251 1 Q Next? 2 MS. MARSH: You said "the most." 3 THE WITNESS: I mean, I don't know 4 what -- 5 BY MR. KLAYMAN: 6 Q Name me five who you think is -- 7 A Christopher Ruddy, Wesley Pruden, 8 Pat Buchanan -- I don't know. I guess you 9 could call him a journalist. 10 Q Lynn Schmidt, Washington Post? 11 A I don't know a Lynn Schmidt. Sue 12 Schmidt? 13 Q Sue Schmidt? 14 A I'm not a fan of her reporting, but 15 I don't know that I would -- certainly would 16 not put her in that category. 17 Q John Fonda in the Wall Street 18 Journal? 19 A He probably -- I'd put him in that 20 category. 21 Q William Safire? 22 A No. Maybe I have -- I wouldn't 252 1 quite -- you know, and I don't think I -- I 2 certainly would not call him an ally to the 3 President, but I wouldn't put him in the same 4 category I would Fonda. 5 Q Michael Kelly? 6 A I wouldn't put him in the same 7 category, but he certainly is not a fan of 8 the President's. 9 Q Let's go back, say, to the fall of 10 1996, around the time that the whole campaign 11 finance scandal period hit. Do you remember 12 that? Through the election. 13 A I do. 14 Q Who do you talk with most outside 15 of the White House about the Clinton 16 administration? 17 MS. MARSH: About the campaign fund 18 scandal? 19 BY MR. KLAYMAN: 20 Q No, about anything dealing with the 21 Clinton administration. I'm just marking the 22 period of time. 253 1 Just right before the election and 2 up to the present, who have you talked to 3 most outside of the administration about the 4 administration? 5 A Stan Greenburg. 6 Q Who else? 7 A Mandy Grunwald. 8 Q Who else? 9 A George. 10 Q George Stephanopoulos? 11 A Mm-hmm. 12 Q Who else? 13 A I mean, I don't think anybody would 14 have -- you know? 15 Q Paul Begala before he joined the 16 White House? 17 A Oh, yeah. Yeah. I'm sorry. 18 Q Susan Thomases? 19 A No. I haven't talked to Susan 20 Thomases in I don't know how long. 21 Q Harry Thompson? 22 A I've talked to Harry infrequently. 254 1 Q But you talked to him from time to 2 time? 3 A I talk to him from time to time. 4 Q And his wife? What's her name? 5 A Susan Bloodworth, I think it is. 6 Linda Bloodworth Thompson. But very rarely 7 do I speak to her. But I consider her a 8 friend. 9 Q Leon Panetta? 10 A Rarely if ever. 11 Q Mickey Kantor, you talk to him a 12 bit, don't you? 13 A Once this year. 14 Q Have you talked to him recently? 15 A He called me right after -- when he 16 sort of came on board and just called to 17 thank me. He said, "You know, you're really 18 in there digging hard for us, and I 19 appreciate it." And that was the last 20 conversation I had with Mr. Kantor. Most 21 people -- 22 Q What do you mean by "coming on 255 1 board"? 2 A I think he -- didn't he come to 3 help the President, or he's one of the 4 lawyers for the President or something, is my 5 understanding. 6 Q Harold, you've talked to him quite 7 a bit, haven't you? 8 A No. I bet you I haven't talked to 9 Harold in a month. Most people know if they 10 need to communicate, if they're doing -- I'm 11 sorry. 12 Q Go on. You can finish. 13 A No. I've not talked to Harold 14 in -- I don't know how long. 15 Q Harold's friend, isn't he? 16 A He certainly is. He certainly is. 17 Q He's a good friend of yours? 18 A He is. 19 Q Bob Bennett? 20 A He's a friend of mine. 21 Q And you've talked to him quite a 22 bit in the last year or so, haven't you? 256 1 A Well, I certainly have talked to 2 him in the last year or so. But not on the 3 same level that I talked to some of these 4 other people. 5 Q David Kendall? 6 A He's a friend of mine. I speak to 7 him periodically. He also was my attorney on 8 matters nonrelated to this, as is 9 Mr. Barnett, who is at the same firm as 10 Mr. Kendall, and if Mr. Barnett is not in, I 11 generally will speak to Mr. Kendall vis-a-vis 12 legal advice. We are friends. I have lunch 13 with his -- he and his children during the 14 holidays. But he's pretty busy. I don't 15 talk to him a great deal. 16 Q Is there anybody else that you talk 17 to, say, more than once a month during this 18 last year and a half? 19 A Oh, man. Oh, man. 20 MS. MARSH: About anything at all? 21 BY MR. KLAYMAN: 22 Q About anything related to the 257 1 Clinton administration? 2 A Mr. Klayman, I have sat here and 3 endeavored to try to answer every question. 4 I have five sisters that I talk to. 5 Q I don't want your sisters, believe 6 me. 7 A You know, I'm under oath here. I'm 8 really trying to give you as an honest an 9 answer as I can. I talked to a friend of 10 mine in New York by the name of Gus Weil Jr., 11 who is a guy I knew from Baton Rouge. John 12 Max. 13 Q I'm talking about the people you 14 talk to frequently about the Clinton 15 administration. 