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


         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?


         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?


         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


         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


         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


         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?


         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.


         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:


         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


         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


         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.


         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?


         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.


         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


         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?


         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.


         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:


         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


         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.


         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


         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


         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:


         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


         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


         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.


         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


         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


         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.


         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.


         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


         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?


         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


         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


         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.


         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


         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.


         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.


         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


         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.


         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


         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?


         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


         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.


         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


         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.


         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


         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?


         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?


         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.



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