51


       1    the White House or anywhere else defining

       2    what's a public record, a private record or a

       3    confidential or a classified document?

       4         A    Yes.

       5         Q    Who?

       6         A    Actually, no, I have not been

       7    instructed on the differences between those

       8    types of documents.

       9         Q    So, therefore, you really don't

      10    know, legally speaking, what a public

      11    document is?

      12         A    You're right, I probably don't know

      13    the legal exact definition of a public

      14    document.

      15              MS. SHAPIRO:  Objection.  It calls

      16    for a legal conclusion.

      17              MR. KLAYMAN:  Improper objection.

      18    Certify it.

      19              BY MR. KLAYMAN:

      20         Q    This research office.  Have you

      21    ever seen it listed on any kind of chart, a

      22    White House chart organogram, something like








                                                              52


       1    that?

       2         A    No, I have not.

       3         Q    Do you have access in the course of

       4    your duties in working with Mr. Begala to a

       5    telephone directory?

       6         A    Yes, I do.

       7         Q    And Tom and Glen's name would be

       8    found on that telephone directory?  You've

       9    seen it there?

      10         A    I have never personally seen their

      11    names in the personnel directory.

      12         Q    Do you have a Rolodex?

      13         A    No, I do not.

      14         Q    You've called down there, haven't

      15    you?

      16         A    Yes, I have.

      17         Q    Where did you get the number or the

      18    extensions so you'd know where to call?

      19         A    From Mr. Janenda.  There is a

      20    shared sheet that some assistants use that

      21    have commonly used phone numbers organized by

      22    name.  I have -- I have picked up his number








                                                              53


       1    from that sheet.  For Glen -- Glen personally

       2    gave me his phone number.

       3         Q    And you have that sheet?

       4         A    Yes, I do.  Not on me, but it's at

       5    work.

       6         Q    And that sheet lists the various

       7    offices by subject matter and then it has the

       8    names of the persons and the phone numbers?

       9         A    No, it does not.  It's only names

      10    and phone numbers and where people sit.

      11         Q    Who gave you that sheet?

      12         A    Deman Martin.

      13         Q    Who is Deman Martin.

      14         A    I don't know his exact title, but

      15    he works in the chief of staff's office.

      16         Q    Mr. Erskine Bowles' office?

      17         A    Right.

      18         Q    And why did he give you that sheet?

      19         A    Because I asked for it.

      20         Q    Did someone ask you to ask for it?

      21         A    No.

      22         Q    Why did you ask for it?








                                                              54


       1         A    Because there was -- it was

       2    something that would help me out in my daily

       3    duties.

       4         Q    And that's because you have quite a

       5    good deal contact with this research office,

       6    correct?

       7         A    No.

       8         Q    But you do have frequent contact

       9    with that office, do you not?

      10         A    I have occasional contact.

      11         Q    How do you define "occasional"?

      12         A    That it varies.

      13         Q    Once a day?

      14         A    There's nothing rhythmic about it.

      15    It varies.  Sometimes a couple times a day,

      16    sometimes not for a week.

      17         Q    Now have you ever contacted or had

      18    any dealings with the research office at the

      19    request of Mr. Begala?

      20         A    Yes, I have.

      21         Q    And that's frequent?

      22         A    It varies, but it is now less








                                                              55


       1    frequent.

       2         Q    When did it become less frequent?

       3         A    When I got Lexis/Nexis on my

       4    computer.

       5         Q    When was that?

       6         A    I think -- I'd have to guess, but I

       7    think three to four weeks ago.

       8         Q    Was there a reason why you got

       9    Lexis/Nexis on your computer?  Did anyone

      10    tell you why you got it?

      11         A    I asked for it.

      12         Q    And why was that?

      13         A    So I wouldn't have to bother the

      14    people in research all the time when I could

      15    easily retrieve something myself.

      16         Q    Who did you ask to get that?

      17         A    First I ran it by Jayson Goldberg

      18    in the chief of staff's office.

      19         Q    Who is Jayson Goldberg?

      20         A    I don't know his exact title.  He

      21    assists the chief of staff.

      22         Q    Did Mr. Begala ask you to run it by








                                                              56


       1    him?

       2         A    No.

       3         Q    And then what happened?

       4         A    He told me to submit a request to

       5    Betty 컴컴.  I don't know how to say her last

       6    name.  She, she works in Room 1, which is our

       7    administrative office.

       8         Q    Who is Betty 컴컴?

       9         A    I don't know her exact title.  I

      10    just know that when we're looking for

      11    subscriptions that she is a person that we

      12    run things by for -- to have things approved.

      13         Q    Anyone else?

      14         A    That's it.

      15         Q    Where is your office situated in

      16    comparison with Mr. Begala's office?

      17         A    We share an office.

      18         Q    You're in his office?

      19         A    Correct.

      20         Q    He has a desk in his office and you

      21    have a desk in his office?

      22         A    Correct.








                                                              57


       1         Q    So you can hear all of his

       2    telephone conversations?

       3         A    Theoretically.

       4         Q    You don't put ear plugs in, do you?

       5         A    No, but I do my best to block him

       6    out.

