201 1 very close with James Carville, are you not? 2 A I'm -- your characterization. My 3 characterization is that he worked for James 4 for part of 1997. 5 Q Do you know how he got his job? 6 A I do not. 7 Q Glen Weiner has told you that he 8 worked for Carville, correct? 9 A I'm sure he has. It's not a 10 secret. 11 Q And what did he tell you he did for 12 James Carville? 13 A He worked on James' project or 14 whatever it was -- education project or 15 something. It was some group that James had 16 set up and -- 17 Q Education Information Project? 18 A That would sound right. 19 Q EIP. Tell me what you know about 20 that project. 21 A What I know about it. I read quite 22 a bit about it when James set it up. It was 202 1 in the newspapers. It was James defending 2 the President and that's my -- it was, 3 basically, James, my recollection of it. 4 Q You talked to Mr. Carville about 5 that project, have you not? 6 A I don't believe I have actually. 7 Q You've had conversations with 8 Mr. Carville within the last year. Have you 9 not? 10 A I don't have any -- I'm trying to 11 be -- I don't have any specific recollection 12 of having done so, although I wouldn't say 13 that it would have been -- you know, it may 14 have happened that I spoke to him. 15 Q Where did you hear the phrase 16 specific recollection? Where do you come up 17 with that? 18 A My testimony. 19 Q Is that a White House phrase? Have 20 they taught people in the White House to use 21 that phrase when you can't remember? 22 A No, sir. 203 1 Q Where did you hear it before? 2 A I don't know. I've heard it 3 before. 4 Q Have you ever been deposed before? 5 A No, sir. 6 Q Have you ever provided testimony in 7 court? 8 A No, sir. 9 Q Have you ever seen any 10 documentation passed around the White House 11 or anywhere else that tells you how to answer 12 tough questions at depositions? 13 A Never. 14 Q Why didn't you just say I have no 15 recollection? What's the difference between 16 no recollection and specific recollection? 17 A It's my best attempt at an honest 18 answer. It would not have been completely 19 unheard of if I had spoken to James Carville 20 in the past year, but I have no specific 21 recollection of having done so. 22 Q Is that your phrase, "specific 204 1 recollection"? 2 A Yes, it is, it just came out of my 3 mouth. 4 Q Do you have any legal training? 5 A No, sir. 6 Q Did you read any deposition 7 transcripts in this lawsuit that you're here 8 on today before you came in here this 9 morning? 10 A Yes, I did. 11 Q What did you read? 12 A I read James Carville's deposition, 13 Paul Begala's deposition and Stacey Parker's 14 deposition. 15 Q Where did you get those 16 depositions? 17 A From my attorneys. 18 Q Did they ask you to read them? 19 MS. GILES: Objection. You're not 20 to answer any questions about what your 21 attorneys told you or asked you to do. 22 MR. KLAYMAN: How is that 205 1 attorney/client? 2 MS. GILES: Any conversation 3 between his attorneys either from us to him 4 or from him to us are privileged and we 5 instruct him not to answer. 6 MR. KLAYMAN: That's an 7 instruction. That is not the conveyance of a 8 piece of confidential information. It has to 9 confidential to constitute attorney/client. 10 MS. GILES: I'm instructing him not 11 to answer. 12 MR. KLAYMAN: Certify it. 13 BY MR. KLAYMAN: 14 Q Did they tell you why they wanted 15 you to read those deposition? 16 MS. GILES: Objection. Instruct 17 the witness not to answer. You're free to 18 ask him whether he's ever -- 19 MR. KLAYMAN: Certify it. 20 BY MR. KLAYMAN: 21 Q They wanted to make sure that your 22 testimony conformed with the testimony 206 1 previously given in this case. 2 MS. GILES: Objection. 3 BY MR. KLAYMAN: 4 Q Isn't that what they told you? 5 MS. GILES: That's privileged and 6 he can hardly speak to other people s 7 knowledge or understanding. 8 MR. KLAYMAN: Certify it. 9 BY MR. KLAYMAN: 10 Q Ms. Paxton specifically, is she the 11 one that told you to read those deposition? 12 MS. GILES: Objection. Instruct 13 the witness not to answer. 14 MR. KLAYMAN: Certify it. 15 MS. GILES: Can we move on beyond 16 topics he's had that -- 17 MR. KLAYMAN: Well, this wouldn't 18 be attorney/client information. I mean 19 you're obviously telling him not to answer, 20 but I'm getting it on the record so I can 21 then file an appropriate motion. 22 BY MR. KLAYMAN: 207 1 Q Before you came here to testify 2 today did you talk to James Carville Carville 3 about your deposition? 4 A No, sir. 5 Q When was the last time you talked 6 to Mr. Carville? 7 A The last time I recall even, you 8 know, being around him or seeing him was at a 9 Christmas party, but I don't even know that I 10 spoke with him at that point. That's my 11 recollection. 