101
1 Q Well, I'm going to ask you a
2 follow-up question.
3 A Could you explain what you just
4 said so I can understand what you're saying.
5 Q No, I don't have to explain. I'm
6 the one asking the questions.
7 A Oh, okay.
8 Q Generically speaking, how do you
9 define a personal document that you keep in
10 that facility over there in Georgetown?
11 What's the criteria?
12 A A document that I would ordinarily
13 keep in my personal capacity.
14 Q So as long as you deem it to be in
15 your personal capacity, then it's personal
16 and doesn't have to be produced?
17 MS. SABRIN: Objection.
18 Mischaracterizes his testimony.
19 THE WITNESS: Mr. Klayman, just so
20 that we can sort of move on, to use your
21 inimitable phrase, I received the subpoena, I
22 testified to that, I turned it over to my
102
1 attorney. We went down the subpoena. I
2 searched my house at Dumbarton Street for
3 documents that would be remotely related to
4 the subpoena, and I turned them over. I
5 didn't find any, because there were none
6 there. But I did conduct a search of my
7 apartment for documents that are, were
8 related to your subpoena.
9 BY MR. KLAYMAN:
10 Q When did you conduct that search?
11 A The other day.
12 Q Did anyone assist you in that
13 search?
14 A No. I did it myself.
15 Q Did anyone observe you doing that
16 search?
17 A No. The cats did.
18 Q Who did?
19 A The cats.
20 Q The cats.
21 A Yeah, two cats.
22 Q Do they have names?
103
1 MS. SABRIN: Objection, relevancy.
2 BY MR. KLAYMAN:
3 Q Where do you store the documents in
4 your house?
5 A Well, we have books upstairs. We
6 have various documents upstairs. There's
7 documents on the fourth floor, the second --
8 let's see how many floors are there. There's
9 the basement. There's documents in the
10 basement.
11 There's documents, as you've
12 defined the word "documents," on the first
13 floor. There's documents on the second
14 floor. There's documents on the third
15 floor -- one two, fourth floor, I'm sorry.
16 The fourth floor, if you count the basement.
17 So there are documents on all floors.
18 Q You have four floors in your
19 townhome.
20 A Yes.
21 Q What documents do you keep in the
22 basement?
104
1 A Books, financial records, various
2 different documents. Wrapping paper.
3 Q Notes?
4 A Yeah, I keep notes there.
5 Q Copies of letters?
6 A Yes, all sorts of documents.
7 Q Where are they stored in the
8 basement? Is there a file cabinet there?
9 A No.
10 Q Where are they stored?
11 A In various parts.
12 Q How are they stored, in boxes?
13 A In various parts. Well, the
14 wrapping paper I keep sort of on the floor in
15 the boxes. The newspapers, I keep some in
16 boxes, some on the floor. The old magazines,
17 some of those I keep on the shelf.
18 Bubble paper, does that come within
19 the document -- yeah, bubble paper we keep
20 down there, also. But, you know, it's around
21 different parts of the basement. There are
22 some notes there. There are some financial
105
1 records there. There are some letters there.
2 There is some books there.
3 Q What documents do you keep on the
4 first floor?
5 A Roughly, the same answer. I mean
6 there are books there. Primarily books, I
7 would say, on the first floor. There's
8 some --
9 Q But also notes and correspondence.
10 A Yeah, and my daughter has some
11 drawing paper there. She does a lot of
12 artwork. There's some pictures on the walls.
13 Those are documents, I think, aren't they?
14 Yeah. There is also some videotapes on the
15 first floor and some audiotapes on the first
16 floor. Oh, there are some CD disks on the
17 first floor.
18 Q The third floor, what do you keep
19 on the third floor?
20 A A combination of the stuff that
21 I've just talked to you about, with the
22 exception of wrapping paper. We generally
106
1 keep that down, and the bubble paper, we
2 generally keep that down in the basement.
3 Q Fourth floor?
4 A Fourth floor, not many documents up
5 there, mostly -- there's some wrapping paper
6 up there, I don't want to mislead you on the
7 wrapping paper. There's some wrapping paper
8 up there. There are not many notes up there.
9 There are some magazines, basically National
10 Geographic and the like.
11 Q Are you aware you're in a court
12 proceeding, Mr. Ickes?
13 A Do I look stupid?
14 Q Are you aware that as a lawyer that
15 you have some respect to this proceeding and
16 not to make fun of it?
