1
1 UNITED STATES DISTRICT COURT
DISTRICT OF COLUMBIA
2
-----------------------------x
3 CARA LESLIE ALEXANDER et al.,:
:
4 Plaintiffs, :
:
5 :
v. : Civil Action
6 : No. 96-2123 (RCL)
FEDERAL BUREAU OF :
7 INVESTIGATION et al., :
:
8 Defendants. :
-----------------------------x
9
Washington, D.C.
10
Wednesday, March 18, 1998
11
12 Deposition of
13 ELEANOR STACY PARKER
14 a witness, called for examination by counsel
15 for Plaintiffs pursuant to notice and
16 agreement of counsel, beginning at
17 approximately 10:16 a.m. at the offices of
18 Judicial Watch, Inc., 501 School Street S.W.,
19 Washington, D.C., before Sherry C. Knox,
20 notary public in and for the District of
21 Columbia, when were present on behalf of the
22 respective parties:
2
1 APPEARANCES:
2 On behalf of Plaintiffs:
3 LARRY KLAYMAN, ESQUIRE
Judicial Watch
4 501 School Street S.W., Suite 725
Washington, D.C. 20024
5 (202) 593-8442
6 On behalf of Government Defendants:
7 ELIZABETH J. SHAPIRO, ESQUIRE
ANNE L. WEISMAN, ESQUIRE
8 Federal Programs Branch
Civil Division
9 United States Department of Justice
901 E Street N.W.
10 Washington, D.C. 20530
(202) 514-5302
11
JON PIFER, ESQUIRE
12 Office of the General Counsel
Federal Bureau of Investigation
13 935 Pennsylvania Avenue N.W.
Washington, D.C. 20535
14 (202) 324-4522
15 SALLY PATRICIA PAXTON, ESQUIRE
Special Associate Counsel to the President
16 The White House
Washington, D.C.
17 (202) 456-5079
18 On behalf of Defendant Hillary Rodham Clinton:
19 MARCIE.R ZIEGLER, ESQUIRE
Williams & Connolly
20 725 12th Street N.W.
Washington, D.C. 20005
21 (202) 434-5803
22 * * * * *
3
1 C O N T E N T S
2 EXAMINATION BY: PAGE
3 Counsel for Plaintiffs 5
4 PARKER DEPOSITION EXHIBITS:
5 No. 1 - Judicial Watch Press Release 138
6 No. 2 - Broadcast Transcript 153
7 No. 3 - Begala Declaration 257
8 No. 4 - Notice of Begala Deposition 268
Duces Tecum, Attachments
9
No. 5 - Notice of Parker Deposition 289
10 Duces Tecum, Attachments
11 No. 6 - March 1998 Calendar 299
12 No. 7 - October 1997-April 1998 302
Calendar
13
No. 8 - Selected Investigations List 306
14
No. 9 - "Gingrich Keeps His Promise" 306
15 Report
16 No. 10 - Appointments Schedule 312
17 No. 11 - Federal Bureau of 354
Investigation (FBI) Press
18 Release
19 No. 12 - FBI General Counsel Report 355
20 No. 13 - Response to Notice of
Deposition Duces Tecum
21
22 * * * * *
4
1 P R O C E E D I N G S
2 THE VIDEO SPECIALIST: Good
3 morning. This is the video deposition of
4 Eleanor Stacy Parker taken by the counsel for
5 the plaintiff in the matter of Cara Leslie
6 Alexander et al. v. Federal Bureau of
7 Investigation et al. in the U.S. District
8 Court for the District of Columbia, Case
9 Number 96-2123 (RCL) held in the offices of
10 Judicial Watch, 501 School Street Southwest,
11 Washington, D.C., on this date, March 18,
12 1998 and at the time indicated on the video
13 screen, which is 10:16 a.m.
14 My name is Sylvanus Holley. I'm
15 the videographer. The court reporter today
16 is Sherry Knox from the firm of Beta
17 Reporting.
18 Will counsel now introduce
19 themselves?
20 MR. KLAYMAN: Larry Klayman on
21 behalf of Judicial Watch, general counsel.
22 MR. FITTON: Tom Fitton, legal
5
1 assistant, Judicial Watch.
2 MS. SHAPIRO: Elizabeth Shapiro
3 representing the witness, Executive Office of
4 the President, and the FBI.
5 MS. PAXTON: Sally Paxton with the
6 White House.
7 MS. WEISMANN: Anne Weismann
8 representing the witness.
9 MS. ZIEGLER: Marcie Ziegler
10 representing Hillary Clinton.
11 THE VIDEO SPECIALIST: Will the
12 court reporter please swear in the witness?