12 Q Did you speak with Mr. Begala about 13 your deposition today? 14 A No, sir. 15 Q Did you speak with 16 Mr. Stephanopoulos about your deposition 17 today? 18 A No, sir. 19 Q Ms. Parker? 20 A No, sir. 21 Q When was the last time you spoke 22 with Mr. Stephanopoulos? 208 1 A Probably, general, Spring -- Spring 2 of 1997. 3 Q When was the last time you spoke 4 with Mr. Begala? 5 A Probably last week. 6 Q What did you speak with Mr. Begala 7 about last week? 8 A I have not -- let me clarify. I 9 have not spoken with him since I was served. 10 I may have ran into him last Monday in the 11 course of the workday. I don't have any 12 specific recollection of -- 13 Q What did you speak with him about? 14 A I think I may have said hello to 15 him last Monday in the hallway when I bumped 16 into him. 17 Q Do you ever interact with 18 Mr. Begala over your job functions? Do you 19 provide information to his office? 20 A Certainly. 21 Q Tell me in the course of your 22 duties and responsibilities how your office 209 1 researches information and how it processes 2 that information, how it disseminates the 3 information. 4 How does your office work? What's 5 it set up to do? How does it take a request 6 to do research? How does it then do that 7 research and how does it then give the 8 research back? 9 A Do you want to maybe break those 10 down? 11 Q Sure, but I'm just laying it out so 12 you can tell me in your words. 13 A What's the specific -- 14 Q I want to find out how your office 15 works and what everybody's job is, if you 16 would? 17 A There are, I'd say four -- four 18 different things that the office does. First 19 is to track the administration record on 20 issues, accomplishments, criticisms both, on 21 issues and to maintain a set of 22 accomplishment documents that are up to date 210 1 and accurate. Secondly, the vetting process 2 that I described. Thirdly, we do a lot of 3 paper for events like Presidential -- if the 4 President is going, you know, to do an event 5 on education, we might help provide paper for 6 that event. And then, fourth, there are just 7 general other -- other things that come up 8 that we're asked to -- to help with. Those 9 are the -- the bulk of my what my office 10 does. I'd say 98, 99 percent. 11 Q As part of your duties and 12 responsibilities, do you process requests by 13 other persons in the White House to do 14 opposition research? 15 A I don't understand. 16 Q Let's say can Mr. Begala call down 17 to you and ask you to research a particular 18 matter? 19 A Well, first of all, when you refer 20 to opposition research, I don't do what I 21 consider by my definition to be opposition 22 research at the White House. Is that your 211 1 question? 2 Q No. My question was, if someone in 3 the White House wants to get something 4 researched, is it within the purview of your 5 duties and responsibilities, your office's, 6 to do that research for them? 7 A It may or may not be actually. It 8 depends on what it is and what else is going 9 on. 10 Q Have you ever been requested to do 11 any type of research by Paul Begala's office? 12 A Probably. I'm sure we have. 13 Q And what specifically was your 14 office requested to research? 15 A There are a lot of times where 16 Paul -- I'm sure there are occasions where 17 Paul is looking for a particular transcript 18 or a past speech or something from the '92 19 campaign like a speech that the President 20 made that he'll remember, but be looking for 21 a copy of. Or he may be working on a 22 particular issue and -- like, you know, an 212 1 education event and ask for something 2 specific to that -- to that issue. 3 Q Has Mr. Begala ever asked you to do 4 any research on Mr. Richard Scaife? 5 A No, sir. I mean, no, I don't 6 believe during the time -- 7 Q When I say you, I mean your office. 8 A In the capacity as director of the 9 office, I have no -- no knowledge of that. 10 Q Let me ask the question this way: 11 Has anyone ever asked your office to do 12 research on Mr. Scaife? 13 A No, I have no recollection of that. 14 Q You don't remember? Is that what 15 you're telling me? 16 A No, I don't -- I don't have any 17 recollection of anyone having asked me to do 18 any research on Mr. Scaife. 19 Q Has anyone asked not you, your 20 office? 21 A My office. 22 Q Has anyone asked that your office 213 1 do any research on Ken Starr? 2 A No, sir, with -- again, just so 3 that I'm being fully forthcoming, I'm not 4 saying that it isn't possible that someone 5 asked me for a transcript or a press article 6 or something like that that had -- that was 7 relevant to that, but I don't specifically 8 remember that. But that would have been -- 9 if that had happened, it wouldn't surprise 10 me. 11 Q Bob Barr? 12 A What about him? 13 Q Has anyone ever asked you to do any 14 research, you meaning your office, on Bob 15 Barr? 16 A Not to my recollection. I believe 17 on one occasion someone asked -- asked to 18 pull up his remarks that he made on the 19 floor. I believe that's the only occasion I 20 can recall. 