17 A Mr. Klayman, you asked me a
18 question. I read your definition of
19 "documents." I was trying to give you as
20 complete an answer as possible. Do you want
21 me to read your definition to you? "The
22 word 'document' shall mean any written or
107
1 graphic matter or other means of preserving
2 thought or expression, and all tangible
3 things from which information can be
4 processed or transcribed, including but not
5 limited to, correspondence, memoranda, notes,
6 messages, letters, telegrams, teletype
7 messages, bulletins, diaries, chronological
8 data, minutes, books, reports, charts,
9 ledgers, invoices, worksheets, receipts,
10 computer recordations, including but not
11 limited to, file listings" -- whatever that
12 means -- "printouts, schedules, affidavits,
13 contracts, transcripts, surveys, graphic
14 representations of any kind, photographs,
15 graphs, microfilms, videotapes, tape
16 recordings, motion pictures or other film."
17 So all I was trying to do, Mr. Klayman, was
18 be responsive to the definition that you set
19 forth in your --
20 Q You didn't see the word "bubble
21 paper," did you?
22 A What?
108
1 Q You didn't see that bubble paper is
2 included in the definition, did you?
3 A No, but some of the bubble paper I
4 have things are written on it. So that would
5 be something that would come within the scope
6 of this subpoena.
7 Q What do you write on bubble paper?
8 A What?
9 Q What do you write on the bubble
10 paper?
11 A It came in the packing with stuff
12 written on it.
13 Q I'm just asking you.
14 A I was just trying to be responsive
15 to your definition that you set forth in your
16 subpoena.
17 Q Mr. Ickes, I'm very patient. I'm
18 just trying to have a proper decorum, a
19 proper approach, a proper respect for the
20 court. I ask whether you appreciate that
21 you're in a court proceeding.
22 A I said do I look stupid.
109
1 Q I take it that you keep a diary.
2 A I don't keep a diary.
3 Q Have you ever kept a diary?
4 A No. I was going to, but given all
5 the subpoenas that you people down here in
6 Washington fling about, I decided not to.
7 Q Have you ever kept a diary?
8 A No. I'm not much of a diarist.
9 Q Your dad used to keep a diary,
10 didn't he?
11 A He did keep a diary, yes. He kept
12 several.
13 Q At one time you did keep a diary
14 yourself. Correct?
15 MS. SABRIN: Asked and answered.
16 BY MR. KLAYMAN:
17 Q At one time.
18 A I don't recall ever keeping a
19 diary.
20 Q You don't remember?
21 MS. SABRIN: Asked and answered.
22 BY MR. KLAYMAN:
110
1 Q When you say "I don't recall" do
2 you mean "I don't remember" or do you mean
3 no?
4 A I meant what I said.
5 Q Are you refusing to answer the
6 question?
7 A No, I answered your question. You
8 may not like the answer, Mr. Klayman, but I
9 answered the question. So you can't certify
10 that I didn't answer the question. You might
11 certify that you didn't like the answer.
12 That's a whole different question, of course.
13 Q I'll just certify it. How's that?
14 A You can do anything you want.
15 Q Have you had any other residences
16 in the last ten years other than the ones
17 you've just identified?
18 A Ten years. Let me see. That would
19 take us back to 1988. Yes, I have.
20 Q Where were they?
21 A For a short period of time I rented
22 an apartment on 18th Street here in
111
1 Washington, D.C.
2 Q Did you keep documents in that
3 apartment?
4 A I did.
5 Q When did you rent that apartment?
6 A It was approximately the first part
7 of January of 1994 until approximately June
8 of 1994.
9 Q Were those documents transferred
10 from that apartment to the current residence
11 that you now have?
12 A The ones that I didn't throw away
13 were, yes.
14 Q Were any documents put anywhere
15 else, in a storage facility?
16 A No.
17 Q Do you or your wife or any of your
18 family rent a storage facility in Washington,
19 D.C.?
20 A No.
21 Q So all documents that you have
22 would either be in your home or with your
112
1 counsel.
2 A No.
3 Q Where else would the documents be?
4 A In my office.
5 Q Where's your office?
6 THE WITNESS: Do I have to give
7 that?
8 MS. SABRIN: Can we give that to
9 you off the record?
10 BY MR. KLAYMAN:
11 Q Are you listed in the phone book?
12 A I have no idea. I've never looked
13 in the phone book.
14 Q What's the name of your office?
15 A What do you -- my office --
16 Q Are you working for anyone, are you
17 working for yourself?
18 A Oh, no. My office doesn't have a
19 name.
20 Q Are you working for an entity of
21 any sort?
22 A I own an entity, yes.
113
1 Q What is the name of the entity?
2 A It's the Ickes & Enright Group.
3 Q Ickes and Right Group.
4 A No. The, t-h-e, Ickes,
5 I-c-k-e-s --
6 Q The Ickes Enright Group.
7 A No, the Ickes & Enright Group.
8 Q Enright Group.
9 A Ickes & Enright.
10 Q Thank you.
11 A There's an "and" in between, it's
12 an ampersand.