16 A I mean, I talk to them if it comes 17 up. One of my best friends is a joke writer 18 for Jay Leno. I talk to literally every day. 19 I have any number of -- 20 Q What's his name? 21 A John Max. I have any -- do you 22 understand? I have any number of friends. I 258 1 tend to tend to stay very close to people 2 once I get to know them. So there are any 3 number of people I talk to frequently. 4 You asked me a question when I am 5 under oath, how many people do I speak to two 6 or three times a month, and I mean, I -- 7 Q The people that you've mentioned 8 were Stan Greenburg, Mandy Grunwald, George 9 Stephanopoulos, Paul Begala, Leon Panetta, 10 Mickey Kantor -- 11 A I don't speak to -- what I said is, 12 I don't think I've had a phone conversation 13 with Leon Panetta since he left the White 14 House. The only contact I had with Leon that 15 I can recollect is I was flying out to San 16 Francisco, and he and his wife on the 17 airplane, and we had a very pleasant 18 conversation. He's not someone that I'm in 19 sort of contact with. 20 Mr. Ickes is a friend of mine, but 21 I don't speak to him very often. 22 Q Fine. I'm just identifying them. 259 1 A Well, I know, but I'm trying -- 2 Q I'm not trying to go over testimony 3 here. Mickey Kantor, Bob Bennett, David 4 Kendall, and Mr. Barnett. What's his first 5 name, at Williams and Cohen? 6 A Robert. He's my lawyer. 7 MS. MARSH: I'm growing to object 8 to this question to the extent that you're 9 implying that he testified that he talked to 10 all these people two or three times a week. 11 He did not say that -- 12 THE WITNESS: I never said that 13 I -- 14 MR. KLAYMAN: I didn't say two or 15 three times. The testimony is clear. 16 BY MR. KLAYMAN: 17 Q All of these people are sympathetic 18 to the Clinton administration, are they not? 19 MS. MARSH: Objection. 20 THE WITNESS: Yes. 21 BY MR. KLAYMAN: 22 Q In fact, you could characterize 260 1 them as White House allies, couldn't you? 2 MS. MARSH: Objection. Whatever 3 that means. 4 MS. GILES: Objection. 5 THE WITNESS: Yes. 6 BY MR. KLAYMAN: 7 Q Who else is there that are White 8 House allies that you know of, that you're in 9 contact with? 10 MS. MARSH: How are you defining 11 that term? 12 BY MR. KLAYMAN: 13 Q Who in your view, Mr. Carville, 14 would be the top ten list of White House 15 allies who are not with the administration? 16 MS. MARSH: Do you know what he 17 means by "White House ally"? 18 BY MR. KLAYMAN: 19 Q Friends? 20 A There are people that I don't know 21 who are tremendous allies of the President. 22 I do not know if I -- I don't think I ever 261 1 met Walter Kaye. He's a fund-raiser in the 2 Democratic party, to my knowledge. I'm sure 3 he would be a big ally to the President. 4 I mean, I only know the sort of 5 political people, and the people I knew from 6 '92, and I don't know -- it's a word that I 7 don't know -- you know, contextually, I don't 8 know how to put it. But yes, the people that 9 I talk to about politics tend to be 10 sympathetic to the Clinton administration. 11 Q And who in your view, 12 notwithstanding those people you've 13 identified, would be in the top ten list of 14 allies? 15 MS. MARSH: Objection. Asked and 16 answered. 17 THE WITNESS: I can't -- 18 BY MR. KLAYMAN: 19 Q You mentioned Walter Kaye? 20 A He's just somebody that I've heard 21 of. I don't think I know Walter Kaye, but 22 I've seen his name in the paper, and I know 262 1 that he's close to the President. 2 Q You've heard of James and Maktar 3 Riadi, haven't you? 4 A Who? 5 Q James and Maktar Riadi, owners of 6 the Lipo Group? 7 A The owners -- I've certainly heard 8 of the Lipo Group. I do not know these 9 people. 10 Q Well, they're White House allies, 11 aren't they? 12 MS. MARSH: Objection as to 13 relevance. 14 MS. GILES: Objection. 15 THE WITNESS: If I don't know 16 them -- if I don't know them, how -- you 17 know, if you ask me a question and I say I 18 don't know these people, if you ask me if 19 they're White House allies, I mean, I do not 20 know them. 21 BY MR. KLAYMAN: 22 Q You ever hear of Charlie Tree? 263 1 A Sure. 2 Q He's a White House ally, isn't he? 3 MS. MARSH: Objection as to 4 characterization and also to relevance. 5 THE WITNESS: I don't know Charlie 6 Tree, but I certainly -- at least he was. I 7 don't know, you know, what he's doing now. 8 BY MR. KLAYMAN: 9 Q Johnny Chung, he was a White House 10 ally, right? 11 MS. MARSH: Same objection. 12 THE WITNESS: I don't know Johnny 13 Chung. 14 BY MR. KLAYMAN: 15 Q Based on what you know, was he a 16 White House ally? 17 MS. MARSH: He doesn't know him. 18 THE WITNESS: I don't know him, but 19 I'm sure he was a -- if I see what I've seen 20 in the press, he was a -- wasn't Johnny Chung 21 a fund-raiser? I mean, you would know. I 22 think he was a fund-raiser. 