       7         Q    And do you have a desk in that

       8    office?

       9         A    Correct.

      10         Q    And does he have a desk in that

      11    office?

      12              MS. SHAPIRO:  Asked and answered.

      13              BY MR. KLAYMAN:

      14         Q    You can respond.

      15         A    Yes.

      16         Q    And what else is located in that

      17    office?

      18         A    You want to know about the

      19    furniture?

      20         Q    Yes, and the file cabinets.

      21         A    Okay.

      22         Q    I don't care about clocks.  I don't








                                                              58


       1    care about paper clips, I don't care about

       2    blotters or pictures on the walls unless the

       3    eyes move, but I just care about what you

       4    have that can store documents.

       5         A    I have a drawer in my desk that can

       6    store documents and I have a desk behind my

       7    desk that I put some documents in.  There are

       8    some file folders on his desk that I put

       9    there, and there's some file folders on my

      10    desk that hold -- that hold files.

      11         Q    Are there any lateral cabinets,

      12    file cabinets?

      13         A    No.

      14         Q    Is there a fax machine in that

      15    office?

      16         A    Yes, there is.

      17         Q    One or more?

      18         A    One.

      19         Q    Who operates the fax machine?

      20         A    Primarily me but on occasion Paul.

      21         Q    I take it there is a fax log so you

      22    can record outgoing and ingoing faxes.








                                                              59


       1         A    No, there's not.

       2         Q    Is there any way to record outgoing

       3    and ingoing faxes?

       4         A    I imagine if one wanted to write it

       5    down they could, but I haven't done that.

       6         Q    Well, the fax machine spits out a

       7    listing of the faxes that have been sent,

       8    correct?

       9         A    But I toss it.  I throw it out.

      10         Q    Where do you throw it?

      11         A    In the garbage.

      12         Q    I take it that the office has a

      13    shredder, a document shredder?

      14         A    No, it does not.

      15         Q    Have you ever shredded documents?

      16         A    No, I have no.

      17         Q    Have you ever been asked to shed

      18    documents?

      19         A    No, I have not.

      20         Q    Do you know if Mr. Begala shredded

      21    documents?

      22         A    I have no reason to believe that he








                                                              60


       1    has shredded documents.

       2         Q    Does Mr. Begala keep a desk

       3    calendar that he writes into?

       4         A    No, he does not.

       5         Q    Do you keep a desk calendar you

       6    write into?

       7         A    No, I do not.

       8         Q    Do you keep a note pad on your desk

       9    generally?  I take it you do.

      10         A    Yes, but I'm not systematic in

      11    which note pad I write things in.

      12         Q    And Mr. Begala keep a note pad on

      13    his desk, doesn't he?

      14         A    He has a couple of pads that --

      15    it's not something that's a staple to his

      16    desk.  It's something that he uses for

      17    occasional notes.

      18         Q    What type of a device is it?

      19         A    What are you referring to?

      20         Q    The note pad.  Is it a yellow note

      21    pad like a legal pad?

      22         A    Are you talking about my desk or








                                                              61


       1    Paul's?

       2         Q    Paul's.

       3         A    Sometimes he use a legal pad,

       4    sometimes a White House pad, sometimes

       5    stickies.  That's all I'm aware of?

       6         Q    Are you the one who's responsible

       7    for filing documents in the office that you

       8    share with Mr. Begala?

       9         A    Yes, I am.

      10         Q    And you have, of course, file

      11    documents that you yourself create, right?

      12         A    Correct, but they are very few.

      13         Q    And you file documents that

      14    Mr. Begala receives or creates, correct?

      15         A    Primarily.

      16         Q    And is it Mr. Begala's given you

      17    the instruction on how to do the filings?  I

      18    take it it is?

      19         A    No, no he has not.

      20         Q    How do you know how to make

      21    filings, where to file things, what to file,

      22    et cetera?  What, if anything, to throw away?








                                                              62


       1    Are you been given any instructions in these

       2    regards?

       3              MS. SHAPIRO:  Objection.  Compound

       4    question.

       5              MR. KLAYMAN:  It's a legitimate

       6    compound question.

       7              BY MR. KLAYMAN:

       8         Q    Well, I want whether you have had

       9    any instructions on how to do filings and

      10    where to store documents and other things?

      11         A    Paul prefer that we not keep things

      12    that we don't need.  I make the decision as

      13    to whether -- well, usually I make the

      14    decision as to whether we should keep

      15    something, and I make that decision based on

      16    whether I think he will need it again in the

      17    future unless he specifically asked me to

      18    file something under X or Y.

      19         Q    Is there a listing of all the files

      20    that you keep?

      21         A    No, uh-uh.

      22         Q    I take it there is an organization








                                                              63


       1    for how you have done filings in the office,

       2    correct?  There is a system?

       3         A    Yes and no.  Sometimes I have a

       4    little bit of a system.  Sometimes I just

       5    place things where I think I can find them

       6    easily.