21 Q Judicial Watch? 22 A No, not to my recollection. 214 1 Q Larry Klayman? 2 A No, sir. 3 Q Senator Fred Thompson? 4 A Again, I don't -- it's possible 5 that someone may have been looking for an 6 article or a transcript. He certainly was 7 someone who was in the news and all, but I -- 8 I don't have any specific recollection and 9 I've certainly never done. You know, any 10 work on him personally, no. 11 Q When I say you, your office. 12 A My office. That's how I'm 13 answering it. 14 Q John Fund? 15 A No, sir. 16 Q Michael Issikoff? 17 A Have I ever done research on 18 Michael Issikoff. 19 Q Has your office ever been asked to 20 do research on Michael Issikoff or have you 21 ever done research on Michael Issikoff? 22 A Well, can we -- maybe if we can 215 1 clarify the term "research." Again, I would 2 say it's possible that someone had asked me 3 for an article that he had written, but I -- 4 beyond that I cannot think of anything, no. 5 Q Susan Schmidt of The Washington 6 Post? 7 A Same answer. 8 Q Did you talk to Ann Lewis about 9 your being deposed here today? 10 A No, sir. 11 Q Have you ever been asked to do any 12 research or did you do any research 13 concerning Linda Tripp? 14 A No, sir, although, as I already 15 told you, when I searched my files, there 16 were two public documents that came up which 17 I believe just the nature of the fact that 18 they were transcripts, they were in my files. 19 Q Kathleen Willey? 20 A No sir. 21 Q John Whitehead of the Rutherford 22 Institute? 216 1 A No, sir. 2 Q Paula Corbin Jones? 3 A No, sir. 4 Q Landmark Legal Foundation? 5 A No, sir. 6 Q Larry Patterson? 7 A No, sir. 8 Q L.D. Brown, State Trooper, 9 Arkansas? 10 A I have no recollection of anyone in 11 my office having ever done research on any of 12 them. 13 Q Pat Robertson? 14 A No, sir. No, the only thing that 15 is possible is that one of the functions we 16 have is to do a calendar of upcoming events. 17 So, again, as broadly answered, it's 18 possible. Like his Web site with a list of 19 events. Like if -- if the Christian 20 Coalition had a major event coming up, that 21 might go up on the, like, calendar of 22 upcoming events. Beyond that, no, I don't 217 1 believe there's ever been any research done. 2 Q Jerry Falwell? 3 A I'm not sure. 4 Q Newt Gingrich? 5 A I'm sure that Newt Gingrich is, in 6 his capacity as speaker of the house, is all 7 over -- I mean he's probably in our -- his -- 8 I don't think -- no specific research on Newt 9 Gingrich, but I'm sure that his position on 10 issues is something that we've been asked for 11 or have provided to people. 12 Q Joe DiGenova? 13 A No, sir. 14 Q Do you know who Joe DiGenova is? 15 A I have a vague sense that he's an 16 attorney Beyond that -- 17 Q Victoria Toensing? 18 A No, sir. 19 Q Christopher Ruddy? 20 A No, sir, although I -- 21 Q Well, you started to nod. What 22 have you -- 218 1 A No, I know he is and it's -- it's 2 possible that on one occasion there was some 3 articles that we pulled down that he had 4 written and that we shared with people. 5 Q Pat Buchanan? 6 A Yeah, I -- I don't recall having 7 ever done any research on him. May have 8 pulled down something he wrote. 9 Q Gennifer Flowers? 10 A No, sir I don't. 11 Q Rush Limbaugh? 12 A No, sir. 13 Q Dick Morris? 14 A No, sir. 15 Q You're aware, are you not, that 16 James Carville currently keeps a number of 17 files on individuals and entities which are 18 the conservative movement? You're aware of 19 that, aren't you? 20 A I'm not aware of how -- you know, 21 what files Mr. Carville keeps, no. 22 Q Glen Weiner has told you that, 219 1 hasn't he? That Mr. Carville has a lot of 2 files about perceived adversaries of the 3 Clinton administration like Mr. Scaife and 4 Bob Barr and others? 5 A No, and I would not say -- I'm, 6 generally, aware of what the organization was 7 set up for and that, you know, that was the 8 kind of work that Glen did while he was 9 there, but I have no specific knowledge of 10 how the files are kept or who is in his files 11 and who's not in his files. 12 Q In your office there is a list of 13 the files that Glen set up for James 14 Carville, is there not? 15 A Not to my knowledge, no. I don't 16 believe that there is such a list. 17 Q And, in fact, your office has 18 communicated with Carville's office from time 19 to time to determine what information they 20 have; isn't that correct? 