13 Whereupon,
14 ELEANOR STACY PARKER
15 was called as a witness and, having been
16 first duly sworn, was examined and testified
17 as follows:
18 EXAMINATION BY COUNSEL FOR PLAINTIFFS
19 BY MR. KLAYMAN:
20 Q Will you please state your name?
21 A Eleanor Stacy Parker.
22 MR. KLAYMAN: As a preliminary
6
1 matter, I just put on the record my
2 continuing objection should Ms. Paxton, on
3 behalf of White House counsel's office,
4 confer with the witness. I understand from
5 previous depositions that she will not agree
6 not to confer with the witness and the reason
7 for that is she is a material witness in this
8 case.
9 MS. SHAPIRO: We understand your
10 objection.
11 MR. KLAYMAN: Throughout the
12 deposition. Throughout the deposition.
13 MS. SHAPIRO: We understand your
14 objection, and we will not abide by it. We
15 don't agree.
16 MR. KLAYMAN: Certify this.
17 MS. SHAPIRO: Could I also for the
18 record serve you with Ms. Parker's response
19 to your document request? I'm handing a copy
20 to legal assistant.
21 MR. KLAYMAN: Do you have extra
22 copies of this or will we need to make extra
7
1 copies if we mark it as an exhibit?
2 MS. SHAPIRO: I think I have one
3 extra copy.
4 MR. KLAYMAN: Do you want a copy,
5 Ms. Ziegler, right now or would you wait
6 until the end?
7 MS. ZIEGLER: I can wait until the
8 end.
9 MR. KLAYMAN: All right. Thank
10 you.
11 BY MR. KLAYMAN:
12 Q Ms. Parker, how old are you?
13 A Twenty-three.
14 Q Where were you born?
15 A Detroit, Michigan.
16 Q Where did you go to high school?
17 A Troy High School in Troy, Michigan.
18 Q And when did you graduate?
19 A In 1992.
20 Q And what happened in 1992? Did you
21 go on to higher education or did you get a
22 job professionally?
8
1 A Are you referring to the summer or
2 the fall?
3 Q Let's say the summer.
4 A I volunteered in two different
5 places. I volunteered for Sandy Levin for
6 Congress, and I also volunteered for the
7 Oakland County Democratic party.
8 Q And what specifically did you do?
9 A I did menial intern duties for the
10 Sandy Levin campaign. I -- I assembled
11 clips. I did occasional odd tasks. It's --
12 I don't remember very well exactly what I
13 did.
14 Q How did you get the job? Did you
15 know somebody?
16 A No. I saw their office that was
17 open and I went in and said that I wanted to
18 help.
19 Q And what happened after the summer,
20 if anything? Did you go to a university or
21 did you get another job?
22 A In the fall, I began at the George
9
1 Washington University.
2 Q Here in Washington, D.C.?
3 A Correct.
4 Q And what year was that again?
5 A That was 1992.
6 Q And what did you major in at George
7 Washington?
8 A I began by majoring in
9 international affairs or relations, I don't
10 remember how they distinguish it there. And
11 in -- and then the next year, I changed my
12 major to political communication.
13 Q What year did you graduate, if at
14 all?
15 A I finished in 1996.
16 Q And what, if anything, did you do
17 in 1996 professionally speaking?
18 A When I graduated, I temped until I
19 could begin campaign work, and in August --
20 Q Who did you temp for?
21 A Help, Unlimited.
22 Q And how long did you stay there?
10
1 A I believe it was through the end of
2 August. I was waiting to get my first
3 campaign assignment.
4 Q What type of jobs did you do for
5 Help, Unlimited?
6 A Clerical and data entry jobs.
7 Q Who was your immediate supervisor
8 at Help, Unlimited?
9 A I don't remember their names.
10 Q Do you remember their first names?
11 A Not at this time.
12 Q Do you remember the names of some
13 of the companies or individuals you worked
14 for when you worked for Help, Unlimited?
15 A Environmental Defense Fund.
16 Q Was there a person there that you
17 worked for?
18 A I don't remember specifically their
19 names. I worked primarily as a receptionist,
20 and I don't remember their names.
21 Q You're aware you're under oath, are
22 you not?
11
1 A Oh, yes.
2 Q And being under oath means that you
3 have to tell everything you remember?
4 A Correct.
5 MS. SHAPIRO: Objection. She
6 doesn't need to be reminded she's under oath.
7 She took an oath when she began the
8 deposition.
9 MR. KLAYMAN: Well, the oath is a
10 very formalistic recitation of law. I just
11 wanted to make sure she understood as a
12 general sense.
13 BY MR. KLAYMAN:
14 Q You are aware that you can't forget
15 and say you forgot if in fact you remember?
16 You're aware of that?
17 A I'm aware.
18 Q Did you work for any other entities
19 or individuals other than the Environmental
20 Defense Fund?
21 A Yes, I did.
22 Q Which ones?
12
1 A Off the top of my head, I can't
2 remember.
3 Q Before your deposition today, did
4 you talk to anybody about it other than the
5 attorneys sitting at this table?