264 1 BY MR. KLAYMAN: 2 Q Did you ever meet Mr. Livingstone, 3 Craig Livingstone? 4 A I have. 5 Q When did you meet Mr. Craig 6 Livingstone? 7 A Last week. 8 Q Under what circumstances? 9 A I was sitting at the bar at the 10 Palm. This guy walks in and comes up to me 11 and he says, "James, this here is Craig 12 Livingstone." And I said, "Oh." I said -- I 13 recognized him, seen his picture in the 14 paper. I said, "How you doing?" "Just 15 fine." He says, you know, said something to 16 the effect that, you know, you're really 17 doing a good job out there. I said, "Thank 18 you. Appreciate it." He walked away. 19 I said, "Excuse me." I said, "Can 20 I ask you a question? Have I ever met you?" 21 And he said that he remembered that I had a 22 phone conversation with him about some kind 265 1 of forms that I -- disclosure forms or 2 something that I had to fill out during the 3 early part of the administration. 4 So I gather from my conversation 5 with him that he recollects that we had a 6 phone conversation, of which I would -- I 7 don't remember, but he says it, and I'm sure 8 he's telling the truth. 9 Q Did you tell him that you were 10 going to be deposed in this lawsuit? 11 A I said -- you know, I did. I said, 12 "It's highly I'll be asked and so on, and I 13 want to be able to tell the truth. Do I know 14 you, and what's our relationship?" You're 15 right. 16 Q Have you ever had dinner with Craig 17 Livingstone? 18 A If I never -- Mr. Klayman, if I 19 never met him, and all he remembers is he 20 remembers having one phone conversation with 21 him, then I don't think I've had dinner with 22 him. 266 1 Q Did you ever meet him at the Ashby 2 Inn in Paris, Virginia? 3 A No. I've been to the Ashby Inn, 4 but I've never met Mr. Livingstone at the 5 Ashby Inn in Paris, Virginia. 6 Q Have you been to the Ashby Inn more 7 than once? 8 A Yes. 9 Q How many times have you been there, 10 approximately? 11 MS. MARSH: Objection as to 12 relevance. 13 THE WITNESS: Seven or eight, 14 maybe. 15 BY MR. KLAYMAN: 16 Q When was the first time you went? 17 Approximately what year? 18 A 1993. 19 Q Did you go for personal reasons? 20 Business reasons? 21 A I have a place out in that part of 22 the world, and it's up -- when I lived on 267 1 Pine Knob, it was -- it is a place that I 2 like, and I like the people that run it. And 3 it was a nice drive from my place. I've 4 never been there to -- I don't think I've 5 ever been there for business reasons. 6 Q It's owned by John and Roma 7 Sherman? 8 A It is. 9 Q And they're friends of yours? 10 A They are. I mean, I didn't know 11 them until I started going there, but I know 12 them. I haven't been there in a while. But 13 I would call -- to a certain extent, I would 14 call them friends. 15 Q They introduced you to Craig 16 Livingstone, didn't they, at that Ashby inn? 17 A Again, I don't remember it. 18 Mr. Livingstone doesn't remember it. And, 19 you know, I had no recollection of meeting 20 him. I specifically asked him if I did, and 21 he says the only thing that he ever recalls, 22 me having a phone conversation with him. 268 1 I don't -- to the best of my 2 knowledge, I don't know the man. And I 3 actually asked him, and that's what he told 4 me. 5 Q Did you specifically discuss, when 6 you saw Mr. Livingstone at the Palm last 7 week, whether he had met you at the Ashby 8 inn? 9 A No, I didn't. I asked him if I 10 knew him. I said, "Do I know you? Do we 11 know each other?" 12 And he said that what he remembers 13 is that we had a phone conversation about a 14 form that I filled out. 15 Q You asked him because you were 16 worried about this case? 17 A No. What I wanted to do is, I 18 figured that you would ask me the question, 19 and I wanted to try to give you as truthful 20 an answer as I could. And the truth as I 21 knew it then is, I did not know him or have 22 any contact with him. 269 1 Go ahead. 2 Q The story where he says that you 3 called him when he was director of White 4 House security -- 5 MS. MARSH: What story? 6 BY MR. KLAYMAN: 7 Q -- he related to you at the Palm, 8 right? 9 A Yes. 10 Q Was that to get your security 11 clearance that you called him? 12 A He said it was about some forms. I 13 suspect that it was. 14 Q Dealing with security clearances? 15 A I suspect that it was. He just 16 said I called him with reference to some 17 forms I was filling out. Those would be the 18 forms that I was filling out. 19 Q Now, you had a pass to The White 20 House at one time, didn't you? 21 A That is correct, I did. 22 Q Do you still have one? 270 1 A No, sir, I don't. 2 Q Was that a temporary pass? 3 A No. 4 Q What was it, a permanent pass? 5 A Yes, sir, it was. 6 Q And that permanent pass was yanked, 7 wasn't it? 8 A Yes, sir, it was. 9 Q And why was it yanked? 