151 1 right? 2 A No, my vague recollection is 3 that -- I just don't know. I don't recall. 4 I'm sorry. 5 Q So one day you woke up and you were 6 at the DNC and you don't know how you got 7 there? 8 A No. I'm just saying I -- I do not 9 recall any conversation as to how, but that 10 there was a general -- somehow or another I 11 was told that -- I couldn't tell you how -- 12 but that I was moving to the DNC. 13 Q And what were you asked to research 14 at the DNC? 15 A It was similar work. It was 16 campaign research for the general election. 17 So just instead of doing public records 18 research on democratic primary opponents we 19 would have been doing public records research 20 on the opponent for the general election, 21 President Bush. 22 Q And who did you work with in doing 152 1 that research? 2 A I'm sure, you know, the entire -- 3 Q Well, who can you remember, the 4 main people? I'm not talking about lower 5 level people. Main people. 6 A Many of the same -- I mean Zack 7 Silverstein, Eric Berman I already mentioned 8 and Dan Carol, who was at the DNC. So -- I 9 mean there were -- I'm sure there were 10 others. There were -- the DNC had its own, 11 you know, research operation, so I can't 12 recall all those people. I'm sorry. 13 Q And what subject matters did you 14 and your colleagues work on in doing 15 research? What related to President Bush did 16 you research? 17 A The person changed, but the content 18 didn't. We did research on President Bush's 19 public record on, basically, the same host of 20 issues that we had done during the primary. 21 Q Did you do any research on members 22 of his family, like Jed Bush or George W. 153 1 Bush or Barbara Bush or Bushes? 2 A I don't -- no, I don't believe I 3 did, no. 4 Q Did anyone else? I take it they 5 did? 6 A I don't -- I mean I -- 7 Q Neal Bush? 8 A I can't speak to what others may 9 have done. I remember that there were issues 10 regarding it, but I don't remember anyone 11 doing -- doing the research and I did not, I 12 don't believe, do any research on his family. 13 Q So you don't know if other people 14 did, but you didn't? 15 A Correct. 16 Q Has someone told you before this 17 deposition if you don't want to answer a 18 question, you can forget? 19 A No, sir. 20 MS. GILES: Objection. That's a 21 harassing question. The witness is doing his 22 best -- 154 1 BY MR. KLAYMAN: 2 Q I'm not talking about your counsel, 3 just anybody generally. 4 A I have never heard that. 5 Q In an interview you can't be held 6 accountable for perjury if you just forget? 7 A No, sir. 8 Q Did you ever hear that before? 9 A I've never heard that before, no. 10 MS. GILES: There's no need for 11 these threats of perjury. The witness is 12 being very cooperative. 13 BY MR. KLAYMAN: 14 Q They're not threats. I want to 15 know. 16 A I've never heard that before. 17 Q Have you ever heard that inside the 18 White House? 19 A No, sir. 20 Q So are you saying that no one did 21 research on the Bush family? 22 A No, I don't think that's what I 155 1 said. I said I don't recall having done it 2 myself and I -- I don't recall anyone else 3 having done it, although I remember there 4 were issues. I -- just my memory of that 5 time period I can't -- I don't recall it. 6 Q Who did research on allegations 7 that George Bush had an affair? 8 A No one as far as I know. 9 Q Who did research on Jed Bush and 10 his dealings in Florida? 11 A Again, I don't recall anyone. In 12 fact, I don't know -- I don't know what 13 you're talking about. 14 Q During the time that you were in 15 that office you or others had contact with 16 individuals outside of the DNC? 17 A I'm sure we probably did, yeah. 18 Q Who did you have contact with? 19 MS. GILES: Objection. The 20 question is pretty broad. 21 BY MR. KLAYMAN: 22 Q You can respond. 156 1 A You know, it is too broad. I would 2 like to ask you what you mean. I mean we 3 went to lunch, we met with other staffers, 4 well, that would be the DNC. I mean it's a 5 broad question. 6 Q Sometimes did you interact with 7 members of the media who would give you 8 information about Bush and people in his 9 campaign? 10 A Did members of the media give me 11 information? 12 Q Or others, to the best of your 13 knowledge? 14 A No, I can't recall that. 15 Q Did you or anyone else ever have 16 contact with anyone who worked for or had 17 worked for the FBI? 18 A No, not -- not -- I mean I'm 19 answering for myself, but I have no knowledge 20 of anyone having met with the FBI. 21 Q Did you or anyone else ever receive 22 anonymous information? 