6 A Yes.
7 Q Who?
8 A I told my mother.
9 Q Who is your mother?
10 A Must I give you the name of my
11 mother?
12 Q Yes.
13 MS. SHAPIRO: I object to the
14 relevancy of her giving her mother's name.
15 BY MR. KLAYMAN:
16 Q You can respond.
17 What's her first name?
18 A Her first name is Carol.
19 Q Carol Parker?
20 A No.
21 Q And what's her name? What's her
22 last name?
13
1 MS. SHAPIRO: What's the need for
2 this? Could you just explain for the record
3 what the relevance is?
4 MR. KLAYMAN: It's obvious what the
5 need is. She may have talked to her mother
6 and given her information.
7 MS. SHAPIRO: That's not a proper
8 inquiry.
9 MR. KLAYMAN: If you want to give
10 it to the court under a protective order,
11 that's fine. I have no problem with that.
12 You can put it under the protective order.
13 MS. SHAPIRO: Do you want to seal
14 this deposition?
15 MR. KLAYMAN: No, I'm willing to
16 have the name put under protective order.
17 MS. SHAPIRO: That protective order
18 is under dispute right now.
19 MR. KLAYMAN: All right, you don't
20 want to provide the names, certify it.
21 MS. SHAPIRO: Fine.
22 MR. KLAYMAN: Is that the
14
1 instruction, not to provide the name?
2 MS. SHAPIRO: Yes.
3 BY MR. KLAYMAN:
4 Q Who else did you talk to about the
5 deposition?
6 A My father.
7 MR. KLAYMAN: Same instruction?
8 MS. SHAPIRO: Yes, unless she wants
9 to give his first name.
10 BY MR. KLAYMAN:
11 Q Do you want to give his first name?
12 A No.
13 Q All right, certify it.
14 Did you talk to anybody else?
15 A Yes.
16 Q Who else?
17 A My boyfriend.
18 Q And what's his name?
19 A Jonathan.
20 Q And what's his last name?
21 MS. SHAPIRO: Let's take a quick
22 break.
15
1 THE VIDEO SPECIALIST: We're going
2 off video record at 10:24.
3 (Recess)
4 THE VIDEO SPECIALIST: We're back
5 on video record at 10:25.
6 MS. SHAPIRO: This line of
7 questioning is improper in that you haven't
8 established what she might have talked about
9 to these people. She's willing to tell you
10 the substance of her conversations and
11 generally who they were, her mother, her
12 boyfriend, her father, but there's absolutely
13 no purpose, other than an improper purpose,
14 for her to be naming people when you haven't
15 established any relevancy or if you want to
16 put the video and the transcript under seal.
17 MR. KLAYMAN: I'm not going to put
18 the entire video and transcript under seal,
19 but as a courtesy to her, if she didn't want
20 to give us the names of her mother and
21 father, I was willing to let her do that
22 under seal.
16
1 I had asked a very simple question,
2 whether she talked to them about this
3 deposition. That is highly relevant.
4 MS. SHAPIRO: And she said yes.
5 MR. KLAYMAN: And I asked them for
6 the names.
7 MS. SHAPIRO: That's right. And I
8 think until you establish that there's
9 anything relevant that she discussed with
10 them, that their names are absolutely
11 irrelevant and improper.
12 MR. KLAYMAN: Well, I may never
13 know that if she's not being completely
14 candid here today, and that's why you need to
15 get the names of these people.
16 MS. SHAPIRO: Well, I view --
17 MR. KLAYMAN: That's a catch-22.
18 MS. SHAPIRO: I view asking for
19 these names as harassment unless you've
20 established that there is some kind of
21 substance.
22 MR. KLAYMAN: It's not harassment,
17
1 and I'll certify this whole line of inquiry,
2 and we'll go to the court on it.
3 MS. SHAPIRO: That's fine.
4 MR. KLAYMAN: This is a standard
5 type of deposition question in all civil
6 proceedings.
7 MS. SHAPIRO: That's fine.
8 MR. KLAYMAN: Who did you talk to
9 about your deposition.
10 MS. SHAPIRO: That's right, and she
11 told you and I think she's answered that
12 question. And she's willing to tell you any
13 information you want to know about the
14 substance of those conversations.
15 MR. KLAYMAN: I --
16 MS. SHAPIRO: She's not going to
17 name names when there's no relevancy that's
18 been established.
19 MR. KLAYMAN: The relevance
20 established, if she talked to them about this
21 deposition, that is the most relevant
22 question that I could have asked her.
18
1 MS. SHAPIRO: Well, you haven't
2 asked her what she said to them. How do you
3 know it's relevant?