13 Q When did you establish that entity?
14 A Approximately late January/early
15 February of 1997.
16 Q That was established shortly after
17 you left the White House. Correct?
18 A Yes, it was.
19 Q The Enright is Janice Enright, your
20 assistant?
21 A Yes, she's my partner.
22 Q Is she a lawyer, too?
114
1 A She's not mercifully.
2 Q What's her professional background,
3 just generally speaking?
4 A She's worked at various jobs,
5 worked for me in my law office. We worked
6 together at the White House. She now is my
7 partner at the law -- at our firm.
8 Q Between the period that you left
9 the White House on January 20th, 1997 and
10 February of '97 when you entered into this
11 enterprise, did you store documents in any
12 location other than your residence here, New
13 York or at your lawyer's office?
14 A No.
15 Q What does Ickes & Enright do? What
16 kind of a firm is it?
17 MS. SABRIN: You can generalize.
18 A It's a consulting firm.
19 Q What does it consult in?
20 A We consult for our clients.
21 Q I'm just asking generically what
22 kind of consulting you're doing.
115
1 A It depends on the client.
2 Different clients have different needs.
3 Q Is it a lobbying group?
4 A We do some lobbying.
5 Q You lobby the White House?
6 A I'm not permitted to lobby the
7 White House.
8 Q But you do it anyway?
9 A No.
10 MS. SABRIN: Objection.
11 MS. SHAPIRO: Objection.
12 BY MR. KLAYMAN:
13 Q Do you lobby Congress?
14 A We do some lobbying of Congress.
15 Q Do you lobby government agencies?
16 A On occasion.
17 Q What government agencies do you
18 appear most in front of?
19 A We do some -- we've done very
20 little lobbying of the government agencies.
21 I think it's basically Health and Human
22 Services. We've done some stuff with
116
1 transportation.
2 Q Do you have other employees besides
3 Ms. Enright?
4 A She's not an employee.
5 Q Partner. Is this a corporation,
6 the Ickes & Enright?
7 A It's not.
8 Q It's a partnership.
9 A It's -- basically, I don't know
10 what you call it here in Washington. It's
11 basically an unincorporated association, if I
12 were to use an analogy to New York law. But
13 we operate as a partnership.
14 Q It's registered to do business in
15 the District of Columbia?
16 A It is.
17 Q I take it that there are employees.
18 A There are two partners.
19 Q Ickes and Enright.
20 A Right.
21 Q Who works for Ickes & Enright
22 currently?
117
1 A I work for Enright and Enright
2 works for Ickes.
3 Q Do you have a secretary?
4 A No.
5 Q Do you have an assistant?
6 A No.
7 Q Do you have a receptionist?
8 A No.
9 Q No one else works there except you
10 and Ms. Enright?
11 A That's correct.
12 Q Not one living human being other
13 than the two of you work there.
14 A I think I've answered that,
15 Mr. Klayman.
16 Q Do you have file cabinets in that
17 office?
18 A Yes.
19 Q That office is listed in the phone
20 book, isn't it?
21 A I don't know. I've never checked
22 the phone book.
118
1 Q You do have a phone, don't you?
2 A Yes, I have a phone.
3 Q Have you ever used temporary
4 employees?
5 A No.
6 Q Ever used a temporary service?
7 A No. Other than for messengers. Do
8 you mind if a get a drink of water? I'm
9 getting mighty dry here.
10 MR. FITTON: I'll get it for you,
11 sir.
12 MR. KLAYMAN: Let's take a
13 two-minute break. Do you want to take a
14 five-minute break?
15 THE WITNESS: Let's do it in two
16 minutes.
17 VIDEOGRAPHER: We're going off the
18 video record at 11:37.
19 (Recess)
20 VIDEOGRAPHER: We're back on video
21 record at 11:47.
22 BY MR. KLAYMAN:
119
1 Q Mr. Ickes, do you retain any other
2 attorneys other than Skadden & Arps?
3 A I do.
4 Q What other attorneys do you retain?
5 A I retain the firm of Oldecker, Rein
6 and Ucheck, which is a Washington, D.C. firm.
7 Q Are any documents that you took
8 from the White House stored there?
9 A No. Mr. Klayman, just so there's
10 no misunderstanding, we have a receptionist
11 who is not an employee of our company but who
12 does answer our phone. There's a number of
13 offices that occupy that suite area. So that
14 receptionist does answer our phone.
15 Q What's her name?
16 A It varies. They rotate people
17 almost on an hourly basis.
18 Q This is a temporary service?
19 A No. It's an employee of Griffin
20 Johnson which is the firm that we sublease
21 from.
22 Q Does anyone at that firm ever
120
1 assist you and Ms. Enright in doing filing or
2 doing word processing or anything that's of
3 an administrative nature?