157 1 A Oh, yeah, sure. 2 Q About what? 3 A Well, we used to get, the research 4 office, no matter where I've been, you know, 5 you get random letters that people write in 6 scratched out with all kinds of crazy 7 theories or -- 8 Q How long did you work at the DNC? 9 A Again, there were two different 10 periods. Are you referring to the first 11 period that I worked there? 12 Q The period you were just 13 describing. 14 A Mid -- the best of my recollection, 15 sometime around mid July through the -- 16 through November or something along those 17 lines. 18 Q Of what year? 19 A Of 1992. 20 Q And what happened then? Did you 21 move positions? 22 A At the end of the campaign? 158 1 Q Yeah. 2 A I did. 3 Q Where did you go? 4 A I went to the Presidential 5 Transition Office. 6 Q And who did you work for there? 7 A I worked under Robert Reich. 8 Q And what was your job? 9 A I was a staffer in the economic 10 policy group. 11 Q On the transition? 12 A Correct. 13 Q What were your duties and 14 responsibilities? 15 A I was just a staff person, to 16 help -- you know, they had a number of 17 people. I was a staff person. I did 18 remedial copying. I did -- honestly I don't 19 have a great recollection as to what was -- 20 what I did there. 21 Q And how long did you stay there? 22 A Through inauguration day, 159 1 January 20th. 2 Q And what, professionally speaking, 3 if anything, happened then? Did you get 4 another job after inauguration day? 5 A Yes, I did. 6 Q What job did you have? 7 A I worked at the Department of 8 Labor. 9 Q Reich got you a job there? 10 A I wouldn't say that, but I started 11 to work there as I was associated with his 12 group of people, as he was a designate. I 13 don't know that he got me a job, but I went 14 to work at the Department of Labor. 15 Q And what was your job there? 16 A I was among a group of people that 17 were just trying to help get his organization 18 in office up -- up and running and start to 19 figure out what candidates there were for -- 20 for what open positions that there were. 21 Q Did you have a job title? 22 A If I did, I don't recall what it 160 1 was. 2 Q Who was your immediate supervisor 3 there? 4 A Deputy -- I don't remember his 5 title, but it was Tom Glen to the best of my 6 recollection. 7 Q Where is he today? 8 A I have no idea. 9 Q How long did you stay there? 10 A I believe it was from January 20th 11 or 21st through mid to late February of the 12 same year. 13 Q And what happened then? 14 A I got a job at the DNC. 15 Q And what job did you get? 16 A Deputy director of research, 17 communications research. 18 Q Were you recommended for that job 19 by anybody? 20 A I think the actual title was issues 21 and research, but anyway. 22 Q And who recommended you for that 161 1 job? 2 A Well, a number of people. 3 Q Who? 4 A I asked -- I asked some people, 5 Eric Berman, I believe James Carville, I 6 asked if he would make a call on my behalf. 7 I'm sure there were others. I just -- I 8 can't recall. I tried to get a couple of 9 people to make phone calls on my behalf. 10 Q Why would Carville make a phone 11 call on your behalf? Had you had enough 12 experience interacting with him that he could 13 say something substantive about you? 14 A I think it was just that he knew of 15 me and that I had worked hard on the campaign 16 and he thought very highly of my boss, so he 17 was not opposed to helping me get a job. 18 Q You called him and asked for a 19 recommendation? 20 A I honestly don't recall. I may 21 have or I may have sent him a note or 22 something. I don't recall. 162 1 Q And he recommended you? 2 A I was not privy to the 3 conversation, but I believe after I started 4 at DNC that someone -- someone told me that 5 James had made a call on my behalf. So I 6 believe he did, although I can't speak for 7 him. 8 Q And you got to know him during the 9 campaign and during your work at the DNC 10 because you shared some of the information 11 that you gathered as a researcher with 12 Mr. Carville, correct? 13 A Sure, that's fair. 14 Q You worked closely with him? 15 A That's your characterization. I 16 was one of -- on the primary -- on the 1992 17 campaign. I'm not sure whether I would say I 18 worked closely with him. I had a boss that 19 worked closely with him. I spoke with him 20 occasionally and I believe he knew who I was. 21 Q Your boss was Eric Berman? 22 A Correct. 163 1 Q And you worked closely with Begala 2 during that campaign, correct? 3 A Same answer. 4 Q And you worked closely where 5 Stephanopoulos? 6 A Again, I don't recall having had 7 much interaction with him from 1992. 