4 MR. KLAYMAN: I will ask her that,
5 certainly, but whatever she said to them may
6 or may not be the case because then I have
7 the right to see whether from these other
8 witnesses other types of information were
9 provided. I do not take the witness on face
10 value. If that was the case, I'm sure we
11 wouldn't be here today, Ms. Shapiro.
12 MS. SHAPIRO: Well, we are --
13 MR. KLAYMAN: Because it's been
14 your position that nothing's ever happened
15 here that is in any way subject to
16 litigation. That's been your position.
17 MS. SHAPIRO: This witness has
18 taken an oath. I don't think there's any
19 point in getting into a discussion here about
20 the legality of your line of questioning. We
21 stated our objection. We view it as
22 improper, we view it as harassment. If you
19
1 want to take that to the judge, that's fine,
2 but why don't we move along?
3 MR. KLAYMAN: I view your
4 inappropriate objections as harassment.
5 BY MR. KLAYMAN:
6 Q Ms. Parker, who else did you talk
7 to about your deposition?
8 A I've told friends about my
9 depositions -- deposition, sorry.
10 Q Which friends?
11 MR. KLAYMAN: Same instruction?
12 MS. SHAPIRO: Yes.
13 MR. KLAYMAN: Certify it.
14 BY MR. KLAYMAN:
15 Q Anyone else?
16 A My grandmother.
17 MR. KLAYMAN: Same instruction?
18 MS. SHAPIRO: Yes.
19 BY MR. KLAYMAN:
20 Q Anyone else?
21 A No.
22 Q Mr. Paul Begala?
20
1 A I didn't tell him about my
2 deposition.
3 Q Did you talk to him about your
4 deposition?
5 A Yes.
6 Q Why didn't you tell me that when I
7 asked you?
8 A You asked me who I told about my
9 deposition.
10 Q How did Mr. Begala find out that
11 you were being deposed, to the best of your
12 knowledge?
13 A My -- Ms. Paxton came in and --
14 MS. SHAPIRO: I'm just going to
15 caution the witness not to reveal the
16 substance of any conversations between her
17 and Ms. Paxton.
18 THE WITNESS: Okay.
19 BY MR. KLAYMAN:
20 Q You can reveal that Ms. Paxton came
21 in.
22 A Ms. Paxton came in.
21
1 Q Came in where?
2 A Came in to our office.
3 Q When?
4 A Last week.
5 Q And at that time, did you have a
6 meeting with Mr. Begala over this deposition?
7 A No.
8 Q Did you have a meeting with
9 Ms. Paxton over this deposition?
10 A Not at that time.
11 Q What meetings did you have with
12 either Ms. Paxton or Mr. Begala about this
13 deposition?
14 A Could you repeat that question,
15 please?
16 Q What meetings did you have with
17 Ms. Paxton or Mr. Begala about your
18 deposition, meetings or conversations?
19 A I had meetings with Ms. Paxton and
20 my counsel. I had no meetings with
21 Mr. Begala regarding this.
22 Q Who is your counsel?
22
1 A Ms. Shapiro.
2 Q And when did those meetings take
3 place?
4 A On occasion over the last week.
5 Q How many?
6 A I'm not sure.
7 Q Roughly speaking?
8 A Three to six.
9 Q How many?
10 A Three to six, varying length.
11 Q And how long was each meeting?
12 A They were varying length.
13 Q Let's take the first meeting. How
14 long was that?
15 A I don't remember.
16 Q Roughly speaking.
17 A I don't remember. They all blur
18 together.
19 Q Well, how long were the meetings if
20 you added all of the three to six together,
21 roughly speaking?
22 A Under four hours.
23
1 Q And who was present at those
2 meetings besides Ms. Shapiro and Ms. Paxton?
3 A No one.
4 Q Did you ever discuss your
5 deposition with Mr. Begala?
6 A Yes.
7 Q When was that?
8 A On occasion over the last week.
9 Q When was the first such meeting?
10 MS. SHAPIRO: Objection. She
11 testified that there wasn't a meeting.
12 BY MR. KLAYMAN:
13 Q You discussed it by phone? How did
14 you discuss it with him? What was the mode?
15 What was the, the way that you made the
16 discussion with him?
17 A We were in -- we were in the
18 office, and -- and we occasionally spoke
19 about it.
20 MR. KLAYMAN: I'm going to object,
21 and please certify this. That kind of a
22 remark, giving the witness testimony, is
24
1 wholly inappropriate and sanctionable.
2 Certify it.
3 MS. SHAPIRO: I didn't give her
4 testimony. She testified, and you can read
5 it back.
6 MR. KLAYMAN: It's clear you were
7 trying to lead her in a direction which
8 wasn't even true, Ms. Shapiro.
9 MS. SHAPIRO: The record will speak
10 for itself. I only ���� her testimony.
11 MR. KLAYMAN: It will and please
12 mark this for sanctionable conduct.
13 BY MR. KLAYMAN:
14 Q How long were these discussions in
15 the office over the last week?