21 A I don't believe so with the -- I 22 would say that it's my vague recollection 220 1 that -- that when Glen started working for 2 me, after having left James, that there may 3 have been -- he may have had a conversation 4 or two with people back there saying I have 5 left, but if you're looking for such and 6 such, it used to be here. I mean that kind 7 of conversation, but -- 8 Q Faxes have come into your office 9 from Carville, have they not, or EIP? 10 A Not that I'm aware of. 11 Q Have faxes come in from 12 Stephanopoulos? 13 A Faxes from Stephanopoulos? 14 Q Yes. 15 A No, not that I'm aware of. 16 Q Your office communicates from time 17 to time with the Democratic National 18 Committee, does it not? 19 A Certainly. 20 Q And it provides information to the 21 Democratic National Committee, does it not? 22 A Certainly. 221 1 Q Provides information about people 2 who have challenged or criticized the Clinton 3 administration? 4 A No, sir. 5 Q It never has done that? 6 A I cannot think of any occasion -- 7 and maybe you would have to be more clear 8 about who you're talking about. 9 Q Well, a person or a group that's 10 been critical of Clinton. Haven't you sent 11 information to the DNC about such persons or 12 groups? 13 A I don't recall having done that, 14 although I wouldn't rule out that -- you 15 know, if I saw an article that I thought -- a 16 printed article that was of interest to me, 17 that I might, you know, say did you guys see 18 that in the course of a conversation. 19 Q When did that happen? 20 A I'm sure that it's probably 21 happened, but I don't -- I'm trying to think 22 of the specific example. I don't have one. 222 1 I'm sorry. 2 Q Did you ever see the movie "The War 3 Room"? 4 A I did. 5 Q Do you remember the scene where 6 George Stephanopoulos is on the phone, he's 7 talking to somebody who's a democrat and 8 they're talking about a s certain piece of 9 information and Stephanopoulos says something 10 to the effect, well, you know, you better 11 never do that because, if so, you'll never 12 work in the democrat party again? Do you 13 remember that? 14 A I remember that, yes. 15 MS. GILES: Objection to the 16 question on the grounds of relevance. 17 MR. KLAYMAN: I'm laying a 18 foundation. 19 BY MR. KLAYMAN: 20 Q What was your understanding of what 21 was being discussed in that -- 22 A I have absolutely no understanding 223 1 and I was at the preview of the movie and 2 when that was said everyone laughed, so -- 3 Q Now, you're very much aware, are 4 you not, that if you say the wrong thing at 5 this deposition, you may never work with the 6 democrats again? 7 A No, sir, I'm concentrating on 8 giving you full and honest answers. 9 Q But obviously that segment of the 10 movie caught your attention? 11 A No. As I said, I -- what I can 12 recall is that people laughed and thought it 13 was sort of funny, like what was he talking 14 about. 15 Q What's funny about it? 16 MS. GILES: Objection. His 17 reactions to a movie? I mean can we move on 18 to more relevant topics? 19 BY MR. KLAYMAN: 20 Q Did you laugh? 21 A No, I didn't laugh. I just 22 remember it seemed to be something that 224 1 people thought was funny. 2 Q Has your office had contact with 3 Terry Linzner's office? Do you know who 4 Terry Linzner is? 5 A I do know he is from 6 publicly-reported stories. 7 Q Has your office ever had contact 8 with him? 9 A None whatsoever that I'm aware of 10 at all. 11 Q His firm is called IGI 12 International, did you ever hear that? 13 A I've heard of him and I'm that he 14 has a firm, but I can't say the name of the 15 firm means anything to me. 16 Q Did you ever have contact with IGI? 17 A No, sir, not to best of my 18 knowledge. 19 Q Has your office ever had contact 20 with Williams & Connolly or David Kendall or 21 anybody from Williams & Connolly? 22 A Not that I'm aware of, no. 225 1 Q Same question with regard to Bob 2 Bennett from Skadden & Arps? 3 A Not that I'm aware of. 4 Q Do you know what Skadden & Arps is? 5 It's a law firm. 6 A It's a law firm. 7 Q Have you ever had contact with a 8 private detective by the name of Pellicano? 9 A No, sir. 10 Q Palladino? 11 A Not to the best of my -- I mean if 12 he walked in the door, I wouldn't know who he 13 was, but to the best of my knowledge I 14 don't -- I don't believe so. 15 Q Who are the people that you 16 interact with most at the White House, that 17 you see most on a routine basis? 18 A My own -- 19 Q Not the people in your office, 20 obviously those people, but outside of your 21 office, your suite of offices. 