition that you're 15 on here today, have you had a chance to 16 review the deposition of George 17 Stephanopoulos or Paul Begala? 18 A I have not even seen George's. I 19 saw Paul's, and didn't really have a chance 20 to review it or anything of any consequence. 21 Q Did he talk to you about it? 22 A Briefly. 228 1 Q When did he talk to you about it? 2 A Sometime last week, probably, but 3 not in any sort of great detail. 4 Q Did George Stephanopoulos talk to 5 you about his? 6 A A little bit, but -- if anything 7 less. 8 Q When did you talk to Paul Begala 9 about it? 10 A Last week, I'm sure. 11 Q And who called who? 12 A Oh, I don't know. You know, that 13 kind of thing, who knows? We call each 14 other, you know, on the phone a lot, people I 15 like to talk to. I have no idea. 16 Q And how long was the conversation? 17 A Well, I've had any number of 18 conversations with him. How long was the 19 conversation about his deposition? 20 Q Yeah. 21 A Two or three minutes. 22 Q And what did Mr. Begala tell you? 229 1 A He said that -- well, he said at 2 the end that you asked him if you had been 3 rude to him, and he said told you no, you 4 hadn't, but that you were rude to the court 5 reporter or something. And he said that you 6 had a -- you asked him a lot about campaigns 7 that we'd been in and, you know, how we did 8 research and that kind of stuff. 9 That's about what I remember. 10 Q What did you say to him? 11 A Boy, I don't know what I said to 12 him. I mean, what I honestly said I have no 13 earthly reason on God's green earth what I 14 would know about the FBI files, which I've 15 not been asked about, I might add. It 16 just -- I know nothing about it. I have not 17 the vaguest idea of what happened. And I 18 have no earthly idea. 19 But, I mean, if there was this 20 urgency to talk to me, I don't know -- that's 21 the one thing we haven't talked about. I 22 don't know anything about anybody's FBI file. 230 1 I told him I've never seen an FBI file. I 2 wouldn't know what an FBI looked like if I 3 saw one. And I certainly would never have 4 discussed the content of anybody's FBI file. 5 If I went through my whole life and never saw 6 the FBI, I would be happy, Mr. Klayman. 7 But that was the long and short of 8 the conversation. 9 Q Did you have a conversation with 10 Stephanopoulos? I guess you did, right, 11 after his deposition? 12 A Right. He told me you asked him if 13 you had a speeding ticket. That's what I 14 remember. 15 Q Who called who? 16 A Who knows? I mean, absolutely, I 17 talked to Mr. Stephanopoulos and Mr. Begala 18 enough that I don't know any one time or 19 another where a phone call originates. 20 Q And both these calls occurred last 21 week? 22 A I don't know. Maybe Mr. Begala's 231 1 call was the week before last. I don't 2 remember. 3 Q What else did you discuss with 4 Mr. Stephanopoulos? 5 A Everything from what's going on 6 with ABC, you know what I mean, to what's 7 going on in his life to, you know, politics 8 around the country, to whatever friends talk 9 about. 10 Q I'm talking about his deposition. 11 A Not -- again, I did not talk to him 12 a lot about the deposition. And, you know, I 13 think -- he asked about this Ellen Rometsch 14 thing or something, and he said he read that, 15 I thought, in "Pillars of Fire." If I think 16 of something else, I'll be glad to tell you. 17 Q What did he tell you about Ellen 18 Rometsch? 19 A He said he was reading it on the -- 20 I think what he told me, if I remember 21 correctly, was reading it over the weekend, 22 because I called him the night that he said 232 1 that. And I said, "What the hell are you 2 talking about, man?" You know. But I didn't 3 have very exhaustive conversations with him 4 about it. 5 Q You know who Ellen Rometsch was, 6 don't you? 7 A I do now. I had no idea in a 8 thousand years who she was, until I'm sitting 9 there watching the television one Sunday 10 morning, and I hear George say that, and I 11 like to jumped out the bed. 12 Q Why did you want to jump out of 13 bed? 14 A Because I never heard of it and I 15 never heard of any such thing. The last 16 thing I would do is look into anybody's sex 17 life. I can assure you of that. That's 18 not -- and I never heard anybody discuss any 19 such thing. And I called Mr. Stephanopoulos 20 and told him as much. 21 Q But you have studied history, have 22 you not? 233 1 A Yeah. 2 Q And you know that J. Edgar Hoover 3 is reported to have used FBI files to look 4 into people's backgrounds when he was FBI 5 director? 