16 A Never longer than a minute.
17 Q And how many such discussions were
18 there?
19 A I don't know.
20 Q Roughly speaking?
21 A Less than five.
22 Q What was discussed during the first
25
1 discussion?
2 A I can't accurately answer that
3 because things that he have said to me, they
4 blur together, and I can give you a general
5 idea of what he said to me, but I can't speak
6 to each individual --
7 Q Please provide a general idea of
8 what he said to you and what you said to him,
9 if anything.
10 A He told me not to worry, he told me
11 to tell the truth.
12 Q And that required six different
13 conversations?
14 A He was trying --
15 MS. SHAPIRO: Objection. That's
16 not a question.
17 BY MR. KLAYMAN:
18 Q I'm asking you. That requires six
19 different conversations?
20 A He was trying to reassure me.
21 Q The answer calls for a yes or no.
22 MS. SHAPIRO: Objection. She
26
1 answered the question.
2 BY MR. KLAYMAN:
3 Q Please respond.
4 A He was trying to reassure me.
5 Q Are you saying that's all that was
6 discussed, six different times?
7 A He also said that we shouldn't talk
8 about this.
9 Q Talk about what?
10 A Talk about the deposition.
11 Q Did he say anything else?
12 A Not to the best of my recollection.
13 Q And what did you say?
14 A I said okay.
15 Q You said okay six different times?
16 A Yes.
17 Q So it was the same conversation six
18 different times?
19 A To the best of my recollection.
20 Q Did you ask him any questions
21 during these conversations?
22 A No, he made it very clear that we
27
1 weren't to talk about the deposition.
2 Q He made it clear that you were to
3 talk about it only with Ms. Paxton and
4 Ms. Shapiro?
5 A He reminded me that those
6 conversations were privileged.
7 Q He told you that the conversations
8 with Ms. Paxton and Ms. Shapiro were
9 privileged?
10 A Yes.
11 Q How did that come up?
12 A I don't remember.
13 Q So now you're adding something
14 different than what you previously told me.
15 It wasn't just tell the truth and it will be
16 okay. It was the conversations you have with
17 Ms. Shapiro and Ms. Paxton are privileged?
18 A It was also part of we should not
19 talk about this deposition.
20 Q And Mr. Begala told you I'll give
21 my information to Ms. Paxton and Ms. Shapiro
22 and they'll tell you what I have to say?
28
1 A He did not say that.
2 MS. SHAPIRO: Objection.
3 BY MR. KLAYMAN:
4 Q Did you understand that to be the
5 case?
6 A Could you repeat that?
7 Q Did understand that to be the case?
8 A Understand what to be the case?
9 Q That that's the way it was going to
10 work, that Mr. Begala would relay what he
11 wanted to say to you through Ms. Paxton and
12 Ms. Shapiro?
13 A There was -- he did not insinuate
14 that, he did not say that, I did not
15 understand that.
16 Q Have you had an opportunity to
17 review Mr. Begala's deposition transcript?
18 A Yes, I have.
19 Q How many times?
20 A Once.
21 Q Did you go over it carefully with
22 Ms. Shapiro and Ms. Paxton?
29
1 MS. SHAPIRO: Objection.
2 BY MR. KLAYMAN:
3 Q You can respond.
4 MS. SHAPIRO: No, she can't
5 respond.
6 MR. KLAYMAN: Whether she went over
7 the deposition with you?
8 MS. SHAPIRO: If she went over it
9 with us, she cannot respond.
10 MR. KLAYMAN: I'm not asking her
11 about any communications between you, just
12 whether she went over a document with you,
13 which is a public document.
14 MS. SHAPIRO: She can't respond
15 about what we did during privileged
16 conversations.
17 MR. KLAYMAN: Certify it.
18 You're on notice. Every time you
19 take this kind of a stance, we will include
20 this for a motion for sanctions.
21 MS. SHAPIRO: I object to your
22 constant threatening of me.
30
1 MR. KLAYMAN: I'm just putting you
2 on notice so the next time you do it you'll
3 do it with an intent.
4 MS. SHAPIRO: I'm just asserting
5 privileges and objections pursuant to the
6 rules.
7 And let me say, once again, as I've
8 said every time we have been in deposition
9 together, that you persistently talk over me.
10 Would you please give me the courtesy of
11 finishing what I have to say and then you can
12 speak?
13 MR. KLAYMAN: I don't need those
14 kinds of lectures, Ms. Shapiro. It's not my
15 intention to talk over you. The fact is you
16 keep making the objection beyond that which I
17 think is a conclusion, so I'm happy to have
18 you speak on the record, but I don't need
19 lectures. And I am telling you that we will
20 move for sanctions, and I want you to have
21 this in your knowledge when you do it again.
22 MS. SHAPIRO: And I would keep the
31
1 same in mind for yourself, Mr. Klayman.