4 A No. We do everything ourself.
5 Q When you worked at the White House
6 did you have a computer?
7 A I did not personally have one, no.
8 Q Do you know how to use a computer?
9 A I do now.
10 Q When you were at the White House
11 did you ever do some word processing on your
12 own?
13 A No.
14 Q Who was your assistant there
15 throughout the time that you were at the
16 White House?
17 A Well, my top assistant was Janice
18 Enright, but I had a number of people who
19 worked for me.
20 Q Who was that? In the
21 administrative capacity that would handle the
22 generation and storage of documentation.
121
1 A There were various people. They
2 primarily were -- they were primarily
3 interns. They worked for us on a rotating
4 basis. There was one fellow by the name of
5 John Sutton who worked on a very regular
6 basis. I think he was, he was paid, but with
7 I think rare exception, virtually all the
8 other people were interns and worked on a
9 rotating basis.
10 Q Now, did you leave the White House
11 with any diskettes that contained computer
12 recordations?
13 A I don't think so, because whatever
14 diskettes we had were left there, as far as I
15 know. I certainly didn't leave with any, and
16 I don't think we did.
17 Q But you're not sure?
18 A I'm not positive, no.
19 Q Did you use a laptop computer when
20 you were with the White House?
21 A I didn't use a computer.
22 Q Did Ms. Enright use a laptop
122
1 computer?
2 A No, she did not.
3 Q She frequently, as your assistant,
4 would type out things for you such as
5 letters?
6 A She would and others, and many
7 others did, yes.
8 Q She took some dictation, didn't
9 she?
10 A I don't dictate.
11 Q Did she do your filing for you?
12 A No. I did it.
13 Q You did all your own filing at the
14 White House?
15 A No. Either I did it or the
16 interns, people who worked either immediately
17 outside of our office or people who worked
18 across the street in the old EOB did the
19 filing.
20 Q Now, when you worked at this law
21 firm, and let me see if I can get the name of
22 that law firm, I know you don't like to
123
1 repeat yourself, so I figured I'd get the
2 name. Meyer, Souzzi, English & Klein?
3 A Yes.
4 Q Am I pronouncing Souzzi right?
5 A You are.
6 Q What type of work did that law firm
7 do?
8 A It was a general practice firm. It
9 did civil litigation, some minor criminal --
10 or not minor. It did some small amount of
11 white collar criminal, but it was primarily
12 civil litigation, certiorari work, contracts,
13 corporate and the like, matrimonial.
14 Q In fact, among various specialties
15 labor law was actually one of them. Correct?
16 A They did a fair amount of labor
17 law.
18 Q Was there a partner there when you
19 joined as an associate who specialized in
20 labor law that you worked with?
21 MS. SABRIN: Objection, relevancy.
22 BY MR. KLAYMAN:
124
1 Q You can respond.
2 A I don't -- there was a partner by
3 the name of Dan Palmari who now is a judge in
4 Nassau County who was the person who did most
5 of the labor work there. Jack English, who
6 was the founding partner of the firm, did a
7 lot of labor work.
8 Q You worked most closely with
9 Mr. Palmari?
10 A Not initially, no. I did not do
11 labor work initially.
12 Q Did you learn labor law at the
13 firm?
14 A I did.
15 Q Who did you learn it from?
16 A I learned it from Palmari, English
17 and then picked it up.
18 Q In the course of your working for
19 that firm, they represented various labor
20 unions. Correct?
21 A They did.
22 Q Which labor unions did they
125
1 represent?
2 A Oh, I could name two or three.
3 They represent a large number of unions and
4 pension funds and benefit funds. I haven't
5 been there for a long time, obviously. At
6 the time that I worked there, the three
7 unions that I can recall are Local 1199 which
8 is based in New York City --
9 Q Who is Local 1199 with? What's the
10 general name of the union?
11 A It was a hospital workers union.
12 Q Okay.
13 A The international union, one of the
14 locals, the main local out on Long Island of
15 the International Union of Operating
16 Engineers, some electrical workers. I'm just
17 rummaging through my head. I don't recall
18 others. They represented a fairly broad
19 range of unions.
20 Q Of course.
21 A Local 11 -- we represented
22 Local 100 of the Hotel Restaurant Workers
126
1 Union.
2 Q Yes. In fact, the head of that
3 union was Paul Castellano when you were
4 working with that union?
5 A He was not.
6 Q What was Mr. Castellano's position?
7 A He didn't have a position, as far
8 as I knew.
9 Q Who was the head of that union at
10 the time?
11 A The head of the local or the
12 international?
