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.
of this deposition