       7         Q    Tell me what the system is.

       8         A    Well, in my one drawer, I actually

       9    have things in alphabetical order and the

      10    place that -- on my file folders on my desk,

      11    it's a matter of where I think -- where I

      12    remember where I put it.  I don't have a

      13    systematic order.  It's something I just kind

      14    of put there for my pleasure.  Where I put

      15    files in the desk behind me, I just place

      16    them there.  I don't have any kind of order,

      17    any kind of system, it's just to keep them

      18    there until we need them or don't need them.

      19         Q    Do you file computer disks?  Do you

      20    and Paul use computer disks?

      21         A    No.

      22         Q    Paul has a computer, correct?








                                                              64


       1         A    Yes, he does.  I needed to make a

       2    correction.  I do have one disk.

       3         Q    Paul has a computer correct?

       4         A    Yes, he does.

       5         Q    And you've seen him use the

       6    computer, have you?

       7         A    Yes, I have.

       8         Q    And he uses the computer fairly

       9    routinely, does he not?

      10         A    Yes, he does.

      11         Q    In fact, he's a pretty good typist,

      12    isn't he?

      13         A    I'm not one to judge typing

      14    ability.

      15         Q    But he knows how to type?

      16         A    Yes, he does.

      17         Q    And he knows how to operate the

      18    computer?

      19         A    Yes, he does.

      20         Q    And he uses the computer sometimes

      21    for e-mail, doesn't he?

      22         A    On occasion.








                                                              65


       1         Q    And he uses the computer to do

       2    memoranda?

       3         A    Yes.

       4         Q    And he uses the computer to make

       5    correspondence, letters?

       6         A    On rare occasion.

       7         Q    And he uses the computer to go into

       8    Internet?

       9         A    Yes.

      10         Q    And does he have Lexis us on his

      11    computer?

      12         A    No.

      13         Q    You have Lexis on your computer?

      14         A    Yes.

      15         Q    And you know how to do all the

      16    things that I just described that Paul can

      17    do?

      18         A    Yes.

      19         Q    When Paul creates a document on

      20    that computer and wants to print it out, how

      21    is that done?

      22         A    He creates a document and prints it








                                                              66


       1    out.

       2         Q    Does he have his own printer?

       3         A    We share a printer.

       4         Q    Both computers are hooked into the

       5    same printer?

       6         A    Correct.

       7         Q    Say he's creating a letter.  Who

       8    would put the letter on letterhead, make

       9    photocopies and mail it?  Who would process

      10    the letter?

      11         A    He would print it out.  He would

      12    put the letterhead in the printer and he

      13    would print it out.  I would make the copies

      14    for records management and put those copies

      15    in the -- our records management bin and mail

      16    it out.

      17         Q    Is there a postage meter in your

      18    office?

      19         A    No.

      20         Q    How is mailing handled?  How do you

      21    get postage on the envelope?

      22         A    We have a mail service.  I don't








                                                              67


       1    know a whole lot about it.  We have a mail

       2    person that comes in and delivers mail and

       3    takes mail, and they take our letters and

       4    they take care of the postage unless it's

       5    personal.  If it's personal, then you have to

       6    put a stamp on it.

       7         Q    I take it there is a postage log or

       8    at least a mail log in your office so you

       9    know what went out?

      10         A    No, there is not.

      11         Q    So the way you know what went out

      12    is by keeping copies of what went out?

      13         A    For official, official mail going

      14    out, yes.

      15         Q    And you're the one who's in charge

      16    in making those copies to send to records

      17    management?

      18         A    Uh-huh.

      19         Q    How do you determine whether

      20    something is official or not official so that

      21    you can make a copy of it?

      22         A    Paul makes that determination.








                                                              68


       1         Q    He tells you what he wants copied

       2    and what shouldn't be copied?

       3         A    If something is sealed and with a

       4    stamp, I know it's personal.

       5         Q    As his definition describes?

       6         A    I don't know what definition he

       7    uses, but I trust his definition.

       8         Q    I take it that he keeps copies of

       9    things that are personal?

      10         A    I'm not aware of that.

      11         Q    You're not aware of the contrary,

      12    are you?  You don't know that he doesn't keep

      13    documents?

      14         A    I've never seen him make a copy of

      15    a personal letter.

      16         Q    Is there a photocopier in your

      17    office?

      18         A    No.

      19         Q    Where do you go to make

      20    photocopies?

      21         A    Right now, I would go around the

      22    corner and use a shared copier.  I don't know








                                                              69


       1    in which department that copier is, but a lot

       2    of people use it.

       3         Q    Does Paul have any computer disks

       4    that he has used since you've been working

       5    for him?

       6         A    Not that I'm aware of.

       7         Q    Does he put everything on hard

       8    drive?

       9         A    I don't know.  I could reason that,

      10    but I don't know.

      11         Q    I take it that there is a backup, a

      12    computer backup, in the White House that

      13    these documents are stored in a central

      14    system as well that are created?

      15         A    I don't understand how the back --

      16    the backup works.

      17         Q    But you know there is one?

      18         A    I get little, you know -- I really

      19    don't know anything about the time backup.  I

      20    don't know how any of that stuff works.

      21         Q    You said "little."  What's the

      22    little stuff you get?  Little memoranda about








                                                              70


       1    how it works?