8 Q Did you get to know Glen Weiner up 9 to the point that you got this job as deputy 10 director? Had you gotten to know him during 11 this period leading up to that job? 12 A No, I don't believe so, no. 13 Q What was your duties and 14 responsibilities as a director? 15 A A host of things. We had to sort 16 of track events as, you know, what was 17 happening to inform the DNC press office and 18 others as to, you know, what we thought was 19 going to be happening. We helped to write -- 20 we worked with the press office to help do 21 press releases. We helped to write -- helped 22 the speech -- there was a speech writer or 164 1 two somewhere along the way that we used to 2 help with remarks for the chairman. We did 3 -- 4 Q How long -- 5 A You know -- sorry. 6 Q Go on. 7 A No. 8 Q How long did you stay in that job? 9 A From -- until middle of 1996. 10 Q I take it you worked with Don 11 Fowler and Chris Dodd in that job? 12 A For whatever the overlap was before 13 I left. 14 Q And what happened in the middle of 15 1996? 16 A I left the campaign -- I mean I 17 left the DNC and took a job at the campaign. 18 Q Who did you work for at the 19 campaign? 20 A Ann Lewis. 21 Q And how did you get your job at the 22 campaign? 165 1 A It's hard to say. I mean it was -- 2 it was -- I had worked on the '92 campaign. 3 Eric had worked on the '92 campaign. He had 4 been research director and I think people 5 sort of looked to him to figure out, you 6 know, how research was going to -- for his 7 opinion and advice anyway. 8 Q And what were your duties and 9 responsibilities for Ann Lewis? 10 A I was the research director for the 11 campaign. 12 Q And you were the research director, 13 numero unno? 14 A Correct, as I said, right. 15 Q And what was your duties and 16 responsibilities as research director and who 17 worked under you? 18 A Who worked under me I'll answer 19 first, if you don't mind. A little compound. 20 Q Whatever you would like. 21 A Okay. David Bocian. 22 Q How is that spelled? 166 1 A B-O-C-I-A-N. 2 Q And where is he today? 3 A He lives in Washington. 4 Q Do you know who he works for? 5 A He works for a law firm I believe. 6 I don't know. I'm not going to guess. 7 Q Well, guess. It's all right. 8 A Patton, Boggs is my guess. I'm not 9 sure if it's accurate. 10 Q Good guess. Next? 11 A Chris Gillespie. 12 Q And what was his job? 13 A One of the research staff. 14 Q Where does he work today? 15 A He does not. 16 Q He's unemployed? 17 A He's in school. 18 Q What school is he in? 19 A Columbia. 20 Q Next? 21 A Ruby Shamir. 22 Q How is that spelled? 167 1 A Which? 2 Q Shamir. 3 A S-H-A-M-I-R. 4 Q And what was Ruby's job? 5 A She was a junior assistant -- I 6 mean an office assistant. 7 Q And where is she located today? 8 A She works for Ann Lewis today. 9 Q What is her job title? 10 A Personal assistant. I don't know 11 what her job title is, but she works for Ann 12 Lewis outside of her office. 13 Q Anyone else? 14 A One other person. Matt Catapano. 15 Q How is that spelled? 16 A Phonetically I'm not -- I can't 17 recall. C-A-P -- no, C-A-T-A-P-A-N-O is my 18 guess. 19 Q And what was his position at the 20 time? 21 A Similar to Ruby, junior research 22 assistant. 168 1 Q And where is he today? 2 A I believe he's still in Washington. 3 Q Do you know where he's working? 4 A No, sir. 5 Q Anybody else? 6 A No. 7 Q Now tell us your duties and 8 responsibilities as the research director. 9 A As the research director, I worked 10 with the press office on press releases you 11 know in, you know, collaborative. I helped 12 the -- there were other people who helped to 13 do the positive, you know, the -- issues 14 papers, but we had a part in that. And 15 certainly, you know, one of the other 16 functions of the campaign research office was 17 we were the home of -- of the research on the 18 opponents in the campaign, Senator Dole. 19 Q And who did you report to? Who did 20 you work with above you? 21 A I reported to Ann Lewis, who was 22 the communications director for the campaign. 169 1 Q Who did she report to you? 2 A You probably -- I don't know 3 what -- how she would answer that. I don't 4 know that. As far as I know Peter Knight was 5 the campaign manager. I assume she may have 6 reported to him. 7 Q During the time that you worked on 8 the '96 campaign as the research director I 9 take it you had contact with Carville from 10 time to time? 11 A I think on maybe one occasion. 12 Q Did you have contact with Mickey 13 Kantor? 14 A No, not to the best of my 15 recollection. 16 Q Who did you generally have contact 17 with? 18 A Are you talking about -- 19 Q Someone notable. Excuse me. 20 A The 1996 campaign? 