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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