       2         A    No, on the computer, sometimes it

       3    says -- I don't even know.  Like, I think

       4    I've seen the words "timed backup," but that

       5    is something I completely do not understand

       6    about a computer system.

       7         Q    But it's been your impression that

       8    it's somehow getting recorded on some central

       9    recordation system?

      10         A    It may be.

      11         Q    Do you send e-mail?

      12         A    Yes, I do.

      13         Q    Inside the White House?

      14         A    Yes, I do.

      15         Q    Do you send e-mail outside of the

      16    White House?

      17         A    On occasion.

      18         Q    Who have you sent e-mail for

      19    outside of the White House, to, who have you

      20    sent e-mail to outside of the White House?

      21         A    Regarding?

      22         Q    Anything.








                                                              71


       1         A    My friends.

       2         Q    Have you sent an e-mail regarding

       3    your business outside of the White House?

       4         A    Excuse me?

       5         Q    Have you sent any e-mail concerning

       6    your government business outside of the White

       7    House?  On government matters?

       8         A    No, not that I'm aware of.

       9         Q    Has anyone ever advised you whether

      10    it's appropriate to be doing your own

      11    personal e-mail on White House computers?

      12         A    When I signed the

      13    telecommunications agreement it was my

      14    understanding there was a clause saying that

      15    on occasion e-mail could be used for personal

      16    uses.  That is my understanding of the

      17    agreement.

      18         Q    And other people in the White House

      19    do this from time to time?  They send

      20    personal e-mail on White House computers?

      21         A    I can't speak for other people.

      22         Q    But have you talked to other people








                                                              72


       1    that have done it?

       2         A    Yes.

       3              MR. KLAYMAN:  Let the record

       4    reflect two counsel are laughing.  I don't

       5    think it's funny.

       6              MS. SHAPIRO:  I'm laughing because

       7    somebody's stomach rumbled very loudly, and I

       8    was trying to figure out if it was the court

       9    reporter or the witness, if you really need

      10    to know.

      11              BY MR. KLAYMAN:

      12         Q    Now, is your office in a suite of

      13    offices, your and Paul's office?

      14         A    It is not a suite.

      15         Q    Well, how is it configured?

      16         A    It is one room.  You walk in, it's

      17    one room.

      18         Q    There are other people in the room

      19    besides you and Paul.

      20         A    Only when they visit.

      21         Q    And what larger configuration is

      22    your office a part of?  Is it part of a








                                                              73


       1    department in the White House, a section?

       2         A    We're in the Old Executive Office

       3    Building on the first floor.

       4         Q    Right.  But what's the name of the

       5    overall office that you both are working for?

       6         A    We both work in the chief of

       7    staff's office; however, our room assignment

       8    does not reflect that.

       9         Q    What's Paul's title?

      10         A    He's assistant to the -- assistant

      11    to the President and counsel to the

      12    President, I believe.

      13         Q    And how far is the chief of staff's

      14    office?  Right next door?

      15         A    Where our chief of staff actually

      16    sits and works?

      17         Q    Yes.

      18         A    No, it's not right next door.  You

      19    have to walk through the Old Executive Office

      20    Building, go across West Executive Drive and

      21    into the West Wing, go up to the first floor

      22    and that is where he sits.








                                                              74


       1         Q    But are there other people on the

       2    chief of staff's staff that work in the

       3    vicinity of your and Paul's office?

       4         A    Can you further define "vicinity"?

       5         Q    Near, close to.

       6         A    In the offices that surround us,

       7    there is no one else from the chief of

       8    staff's office that I'm aware of.

       9         Q    Does Sidney Blumenthal work for the

      10    chief of staff's office?

      11         A    I'm not 100 percent sure which

      12    department he's technically in.

      13         Q    Is it your understanding that he

      14    works for the chief of staff?

      15         A    No, it is not.

      16         Q    What is your understanding he works

      17    for?

      18         A    Communications.

      19         Q    Same question with regard to Ann

      20    Lewis.

      21         A    Communications.

      22         Q    Rahm Emanuel?








                                                              75


       1         A    Chief of staff's office.

       2         Q    What's his job title in the chief

       3    of staff's office?

       4         A    I don't know for sure.  I believe

       5    it's senior advisor to the President of

       6    policy and strategy.

       7         Q    Mike McCurry?

       8         A    I understand him to be the press

       9    secretary.  I don't know what his exact title

      10    is.

      11         Q    Does that mean he's the head of the

      12    communications office?

      13         A    I don't understand him to be.

      14         Q    These communications people we've

      15    just described, are they located close to

      16    your and Paul's office?

      17         A    No, they are not.

      18         Q    Where are they located?

      19         A    In the West Wing.

      20         Q    Do you and Paul sometimes send

      21    e-mails to them?

      22         A    On occasion.








                                                              76


       1         Q    Do you sometimes have documents

       2    sent to them or received from them?

       3         A    Yes, on occasion.

       4         Q    You see Mr. Blumenthal in your

       5    office fairly frequently, don't you?

       6         A    Actually, no, not in our office,

       7    no.

