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.
of this deposition