6 A I understand. I did know that. I 7 did know that. 8 Q And you knew it before you saw 9 George on TV, didn't you? 10 A Well, when he said -- that's why I 11 said, "What are you talking about? No one 12 ever discussed that." You know, I certainly 13 have not. I've never heard of that, nor do I 14 know has anybody ever talked to me about 15 that. I don't know where George got that 16 from. 17 And that was the first time I had 18 heard the name Ellen Rometsch, and it's the 19 first time I even heard -- I didn't even know 20 there was a story about Kennedy and some -- 21 was it an East German spy or something? 22 That's the first time I'd heard the story. 234 1 Q But you knew Hoover had used FBI 2 files? You knew that? 3 A I did, yes, sir. 4 Q And you had read the book "Dark 5 Side of Camelot," hadn't you? 6 A I had not, no, sir. 7 Q You'd heard of it? 8 A I heard of it. 9 Q Do you know Sy Hersh? 10 A I road back on a train one time 11 with him from Philadelphia. It must have 12 been three or four years ago, I guess. I did 13 not know him then. I think that's the last 14 time that I spoke to him. He came up and 15 introduced himself, and we had a pleasant -- 16 it must have been an hour-and-a-half 17 conversation. 18 Q Have you ever seen the book "Dark 19 Side of Camelot"? 20 A I've seen it in bookstores. 21 MS. GILES: Objection as to 22 relevance. 235 1 BY MR. KLAYMAN: 2 Q Did you skim through it? 3 A No. 4 Q Did you ever read excerpts in Time, 5 Newsweek, or any publication? 6 A I read articles about it, but I 7 didn't -- I certainly didn't know anything 8 about any Ellen Rometsch. 9 Was it in -- but I did read 10 excerpts, because I think that in something 11 that you filed with the court, you had a 12 page -- was it out of "The Dark Side of 13 Camelot," or was it out of "Pillars of Fire" 14 or something? It was some appendices to some 15 document that I saw that you had that page 16 there, and I did see that. 17 Q Now, from 1996 to the present, do 18 you still have a consulting agreement with 19 the Democratic national committee? 20 A No, I don't. I don't. I don't 21 have any -- no, sir, I don't. 22 Q But you still provide advice, 236 1 right? 2 A I talk to people at the White 3 House. But I don't -- since 1994, I haven't 4 had. I mean, it goes back to '94. It was a 5 two-year period when I had -- 6 Excuse me. Mr. Klayman, can I just 7 take two minutes and run to the head real 8 quick? 9 MR. KLAYMAN: Well, I was going to 10 suggest. Do you want to stop and take lunch 11 for 15 minutes? 12 THE WITNESS: No. 13 MR. KLAYMAN: Well, I want to take 14 lunch for 15 minutes, so we'll take lunch for 15 15 minutes at this point. 16 And we're now going 3 hours and 20 17 minutes. We're just going to eat for 10 18 minutes. 19 MS. MARSH: He has an appointment 20 at 7 o'clock. That's why we wanted to go 21 straight through. 22 MR. KLAYMAN: Well, we're going to 237 1 take ten minutes for lunch, and you go to the 2 bathroom. 3 (Whereupon, at 1:50 p.m., a 4 luncheon recess was taken.) 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 238 1 A F T E R N O O N S E S S I O N 2 (2:04 p.m.) 3 Whereupon, 4 JAMES CARVILLE 5 was recalled as the witness and, having been 6 previously duly sworn, was examined and 7 testified further as follows: 8 EXAMINATION BY COUNSEL FOR PLAINTIFF 9 CONTINUED 10 BY MR. KLAYMAN: 11 Q Mr. Carville, from 1996 to present, 12 who do you maintain closest contact with at 13 the White House, and most frequent? 14 A At the present time, it would be 15 Mr. Begala and Mr. Emanuel. Prior, I think 16 that Mr. Stephanopoulos left in January 17 of '97, and Mr. Begala came aboard in, I 18 think, somewhere around Labor Day of '97. So 19 in that time, it would have been just 20 Mr. Emanuel, probably. Those are my two 21 closest friends over there. And 22 Stephanopoulos. 239 1 Q And from time to time, you talk 2 with the President and the First Lady from 3 1996 forward? 4 A From time to time. 5 Q How can frequently is that? 6 A It depends. Sometimes I would say 7 I have talked to the President more often 8 than I talk to the First Lady by far. Maybe 9 an average of once a month or less. 10 Q When was the last time you talked 11 to the President? 