101 1 Q Did you have to go through another 2 background check? 3 A Yes. 4 Q Who interviewed you for that one? 5 The FBI? 6 A The FBI interviewed me, yes. 7 Q What agent? 8 A Tom Block. I don't know how to 9 spell his last name. 10 Q Tom Block? How is that spelled? 11 A I don't know. 12 Q Is he still with the FBI? 13 A I don't know. 14 Q And you say there was an interim 15 period? 16 A Correct. 17 Q What was happening during the 18 interim period? 19 A I stopped working in George's 20 office in May '96. That's when I told you 21 that I temped, temped until I could start 22 working on the campaign, worked on the 102 1 campaign, I believe, towards the end of 2 August through mid-October and mid-October I 3 left and I went to England, where I was a 4 visiting student, stayed there until the end 5 of -- end of May. 6 Came back, I worked as an intern 7 again for the summer and it was in the summer 8 that I learned that Paul was coming back and 9 I asked Paul, if he needed an assistant, to 10 consider me. And at the end of my internship 11 there and -- I also stayed on there to do 12 some staff work until I could actually start 13 working at the White House, then I -- in 14 September I began at the White House. 15 Q Have you ever met Vernon Jordan? 16 A Yes, I have. 17 Q When did you meet him? 18 A I don't remember exactly when we 19 first met. 20 Q You met him several times? 21 A Yes, I have. 22 Q Under what circumstances? 103 1 A Business and personal. 2 Q What was the nature -- 3 MS. SHAPIRO: Objection for the 4 record to the relevancy. 5 BY MR. KLAYMAN: 6 Q Well, what's the nature of the 7 business? 8 MS. SHAPIRO: Can you tell me for 9 the record what the relevance is? 10 MR. KLAYMAN: No, because I don't 11 want to give the witness the answers. 12 MS. SHAPIRO: Is it connected to 13 the FBI files matter? 14 MR. KLAYMAN: Please don't 15 interrupt and don't harass me, please. 16 Certify this. 17 BY MR. KLAYMAN: 18 Q What was the nature of the 19 professional? 20 A On occasion he came in to visit 21 with George. 22 Q Do you know why he came in to visit 104 1 with George? 2 A No, I do not. 3 Q Where was your desk in comparison 4 to George's desk? Was it in the same office? 5 A It ranged. My first summer there, 6 I was in an office in the Old Executive 7 Office Building, but after that summer -- in 8 George's offices, there's his office, then 9 there's the room in front of it and his 10 assistant sat in the seat that was closest to 11 his office and then the intern or volunteer 12 or whoever was helping the assistant sat in 13 the other seat and I sat in that seat 14 primarily. On occasion I would substitute 15 for his assistant and I would sit in the 16 assistant's seat, but there was never any 17 time I actually was sitting in George's 18 office. 19 Q But you've overheard conversations 20 between George and Vernon Jordan? 21 A No, I have not. 22 Q And you say you've seen him 105 1 personally. How so? 2 MS. SHAPIRO: Asked and answered. 3 BY MR. KLAYMAN: 4 Q You can respond. 5 A I've seen him. I've -- he's 6 offered me counsel in the past. I have, I 7 have -- I consider him a friend. 8 Q What did he counsel? 9 MS. SHAPIRO: Objection. Can you 10 please tie this up to the relevance. 11 BY MR. KLAYMAN: 12 Q You can respond. 13 MS. SHAPIRO: I really think that 14 this is an improper pursuit pursued for an 15 improper purpose. 16 BY MR. KLAYMAN: 17 Q Did he offer counsel on whether you 18 should tell the truth at depositions? 19 A No, he did not. 20 Q Did he offer you counsel on getting 21 you a job? 22 A Vaguely. 106 1 Q When was that? 2 A A couple of years ago. I was -- I 3 believe we had talked about it in '95. 4 Q You talked about it recently, 5 didn't you? 6 A No. 7 Q You talked about it after you found 8 out you were going to be deposed in this 9 case, didn't you? 10 MS. SHAPIRO: Objection. That is 11 not her testimony. You're just harassing 12 her. 13 BY MR. KLAYMAN: 14 Q You can respond. 15 A But for the record I would like to 16 state no. 17 Q You say you're friends. You have 18 gone out socially with Mr. Vernon Jordan? 19 You can respond. You can respond. 20 MS. SHAPIRO: Can we take a break 21 for a moment? 22 MR. KLAYMAN: I want her to answer 107 1 this question. We'll take a break -- 2 MS. SHAPIRO: We'll take a break 3 now. 4 MR. KLAYMAN: All right, over my 5 objection. Certify it. 6 THE VIDEO SPECIALIST: Off video 7 record at 11:42. 