13 Q The local.
14 A A man by the name of Anthony R.
15 Amodeo, A-m-o-d-e-o.
16 Q Mr. Amodeo has reportedly, I'm not
17 getting to the truth of the matter, has been
18 reported to have links with organized crime.
19 Correct?
20 MS. SABRIN: Objection, relevancy.
21 BY MR. KLAYMAN:
22 Q You can respond.
127
1 A There were reports to that effect.
2 Q There were reports that somehow
3 this union was linked with Paul Castellano
4 who at the time was head of the Gambino crime
5 family. Correct?
6 MS. SABRIN: Objection, relevancy.
7 BY MR. KLAYMAN:
8 Q You can respond.
9 A I don't know what crime family he
10 was allegedly head of. But there were
11 allegations of linkage between Amodeo and
12 Castellano.
13 Q You've heard of the Gambino family,
14 haven't you?
15 MS. SABRIN: Objection relevancy.
16 BY MR. KLAYMAN:
17 Q Correct?
18 A I have.
19 Q Have you ever met Anthony Chick
20 Amodeo?
21 MS. SABRIN: Objection, relevancy.
22 THE WITNESS: He was the head of
128
1 the Local 100.
2 BY MR. KLAYMAN:
3 Q In the course of your
4 representation of Local 100 you worked
5 closely with him. Correct?
6 MS. SABRIN: Objection as to form
7 and relevancy.
8 BY MR. KLAYMAN:
9 Q You can respond.
10 A I worked at, I represented the
11 union primarily on arbitrations, National
12 Labor Relations Board work and negotiating
13 collective bargaining agreement in that in
14 the course of doing that work for several
15 years I worked with him on occasion.
16 Q In fact, you worked with him quite
17 closely, did you not?
18 MS. SABRIN: Objection as to form.
19 BY MR. KLAYMAN:
20 Q You can respond.
21 A I've answered the question. I
22 worked with him -- I don't know what you mean
129
1 by closely. He was the head of the union, I
2 was their lawyer.
3 Q Mr. Anthony Chick Amodeo was also
4 reported to be involved in organized crime.
5 Correct?
6 MS. SABRIN: Objection, relevancy.
7 THE WITNESS: There were
8 allegations to that effect.
9 BY MR. KLAYMAN:
10 Q During the time that you worked as
11 a lawyer on behalf of Local 100, did you meet
12 Mr. Paul Castellano?
13 MS. SABRIN: Objection, relevancy.
14 BY MR. KLAYMAN:
15 Q You can respond.
16 A Not to my knowledge.
17 Q Have you ever met Mr. Paul
18 Castellano?
19 MS. SABRIN: Asked and answered.
20 BY MR. KLAYMAN:
21 Q Have you ever met him?
22 A Asked and answered.
130
1 Q No, I asked you when you were
2 working for the law firm whether you had met
3 him.
4 A Oh.
5 Q But this was a general question.
6 Have you ever met Mr. Paul Castellano?
7 A Not to my knowledge.
8 Q Is this the same Paul Castellano
9 that was murdered by John Gotti in 1985?
10 MS. SABRIN: Objection as to form.
11 BY MR. KLAYMAN:
12 Q The one you're referring to.
13 MS. SABRIN: You're the one
14 referring who is referring to him, so how can
15 he know?
16 BY MR. KLAYMAN:
17 Q You are aware that Mr. Paul
18 Castellano was murdered by John Gotti in '85.
19 Correct?
20 MS. SABRIN: Objection, relevancy.
21 THE WITNESS: I don't know who
22 murdered him.
131
1 BY MR. KLAYMAN:
2 Q Your firm, when you were there,
3 represented Teamsters Local 560?
4 A I know that it represented some
5 Teamsters local. I couldn't tell you the
6 number, Mr. Klayman.
7 Q But you did work on matters
8 involving the Teamsters union. Correct?
9 A No, I did not. If I did any work
10 it was totally peripheral. Other lawyers in
11 the labor group dealt with the Teamsters.
12 Q You never worked on any legal
13 matter that concerned in any way the
14 Teamsters?
15 A Now I don't want to be that --
16 that's a very broad statement you made. I
17 said I may have worked on some peripheral
18 matters, but as I do not recall -- I don't
19 recall as I sit here today doing any work for
20 Teamsters, any Teamsters clients. That's not
21 to say that I may have been in some meetings
22 and may even have done some minor work. But
132
1 I don't recall it.
2 Q Have you ever met Mr. Tony
3 Provenzano?
4 A Not to my knowledge.
5 Q You're not sure?
6 A You meet a lot of people in
7 politics and he may have been on, you know, I
8 may have met him. I have no knowledge of it.
9 I have no knowledge of meeting him. I have
10 no knowledge of meeting Castellano, and would
11 be very surprised if I had met them.