2 MR. KLAYMAN:
3 Q Ms. Parker, what did you talk about
4 with your mother about this deposition?
5 A I told her I had been subpoenaed,
6 that I was called for a deposition today. I
7 explained to her that Mr. Begala had also
8 been subpoenaed and called to deposition. I
9 asked her if she remembered the FBI file
10 problems in order to contextualize what was
11 -- this whole situation.
12 Q Did she tell you anything?
13 A She expressed shock, surprise,
14 anger, and told me to tell the truth --
15 Q Why was she angry? Did she express
16 that?
17 A She was angry because her daughter
18 was being subpoenaed.
19 Q What did you tell her about the
20 subject of your testimony today that got her
21 angry?
22 MS. SHAPIRO: Objection.
32
1 BY MR. KLAYMAN:
2 Q If anything?
3 MS. SHAPIRO: Mischaracterizes her
4 testimony.
5 BY MR. KLAYMAN:
6 Q If anything, if anything?
7 A She was angry about the process,
8 and she did not understand why I was being
9 subpoenaed.
10 Q Did you tell her because you work
11 for Mr. Begala and helped in document
12 collection?
13 A Yes, I did.
14 Q And she still expressed anger?
15 A Yes, she did.
16 Q Now, you understand why you've been
17 asked to testify, don't you?
18 A In a cursory way.
19 Q You are aware that Mr. Begala
20 testified that you helped him produce the
21 documents that Judicial Watch requested?
22 A I'm aware.
33
1 Q And you understand that's a
2 legitimate line of questioning, is it not?
3 MS. SHAPIRO: Objection. That
4 calls for a legal conclusion.
5 BY MR. KLAYMAN:
6 Q Do you take it as legitimate?
7 A I don't want to judge a legitimacy.
8 Q Do you resent being called here
9 today?
10 A Not yet.
11 Q Did you resent it before?
12 MS. SHAPIRO: Objection as to
13 relevancy.
14 BY MR. KLAYMAN:
15 Q Before you actually came into this
16 room?
17 A No.
18 Q Did you say anything else to your
19 mother or did she say anything else to you?
20 A Not that I can remember.
21 Q What was discussed with your
22 boyfriend about this deposition?
34
1 A I told him that I had been
2 subpoenaed and called to deposition.
3 Q Did you tell him why you thought
4 you were being called to deposition?
5 A Yes.
6 Q And what did you tell him in that
7 regard?
8 A I told -- I tried to explain to him
9 what little I know about the FBI files
10 matter. I told him that my boss had been
11 subpoenaed and called to deposition, and I
12 told him that they probably wanted me to come
13 in because of questions regarding the office.
14 Q The little that you knew about the
15 FBI file matter, where did you obtain that
16 information?
17 A News clippings.
18 Q Who gave you the news clippings?
19 A I barely remember reading them in
20 the summer of '96.
21 Q Was that information that your
22 mother provided to you? Did you talk to her
35
1 before your boyfriend.
2 A There was two parts to that
3 question. Which do you want me to answer?
4 Q Did you talk to your mother before
5 you talked to your boyfriend?
6 A Yes, I did.
7 Q And was the information relayed to
8 your boyfriend about filegate, was your
9 mother told you about it or did you get it
10 from another source?
11 A You have to repeat the last part of
12 that question.
13 Q What you related to your --
14 MS. SHAPIRO: Objection. That's a
15 completely vague question.
16 BY MR. KLAYMAN:
17 Q What you said to your boyfriend
18 about filegate, did you get that information
19 from your mother or did you also get it from
20 other sources?
21 A First of all, I don't appreciate
22 the characterization of this problem as
36
1 filegate. Second of all, my mother did not
2 give me any information.
3 Q Why don't you appreciate the
4 characterization as filegate?
5 A I don't understand what it means.
6 Q I don't understand what you mean.
7 What do you mean, you don't appreciate the
8 characterization? You sounded quite
9 indignant there. Is it your position that
10 the Clinton administration is being unfairly
11 questioned about this matter?
12 A I don't have a position on this.
13 Q Have you been told that this case
14 is frivolous and has no merit by anybody in
15 the Clinton administration in the White
16 House?
17 A No, I have not.
18 Q Has Mr. Begala told you that?
19 A He's not said that.
20 Q I'm going to call it filegate
21 because that's what everybody calls it, so
22 that's the definition for this case,
37
1 filegate.
2 A Okay.
3 Q And has Mr. Begala ever talked to
4 you about filegate?
5 A You must define "filegate."
6 Q The transfer of FBI files from the
7 FBI to the White House about Republican
8 employees of the White House during this
9 administration.
10 A Mr. Begala has never mentioned
11 anything regarding what you just said -- what
12 you just said.
13 Q So tell me what you said to your
14 boyfriend about filegate.