10 A Because Mr. Panetta became chief of 11 staff, and he didn't want anybody outside of 12 the White House having a pass like that. 13 Q At that time, there were issues 14 concerning some of the clients you were 15 working for and a potential conflict of 16 interest, correct? 17 A Not to me that I know of. Which -- 18 give me an example. 19 Q I'm asking you. 20 A No, I don't know of any conflicts 21 that came up. But refresh my memory if there 22 was. 271 1 Q Mr. Panetta's decision to yank your 2 pass, was that a punishment of some sort? 3 MS. MARSH: Objection. How does he 4 know why Mr. Panetta made that decision? 5 THE WITNESS: I don't know. He 6 would have to answer that. 7 BY MR. KLAYMAN: 8 Q Well, what do you know as to why it 9 was done? 10 A I don't know. He said he didn't 11 want people that didn't work in The White 12 House to have it, was my understanding. So I 13 don't know what -- you'd have to ask him. I 14 can't supply a reason. 15 Q Were you forced to disclose your 16 finances if you wanted to continue having a 17 pass? 18 A I disclosed my finances prior -- I 19 already did disclose my finances. They were 20 disclosed. 21 Q Have you ever met Anthony Marcesa? 22 A When I saw his picture, I know 272 1 that -- I don't know where, but it's just 2 like you see somebody's picture, and I said, 3 "You know, I think I know that guy." 4 And he was -- I did races in 5 Pennsylvania, and he was involved in some way 6 or form in Democratic politics in 7 Pennsylvania. 8 Q And you've been involved in 9 Pennsylvania politics? 10 A I have. 11 Q In fact, you were campaign manager 12 for Harris Wofford, were you not? 13 A I really wasn't a campaign manager 14 for Harris Wofford. Paul and I did it, and 15 Paul actually ran the campaign. You know, we 16 were working together on it. But more 17 appropriately, he would be the title of 18 campaign manager. 19 Q Well, what was your role in that 20 campaign? You worked on it? 21 A Well, I was working with Paul. We 22 were a firm. But he did the day-to-day stuff 273 1 that a campaign manager did. I did strategy 2 and that kind of stuff and helped him -- you 3 know, that kind of stuff, and helped him, and 4 did that kind of stuff. 5 But I was certainly very involved 6 in the Harris Wofford campaign, but I would 7 leave the title of campaign manager to Paul. 8 Q Well, you've been reported as 9 receiving credit as being the architect of 10 that Wofford campaign? 11 MS. MARSH: Objection. Now you're 12 characterizing -- 13 THE WITNESS: Mr. Klayman, I was 14 very, very involved in the Wofford campaign. 15 I lived in Philadelphia during the Wofford 16 campaign. I would have just characterized 17 Paul as the campaign manager, and would try 18 to -- would characterize me as the lead 19 strategist. If you want to -- it's not a 20 nomenclature thing and a Pope or somebody. 21 It's just whatever you want to call yourself. 22 But in terms of the day-to-day running of the 274 1 campaign, it was Mr. Begala that did that. I 2 worked mostly on strategy and that type of 3 stuff. But we were partners. We were 4 together. We lived in the same apartment, 5 you know. We spent almost all of our time 6 together. 7 BY MR. KLAYMAN: 8 Q Did you get to know Mr. Marcesa on 9 that campaign? 10 A No, I don't think so. I don't know 11 that I -- all it is, when I saw this guy's 12 picture, I said, "I think I -- it's somebody 13 that I think I ran across." 14 But I don't know where. 15 Q Did you get to know Mr. Livingstone 16 on that campaign? 17 A Mr. Klayman, I don't know how many 18 times I'm going to testify, I don't know 19 Mr. -- to my knowledge, I don't know 20 Mr. Livingstone. I asked Mr. Livingstone, 21 "Do I know you," and he said, "No, you had a 22 conversation with me." 275 1 Now, you can keep asking me a 2 question over and over again. That's the 3 answer that I know. I don't even think 4 Mr. Livingstone is from -- I don't even know 5 if he's from Pennsylvania. 6 Q Are you aware that he worked in 7 Pennsylvania politics? 8 A No, I'm not. 9 Q Now, during the 1992 campaign, are 10 you aware of what, if anything, 11 Mr. Livingstone did on it? 12 A No, sir, I'm not. 13 Q What about Chicken George. Do you 14 know who was Chicken George? 15 A He was a kid that went to Michigan 16 State. 17 Q Was Mr. Livingstone in charge or 18 have anything to do with Chicken George? 19 A Not to my knowledge. 20 Q Was he Chicken George? 21 A No, he was not. 22 Q He wasn't one big chicken? 276 1 MS. MARSH: Objection. He just 2 told you who Chicken George was. 3 THE WITNESS: If you look in my 4 book -- give me my book and I'll find out. I 5 think I got it in there. 