22 A The -- certainly my -- the rest of 226 1 the communications staff, Ann Lewis, speech 2 writer, Michael Waldman and his staff, 3 people -- a lot of people who put together -- 4 I don't even know where they all work, but in 5 relation to the vetting work there are a 6 number of people who are constantly putting 7 together lists of who is going to be invited 8 to particular events that we work with quite 9 a bit. The -- it's not uncommon for us to 10 work with the press office and its staff in 11 terms of they might be looking for a -- 12 Q Is this Mike McCurry's office when 13 you say "press office"? 14 A He's the press secretary, correct. 15 Q And who works just underneath him? 16 A Who works just underneath him? 17 Q Who's in that office that you can 18 remember? 19 A Who's in the press office? 20 Q Uh-huh? 21 A Amy Weiss Toby, Joe Lockhart, Barry 22 Toiv, Steve Silverman. I'm trying to think. 227 1 That's the best of my recollection. There 2 are more -- 3 Q And you interact -- 4 A There are more people. 5 Q You interact regularly with these 6 people? 7 A Not regularly in the sense that 8 there's a scheduled meeting of any kind, but 9 it's not uncommon that, you know, there might 10 be something that would come up that we would 11 help, you know, help them find. 12 Q And you do interact with Sidney 13 Blumenthal? 14 A I do occasionally, yeah. I bump 15 into him at staff meetings a couple times a 16 week. 17 Q He's in the communications office, 18 too, isn't he? 19 A I believe he is, yes, is my 20 understanding. I could be wrong, but I 21 believe he's under Ann Lewis, communications. 22 Q Why didn't you mention him when I 228 1 was asked you? 2 A I was continuing to list people and 3 you interrupted me. 4 Q Well, we were outside the 5 communications office at that point. 6 A I probably would have said so. 7 I -- I was naming people. 8 Q Name some more. 9 MS. GILES: What's the question? 10 People he's ever had contact with or -- 11 MR. KLAYMAN: Who does he interact 12 with most on a regular basis. 13 THE WITNESS: Well, and he wouldn't 14 fit into that category, which is probably why 15 I didn't name him. Ruby Shamir, who is Ann 16 Lewis' assistant, Stacey Spector is deputy 17 communications director. 18 BY MR. KLAYMAN: 19 Q And how is that name spelled? 20 A First or last? 21 Q Last. 22 A I believe it's S-P-E-C-T-O-R. 229 1 Q Is she related to Arnold Spector, 2 the senator? 3 A Not to the best of my knowledge. 4 Q Anyone else? 5 A I mean -- 6 Q What does Sidney Blumenthal do? 7 What is his job? 8 A He's a -- I don't know his title or 9 anything, but he's a senior communications 10 person, to the best of my knowledge, under or 11 within communications working with Ann Lewis. 12 Q Now, his job is to dig up dirt, 13 isn't it? 14 A No, sir, not to my best of my 15 knowledge. 16 Q Who does he work with primarily? 17 A As far as I can tell, he spends a 18 lot of time -- well, I don't want to flip. I 19 don't know. 20 Q No, tell me what you mean. You're 21 not going to be flip. 22 A Spends a lot of time in his office 230 1 on the phone. I don't know who he works 2 with. I'm sure he's -- I mean he's part of 3 the senior communications staff. I don't 4 know who he works with. 5 Q He works under Ann Lewis, does he 6 not? 7 A Again, I -- I believe that's true, 8 but I -- I haven't seen it on a chart. 9 Q Did you ever ask Ms. Lewis what he 10 does? 11 A No, sir. 12 Q Have you ever asked anybody what he 13 does? 14 A No, sir. 15 Q Do you know who he's in contact 16 with on a regular basis? 17 A No, sir. 18 Q You think you have sen -- 19 MS. GILES: If I get some 20 relevance to -- 21 BY MR. KLAYMAN: 22 Q You have seen -- 231 1 MS. GILES: If I can just get -- if 2 I can -- 3 MR. KLAYMAN: This is discovery. 4 MS. GILES: -- state my objection 5 for the record. This witness' knowledge 6 about other people's duties seems very far 7 afield. 8 MR. KLAYMAN: No, this is -- 9 MS. GILES: Can you tie this back 10 to the subject matter of the case? 11 MR. KLAYMAN: This is relevant. 12 I'm trying to find out how the communications 13 office operates. 14 BY MR. KLAYMAN: 15 Q You have received from 16 Mr. Blumenthal and/or his office from time to 17 time materials from Salon Magazine, have you 18 not? 19 A I believe probably I have, yes. 20 Q You know there's a Salon Magazine. 21 A I don't specifically recall. I'm 22 sure, you know, he'll often send an envelope 232 1 with a number of press clips in it of some 2 kind or another that will arrive, you know, 3 from his office. 4 Q Do those envelopes have 5 instructions in them? 6 A No, sir. 7 Q And what do you do with those press 8 clips? 9 A Occasionally I read them. 10 Occasionally I don't read them. 11 Q Does it have a routing slip to who 12 it's sent? 13 A No, sir. 14 Q Do you know whether other people 15 are receiving them as well? 16 A I couldn't say. 17 Q Is there any indication as to who 18 received the same materials that you 19 received? 