21 Q Yeah. 22 MS. GILES: Objection. 170 1 BY MR. KLAYMAN: 2 Q Besides Ann Lewis who did you 3 interact with that would be a level higher 4 than yourself? 5 A Certainly Ann Lewis, on occasion 6 Peter Knight. I mean I don't know. There 7 are probably a whole bunch of people who were 8 above me. I don't know how to answer that. 9 There -- 10 Q Who did you interact with at the 11 DNC? 12 A During the time I was -- 13 Q Research director for the campaign. 14 A Certainly Eric Berman and not a 15 whole lot of -- 16 Q Don Fowler? 17 A No, not that I -- not that I 18 recall, no. 19 Q Chris Dodd? 20 A Not that I recall. 21 Q Marvin Rosen? 22 A No, not that I recall. 171 1 Q John Huang? 2 A No, sir. 3 Q Did you ever meet John Huang? 4 A Not to the very best of my 5 ability -- my recollection I don't believe I 6 ever have. 7 Q Terry McAuliffe? 8 A I have -- I don't believe I ever 9 met, no. 10 Q Ron Brown? 11 A During the '96 campaign? 12 Q I'm talking about not then, but 13 before have you ever met? 14 A During what -- 15 Q Ever. Ever. 16 A Did I ever met Ron Brown? 17 Q Yeah. 18 A I believe there was maybe an 19 occasion or two at the end of the -- 20 Q What were the major issues that 21 your office researched during the campaign 22 concerning Dole? 172 1 A We're now talking again about the 2 1996 campaign? 3 Q Yeah, and I'm not interested in 4 matters dealing with his policy or matters 5 dealing with his voting record. I'm talking 6 about issues dealing with ethics and perhaps 7 his personal conduct. 8 A Well, that would, you know, to my 9 recollection that's just about my entire job, 10 was his public record and his voting record 11 and his record as a public official, was what 12 we spent our time researching. 13 Q Who in your office researched 14 whether Bob Dole had had prior relationships 15 with women other than his wife? 16 A No one. I was the director of the 17 office and I believe that no one ever did 18 that. 19 Q Did anyone ever research issues 20 concerning where the Dole campaign got 21 campaign contributions? 22 A Well, I'm sure they probably came 173 1 up in discussion. 2 Q Who did that? 3 A I couldn't say specifically. I'm 4 sure any -- any of us may have on occasion. 5 Campaign finance was certainly an issue 6 during the campaign that had to do with 7 people's public records. 8 Q Did you look into Haley Barber and 9 his activities? I take it you did. 10 A No. I'm trying to think and give 11 you an honest answer. I don't believe we 12 did. I mean certainly I recall that that was 13 in the newspaper at some point, but I 14 don't -- I don't believe or I wouldn't rule 15 out that someone read something in the 16 newspaper in my office, but -- 17 Q I take it you looked into the 18 divorce records of Bob Dole? 19 A No, I don't believe that we did, 20 no. 21 Q Do you know who did in the 22 campaign? 174 1 A I don't believe that anyone did. 2 Q His real estate records? 3 A His real estate records? 4 Q Yeah. Who looked into that? 5 Ownership of condominiums down in Florida. 6 A That was certainly something we 7 knew about that was public that was, I'm 8 sure, summarized from the -- 9 Q I didn't ask you if it was public. 10 I asked you who looked into it. 11 A And I'm trying to answer the 12 question and I don't -- I don't recall that 13 other than what was publicly written about 14 it. It was widely written about that there 15 was. Beyond that information I don't believe 16 anyone. 17 Q Well, who was assigned to gather 18 the so-called public information in your 19 office? 20 A Who was generally or about this? 21 Q About the ownership of the 22 condominium at the Seabreeze on Bal Harbor in 175 1 Miami. 2 A I couldn't tell you. I don't 3 believe anyone was specifically assigned to 4 it. 5 Q Well, who, generally, was assigned 6 to? 7 A I don't believe anyone was assigned 8 to it is my answer. It is certainly 9 something that we were aware of that may have 10 been in the document summarized from public 11 reporting. 12 Q Well, how did that document arrive 13 to your attention? 14 A That's what I'm answering to you. 15 It could have been me. It could have been 16 any of the other people in my staff that 17 summarized those public reports, that wrote 18 it into a document. I don't recall who did, 19 if, you know -- 20 Q Who was assigned to look into 21 Mr. Dole's tax filings? 22 A My recollection is that they were 176 1 provided, that there was a -- a day in which 2 he made them public and that our office 3 certainly looked at them. But I don't -- I 4 don't recall whether it was anyone's 5 particular responsibility to do that. 6 Q For someone that was head of the 7 office you seem to have very little 8 information about what went on there. 