12 Q But at the time that you worked at
13 the firm you were aware that Mr. Amodeo
14 reportedly knew Mr. Castellano.
15 A It was said in the papers, yes.
16 Q You read those papers.
17 A That's where I got the information.
18 Q Now, in the course of working for,
19 as a lawyer, Local 100 of the Hotel and
20 Restaurant Workers International, did you
21 ever have any occasion to use private
22 investigators?
133
1 A Did I as a lawyer?
2 Q Yes.
3 A I don't recall using any private
4 investigators. I assume -- I don't know
5 whether our firm used private investigators.
6 To my personal knowledge, I don't recall
7 using any.
8 Q Lawyers do sometimes use private
9 investigators. That's been your experience
10 in legal practice, is it not?
11 A Some lawyers do, some lawyers
12 don't, I imagine. That's what I've read.
13 Q You do know a private investigator
14 by the name of Jack Palladino, don't you?
15 A I know only through newspaper
16 accounts. I don't recall ever having met
17 him. I don't think I've -- to my knowledge,
18 I've never met him; and to my knowledge, I've
19 never talked to him.
20 Q The labor unions that you
21 represented when you were with this law firm
22 used Jack Palladino has as a private
134
1 investigator, did it not?
2 A I don't know that.
3 MR. KLAYMAN: I'm going to show you
4 what I'll ask the court reporter to mark as
5 Exhibit 5.
6 (Ickes Deposition Exhibit No. 5
7 was marked for identification.)
8 BY MR. KLAYMAN:
9 Q This is an article in The
10 Washington Times of yesterday,
11 May 20th, 1998, "Teamsters chief MUM on Ruff
12 payment." I show you a copy of this.
13 MS. SHAPIRO: Did you say you were
14 marking that?
15 MR. KLAYMAN: Yes, as Exhibit 5.
16 BY MR. KLAYMAN:
17 Q Mr. Ickes, did you see this article
18 yesterday in The Washington Times?
19 A I did not.
20 Q If you'd like an opportunity to
21 review it.
22 A Yeah, if you would. I've skimmed
135
1 it.
2 Q Does this refresh your recollection
3 as to whether you know Mr. Jack Palladino?
4 A It does not.
5 Q What information, if any, do you
6 have with regard to reports in this article
7 that Mr. Charles Ruff relayed $152,883 to
8 Jack Palladino?
9 A This is the first I've heard of it.
10 Q You know Charles Ruff, don't you?
11 A I met him very briefly.
12 Q You are aware that Charles Ruff
13 represented the Teamsters before he became a
14 White House counsel?
15 A I was not until I read this
16 article.
17 Q You never knew that?
18 A I was not until I read this
19 article.
20 Q Going back to the 1992 primary
21 campaign, did you ever meet a Betsy Wright?
22 A Yes.
136
1 Q How did you meet Betsy Wright?
2 A I met her in connection with the
3 campaign.
4 Q Under what circumstances did you
5 meet her?
6 A She was on the staff. I don't
7 recall when I first met her, but I met her,
8 as I say, in connection with the campaign,
9 either in Arkansas -- probably in Arkansas.
10 Q You, of course, knew what her
11 duties and responsibilities were generally?
12 A I did not.
13 Q You are aware that one of her
14 duties and responsibilities was reported to
15 be gathering information about women who were
16 thought to be able to come forward with
17 regard to relationships with then Governor
18 Clinton?
19 A As I say, I don't know what her
20 responsibilities were. I had very little to
21 do with Betsy. I was -- I didn't even go
22 down to Arkansas until after the general
137
1 election.
2 Q You are aware it's been reported
3 that she on behalf of the Clinton campaign
4 hired private investigators to look into the
5 lives of certain women that reportedly had
6 relationships with then Governor Clinton?
7 A I have some vague recollection of
8 reading articles to that effect.
9 Q Are you aware of the private
10 investigators that she hired?
11 MS. SABRIN: Objection as to form.
12 BY MR. KLAYMAN:
13 Q You can respond.
14 A You have to rephrase the question.
15 I don't know --
16 Q Have you ever heard of anybody by
17 the name of Anthony Pellicano?
18 A I've heard the name, yes.
19 Q Have you met Anthony Pellicano?
20 A Not to the best of my knowledge.
21 Q Have you ever talked to him?
22 A Not to the best of my knowledge.
138
1 Q You are aware he is a private eye
2 in Los Angeles?
3 A I've read newspaper reports to that
4 effect.
5 Q You read those newspaper reports
6 that in fact Mr. Pellicano was hired by the
7 Clinton campaign to dig up dirt on women?
8 MS. SABRIN: Objection as to form,
9 assumes facts not in evidence.