20 A No, sir, there's not. There's no 21 indication. 22 Q Now, what was the subject matter of 233 1 some of the materials you received from 2 Mr. Blumenthal? 3 A They, generally, have to do with 4 Ken Starr's investigation and, you know, I 5 would say they -- that's to my recollection, 6 that they're, generally, along those topics. 7 Q Now, is there anything with regard 8 to Filegate that you've received from him? 9 A Not to the best of my recollection, 10 but, again, I haven't -- a lot of times I 11 don't -- I don't read the -- I don't read 12 everything he sends us, so -- 13 Q Is that stuff sent to you, you Tom 14 Janenda? 15 A Me personally, yes. 16 Q And I take it you called him and 17 said Mr. Blumenthal, why are you sending me 18 this stuff? 19 A No, I haven't. 20 Q You have no curiosity? 21 A No, he's -- no, I haven't done 22 that. 234 1 Q Do you take what he sends you and 2 just throw it out immediately? 3 A No, I don't throw it out 4 immediately. Sometimes I read it. Sometimes 5 I don't read it. Sometimes it sits on my 6 desk for, you know, a couple of days. 7 Q What do you do with it? 8 A Generally, I throw it out at the 9 end of the week or at the end of the day. I 10 get rid of it. I get -- people forward a lot 11 of articles, you know, across the board to 12 me. 13 Q I take it that you have filed some 14 of the materials that Mr. Blumenthal has sent 15 you? 16 A No, sir, and I specifically looked. 17 Q You or your office? 18 A No, not that I'm aware of. Again, 19 those are press clips. I mean that's, 20 generally, all -- I can't -- just press clips 21 of things that -- things that are interesting 22 as far as I know. 235 1 Q You said that you attend staff 2 meetings, correct? 3 A I think I said I attend 4 communications staff meetings, yes. 5 Q How frequent do those meetings 6 occur? 7 A It varies, but they are scheduled 8 to occur Monday, Wednesdays and Fridays. 9 Q And at what time do they occur? 10 A Usually somewhere in the vicinity 11 of 9:15. 12 Q 9:15 a.m. 13 A Yes, sir. 14 Q And how long did do, generally, 15 last? 16 A It varies. They're brief. Fifteen 17 minutes. 18 Q Does the communications department 19 ever have meetings longer than 15 minutes? 20 A I'm sure they probably do. 21 Q You had meetings longer than 15 22 minutes when the Monica Lewinsky story broke, 236 1 did you not? 2 MS. GILES: Objection. We're not 3 going to get into the Monica Lewinsky matter. 4 BY MR. KLAYMAN: 5 Q He can respond. 6 A I'm happy to respond. I've never 7 been in any meeting about Monica Lewinsky. 8 Q Did you have a meeting longer than 9 15 minutes when the peace accord was reached 10 with Northern Ireland? 11 A Again, am I answering for myself or 12 am I answering for the communications 13 department? 14 Q Communications department. 15 A I can't answer for the 16 communications -- I was not in a meeting -- I 17 don't know. The communications department 18 could have had a four-hour meeting about the 19 peace in Northern Ireland. 20 Q Are you not invited to general 21 communications department meetings? 22 A That are a lot of meetings. I am 237 1 not invited to every meeting, no. 2 Q How is it decided what meeting you 3 attend and what meeting you don't then? 4 A I would be, you know, notified by 5 someone or my -- I would be requested to 6 attend. 7 Q How are you, generally, notified? 8 A Either a phone call or an E-mail. 9 Q And where does the phone call or 10 E-mail come from? 11 A I just find it very difficult to 12 answer these questions because it's -- I mean 13 you're asking a communications meeting. 14 There are communications meetings probably 15 two or three at a time in the White House and 16 they're on what's happening this week, next 17 week. I -- I get invited to some. I don't 18 get invited to some. 19 Q Well, tell me where you can 20 remember having gotten notification to attend 21 a communications meetings, all the different 22 sources. 238 1 A E-mail and phone calls. 2 Q From who? 3 A Often Ruby Shamir, Stacey Spector, 4 rarely -- occasionally Michael Waldman, 5 speech writer. Beyond that I'm -- I'm 6 guessing. 7 Q Did you ever get notification from 8 Paul Begala's office to attend a meeting? 9 A I remember -- it hasn't happened 10 often, but it may have happened -- I believe 11 there was a -- he was attempting -- Paul was 12 attempting to host a meeting that was like a 13 week ahead, yes, I believe I was -- 14 Q You got notification from Sidney 15 Blumenthal's office to attend a meeting? 16 A No, sir, I don't believe so. 17 Q Mike McCurry's office? 18 A It may very well -- it may be. It 19 wouldn't be uncommon, but -- I mean -- I 20 shouldn't say it wouldn't be uncommon. I'm 21 just saying it wouldn't surprise me if I have 22 been invited to a meeting when someone in the 239 1 press office had asked for one, but I don't 2 specifically recall one. 3 Q Ann Lewis? 