6 BY MR. KLAYMAN: 7 Q He would have been a pretty big 8 chicken, wouldn't he? 9 MS. MARSH: Objection. Ask some 10 serious questions. 11 THE WITNESS: I probably have the 12 reference in my book. 13 BY MR. KLAYMAN: 14 Q So you don't know of him doing 15 anything in the '92 campaign? 16 A I do not. 17 Q Did you ever work on the campaign 18 of Governor Casey? 19 A I did. 20 Q Who did he run against? 21 A He ran against two people. In 1986 22 he ran against Lieutenant Governor Scranton. 277 1 And in 1990, he ran against ÄÄÄÄ general, a 2 woman that I recall by the name of Barbara 3 Hayfer. 4 Q And did you do opposition research 5 during that campaign against Scranton? 6 A I'm sure we did. 7 Q Did you hire private investigators? 8 A Of course not, no. 9 MS. MARSH: Objection. Asked and 10 answered. 11 MR. GAFFNEY: I think that question 12 borders on harassing the witness, 13 Mr. Klayman, in light of his prior testimony. 14 And I think you owe him a courtesy to not do 15 that. 16 MR. KLAYMAN: I think you owe me 17 the courtesy of making relevant and timely 18 objections, Mr. Gaffney. 19 MS. MARSH: It is a relevant 20 objection. You've asked him that fifteen 21 million times, the private investigators, and 22 the witness told you. 278 1 MR. KLAYMAN: It's not relevant, 2 and the witness hardly looks harassed. 3 MR. GAFFNEY: Rule 30 provides for 4 an objection to questions that harass the 5 witness. 6 MR. KLAYMAN: I'm entitled to ask 7 general questions and then get more specific, 8 because the witness obviously can develop a 9 memory, perhaps even sometimes through no 10 fault of his own. 11 THE WITNESS: Well, I appreciate 12 that. 13 MR. KLAYMAN: I used the word 14 "sometimes." 15 THE WITNESS: ÄÄÄÄ the benefit of 16 the doubt. 17 BY MR. KLAYMAN: 18 Q Now, did you ever do any opposition 19 research during that campaign? 20 A Of course we did opposition 21 research. 22 Q How did you do it? 279 1 A How did we do it? We had people 2 that went -- he was lieutenant governor. We 3 talked about what he did or did not do as 4 lieutenant governor. As I recall, attendance 5 became somewhat of an issue in that campaign. 6 We never hired a private investigator or 7 anything like that. 8 Q Did you dig up anything on Governor 9 Scranton that was controversial? 10 A Dig up anything? Well, there were 11 things that were controversial about him that 12 were known. We didn't have to. It was all 13 over the press. 14 Q What was that? 15 A That he was -- he wanted to bring 16 transcendental meditation to state government 17 or something, if I could remember. If I 18 could go find the clip; I don't have it in 19 front of me or something. 20 But I never -- I mean, I never 21 remember anything in that campaign about 22 anything to do with Governor Scranton's sex 280 1 life or any such thing. 2 Q I didn't ask you about sex life. 3 A Well, you asked me. I'm trying to 4 answer your question. 5 Q That's not the only thing. 6 A It was an article -- I think it was 7 in Time Magazine, but I'm not sure. Yeah, 8 it's been 12 years ago. 9 Q Sex lives are not the only things 10 that may be controversial, correct? 11 A Right. Right. Of course, we did 12 research on Governor Scranton, and Governor 13 Scranton did research on us. 14 Q You ever hear of a Dennis Casey? 15 A I have, and I think he's a western 16 Pennsylvania guy. But it's a name -- I 17 wouldn't know him if I saw him, but it's a 18 name that I've heard around Pennsylvania 19 politics. 20 Q Have you ever worked with him? 21 A Not to my knowledge. But, you 22 know, statewide campaigns are big campaigns, 281 1 and I couldn't name you three people that 2 worked in the Pittsburgh office. 3 Q Did you ever hear of Ron Klink? 4 A I've heard of Ron McClain, but not 5 Ron Klink -- well, can you tell me who he is? 6 Sometimes if you tell me sort of a title for 7 somebody, I might not know the name, but I 8 might know the guy. 9 Q Ever hear of a Dan Caligari? 10 A No. I remember Richard Caligari 11 who was the mayor of Pittsburgh who 12 tragically died, so it's a name -- it's a 13 Pittsburgh kind of name. 14 Q You ever hear of Jim Rowe? 15 A No, sir. If you tell me who he is, 16 I can -- 17 Q About 15 minutes ago, you told me 18 that when you talked to George Stephanopoulos 19 recently, he told you something about ABC in 20 your conversation. What was that? 21 MS. MARSH: Objection. 22 THE WITNESS: I think it had to 282 1 do -- that the ratings for their Sunday 2 morning television show had gone up a little 3 bit, or something to that effect. Well, I 4 think he said it was like the leading -- it 5 had something to do with how this week's show 6 was doing. I can't remember exactly what. 7 BY MR. KLAYMAN: 8 Q Did he say thanks to his 9 commentary? 