12 A Saturday. 13 Q Was that in person or by phone? 14 A By phone. 15 Q Who called who? 16 A The President called me. 17 Q And how long was the conversation? 18 A Not very long. Maybe five minutes 19 or so. 20 Q What was discussed? 21 MS. MARSH: Objection as to 22 relevance. 240 1 BY MR. KLAYMAN: 2 Q You can respond. 3 A He said that there were some -- 4 there was a Kathleen Willey, and what he said 5 was there was some letters that she had 6 written, and they were -- his lawyers were 7 considering -- I think were considering about 8 making them public, and what did I think 9 about it? 10 Q And what did you tell him? 11 A I'm not sure if I know what's in 12 there, but if it was something that was past 13 the time that she made this allegation, it 14 was probably a pretty good idea. 15 Q Did he ask you to help make them 16 public? 17 A No, sir. 18 Q What else did you discuss during 19 that conversation? 20 A Well, he had asked about my mother, 21 and he said -- the last time he called, he 22 called me about her. And I think that was 241 1 the nuts and bolts of the conversation. 2 Q Did you talk to anybody else at the 3 White House in the last week? 4 A Oh, yeah. 5 Q Who did you talk to? 6 A I talked to Mr. Begala. I talked 7 to Mr. Emanuel. I talked to Mr. Blumenthal. 8 Q Anyone else? 9 A Well, let me think some more, so I 10 don't -- in the last week? Probably three. 11 Q What did you discuss with 12 Mr. Begala? 13 MS. MARSH: Objection as to 14 relevance. 15 BY MR. KLAYMAN: 16 Q You can respond. 17 A Oh, it must have been 20 topics, I 18 think, from -- you know, we're friends. We 19 talked a couple or three times a day. 20 Q What did you talk to him that 21 refers or relates in any way to the Clinton 22 Administration? 242 1 A The tax, the abolish-the-IRS thing. 2 Certainly we talked about the coming-up thing 3 on "60 Minutes" last night with Kathleen 4 Willey. I was on one of the -- I was on Wolf 5 Blitzer's show Sunday morning. We talked 6 about that. We talked about the basketball 7 tournament. We talked about, you know, a 8 variety of things. I couldn't give you a 9 roster, as they say -- 10 Q You talked to him about your 11 deposition here today? 12 A As I had indicated to you earlier 13 before, we did have a conversation about it. 14 It was pretty abbreviated, and I already told 15 you what I remember being said. 16 I may remember something else as 17 this goes on. If it does, I'll tell you. 18 Q What did you talk about Mr. Willey? 19 MS. GILES: Objection as to 20 relevance. Mr. Klayman, I really don't mean 21 to be argumentative, but is there any attempt 22 to link any of these questions to the FBI 243 1 files matter? 2 BY MR. KLAYMAN: 3 Q You can respond. 4 MS. MARSH: The same objection. 5 THE WITNESS: Yeah. He said that, 6 you know, don't -- he advised me not to say 7 anything unnice about Ms. Willey, I guess. 8 BY MR. KLAYMAN: 9 Q Did he ask you whether you had any 10 intelligence on Ms. Willey? 11 A No. 12 MS. MARSH: Objection. 13 BY MR. KLAYMAN: 14 Q Whether you had any dirt about her? 15 A No, no. 16 Q Mr. Blumenthal, what did you talk 17 about with him? 18 MS. MARSH: Objection as to 19 relevance. 20 THE WITNESS: A lot about this 21 story that -- the story about something 22 called the Arkansas Project, where like a 244 1 million and a half dollars was spent 2 investigating the President. We talked about 3 that a lot. 4 We talked about the fact that there 5 was a story in Slate Magazine about troopers 6 being paid off a lot. I think that was the 7 principal thrust of my conversation with 8 Mr. Blumenthal. 9 BY MR. KLAYMAN: 10 Q Did you have a last conversation in 11 the last week or so with Mr. Emanuel? 12 A Four or five, I'm sure. 13 Q What did you discuss with him 14 during those four or five? 15 A Everything from where he was going 16 with his life to what was going to happen 17 with the Kathleen Willey story to -- I'm 18 trying to think. 19 We had speculation about the '98 20 elections to -- you know, just stuff that -- 21 Mr. Emanuel was known and famous for very 22 abbreviated phone calls. You could talk to 245 1 Mr. Emanuel 3 times a day and not get 40 2 seconds worth of conversation in. 3 Q Before this last conversation with 4 the president that you just recounted, when 5 had you talked with him previously? 