4 A Yes, absolutely. 5 Q Who is, generally, in attendance at 6 these meetings Monday, Wednesday and Friday 7 from 9:15 that take about 15 minutes? Who, 8 generally, attends? 9 A The communications staff. 10 Q I'm talking about people, names. 11 A Ann Lewis, Stacey Spector, Ruby 12 Shamir, myself, my staff. I don't know if I 13 said Michael Waldman, his speech writing 14 staff, Sidney Blumenthal sometimes yes, 15 sometimes no, Ann Walker sometimes yes, I 16 mean, you know, again, and there are a couple 17 of people that do communications or speech 18 writing for like foreign policy and that's -- 19 to the best of my ability to recall those are 20 the people that are at that meeting. 21 Q I take it you discussed the fact 22 that you were being deposed in Judicial 240 1 Watch's lawsuit in one of these staff 2 meetings, didn't you? 3 A No, sir, I did not. 4 Q Did anyone raise that issue? 5 A I don't believe so, but, frankly, I 6 haven't been at a couple of them this week 7 and I couldn't answer. I would be surprised 8 because I don't believe that anyone knows 9 that I'm being deposed, so -- 10 Q Have you ever heard Judicial Watch, 11 Larry Klayman or Judge Lamberth mentioned in 12 any of these staff meetings? 13 A Not to the -- I have no 14 recollection of that, no. 15 Q So you don't remember? Might have 16 been discussed, but you just don't remember? 17 A I have no recollection of having -- 18 ever had it come up, but you're right, I 19 couldn't say that it never came up. 20 Q At any of the meetings that you've 21 ever attended in the White House did you ever 22 discuss the Hillary Clinton health care task 241 1 force case that Judge Lamberth had? 2 MS. GILES: Objection. Relevance. 3 BY MR. KLAYMAN: 4 Q You can respond. 5 A I don't know. 6 Q Known as APS, A-P-S. 7 A I'm not familiar with that term. 8 I'm. generally, familiar with the case and I 9 don't believe I've ever had a meeting or been 10 at a meeting when that was discussed. 11 Q What was the last staff meeting you 12 attended? When was that? 13 A Probably Friday because I don't 14 believe there was one -- 15 Q And who was at that meeting? Last 16 Friday you mean? 17 A Yes. 18 Q Who was at that meeting? 19 A I believe, generally, the people I 20 listed. I -- I don't believe Ann Walker was 21 there. I don't believe Sidney Blumenthal was 22 there, but beyond that, I believe that, 242 1 generally, the people I -- I outlined, the 2 communications staff, the speech writers. 3 Q Tell me specifically what was 4 discussed last Friday at that meeting. 5 MS. GILES: Can you wait for a 6 second? 7 I don't want the witness to answer 8 about the topics that were discussed, but if 9 you're going to get into more detail than 10 that, the topics will have to be -- 11 BY MR. KLAYMAN: 12 Q Well, let's hear the topics. Tell 13 us all the topics that were discussed. 14 A It was a pretty quick meeting, to 15 my recollection, that Ms. Lewis had somewhere 16 else to be, and it was, basically, just 17 laying out the -- a quick overview of what 18 the schedule was going to be for the 19 president and what events were going to be 20 happening in the next seven or eight days. 21 Q So what were the general topics at 22 the events? 243 1 A As I said, the President's 2 schedule, the, you know, disaster relief 3 trip, the trip to Chili, those were, 4 basically, you know, what was happening on 5 the calendar of events. 6 Q Any discussion of Paula Corbin 7 Jones? 8 A No, sir. 9 Q When was the last meeting before 10 that meeting that you remember attending? 11 A Kind of blurs together here. 12 Probably the Monday of that week I believe. 13 Q And what were the general topics 14 discussed at that meeting? Well, let me ask 15 you who was at that meeting Monday? 16 A It's really hard for me to say, to 17 be honest with you. I mean it was the same 18 general crowd, but I -- I could not recall 19 exactly, you know, among those people who was 20 there, who wasn't there. 21 Q Same general crowd plus Blumenthal? 22 A I couldn't say that for sure. I 244 1 don't -- I don't recall. 2 Q And what were the general topics 3 discussed? 4 A Just laying the same -- same kind 5 of thing. I mean that's what the gist of the 6 meeting is, where is the President going on 7 Monday, Wednesday, Tuesday, you know, Monday, 8 Tuesday, Wednesday, and then check in with 9 the speech writers on who's working on those 10 remarks, some logistics about, you know, 11 events. That's, basically, my recollection. 12 I can't tell you specifically, but that's the 13 gist of it. 14 MS. GILES: I mean if you want to 15 ask him whether the topics were, you know, 16 FBI files or misuse of government files, 17 obviously you're entitled, but other than 18 that, the inner workings of the 19 communications office has no relevance to 20 this lawsuit. 