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

 

 

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