9 MS. GILES: Objection. Harassing. 10 BY MR. KLAYMAN: 11 Q How do you explain that? How do 12 you explain that? 13 A I'm trying to recall as best I can 14 and give you truthful answers. 15 Q So these things just kind of 16 spontaneously arrived in your office? I mean 17 how did they get there? 18 A He made them -- Senator Dole made 19 them public at a press conference and -- and 20 the campaign got a copy of them when he made 21 them public. 22 MS. GILES: Which things are you 177 1 talking about? 2 THE WITNESS: I believe you're 3 talking about -- 4 BY MR. KLAYMAN: 5 Q I'm talking about tax filings, I'm 6 talking about the Seabreeze condominiums. 7 A No, specifically the tax files is 8 what my answer was regarding. 9 Q What about the condominium issue 10 down there in Miami? Where did that 11 information -- 12 A What about it? 13 Q Who collected it? Who did you 14 assign to collect it? 15 A I think I've already said I 16 don't -- I'm sure it was something we were 17 aware of that may have been written about in 18 a document. I do not have any recollection 19 of having assigned someone to write that 20 document. 21 Q Was there someone who was assigned 22 to uncover negative information about Senator 178 1 Dole? 2 A You have to define what you mean by 3 "negative." 4 Q Anything that might be -- 5 A We were all assigned to -- I mean 6 what I would call comparative, I'm sure he 7 would view as negative, my portrayal of his 8 35 years in office. We were doing 9 opposition research, which was to attempt to 10 cull that information and I'm sure he would 11 view it as negative. 12 Q In the course of your work up to 13 this point in time as the research director 14 of the DNC, of the campaign during 1996, had 15 you ever heard -- 16 A Could you -- I'm sorry. Which 17 period are you talking about? 18 Q The entire period. Everything that 19 you did up to that point in time -- 20 A Up to the time I was -- 21 Q When you were the research director 22 of the campaign in 1996. You had heard 179 1 people refer to negative information as 2 digging up dirt on an opponent, hadn't you? 3 A Oh, I'm sure I had. 4 Q And that, in fact, is -- 5 A Digging up dirt is -- yeah, I'm 6 sure that I've heard that on any pundits or 7 others describe it as such, yes. 8 Q You're aware that that's something 9 that your office was in charge to do? 10 A No, I'm not aware of that. 11 Q Whatever you call it, I mean you 12 want to call digging up dirt something else? 13 What would you call it? 14 A I would call it campaign research. 15 Q So -- 16 A Which is not, to my knowledge, 17 digging up dirt, so that I'm clear about it. 18 Q But to the knowledge of some 19 pundits, that's the way they refer to it, 20 right? 21 A I wouldn't begin to answer for how 22 pundits would refer to campaign research. 180 1 Q Isn't that how you just responded 2 to it? 3 A No, public records research, 4 campaign research. I have no way of 5 explaining how pundits referred to that. 6 Q You just did testify to that, 7 Mr. Janenda? 8 MS. GILES: Objection. 9 Mischaracterizing his testimony. Is there a 10 question pending? 11 BY MR. KLAYMAN: 12 Q What is the distinction between 13 opposition research and digging up dirt based 14 on your experience? 15 A I can only describe to you what my 16 job was. Campaign research was to go through 17 public records on someone's career as a 18 public official, news clips, voting records, 19 that type of information, and attempt to 20 organize it in a way that would be useful for 21 a campaign. 22 Q But you did hear pundits refer to 181 1 negative information about an opponent as 2 dirt during the course of your career, did 3 you not? 4 A I'm not clear on the answer -- the 5 question. If I -- 6 Q You've heard pundits talking about 7 digging up dirt in the context of what you 8 can find out in the public records, right? 9 A Have I ever heard of a pundit 10 describe a campaign in terms of digging up 11 dirt? Is that -- 12 Q Yeah. 13 A I'm sure I have, yeah. 14 Q And he's referring to information 15 you could get publicly, correct? 16 A Who are you talking about? Who -- 17 Q Anybody that you've heard say that. 18 A I have no idea. No, I would not -- 19 I can't answer for what someone was referring 20 to. 21 Q What's your definition of a public 22 record? 182 1 A Information that's available to any 2 citizen. You could find it in a newspaper, 3 find it in the library, find it in the voting 4 records. 