       8         Q    But you do see him frequently?

       9         A    How do you define "frequently"?

      10         Q    More than once a week.

      11         A    Are you asking if I see him more

      12    than once a week or if Paul sees him more

      13    than once a week?

      14         Q    Yes, right?

      15         A    It varies.  Sometimes no, sometimes

      16    yes.

      17         Q    How many times does Paul see

      18    Mr. Blumenthal a week?

      19         A    I can't speak to that.  I don't

      20    walk with Paul.

      21         Q    Roughly speaking?

      22         A    I can't speak to that.








                                                              77


       1         Q    How many times are you aware that

       2    he speaks to Mr. Blumenthal every day?

       3              MS. SHAPIRO:  Objection.

       4              BY MR. KLAYMAN:

       5         Q    You can respond.

       6         A    I can't speak to that.  If I

       7    shadowed Paul, I can speak to that, but I

       8    don't.

       9         Q    Well, you're sitting in the office,

      10    aren't you, with him?

      11         A    Correct, but Paul is not always in

      12    the office.

      13         Q    How many calls, roughly speaking,

      14    either come in from Mr. Blumenthal or are

      15    made to Mr. Blumenthal daily, just roughly

      16    speaking?

      17         A    I can't speak to the calls this go

      18    out.

      19         Q    More than one?

      20         A    I can't speak to the calls that go

      21    out.

      22         Q    You could give me a rough








                                                              78


       1    approximation?

       2         A    You're asking me to guess.

       3         Q    I'm asking you to give me an

       4    approximation.

       5              MS. SHAPIRO:  Objection.  She has

       6    no way to know.

       7              MR. KLAYMAN:  She sits there with

       8    Paul.  Please don't make ridiculous

       9    objections.

      10              MS. SHAPIRO:  It's not a ridiculous

      11    objection.

      12              MR. KLAYMAN:  Certify it.  Improper

      13    conduct.

      14              THE WITNESS:  When Paul picks up

      15    the phone, there is no way for me to know who

      16    he is calling.

      17              BY MR. KLAYMAN:

      18         Q    How does he refer to Sydney

      19    Blumenthal?  Does he call him Sid?

      20         A    Yes.

      21         Q    And you hear the name Sid more than

      22    once a day, don't you?








                                                              79


       1         A    I may.

       2         Q    In fact, you hear it several times

       3    a day, don't you?

       4         A    I may, but that doesn't prove

       5    anything.

       6         Q    What do you think I'm trying to

       7    prove?

       8         A    I don't know.

       9         Q    Well, you obviously thought I was

      10    trying to prove something or you wouldn't

      11    have said that.  So tell me what it is I'm

      12    trying to prove?

      13              MS. SHAPIRO:  Objection, he's

      14    arguing with the witness.

      15              BY MR. KLAYMAN:

      16         Q    Please respond.  Certify this

      17    section.

      18         A    No, it just seemed like you were

      19    trying to get to how many times Paul was

      20    calling Sid.

      21         Q    That's exactly what I'm trying to

      22    get to and how many times Sid calls Paul.








                                                              80


       1         A    But one can mention someone's name

       2    without being on the phone with them.

       3         Q    Well, tell me how many times the

       4    name is mentioned every day.  You hear it all

       5    the time, don't you?

       6         A    I can't speak to that because I

       7    tune him out.

       8         Q    And why are you so defensive about

       9    telling me how many times you think you hear

      10    it?

      11              MS. SHAPIRO:  Objection.  You're

      12    just trying to harass the witness.

      13              BY MR. KLAYMAN:

      14         Q    If you don't hear anything, then

      15    why are you so defensive about it?

      16         A    I gave you my answer.  You're

      17    weren't satisfied with it.  I was taking

      18    offense to the way you were trying to get an

      19    answer.

      20         Q    Are you questioning my authority to

      21    ask questions?

      22              MS. SHAPIRO:  Objection.








                                                              81


       1              THE WITNESS:  No.

       2              BY MR. KLAYMAN:

       3         Q    I told you earlier on that, if you

       4    wish to give me a simple answer, we can move

       5    this along?

       6              MS. SHAPIRO:  Objection.  I really

       7    object to you trying to intimidate an

       8    assistant.  This is not Mr. Begala.  This is

       9    not one of the people that you want to beat

      10    up on.  I really find it obnoxious that

      11    you're trying to bully a 23-year-old

      12    assistant.

      13              MR. KLAYMAN:  I find your

      14    statements to be improper and sanctionable.

      15    Certify this.

      16              BY MR. KLAYMAN:

      17         Q    What I'm trying to say to you is we

      18    can move this thing along quicker or I can

      19    ask the questions in a lot of different ways

      20    until I get a response.  I'm very patient.

      21    If you want to proceed in this way, I'll

      22    proceed in this way.  If you can be a little








                                                              82


       1    more direct, we can move it along quicker.

       2              How many times approximately each

       3    day do you hear Sydney Blumenthal's name?