10 BY MR. KLAYMAN:
11 Q You are aware of that?
12 A I am aware, without taking all of
13 your characterizations I'm aware that
14 Pellicano had apparently had some
15 relationship to the campaign. What the
16 relationship was, what he was doing, I do not
17 know.
18 Q How did you become aware of that?
19 A Newspaper articles.
20 Q You've seen the movie "The War
21 Room," right?
22 A I did see it, yes.
139
1 Q In fact you were in it. Right?
2 A I had what I think would be called
3 a fleeting appearance.
4 Q Do you wish you had more?
5 MS. SABRIN: Objection, relevancy.
6 THE WITNESS: No. Hollywood has
7 never been my goal.
8 BY MR. KLAYMAN:
9 Q Now, in the course of the fleeting
10 appearance, did you come into contact with
11 any private investigators working for the
12 campaign?
13 A Not to my knowledge.
14 MR. KLAYMAN: Off the record just
15 for one minute since someone is banging on
16 the roof.
17 BY MR. KLAYMAN:
18 Q Have you ever met Terry Lenzner?
19 A Yes.
20 Q When did you meet Terry Lenzner?
21 A I met him on several occasions.
22 Q When was the first time you met
140
1 him?
2 A My recollection is sometime in
3 the 1970's, early to mid-seventies.
4 Q Did you meet him in a professional
5 capacity?
6 A No.
7 Q What capacity did you meet him?
8 A I met him through a mutual friend
9 in a social situation.
10 Q Have you ever worked with Terry
11 Lenzner in any matter?
12 A What do you mean by that?
13 Q It's a general question just to get
14 some identification here. Have you ever
15 worked with him on any matter?
16 A No, I've never worked with Terry in
17 any professional way.
18 Q Are you aware of him being a
19 private investigator working on behalf of the
20 Clintons currently?
21 A I became aware of that through
22 newspaper reports.
141
1 Q How are you aware of that?
2 MS. SABRIN: Asked and answered.
3 A Asked and answered.
4 Q Are you currently working in any
5 capacity by or on behalf of President and
6 Mrs. Clinton or the White House?
7 A The word "work" is defined as what?
8 Q I think it's a pretty common word.
9 A Well, is that for -- if it's for
10 employment, am I employed in any capacity,
11 the answer is no.
12 Q Are you providing your services
13 voluntarily to the Clintons or to the White
14 House currently?
15 A I have known both of the Clintons
16 for many, many years. They're close friends
17 of mine. From time to time I talk to them,
18 and I've been doing some work with Mickey
19 Kantor, but all on a voluntary basis.
20 Q You're not being paid for it.
21 A No.
22 Q When did you start doing some work
142
1 with Mickey Kantor?
2 A It was very shortly after the first
3 reports about Monica Lewinsky became public.
4 Q Did you approach Mickey Kantor or
5 did he approach you?
6 A We sort of approached each other.
7 We've known each other for many years.
8 Q What work did Mr. Kantor ask you to
9 do or did you volunteer to do?
10 A I basically said that I would talk
11 to people on the outside. Mickey has a
12 lawyer/client relationship with the
13 President. I do not. So basically what I
14 have done since that period of time is talk
15 to a lot of press people and talk to
16 supporters and others about this situation.
17 Q Your talking to the press and
18 supporters, was this something you decided
19 with Mr. Kantor you would do on behalf of
20 President Clinton?
21 A Yes.
22 Q Who came up with the idea?
143
1 A Mickey and I did during a
2 conversation.
3 Q Where did you have the
4 conversation?
5 A As I recall, it was either on the
6 phone or in his office. I've been to his
7 office a couple of times. We talk a lot on
8 the phone, or we talked on occasion on the
9 phone.
10 Q Roughly speaking when did you have
11 that meeting?
12 A I think it was the week following
13 the week that the first public reports about
14 Ms. Lewinsky were run.
15 Q Why are you having that contact
16 with the press and friends and others? What
17 are you trying to accomplish?
18 A Well, I think what I was -- what I
19 try to accomplish is, one, finding out what
20 stories the press are interested in. Also,
21 the press is often not fully informed of
22 everything that is going on. So basically I
144
1 talk to the press from two points of view.
2 One is to find out what stories they think
3 are interesting, what they're working on; and
4 also to provide information that I may have
5 that the particular press person I'm talking
6 to may not have. But again, I caution you, I
7 do not have a lawyer-client relationship. I
8 know no more about the facts and
9 circumstances than anybody else in the
10 general public who kept a very close track on
11 this through the public presses.
12 Q Did Mr. Kantor and you decide that
13 you would serve in a public relations
14 capacity, is that how you could describe it?
15 A Well, I think I described what I
16 do.
17 Q Is that in essence a public
18 relations capacity?