15 A I didn't mention anything about
16 filegate. I said that there had been some
17 problems -- or there allegedly had been some
18 problems with -- with people's FBI files
19 being read, and, therefore, there was -- I
20 understood that this organization Judicial
21 Watch had a suit against the federal
22 government regarding it and Paul had made a
38
1 joke regarding it and therefore he had been
2 subpoenaed.
3 Q Where had you learned that
4 information, that Paul had been, I take it,
5 Paul Begala, had been subpoenaed because he
6 made a joke?
7 A We received a press release.
8 Q Did you get that from any place
9 else?
10 A Did I get what from any place else?
11 Q That information?
12 A I was first made aware when someone
13 made me aware of the press release.
14 Q Who made you aware of the press
15 release?
16 A Someone in our research office.
17 Q Who is that?
18 A I don't remember.
19 Q A man or a woman?
20 A A man.
21 Q Who was in your research office?
22 Who works there?
39
1 A I don't know all the employees at
2 the research office.
3 Q Well, tell me the ones you know.
4 A Tom Janenda and Glen Wiener.
5 Q Do you know what his job title is?
6 A No, I do not.
7 Q And what's the other fellow's name?
8 A Glen Wiener. I believe it's W-e-i
9 or -- I don't know the spelling.
10 Q W-e-i-n-e-r?
11 A I believe so, but I'm not sure.
12 Q Who else works in that press
13 office, in that research office?
14 A Those are the only two people I'm
15 aware of who work at the office.
16 Q And the research office, is that
17 part of a bigger part of the communications
18 department?
19 A I don't know where it's -- where it
20 fits in the organization.
21 Q But it works with Mr. Begala,
22 correct?
40
1 A How would you define "working
2 with"?
3 Q Works under his direction?
4 A No.
5 Q Whose direction does it work under?
6 A I don't know. I don't know where
7 it fits in the organization.
8 Q Where is it located?
9 A It's in the Old Executive Office
10 Building.
11 Q Is it close to your office?
12 A How do you define "close"?
13 Q Near.
14 A I mean, it's all relative. You
15 have to better define "near."
16 Q Well, let's go with yards, how many
17 yards away --
18 A I don't know how many yards.
19 Q Roughly speaking? Is it on the
20 same hallway?
21 A No.
22 Q Where is it located?
41
1 A It's on the first floor of the Old
2 Executive Office Building.
3 Q What's the room number?
4 A I don't know.
5 Q What's your room number?
6 A 147.
7 Q Do you have to take a stairwell to
8 get down to the research office?
9 A No.
10 Q So you're on the first floor, too?
11 A Correct.
12 Q So how far away is it, roughly
13 speaking?
14 A I don't know how many yards, but if
15 I were walking it would take me about a
16 minute.
17 Q And how many people are there in
18 the research office?
19 A I don't know.
20 Q Roughly speaking?
21 A I don't know.
22 Q I'm not trying in any way to be
42
1 critical here, but we can make this
2 deposition, we can move it along faster if
3 you try to answer my questions as best you
4 can. I'm not going to hold you to exact
5 precision?
6 MS. SHAPIRO: Objection. She's
7 answered the best she can.
8 BY MR. KLAYMAN:
9 Q Otherwise, I'll ask the questions
10 sometimes three or four different ways.
11 Sometimes doing that I've gotten an answer.
12 Now, that can make this a very long process?
13 A I understand.
14 Q And it will be my position,
15 Ms. Parker, that if it becomes a long process
16 that we will ask the Court for permission to
17 bring you back again. So I ask you if you
18 will move this along as quickly as possible?
19 MS. SHAPIRO: Objection to trying
20 to intimidate the witness. She's answering
21 fully.
22 MR. KLAYMAN: I'm not trying to
43
1 intimidate her. I'm trying to get this thing
2 to move along.
3 MS. SHAPIRO: If you can ask more
4 precise questions, maybe it will move along
5 faster or maybe relevant questions.
6 MR. KLAYMAN: Certify this,
7 improper remark.
8 BY MR. KLAYMAN:
9 Q Ms. Parker, how many people
10 approximately have you met from that office?
11 A I've only met two people and they
12 are the people that I have already stated.
13 Q I'm sorry, I didn't understand.
14 MS. SHAPIRO: Could you read the
15 record back then, please?
16 MR. KLAYMAN: No, please answer the
17 question.
18 MS. SHAPIRO: She answered the
19 question. Please ask her another question.
20 MR. KLAYMAN: Do you want to read
21 the record back, that's fine. I'm going to
22 take my time, Ms. Shapiro.
44
1 MS. SHAPIRO: That's fine.
2 (The reporter read the record as
3 requested.)
4 BY MR. KLAYMAN:
5 Q Have you talked to anybody in the
6 White House or elsewhere about this research
7 office?