       4              MS. SHAPIRO:  Asked and answered.

       5              BY MR. KLAYMAN:

       6         Q    Pleads respond.

       7         A    I don't know.

       8         Q    Frequently, correct?

       9         A    I don't know what you mean by

      10    "frequently" and, even if I did know, it

      11    would vary.

      12         Q    More than three or four times?

      13         A    I don't know.

      14         Q    Certify it.

      15              I take it that you sometimes hear

      16    the name Rahm Emanuenl or Rahm, correct?

      17         A    Correct.

      18         Q    How many times do you hear that

      19    name each day?

      20         A    I probably hear that name more than

      21    once each day.

      22         Q    More than three or four times?








                                                              83


       1         A    I'd be guessing.

       2         Q    Certify it.  How many times do you

       3    hear Mike McCurry's name each day?

       4         A    Sometimes once, sometimes more than

       5    once, sometimes none.

       6         Q    How many times do you hear Ann

       7    Lewis' name each day?

       8         A    Sometimes once, sometimes more than

       9    once, sometimes none.

      10         Q    How many times do you hear Erskine

      11    Bowles' name each day?

      12         A    Sometimes once, sometimes more than

      13    once, sometimes none.

      14         Q    Has Hillary Clinton ever came into

      15    your office?

      16         A    No.

      17         Q    Have you ever had any contact with

      18    her?

      19         A    Yes.

      20         Q    When was that?

      21         A    Twice.

      22         Q    On what occasions?








                                                              84


       1         A    In the fall of 1996, I did advance

       2    for the First Lady in Sioux City, Iowa.  And

       3    on the day that she was in, I was in the same

       4    room with her.  We did not talk.  I was -- I

       5    was staff and I had no occasion to speak with

       6    her.  The second time --

       7         Q    Wait, wait.  Who was with her at

       8    the time?

       9         A    I remember Kelly Craighead.

      10         Q    And is that a woman?

      11         A    Correct.

      12         Q    What was her position?

      13         A    I don't know exactly what her

      14    position is.  I know she aids the First Lady.

      15         Q    Is she still working in the White

      16    House?

      17         A    I don't know.

      18         Q    And who else was in the room?

      19         A    I don't remember.  It was very

      20    busy.  I was working.  It was just trying to

      21    get -- get her in and out.

      22         Q    Was anything dealing with FBI files








                                                              85


       1    discussed at that meeting?

       2         A    No.

       3         Q    And you saw the First Lady again?

       4         A    Correct.

       5         Q    When was that?

       6         A    At a holiday party last December.

       7         Q    And where was that holiday party?

       8         A    In the White House.

       9         Q    Was that the whole staff of the

      10    White House?

      11         A    No, it was not.

      12         Q    What staff was it?

      13         A    It wasn't a staff party.

      14         Q    What kind of party was it?

      15         A    I believe it was thrown primarily

      16    for members of the press.

      17         Q    Where was it held?

      18         A    In the White House.

      19         Q    What room in the White House?

      20         A    It was a -- it was a function that

      21    used the entire -- I don't know, not the

      22    entire but whatever -- I haven't been to --








                                                              86


       1    this was my first White House function, so I

       2    don't know what was normal, what was abnormal

       3    about it.  I do know it was a holiday party,

       4    and -- and throughout the course of the party

       5    I went through several rooms in the White

       6    House.

       7         Q    Was there ever any discussion of

       8    FBI files during that press party?

       9         A    No.

      10         Q    Have you ever heard a discussion

      11    about FBI files in the White House?

      12         A    No, I have not.

      13         Q    Have you ever heard a discussion of

      14    filegate in the White House?

      15         A    No.

      16         Q    You hesitated.  Why is that?

      17         A    Well, I wanted to think -- I wanted

      18    to think before I answer, and no.

      19         Q    Did you have an opportunity to ever

      20    meet Sydney Blumenthal in your office?  Has

      21    he ever come over?

      22         A    Yes, he has.








                                                              87


       1         Q    Approximately how many times?

       2              MS. SHAPIRO:  Asked and answered.

       3              BY MR. KLAYMAN:

       4         Q    You can respond.

       5         A    More than once.

       6         Q    More than once a week?

       7         A    No.

       8         Q    Who is located in and around the

       9    office suite that you occupy with Paul, on

      10    either side?

      11         A    Okay.

      12              MS. SHAPIRO:  Objection to

      13    mischaracterizing the testimony.

      14              BY MR. KLAYMAN:

      15         Q    You can respond.

      16         A    I do want to repeat that.  We do

      17    not exist in a suite.

      18         Q    Who is adjoining to your office, to

      19    the left and to the right and on the other

      20    side of the hallway?

      21         A    To our right -- well, if you're --

      22    if you're walking in the office, to our left,








                                                              88


       1    I believe it's Mike Malone.  I'm not quite

       2    sure of his name.

       3         Q    Who is Mike?  What's his title?

       4         A    He, he's in office of

       5    administration and management, I think.  I'm

       6    not quite sure of the full name of the

       7    office, and then on the other side is

       8    Ms. Paxton, and in front of us it's a wall

       9    and a stairwell, so those are our two

      10    neighbors.