5 Q Based on your experience, all 6 information in the public domain is not 7 necessarily accurate, is it? 8 A No, certainly not, certainly not. 9 Q And things can be written based on 10 your experience that are untrue, correct? 11 A I would sure think so, yeah. 12 Are you talking about journalism as 13 a profession or of -- 14 Q Just based on your experience, 15 you've come upon information that has been 16 publicly available which is untrue, correct? 17 A Have I personally -- I probably 18 have. I'm trying to think whether or not 19 there's a specific example of that. 20 Q And, in fact, the Clinton campaign 21 maintained on many occasions that 22 publicly-available information about the 183 1 President's personal life was untrue, 2 correct? 3 A I'm not answering for the campaign 4 or for everything that the campaign ever 5 said. 6 Q Now, allegations about the 7 President's affairs are things that the White 8 House has denied. Correct? 9 MS. GILES: Objection to the 10 relevance of any of these question. 11 BY MR. KLAYMAN: 12 Q Generally speaking. 13 MS. GILES: I have a problem if 14 you're going to go down this path. I mean, 15 we have limits in the relevancy of the 16 questions at this deposition and getting into 17 allegations about the -- 18 MR. KLAYMAN: I'm just trying to 19 find out how he describes negative 20 information and dirt. 21 MS. GILES: You're certainly 22 entitled to ask him that. 184 1 BY MR. KLAYMAN: 2 Q So I'm asking this as an example to 3 do that. 4 A What's your question? 5 Q I'm not asking about those 6 relationships. I'm not going to ask questions 7 about that. 8 I'm asking you, wouldn't you 9 consider, based on your experience, some of 10 the allegations made against the President 11 with regard to his personal relationships 12 with women to be dirt? 13 A Would I? 14 Q Yeah. 15 A Yeah, absolutely. 16 Q And much of that is contained in 17 the public domain, is it not? 18 A Have I read public press accounts 19 that I think -- yeah, absolutely. I've read 20 public press account that I think are -- are 21 inaccurate. 22 Q So if you were assigned to research 185 1 the President's alleged personal life, you 2 would be researching based on a public record 3 that contains dirt, correct? 4 MS. GILES: Objection. Calls for a 5 hypothetical answer. 6 BY MR. KLAYMAN: 7 Q Based on your experience. 8 A Restate the question. 9 Q If you were asked to research the 10 President's alleged personal life, based on 11 your experience, you would be researching the 12 public record which contains dirt? 13 A Which is loaded with a lot of 14 absolute dirt, certainly, a ton of dirt on 15 the President. 16 Q So, therefore, as a researcher gets 17 into public records, you do get into dirt? 18 A On occasion -- when you talk about 19 dirt, can you maybe clarify? Are you talking 20 about personal -- information about people's 21 personal lives? 22 Q I think you just gave me the 186 1 definition, Mr. Janenda. I don't need more 2 from you. I think you know what I'm talking 3 about. 4 A No, I'm asking you if that's the 5 definition you are using. 6 Q I asked you for your definition. 7 I'm not being deposed. 8 A And I've given you my definition of 9 my record, which is public record. 10 Q And what I said is when you get 11 into public records, and that is your job as 12 the research director for the '96 campaign, 13 that that public record can contain dirt, 14 correct? 15 A About -- certainly, but -- 16 Q So, therefore, as part of your 17 duties and responsibilities, when you dig up 18 information on an opponent, that information 19 can include dirt? 20 A No, sir. I was very clear as to 21 what my job was and I was not asked ever 22 to -- to pull together information from the 187 1 public record or otherwise about people's 2 personal lives. I was asked to do it on 3 public records and on issues. I do not -- 4 that's my answer to you. 5 Q But others were asked to dig up 6 information about the personal lives of 7 Senator Dole and his family, were they not, 8 based on your knowledge? 9 A Based on my knowledge, no. Based 10 on my knowledge, I have no knowledge of that. 11 Q You're aware of an allegation 12 during the '96 campaign that Dole had had a 13 relationship with a woman other than his 14 wife, correct? 15 A I remember an article in The 16 Washington Post very near the end of the 17 campaign. 18 Q And somebody in your office 19 provided that information to The Washington 20 Post? 21 A Absolutely not. 22 Q Now, your job at the Labor 188 1 Department, how long did you stay there? 2 Excuse me. We're up to the campaign, 3 correct? 4 Did there come a point in time when 5 you got a job in the White House? 