19 A I think you can draw your own
20 conclusions. I'm not going to characterize
21 it. I've given you in considerable detail
22 what I do.
145
1 Q In this capacity, I'll call it a
2 public relations capacity, do you have
3 contact with Mr. Kantor?
4 A I talk to Mr. Kantor from time to
5 time, yes.
6 Q About how frequently do you talk to
7 him each day since you decided upon this
8 course of action?
9 A It sometimes goes several days
10 without my talking to him. In the last
11 several weeks, it's been several weeks since
12 I've talked to him.
13 Q Roughly speaking, how many times
14 have you talked to him a week since you
15 decided to undertake this activity?
16 A Initially, I would talk to him
17 everyday or every other day. But that has
18 slacked off considerably, as I just described
19 to you.
20 Q How long were those conversations?
21 A As long as necessary. Sometimes a
22 minute, sometimes five minutes, sometimes
146
1 longer. Sometimes less.
2 Q Mr. Kantor would provide
3 information to you in terms of what you had
4 to communicate to the press and friends?
5 A No. He was not providing me
6 information other than we would talk about
7 what was going on at that particular period
8 of time. But as I said before, Mr. Kantor
9 had a lawyer/client relationship with the
10 President. I did not. To my knowledge, he
11 did not provide me with any information that
12 was not already in the public domain.
13 Q Since the time that the Monica
14 Lewinsky scandal broke and you undertook this
15 activity as decided upon with Mr. Kantor,
16 have you had contact with anyone at the White
17 House?
18 A I have.
19 Q Who have you been in contact with?
20 From that point forward when you embarked
21 upon this activity to communicate with the
22 press, et cetera, up to the present.
147
1 A On relatively infrequent basis,
2 Mr. Rahm Emanuel, Paul Begala, Mike McCurry,
3 Ann Lewis, Lanny Brewer, the First Lady, the
4 President. There may be others, but that's
5 sort of the constellation, if you will, of
6 people.
7 Q In the course of your activities as
8 decided upon with Mr. Kantor, have you had
9 contact with anyone else in the media?
10 A In the media?
11 Q Yeah.
12 A Oh, a broad number of people.
13 Q Who?
14 A Well, I didn't come here with a
15 list. I talk to anywhere from 25 to 35, 40
16 reporters.
17 Q Tell me who is in your sphere that
18 you generally talk to.
19 A As I say, there's 25 to 35
20 reporters. You know, I'd have to go back and
21 look through a Rolodex.
22 Q Let's go based on what you can tell
148
1 us now.
2 A I talk to people at Time, Newsweek,
3 The New York Times, The LA Times,
4 infrequently The Washington Times, sometimes
5 the New Republic.
6 Q Salon Magazine?
7 A What?
8 Q Salon Magazine?
9 A I may have. I don't know the
10 people at Salon. So I may have talked to
11 people who contribute to that, but I'm not
12 aware definitely of talking to people.
13 Q Nation Magazine?
14 A Nation very, very, very
15 infrequently.
16 Q New York Observer?
17 A On occasion I've talked to the New
18 York Observer.
19 Q The New Yorker?
20 A Yes.
21 Q What other publications, Wall
22 Street Journal?
149
1 A Wall Street Journal, yes.
2 Q Any others?
3 A I'm sure there are others. Those
4 are the ones that I can recall.
5 Q Tell me who you've dealt with most
6 at Time Magazine.
7 A Oh, I'm not good on names,
8 Mr. Klayman. I would have to go back and
9 look. You know, I've talked to -- typically,
10 there are reporters who are working on the
11 story of the day. Michael Weiskoff I've
12 talked to on a couple of, a number of
13 occasions, Mr. Duffy, and others.
14 Q Jay Breznahan?
15 A It doesn't ring a bell. I may
16 have, but it doesn't ring a bell offhand.
17 Q Who have you talked to most at
18 Newsweek?
19 A That's a good question. Again, I'd
20 have to look. I don't want to insult any
21 reporter by saying that they --
22 Q Mike Isakoff?
150
1 A I don't know Isakoff very well.
2 I've talked to him a couple times.
3 Q Daniel Kleidman?
4 A A couple times, to my knowledge.
5 Q What did you talk to him about?
6 A I don't recall. I couldn't recall
7 the specifics. I talk to a lot of reporters
8 over the course of a day and a week, and I
9 could no more tell you who I talked to, when
10 I talked to, what I said and what they said
11 than the man on the moon.
12 Q Let's just take a break. We'll get
13 rid of our hammering.
14 A Does this go against our time or
15 your time?
16 Q It goes against the guys doing the
17 hampering.
18 VIDEOGRAPHER: We're going off the
19 video record at 12:15.
20 (Recess)
21 VIDEOGRAPHER: We're back on video
22 record at 12:18.