      11         Q    Are you located within a

      12    conglomerate of offices that are part of

      13    White House counsel's office?

      14         A    It is -- the counsel's office -- I

      15    mean -- no, we are not considered in a

      16    counsel suite.

      17         Q    But is the counsel's office close

      18    to your office?

      19         A    Define what you mean by the

      20    "counsel's office."

      21         Q    White House lawyers?

      22         A    I mean, there's several offices --








                                                              89


       1    Ms. Paxton is on one side of us, but, if you

       2    go down another hallway, I know that there

       3    are some counsel offices down that hallway,

       4    but there are also other offices that are

       5    down there, too.

       6         Q    Whose counsel's office are down

       7    that hallway, what counsel?

       8         A    I only know of two people for sure

       9    who are down that way.

      10         Q    Who is that?

      11         A    I know Lisa 컴컴 is down there and

      12    I know Lanny Brewer is down there.

      13         Q    If you were walking, how long would

      14    it take for you do get to Mr. Brewer's

      15    office, a couple of seconds?

      16         A    About a minute.

      17         Q    I take it you're friends with

      18    Ms. Paxton?

      19         A    I wouldn't say that we were

      20    friends.

      21         Q    Going out to have lunch from time

      22    to time?








                                                              90


       1         A    No.

       2         Q    Going out to have a drink or

       3    whatever?

       4         A    No.

       5         Q    But you know each other quite well?

       6         A    No.

       7         Q    Now, how did you get your job in

       8    the White House?  Did someone recommend you

       9    for that?

      10         A    I asked Paul for the job.

      11         Q    How did you get to know Paul?

      12         A    When I worked as an intern before,

      13    I developed a rapport with him and therefore

      14    that's how I got to know him.

      15         Q    When did you start working in the

      16    White House as an intern?

      17         A    I was only technically an intern

      18    for the fall semester of 1995.

      19         Q    And how did you get that job?  Who

      20    recommended you for that?

      21         A    I had been a volunteer before then,

      22    and I wanted to be an intern in order to get








                                                              91


       1    credit at GW for my time there.

       2         Q    Who recommended you for your job as

       3    a volunteer?

       4         A    Actually, I don't remember her

       5    name.  I volunteered during the inaugural in

       6    '93 and the woman who was coordinating

       7    volunteers there, she went into, I believe --

       8    it was a communications office.  I don't know

       9    exactly which office she came into, but she

      10    called me and let me know that there were

      11    opportunities available and that's how I -- I

      12    first came in.

      13         Q    Who recommended for your job as an

      14    intern?

      15         A    I don't remember if someone

      16    expressly recommended me.

      17         Q    Who generally recommended you?

      18         A    I don't remember -- I remember it

      19    being more of a formality.  I don't remember

      20    exactly who worked on it.

      21         Q    You are aware that you don't get a

      22    job as an intern unless someone recommends








                                                              92


       1    you, right?  It doesn't work any other way,

       2    does it?

       3         A    I don't know how the intern office

       4    works.

       5         Q    So you just got this job by

       6    accident?

       7         A    I had been a volunteer in -- in the

       8    -- in that office from May '93 until -- and

       9    up until this is now September '95 I want to

      10    be an intern.  I don't remember exactly if

      11    anyone placed any calls for me.  I don't know

      12    if I just called myself and said now I'd like

      13    to be an intern, could I please have the

      14    forms.  I don't remember exactly how it went.

      15         Q    I take it you were an intern at the

      16    same time as Monica Lewinski?

      17         A    Yes, I was.

      18         Q    You know her?

      19         A    I have met her.

      20         Q    How specifically did you get to

      21    know Paul?

      22         A    Excuse me?








                                                              93


       1         Q    How specifically did you get to

       2    know Paul?

       3         A    What do you mean?

       4         Q    How did you get to know him well?

       5         A    Because he called my office a lot.

       6         Q    What office did you work in?

       7         A    I worked for George Stephanopoulos.

       8         Q    And how long did you work for

       9    George, we'll call him, because his last name

      10    is long?

      11         A    I worked there from May '93 through

      12    May '96 on and off.

      13         Q    And I take it it was George

      14    Stephanopoulos that recommended you to Paul?

      15              MS. SHAPIRO:  Objection.

      16              BY MR. KLAYMAN:

      17         Q    Correct?

      18         A    It is my understanding that Paul

      19    placed a call to George.  I don't know what

      20    was said during the call.

      21         Q    And placed the call about what?

      22    Having you work for him?








                                                              94


       1         A    I don't know the intent of the

       2    call.  I don't know the substance of the

       3    call.  I am -- I'm vaguely aware what they

       4    spoke about my candidacy.

       5         Q    How did you become vaguely aware of

       6    that?

       7         A    They both told me.

       8         Q    Paul wanted you to work with him?

       9         A    I can only guess.  I'm -- he never

      10    came -- I mean, well, yes, he did come out

      11    and say that he wanted me to work for him.

      12         Q    And he told you the reason he

      13    wanted you to work for him because he needed

      14    a loyal person who knew how to keep things

      15    confidential.