6 A Yes, sir. 7 Q When was that? 8 A That was early February of 1997. 9 Q Is that the job that you currently 10 hold? 11 A No. 12 Q What job did you get in February of 13 '97? 14 A There was a -- I was working 15 with -- under the Chief of Staff's office 16 originally because there was a great deal of 17 reorganization going on. So I wasn't 18 immediately within communications research. 19 Q Which Chief of Staff? 20 A White House Chief of Staff Erskine 21 Bowles. 22 Q And how did you get your job with 189 1 Erskine Bowles? Were you recommended by 2 somebody? 3 A I think I was recommended by a 4 number of people, yeah. 5 Q Who? 6 A To him I'm not -- just to be clear, 7 I don't know -- I mean, basically, I did the 8 same thing I've done after the '92 campaign, 9 I asked a couple of people if they would, you 10 know, say a good word on my behalf or 11 something. 12 Q Carville? 13 A I don't think I did because he just 14 wasn't involved in the '96 campaign. 15 Q Who did you ask? 16 A George Stephanopoulos, Rahm 17 Emanuel, Jean Spurling. Those are the three 18 that come to mind. I'm sorry. 19 Q How did you get to know Emanuel and 20 Spurling? 21 A Over the course of, you know, five 22 years I run into them and certainly -- 190 1 Q And you had worked with them in 2 providing them opposition research? 3 A Certainly. Again, my definition of 4 opposition research. 5 Q And what did you do specifically 6 for Mr. Bowles when you worked in his office? 7 A Specifically for him, I don't know 8 whether he would -- let's see. I didn't work 9 with him directly, if that's your question, 10 not that I can recall. 11 Q Who did you work with? 12 A More with his deputies. 13 Q And who were the deputies? 14 A Sylvia Matthews. 15 Q Sylvia? 16 A Correct. 17 Q Matthews? 18 A Yeah. And I did vetting and that 19 was the reason that I was hired. 20 Q Who else? 21 A The other deputy, John Podesta. 22 Q And what was Podesta's duties and 191 1 responsibilities? 2 A I couldn't begin to answer. He's 3 the deputy Chief of Staff. 4 Q He's in charge of cabinet affairs, 5 correct? 6 A I believe that's inaccurate, but I 7 couldn't answer for what his responsibilities 8 are. 9 Q And how long did you stay in that 10 office? Until you got your current job? 11 A Right, and, again, this was -- I 12 was -- it was intended that I eventually, I 13 believe, do research -- move, but there was a 14 lot of organization and people leaving. So I 15 started out in the Chief of Staff's office 16 and moved probably mid summer or something 17 like that. I can't recall exactly. 18 Q Mid summer of what year? 19 A Of last year, '97. 20 Q And that's when you got your 21 current job? 22 A Correct. 192 1 Q Who recommended you for that job? 2 Bowles, Erskine Bowles? 3 A I think -- again, my sense is that 4 it was something that -- that was sort of 5 intended to happen from the beginning, but 6 there was a bunch of -- there was a lot of 7 reorganization going on and people leaving 8 and people arriving. 9 Q The office that you currently had, 10 did that exist before you became the head? 11 A Yes, sir. 12 Q Who ran it? Who had your position? 13 A I believe, as I've already said, it 14 was Ann Walker. 15 Q The same woman who is now down the 16 hall from you? 17 A Correct. 18 Q Now, I take it sometimes you 19 consult with her about your duties and 20 responsibilities since she was the head 21 before you? 22 A Actually not very often. I mean on 193 1 office matters regarding space or something, 2 but beyond that I really don't have much 3 interaction with her. 4 Q When you occupied your job, did she 5 brief you on how to do your job, your current 6 job? 7 A No, we certainly -- she debriefed 8 me as to like quickly here's, you know, 9 here's where we keep the supplies, you know, 10 that kind of information. 11 Q Did she show you where all the 12 files were? 13 A I think she showed me where here 14 files, yeah, and described like these are 15 the -- yes. 16 Q What do you mean her files? 17 A Like she had responsibilities -- I 18 don't know whether she still works on it, but 19 as I -- as I described it to you, she has her 20 own files on whatever -- I don't know what 21 she has in her office, but I don't know. 22 They've never been described to me. 194 1 Q So when she left the position that 2 you currently occupy, she took her files with 3 her? 4 A Accurately stated. They've never 5 moved I'm sure. She's in the same place. 6 Q But you don't know? 7 A Sure, you're right. 8 Q And you didn't ask her in searching 9 for document for Judicial Watch's Notice of 10 Deposition Duces Tecum, "Do you have any 11 responsive documents that you took with you, 12 Ms. Walker?" 