10 A No, he didn't. 11 Q Has he ever told you what the terms 12 of his contract are with ABC? 13 MS. MARSH: Objection as to 14 relevance. 15 MS. GILES: Objection. 16 THE WITNESS: He has not. That's 17 not the kind of thing I'd ask him. 18 BY MR. KLAYMAN: 19 Q Do you have any idea what the terms 20 of his contract are? 21 A No, I don't. 22 Q You don't even know what his title 283 1 is over there, do you? 2 A Sunday morning, you know, talking 3 head, I guess, or whatever you call it. You 4 know, I don't know if he is a -- I mean, I 5 don't know what the -- commentator or what is 6 it I've always said? They say in the White 7 House he's a commentraitor now. 8 Q Commen-what? 9 A I saw in the paper, they had 10 somebody that said he was -- he was harsh on 11 the President -- that said, "Well, he's not a 12 commentator. He's a commentraitor," or 13 something. It was in the paper. 14 Q Who said that? 15 A I don't know. I have no idea. It 16 was just a throwaway line. 17 Q He's never told you in your 18 discussions with him that you're a news 19 source for him, has he? 20 A No, sir. 21 Q Do you know of him saying that to 22 anybody else, do you? 284 1 A No, sir, I don't. 2 Q Based on your knowledge, who does 3 George generally talk with on a weekly basis, 4 let's say in the last six months? 5 A You know, I don't know. You'd have 6 to ask him. You had George here for a 7 deposition, and he has, to my knowledge, 8 always been a truthful guy. And he doesn't 9 really know who I talk to, and I really don't 10 know who he talks to. 11 Q Who does he hang around with in 12 terms of the administration? 13 A All right. Mr. Stephanopoulos, he 14 lives in New York now. So I don't know. 15 Q When he's here? 16 A I don't know. 17 MS. GILES: Objection. You had 18 your chance to depose Mr. Stephanopoulos. 19 That transcript speaks for itself. 20 THE WITNESS: Mr. Klayman, I don't 21 know where he stays when he comes. I suspect 22 ABC puts him up in a hotel, but I do not know 285 1 which one. 2 BY MR. KLAYMAN: 3 Q Have you ever met any of 4 Mr. Stephanopoulos' friends? 5 MS. MARSH: I'm going to put a 6 continuing objection on as to relevance of 7 questions about Mr. Stephanopoulos' personal 8 life, who his friends are, and who -- 9 BY MR. KLAYMAN: 10 Q You can respond. Have you ever met 11 any of them? 12 A Well, I may not know of them. I 13 met -- Mr. Emanuel and Mr. Begala certainly 14 would consider themselves friends of 15 Stephanopoulos. Any number of people. 16 The best person to ask is 17 Mr. Stephanopoulos. I just -- I'm sorry, 18 but -- 19 Q Surely you have been in the 20 presence of George Stephanopoulos when he's 21 had some of his friends with him? 22 MS. MARSH: Objection. 286 1 THE WITNESS: You know, just about 2 every time -- I know that he's friends, good 3 friends with Mark Halperin, who works for ABC 4 news, you know. He's good friends with David 5 Dryer, who works at -- I think David used to 6 work at the Treasury Department. I don't 7 know what he's doing now. Maybe he's out of 8 the government. 9 But I don't -- again, I just 10 can't -- I'm not in a real position to 11 comment on who Mr. Stephanopoulos' friends 12 are. Nor would he be in a position to 13 comment on my friends, outside of the ones he 14 knows. 15 BY MR. KLAYMAN: 16 Q Well, you have gone out for dinner 17 with him, haven't you? 18 A I probably have. But if I go, it 19 would be he and I, or he and I and Mr. 20 Emanuel, or he and I and Mr. Begala, or he 21 and I and Mr. Greenberg. I mean, I don't 22 know. I say with the -- 287 1 (Recess) 2 BY MR. KLAYMAN: 3 Q I take it George has never told you 4 whether or not he has sources inside the 5 Clinton White House? 6 A No. 7 Q He has told you, however, who he 8 gets information outside of The White House, 9 correct? 10 A No, he has not. 11 Q We affectionately call him 12 "George." I'm talking about George 13 Stephanopoulos, correct? I'll just use 14 George. It's faster. 15 A Okay. 16 Q Based on your frequent contact with 17 Mr. Stephanopoulos, how does he obtain 18 information for use on ABC's "This Week"? 19 A I don't know. You'd have to ask 20 him. Mr. Klayman, he lives in New York. I 21 don't know what he does. I don't know what 22 phone calls he makes or anything else. I 288 1 assume that he was here for six hours too, 2 and -- 3 Q But he talks to you frequently, 4 doesn't he? 5 A He does. 6 Q And from time to time, you provide 7 information and documents to him, do you not? 8 A I do not. I don't -- I mean, I 9 probably might talk to him. I don't know if 10 I've ever -- documents? But I don't think 11 I've ever faxed him -- I might have faxed him 12 a clip or something. But I can't remember 13 doing that. 14 Q From 1996 forward, what have you 15 faxed to Mr. Stephanopoulos? 