      16         A    Would you repeat that?

      17         Q    He told you he wanted you to work

      18    for him because your reputation was that you

      19    were a loyal person that knew how to keep

      20    things confidential, hard worker?

      21         A    He didn't say that.

      22         Q    Something like that?








                                                              95


       1         A    Me didn't say that.

       2         Q    Something like that?

       3         A    He didn't say that.

       4         Q    What did he say?

       5         A    I remember that he said he wanted

       6    someone with -- with White House experience

       7    and that he felt comfortable because he knew

       8    me.  That's all I remember him specifically

       9    saying.

      10         Q    And how did he know you?

      11              MS. SHAPIRO:  Asked and answered.

      12              BY MR. KLAYMAN:

      13         Q    You can respond?

      14         A    He knew me because he had spoken to

      15    me several times over the last three years I

      16    had been there.

      17         Q    In dealing with George?

      18         A    In dealing with George.

      19         Q    And what was your title in working

      20    for George?

      21         A    I was either a volunteer on an

      22    intern, depending on the time period we're








                                                              96


       1    talking about.

       2         Q    And you weren't paid?

       3         A    I was never paid.

       4         Q    You had to have a White House

       5    security clearance, did you not?

       6         A    I had a background check done.

       7         Q    And when did that occur?

       8         A    It occurred in '93.  I'm not aware

       9    of the specific time frame.

      10         Q    Were you interviewed by FBI agents

      11    or anyone?

      12         A    Yes, I was.

      13         Q    Who interviewed you?

      14         A    Gary Aldridge.

      15         Q    I take it Mr. Aldridge knows you

      16    pretty well?

      17         A    Only what he could learn reading my

      18    file and interviewing me.

      19         Q    How do you know he read your file?

      20         A    I don't know he read -- if he read

      21    my file.

      22         Q    Then why did you say that?








                                                              97


       1         A    You asked me if he knew me very

       2    well.  I figured the only way he could know

       3    me is if he had read my file because that's

       4    the only way he could know anything about me.

       5         Q    And you are aware that after you

       6    met with Mr. Aldridge that FBI agents

       7    interviewed your acquaintances and friends

       8    and others to find out about you?

       9         A    I'm aware.

      10         Q    And you're very knowledgeable that

      11    what's in your FBI file is strictly

      12    confidential?

      13         A    Very knowledgeable about that.

      14         Q    And you wouldn't want that to get

      15    out to anybody, would you?

      16         A    No, I would not.

      17         Q    And the reason is because you don't

      18    know what's in there, right.

      19         A    That's one of the many reasons.

      20         Q    What are the other reasons?

      21         A    It's confidential.

      22         Q    It could be very harmful to you if








                                                              98


       1    it got out?

       2         A    I'm not aware of the content of my

       3    file.  I just do know that it's confidential.

       4         Q    Have you ever asked to see it?

       5         A    No, I have not.

       6         Q    Are you in Gary Aldridge's book at

       7    all?

       8         A    Not that I'm aware of.

       9         Q    Have you ever seen the manuscript

      10    or any copy of that book?

      11         A    No, I have not.  I mean, I have

      12    seen the book physically.  I've never read

      13    the book.

      14         Q    When did you see the book?

      15         A    I remember seeing it in the

      16    bookstore when it came out.

      17         Q    I take it you did in George

      18    Stephanopoulos' office?

      19         A    A manuscript?  Are you referring

      20    to -- what do you mean, manuscript.

      21         Q    When you worked for George, you are

      22    aware that he had a manuscript of Gary








                                                              99


       1    Aldridge's book that he put his notes on,

       2    were you not?

       3         A    I'm aware that when the book came

       4    out someone in our office had to go to the

       5    bookstore and buy it.

       6         Q    Who asked you to go to the

       7    bookstore?

       8         A    I did not go to the bookstore.  I

       9    don't remember who went but it was not me.

      10         Q    Who asked to go get one?

      11         A    I don't know exactly who asked.

      12         Q    George?

      13         A    I would have --

      14              MS. SHAPIRO:  Objection.

      15              THE WITNESS:  I'd have to guess.

      16              BY MR. KLAYMAN:

      17         Q    Who do you think asked?

      18         A    No.  I -- no, I'd have to guess.

      19         Q    Do you have any inkling?

      20         A    Yes, I have an inkling, but --

      21         Q    Tell me what your inkling is?

      22         A    No.








                                                              100


       1         Q    You have to tell me your inkling.

       2         A    No.

       3              MS. SHAPIRO:  She's testified that

       4    she has no knowledge.

       5              MR. KLAYMAN:  No, she has an

       6    inkling.  She just testified to it.

       7              BY MR. KLAYMAN:

       8         Q    Who do you think asked you to go

       9    get it?

      10         A    I did not get it.

      11         Q    Who do you think asked for it,

      12    regardless of who got it?

      13         A    George.

      14         Q    When you moved over from working

      15    with George to Paul Begala, did your status

      16    change.

      17         A    I mean, there was, there was time

      18    elapsed between when I worked with George and

      19    when I worked with Paul, and, yes, my status

      20    changed.

      21         Q    How so?

      22         A    I became a staff person.

 

 

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