21 MR. KLAYMAN: There have been 22 several times during this lawsuit that you've 245 1 questioned the relevance. The court has 2 issued orders which have tried to explain the 3 relevance of certain issues and certainly 4 it's relevant for me to find out how the 5 office functions, what they generally deal 6 with, and there are matters that go beyond 7 the FBI files that are relevant to this 8 lawsuit. 9 MS. GILES: Sure, other potential 10 misuse of government files I would agree is 11 relevant. 12 MR. KLAYMAN: For instance, Linda 13 Tripp. I mean we have an order recently on 14 the relevance of Linda Tripp. 15 MS. GILES: The potential misuse of 16 government files, I agree. If you want to 17 ask him about that, I welcome those 18 questions. 19 BY MR. KLAYMAN: 20 Q Well, let's talk about Linda Tripp. 21 Clearly there must be an entity 22 inside the White House that collected public 246 1 information about Linda Tripp when the story 2 broke. Who did that? 3 A No one to -- I disagree with the 4 assumption that there is someone and I don't 5 know of anyone. 6 Q Let's talk about Kathleen Willey. 7 Who in the White House gathered public 8 information about Kathleen Willey? 9 MS. GILES: Why is Kathleen Willey 10 relevant? 11 BY MR. KLAYMAN: 12 Q You can respond. 13 MS. GILES: Are you asking about 14 the release of her letter? 15 BY MR. KLAYMAN: 16 Q this is inappropriate. Certify it. 17 MS. GILES: Because, if you're 18 going to ask about misuse of government 19 files, again I -- 20 MR. KLAYMAN: I don't want to spew 21 on the record. We spent two hours in court a 22 few weeks ago going over what was relevant 247 1 about Kathleen Willey. 2 MS. GILES: Absolutely, and we have 3 a court order. 4 MR. KLAYMAN: Okay? I'll indulge 5 you in this instance, but I don't want to get 6 into it each step of the way, but Kathleen 7 Willey's letter were obviously taken out of 8 her personnel files obviously. 9 MS. GILES: We now have a written 10 court opinion April 13th talking about what's 11 relevant in this lawsuit. FBI files matters 12 is your claim. Other potential misuse of 13 government files, then certainly those 14 topics -- 15 MR. KLAYMAN: And the order also 16 talks about the fact that discovery is that 17 which is relevant or may lead to relevant 18 evidence. 19 MS. GILES: And the judge defined 20 what was relevant. 21 MR. KLAYMAN: I'm entitled to ask 22 the question. If you want to continue to try 248 1 to interrupt my questioning, I'll continue to 2 certify. 3 MS. GILES: What is the pending 4 question? 5 BY MR. KLAYMAN: 6 Q Who in the White House gathered 7 information on Kathleen Willey? 8 A Again, no one to my knowledge was 9 collecting information on Ms. Willey. 10 Q You had an opportunity to read the 11 testimony of Stacey Parker, did you not? 12 A Yes. 13 Q And you are aware that she keeps a 14 file for Mr. Begala called opposition 15 research from reading that deposition? 16 A Having -- having read her 17 deposition, I'm aware of that, yes. 18 Q And that in that file was 19 information about Newt Gingrich, Bob Barr, 20 Fred Thompson and perhaps others? 21 A I'm not familiar with the contents 22 of the -- of the file. 249 1 Q I'm talking about from reading her 2 deposition. 3 MS. GILES: The deposition speaks 4 for itself. 5 BY MR. KLAYMAN: 6 Q You can respond. 7 Then why did you give it to him? 8 Please respond. 9 A I'm trying to answer you. I'm, 10 generally, aware that she had such a file. 11 I'm not particularly aware of what it was 12 that was -- what was in it and what wasn't in 13 it. 14 Q Have you ever talked to Stacey 15 Parker? 16 A Certainly, yeah. 17 Q When did you first meet Stacey 18 Parker? 19 A That is a gray area for me. 20 Q What do you mean by gray area? 21 A I mean I know that I know her from 22 before she started working for Paul, but I 250 1 can't exactly be clear as to when it was I 2 met her. I don't know. I can't say when I 3 met her. 4 Q Did you meet her in a professional 5 capacity or a social capacity? 6 A This is why I'm saying it's a gray 7 area, but I vaguely think that I knew who she 8 was, but I don't know where it was that I met 9 her. 10 Q Now, she's testified that she's 11 come down to your office. You saw that in 12 her deposition, did you not? 13 A Yes. 14 Q And you can confirm that she 15 visited your office? 16 A Yeah, I'm sure -- I'm sure that she 17 has. I think one occasion when she first 18 began I was in the office while she was there 19 and I -- yeah. 20 Q When she visited the office, did 21 she see you or did she come to see somebody 22 else?
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