8 A Could you please be more specific?
9 Q I don't want to be more specific.
10 I'm just asking you a general question.
11 A I've never spoken in general terms
12 about the office before.
13 Q How did you find out there was even
14 a research office?
15 A I know that Paul works with Tom and
16 Glen, and sometimes when we need things I can
17 turn to them for help, so if I need a
18 particular clipping or if -- I understand
19 them as a place that, if I'm looking for
20 something in the public record, they can help
21 me find.
22 Q Who told you that, that that's a
45
1 place where, if you need something in the
2 public record, you can look to them?
3 A It's something that I figured out.
4 Q How did you figure that out?
5 A I don't know the exact way that I
6 figured it out. I know that Tom and Glen
7 would bring things to Paul and so I figured
8 out that if they would bring things to Paul
9 that I could ask them when I needed things.
10 I don't remember the exact thought process,
11 but I just -- I figured out that they could
12 help out.
13 Q You've had a conversation with
14 Mr. Begala, have you not, about what Tom and
15 Glen do?
16 A No.
17 Q You've had a conversation with
18 others about what Tom and Glen do?
19 A No.
20 Q You've been to their office, Tom
21 and Glen's, haven't you? That's how you know
22 it only takes only a minute to walk there?
46
1 A Yes, I have.
2 Q Because you have taken things to
3 them from Paul Begala and others?
4 A No, I've borrowed books.
5 Q What books have you borrowed?
6 A I remember borrowing a
7 Congressional directory and I believe I
8 borrowed -- I believe I borrowed some sort of
9 dictionary at one time.
10 Q Have you seen the layout of that
11 office? I take it you have when you've
12 walked in?
13 A Yes, I have.
14 Q How many offices are there?
15 A I'm happy to try -- well, see, it
16 would be guessing and the problem is walking
17 in there I don't know that in that whole
18 suite it's all research. I just know where
19 Glen and Tom visibly sit.
20 Q Well, you allowed to guess?
21 A Well, I don't want to guess.
22 Q Well, I want a general idea. This
47
1 is subject to discovery and discovery allows
2 me to get some information that may lead me
3 to other information; so, roughly speaking,
4 how many offices are there?
5 MS. SHAPIRO: I object to the
6 extent that you are asking her about things
7 that she has no knowledge of. She's not
8 required to guess.
9 MR. KLAYMAN: Certify this. It's
10 inappropriate to tell witness they have no
11 knowledge of things when clearly they're
12 testifying about it. Certify, improper
13 conduct.
14 THE WITNESS: I only know about Tom
15 and Glen. I know that they have two offices.
16 I don't know who else sits in the offices
17 next to theirs. I don't know if they are in
18 the research department. I don't know who
19 they are, what they do, so I can't speak to
20 it.
21 BY MR. KLAYMAN:
22 Q My question was what offices are in
48
1 and around Tom and Glen's offices?
2 A I don't know.
3 MS. SHAPIRO: Asked and answered.
4 BY MR. KLAYMAN:
5 Q Roughly, there are offices in
6 addition to theirs, aren't there, down there?
7 A I'm sorry.
8 Q There are offices in addition to
9 Tom and Glen's down in that area of the EOB,
10 correct?
11 A Yes, there are.
12 Q And there's more than one office,
13 correct?
14 A Yes, there are.
15 Q There's more than two offices,
16 correct?
17 A I'm not sure.
18 Q There are secretaries or assistants
19 sitting in that office, are there not, in
20 that suite of offices?
21 A Not necessarily.
22 Q There are computers in that office,
49
1 correct?
2 A Yes.
3 Q You previously testified that you
4 know that Paul uses them, Paul meaning
5 Begala, for public record stuff, right?
6 A Correct.
7 Q What did you mean by "public
8 record"?
9 A Records that are publicly
10 available.
11 Q How do you define whether records
12 are publicly available?
13 A I don't have an exhaustive
14 definition for that. I know what I'm usually
15 looking for. Usually it's news clippings or
16 votes or trying to find when -- if someone
17 said something in an interview, you know,
18 anything that we can find in the paper or
19 find in the Congressional Record.
20 Q Before your deposition today in the
21 context of preparing for this deposition, you
22 did discuss the phrase "public record" with
50
1 someone, didn't you?
2 A I don't believe I've ever discussed
3 public record with anyone.
4 Q Did you discuss what's meant by
5 public document?
6 A I understand what a public document
7 is.
8 Q How did you learn that?
9 A Well, over my years of studying
10 political science, I somehow have come up
11 with the answer.
12 Q Was there a course on what's a
13 public record?
14 A If there was, I didn't take it.
15 Q Have you ever read government
16 manuals to define what's a public record as
17 opposed to what's a private record?
18 A No, I have not.
19 Q Or confidential record?
20 A No, I have not.
21 Q Has anyone ever given you
22 instructions in the context of your job at