13 A No. 14 Q You didn't ask her that, did you? 15 A I did not. 16 Q So you don't know whether she does 17 or doesn't? 18 A Correct. 19 Q When did you first meet Glen 20 Weiner? 21 A I don't know. It was during the 22 time that I worked at the DNC between '93 and 195 1 '96. 2 MR. KLAYMAN: We can take lunch 3 right now. 4 MS. GILES: How long do you want? 5 MR. KLAYMAN: Take an hour. 6 MS. GILES: Or take less. Half an 7 hour, 45 minutes. 8 THE WITNESS: Half an hour. 9 MR. KLAYMAN: Let's do 45 minutes 10 then. 11 MS. GILES: Come back at 2:15 p.m.? 12 MR. KLAYMAN: That's fine. 13 (Whereupon, at 12:29 p.m., a 14 luncheon recess was taken.) 15 * * * * * 16 17 18 19 20 21 22 196 1 A F T E R N O O N S E S S I O N 2 (1:17 p.m.) 3 Whereupon, 4 THOMAS D. JANENDA 5 was called for continued examination and, 6 having been previously duly sworn, was 7 examined and testified further as follows: 8 VIDEO TECHNICIAN: We're on video 9 record at 1:17 Eastern Standard Time. 10 EXAMINATION BY COUNSEL FOR PLAINTIFFS 11 CONTINUED 12 BY MR. KLAYMAN: 13 Q Mr. Janenda, before we broke for 14 lunch you were saying how you got to knew 15 Glen Weiner. Can you refresh our 16 recollection on what you testified to, how 17 you first got to meet him? 18 A I think I -- all I said was that I 19 met him during the time I worked at the DNC 20 between '93 and '96 . 21 Q What did he do at the DNC between 22 '93 and '96? 197 1 A I don't believe he worked -- I'm 2 saying that's -- I can't pinpoint in that 3 period when I met him. I believe it was 4 later. Maybe either '94 or '95. May have 5 been '95 that he began working there. 6 Q In what context did you meet him? 7 How did you meet him? 8 A He came to work -- came to work in 9 the research department there. 10 Q At the DNC? 11 A Correct. 12 Q As a paid employee? 13 A Yes, sir. 14 Q And he worked under your direction 15 and control? 16 A I was the deputy in the office, so 17 -- 18 Q And what did you ask him to do? 19 A He did all types of -- I mean I'm 20 trying to think what he specifically did. 21 During the whole time he was at the DNC? 22 Q When he was working for you. 198 1 A He did all -- all types of -- I 2 mean everything we all did in the office. 3 Q Which was? 4 A Which was, again, during the period 5 when he was there, working on anything from 6 press releases with the press department to 7 speeches for chairman, campaign research. I 8 believe a variety -- all kinds of -- whatever 9 the office was doing he might have also done. 10 Q Did opposition research? 11 A Yes, campaign opposition research. 12 Q What specific issues did you assign 13 him to work on? 14 A I was not -- the maybe I'm getting 15 stuck. I was not the overall boss of the 16 office to the extent that I myself assigned 17 things to him. I don't have any specific 18 recollections. 19 Q What issues was he assigned to by 20 anyone? 21 A He -- a host of things. I'm sure 22 he did some of the opposition research, 199 1 campaign research, looking towards the '96 2 presidential campaign and I don't have a 3 specific recollection as to who he might have 4 worked on. I'm trying to think. That's to 5 the best of my recollection. 6 And he did also -- what else did he 7 do? He did -- he probably would have been a 8 guy eventually who was paying attention to 9 more of the political attacks coming towards 10 the administration. 11 Q What makes you think that? 12 A I'm just trying to remember what he 13 may have worked on and that's a general 14 recollection. 15 Q What were the political attacks? 16 A A number of political attacks, 17 personal attacks. Those kind of things. 18 Q So he was in charge to dig up 19 information that then could be thrown back to 20 deflect those political attacks? 21 A No, that's not what I said. 22 Q Then what did he do? 200 1 A He kept track of -- I believe as 2 part of his -- he had other jobs as well, but 3 I think he was the guy who was forced to read 4 more of that kind of -- of the attacks on the 5 administration than other people in the 6 office. 7 Q How long did he stay at the DNC in 8 that role? 9 A The general role that I've 10 described, all of it. I don't -- I don't 11 know when he left the DNC. It was sometime 12 after the -- the re-election campaign. 13 Q Was he the person that was in 14 charge in deflecting the attacks over 15 campaign finance of John Huang? 16 A No, sir. 17 Q One of the people? 18 A No, I don't believe so. I was not 19 there during the last months or -- I mean, as 20 I told you already, I left the DNC mid year 21 '96. 22 Q You are aware that Mr. Weiner is
Goto
of this deposition