6 A It was in mid-February. I could 7 look at my calendar and tell you that my 8 mother is not in great health. And I went 9 down to Louisiana, and he called me -- it was 10 on a Friday; if you give me my calendar, I 11 could tell you the exact date -- to express 12 his concern and that my mother and his mother 13 were -- you know, were friends, and he wanted 14 to know how she was doing, et cetera, et 15 cetera, et cetera. 16 Thank you. 17 I took it as a personal trip to 18 Baton Rouge. 19 Q I'll accept just your 20 "mid-February" if you can't find it. 21 A It was -- Mr. Klayman, it could 22 have been. It could even have been -- I 246 1 doubt if it was late January. It was 2 probably -- my guess is it was three, four 3 weeks ago. 4 Q Did you discuss anything with 5 regard to gathering information about 6 perceived adversaries of the Clinton 7 administration? 8 A No, sir, I never have. 9 Q You have discussed that with the 10 President, though, haven't you, doing 11 research on the people that have been 12 attacking the administration? 13 A No, I don't think that I had a 14 conversation with the President like that, 15 best I can recollect. It's generally not the 16 conversation -- the type of conversation that 17 I'll have with him. I would characterize my 18 conversations with the President as that 19 sometimes he calls, and frequently calls to 20 chat. 21 Q By the way, condolences about your 22 mother. 247 1 A I appreciate that. Thank you. 2 She's actually doing a trifle better. 3 Or it's to ask a specific question. 4 But more -- the time he called before that 5 was, at Camp David, a preacher mentioned 6 something out of my book, and he called to 7 tell me that. 8 Q But you have talked to him about 9 finding out more about Ken Starr and his 10 prosecutors, haven't you? 11 A No, I really haven't. I mean, I 12 don't ever recall having a conversation like 13 that with the President. It would be highly 14 unlikely I would. 15 Q Did you ever bring up Judicial 16 Watch, Larry Klayman, and this lawsuit? 17 A No, sir, I have not? 18 Q You only get above the level of 19 "little twerp"? 20 MS. MARSH: Objection. 21 BY MR. KLAYMAN: 22 Q Have you discussed any other 248 1 Clinton adversaries as you perceive them? 2 Who do you perceive to be the big 3 Clinton adversaries right now that want to 4 destroy this President? 5 A You got a week? 6 Q Well, let's abbreviate it. 7 A Starr. 8 Q Anyone else? 9 A Oh, man, you know, I'd rather not 10 get into sort of characterizations about -- 11 you know, I think that there are any number 12 of people -- any politician, you're going to 13 find any number of people, particularly here 14 in Washington, that don't wish you well. 15 Q Well, based on your considerable 16 experience, who do you think actually has the 17 ability, however remote you may view it, to 18 succeed at destroying this presidency? 19 MS. MARSH: Objection as to 20 relevance. 21 THE WITNESS: Starr. 22 BY MR. KLAYMAN: 249 1 Q Is there anyone else? 2 A I'd say he's got the most. 3 Probably -- you know, Richard Scathe Mellon, 4 he's funneled so much money into -- you know, 5 there's a million and a half dollars, and God 6 knows what they paid off. I guess he'd be -- 7 just for his sort of willingness to expend 8 financial resources. 9 Q Who else? 10 A I mean, you know, certainly -- who 11 is the guy from Georgia? Bob Barr, he 12 doesn't wish the President well. I'd even 13 put you in there, Mr. Klayman. I'm sure you 14 don't -- 15 Q Anyone else? 16 A There's plenty of people. Rush 17 Limbaugh. They just -- you know what I mean? 18 I mean, I could spend the rest of my 19 deposition going through people that I -- 20 again, all the time, there are politicians 21 that I don't wish well politically. I mean, 22 that's not necessarily, in and of itself, 250 1 a -- 2 MS. MARSH: Are you finished with 3 your answer, Jim? 4 THE WITNESS: Yeah. 5 BY MR. KLAYMAN: 6 Q Do you want to add some more? You 7 said you could take a week. Maybe you could 8 just give us three minutes. Who else? A top 9 ten list? 10 MS. MARSH: Come on, Mr. Klayman. 11 Ask him a real question. He's given you 12 names. 13 BY MR. KLAYMAN: 14 Q Who in the journalistic community 15 is the most antagonistic, in your view, 16 towards this administration? 17 MS. MARSH: Objection as to 18 relevance. 19 MS. GILES: Object as to relevance. 20 BY MR. KLAYMAN: 21 Q You can respond. 22 A Christopher Ruddy.
of this deposition