16 A I don't know. I just cannot 17 possibly answer that question. 18 Q Do you keep a fax log at your 19 office on Capitol Hill or in the Shenandoah 20 Valley? 21 A I don't even know what a fax log 22 is. 289 1 Q Do you keep a postage log? 2 A A what, sir? 3 Q Postage log? A record of what's 4 mailed? 5 A No, sir. 6 Q Who handles the mailings and the 7 faxes? 8 A They just come over in the thing. 9 I don't know. The thing kind of beeps, and I 10 say, "What do you got?" 11 Q Is that the guy you identified 12 earlier at the beginning of this deposition? 13 What's his name? 14 A Well, anybody in the office, 15 somebody faxes something, they pick it up, or 16 you ask someone, "Fax this to somebody." 17 Q What was that guy's name? Vinnie 18 or something? 19 A Todd. You ought to see all the 20 mail we get. Jeez, when you're on a weekend 21 television show, you get hundreds of letters 22 from people talking about how ugly you are 290 1 and everything else. I mean, if we logged 2 that in, we'd do nothing but log. 3 Do you know how many people write 4 me letters telling me about what a -- 5 Q What do they say? 6 A Oh, man. I can have someone bring 7 some. I get some mail. 8 Q You get some good ones, too? 9 A Yeah, I get some, too. 10 Q Some say you're good looking? 11 A No, I don't get too many of those, 12 Mr. Klayman, I really don't. I get a lot 13 of -- you know, "You must have been born in a 14 Petri dish or something." I get called 15 "Snake eyes." 16 I'm saving -- I'm going to save the 17 kind of best of the best, you know. But 18 yeah, I get -- 19 Q Should we get back to the question? 20 A You ought to see the phone after 21 I've been on television. The office staff 22 hates it. 291 1 Q Who answers it? 2 A Anybody that will pick it up. 3 Q Todd? 4 A Sometimes. 5 Q Now, you are aware as to how 6 Mr. Stephanopoulos prepares to get ready for 7 "This Week," generally speaking? 8 A I am not. 9 Q Just generally? 10 A I am not generally or specifically 11 aware how Mr. Stephanopoulos prepares to get 12 ready. I am not. 13 Q Now, you previously testified that 14 you were sitting at home one day, which I 15 guess is your office, right? 16 A No. I was actually sitting 17 upstairs watching -- I was sitting there 18 watching the thing, and he mentioned this 19 thing about this -- these German things. 20 "What the hell is he talking about?" 21 Q Were you in bed at the time? 22 A Actually, I was just sort of laying 292 1 there. You know, it was -- to the date, I 2 don't know what I was doing. It was probably 3 something I had to go to in Washington that 4 afternoon. But I called him, and -- 5 Q Wait, wait. Where were you 6 watching this? In your bedroom, or in some 7 other room? 8 A No. In my -- in Washington, the 9 place that I rent. In my room, my bedroom. 10 Q Was anybody else in the room with 11 the you? 12 A My wife and my daughter. 13 Q You were all watching it? 14 A Yeah. I was. I don't know if she 15 was. She might have been doing something 16 else. 17 Q And you heard Mr. Stephanopoulos 18 make the statement about Ellen Rometsch? 19 A Mm-hmm. 20 MR. KLAYMAN: I'll show you what 21 I'll ask the court reporter to mark as 22 Exhibit 15. 293 1 (Carville Deposition Exhibit 2 No. 15 was marked for 3 identification.) 4 MR. KLAYMAN: At the end of this 5 deposition, I'm going to ask the court 6 reporter to put Mr. Carville's name on it 7 too. But we can do that at the end with all 8 these exhibits. 9 MR. GAFFNEY: Could you say that 10 again? 11 MR. KLAYMAN: Just "Carville 12 Exhibit," that's all. They're just numbered 13 right now. 14 Now, let's let the record reflect 15 that this is an ABC on-air transcript of the 16 "This Week with Sam Donaldson and Cokie 17 Roberts" of February 8, 1998. 18 MS. MARSH: Object to its 19 characterization as any kind of official 20 transcript. 21 MR. KLAYMAN: We'll let the 22 document speak for itself. 294 1 BY MR. KLAYMAN: 2 Q Would you turn to the second page, 3 Mr. Carville? 4 A I will. I'm right here. 5 Q And I'm going to read with Sam 6 Donaldson in the middle of the page. 7 Why don't you just review this 8 page, and if that refreshes your recollection 9 as to whether this document is what you heard 10 that day in your bedroom on February 8th 11 about Ellen Rometsch? 12 A I did read it, and I can't tell you 13 if it's word for word, but it does seem to 14 be, based on what I heard. 15 Q Now, let me read this. 16 "Sam Donaldson: We know what the 17 White House tactics are. I mean, they've 18 been almost open about it. Attack the press, 19 and perhaps with good reason. Attack the 20 independent counsel, perhaps for some good 21 reason. And stonewall on the central issue, 22 which is the President of the United States. 295 1 And if he has nothing to hide, why is he 2 hiding? 3 "George Stephanopoulos: I agree 4 with that. And there's a different long-term 5 strategy which I think would be far more 6 explosive. White House allies are already 7 starting to whisper about what I'll call the 8 Ellen Rometsch strategy. 9 "Sam Donaldson: I remember her. 10 "George Stephanopoulos: You 11 remember her? 12 "Sam Donaldson: Oh, yes. 13 George Stephanopoulos: She was a 14 girlfriend of John Kennedy who happened to be 15 an East German spy, and Robert Kennedy was 16 charged with getting her out of the country 17 and also getting John Edgar Hoover to go to 18 Congress and say, don't you investigate this, 19 because if you do, we're going to open up 20 everybody's closets. And I think in the long 21 run, they have a deterrent strategy on 22 getting a lot of -- 296 1 "George Will: Monica Lewinsky is 2 an East German spy? 3 "Sam Donaldson: No, but that's a 4 good point. Are you suggesting for a moment 5 that what they're beginning to say is that if 6 you investigate this too much, we'll put all 7 your dirty linen right on the table: Every 8 member of the Senate, every member of the 9 press corps? 10 "George Stephanopoulos: 11 Absolutely. The President said he'd never 12 resign, and I think some around him are 13 willing to take everybody down with him. 14 "Sam Donaldson: Well, may I just 15 say, let the games begin. 16 "George Will: Well, it's called 17 mutually assured destruction in strategic 18 language. 19 "Cokey Roberts: Or MAD," M-A-D. 20 Do you remember hearing that? 21 A I do. 22 Q What was your reaction when you 297 1 heard it? 2 A "What the hell's he talking about?" 3 And I called him and used about those exact 4 words. 5 Q When did you call him? 6 A That night. I called him that 7 afternoon. He wasn't there. I called him -- 8 it must have been around 6:00, 6:30 that 9 night. 10 Q And you got him on the phone? 11 A Yeah. 12 Q And what did you say to him? 13 A What are you talking about? Some 14 East German or whatever? I never heard of 15 such a thing before. 16 Q What else did you say? 17 A And I think he said something 18 about -- he said something about Castro in 19 the same interview, you know. I don't know, 20 or something. 21 But that was the thing that I was 22 like, "You know, what are you doing? What 298 1 are you saying? There's no -- you know, I 2 never heard of such a thing before." 3 You know, Mr. Klayman, I've been in 4 politics for a long time, and again, I 5 have -- you know, we've never made charges 6 about people. I've never discussed, you 7 know, people's sex life, and I sure ain't 8 going to start. And I don't know what George 9 was talking about. 10 Q You were pretty mad when you called 11 him, weren't you? 12 A Yeah. I mean -- well, yeah, I was 13 bewildered or mad, I don't know. You know 14 what I mean? 15 Q And you were mad because you 16 understood what he was talking about was 17 spying into other people's lives, right? 18 A Well, I guess what I thought was, I 19 don't know where -- you know, "Why are you 20 saying this?" This is sort of -- you know, 21 we have East German spies and J. Edgar Hoover 22 and God knows whatnot, and just, you know -- 299 1 Q And before you called him, you knew 2 what the implication of what he said was is 3 that J. Edgar Hoover used FBI files -- 4 A You know, you just simply have to 5 ask -- 6 MS. MARSH: Objection. Asked and 7 answered. 8 THE WITNESS: You know, you had 9 Mr. Stephanopoulos here. You have to ask him 10 what he meant. 11 Q I'm asking you. You were mad -- 12 A Hey, I was mad for the simple 13 reason I never heard anybody discuss such a 14 thing. 15 Q And you were mad because you didn't 16 want to be associated with any implication 17 that FBI files were being used to destroy 18 people? 19 MS. MARSH: Objection. There's 20 nothing in here with his name on it. 21 BY MR. KLAYMAN: 22 Q Correct? Correct? 300 1 A I sure wouldn't want to be with 2 that. I absolutely wouldn't. And if anybody 3 wants to go look at any tape that, when the 4 FBI file story broke, I said, "This is 5 serious stuff." 6 Q And that's why you were mad? 7 A Yeah. I mean, that was one of any 8 number of reasons why I was mad. 9 Q Because it was known out there that 10 you were one of the guys that was out there 11 being critical of Clinton's adversaries? 12 MS. MARSH: Objection. 13 THE WITNESS: I'm one of the guys 14 that's being known to be critical of Starr, 15 yes. Okay? And my criticism, you know, of 16 Starr is about his politics and the way that 17 he conducts his investigation. 18 BY MR. KLAYMAN: 19 Q But you knew that you were 20 perceived to be a White House ally, right? 21 MS. MARSH: By whom? 22 THE WITNESS: Yes.
of this deposition