8 (Recess) 9 THE VIDEO SPECIALIST: We're back 10 on video record at 11:54. 11 MS. SHAPIRO: Can you, Mr. Klayman 12 make a proffer on relevancy of this question? 13 MR. KLAYMAN: The proffer of 14 relevancy is that there has been reported if 15 not demonstrated conduct that Vernon Jordan 16 has allegedly engaged in witness tampering. 17 That's the relevancy among other areas, but 18 that's as far as I'm going to go, but that's 19 enough certainly to allow me to ask these 20 questions. 21 MS. SHAPIRO: And how does that 22 relate to this matter? 108 1 MR. KLAYMAN: I think you know, 2 Ms. Shapiro, you're a pretty bright woman. 3 BY MR. KLAYMAN: 4 Q Now, Ms. Parker? 5 A Uh-huh. 6 MR. KLAYMAN: Can you read back the 7 last question before we convened this 8 deposition? 9 (The reporter read the record as 10 requested.) 11 THE WITNESS: Either once or twice, 12 we've gone out to lunch, and there were two 13 or three times we've gone out to dinner. 14 Q Was anybody with you when you went 15 out to dinner with him? 16 A No. 17 Q Was anybody with you when you went 18 out to lunch? 19 A No. 20 Q During the times that you went out 21 to dinner, when was that? 22 A I don't remember exactly when, but 109 1 it's been over -- over the last three to four 2 years. The last time -- I'm trying to think 3 of when the last time was. I haven't seen 4 him -- the last time I remember seeing him 5 was during the inaugural last year. 6 Q Have you talked to him since then? 7 A A few times, yes. 8 Q When did you talk to him? 9 A The last time I spoke with him was 10 last year at the -- I had already started in 11 the White House. I don't remember exactly 12 when. 13 Q At the time that you went out to 14 dinner with him and went out to lunch with 15 him, were you in any way asked to be a 16 witness in any legal proceeding? 17 A No. 18 Q Did he ever offer to get you a job? 19 MS. SHAPIRO: Objection. She's 20 testified as to the things that would matter 21 to your proffer or relevancy. 22 MR. KLAYMAN: I don't want to give 110 1 her the answers to all my questions. 2 BY MR. KLAYMAN: 3 Q Did he ever offer to get you a job? 4 A He's never offered to get me a job. 5 Q Has he ever assisted you in getting 6 a job in any way, however small? 7 A I remember he kind of tried to help 8 me figure out what I'd be interested in 9 doing. But he -- I'm not aware of any phone 10 calls he's ever placed on my behalf or any 11 actions he's done on my behalf to assist me 12 in getting a job. 13 Q Before your deposition today, are 14 you aware that Judicial Watch had maintained 15 that FBI files may be used by the White House 16 or its allies to try to intimidate Clinton 17 adversaries so they don't look into the 18 Monica Lewinski matter among others? Are you 19 aware that Judicial Watch has taken this 20 position in this lawsuit? 21 A No, I'm not. 22 MR. KLAYMAN: Can I ask that we 111 1 don't have a lot of talking here? It's 2 distracting. 3 MS. SHAPIRO: I'm going to object 4 because I think it was inadvertent on your 5 part. When you said Monica Lewinski, didn't 6 you mean FBI files matter? 7 MR. KLAYMAN: No, I meant Monica 8 Lewinski. 9 MS. SHAPIRO: You're saying your 10 lawsuit's about Monica Lewinski? 11 MR. KLAYMAN: No, what I'm saying 12 is that there is a strategy, perhaps, to use 13 FBI files to intimidate anyone who questions 14 this administration with regard to any 15 scandal. 16 MS. SHAPIRO: I haven't seen that 17 in the complaint. 18 BY MR. KLAYMAN: 19 Q Are you aware of that? 20 A I am now aware of it. 21 Q Well, we'll give you second copies 22 if you'd like. 112 1 Is there anybody else that you've 2 worked with at the White House who have gone 3 out to dinner with Vernon Jordan? 4 MS. SHAPIRO: Objection, again to 5 relevancy. 6 BY MR. KLAYMAN: 7 Q You can respond. 8 A You asked me lunch or dinner? 9 Q Dinner. 10 A Personally, I don't know. I'm sure 11 there are plenty of other people who have. 12 Q But you don't know? 13 A I don't know. 14 Q Anybody who's gone out to lunch 15 with Mr. Jordan that you know? 16 A Yes -- wait, I have to change 17 something because now I remember being at 18 lunch and at the table was Mr. Bowles and 19 Ms. Leslie Gordon, and other people kind of 20 came up and came out, but this was a lunch 21 during an -- during one of the debate preps 22 last year. 113 1 Q I'm talking about recently. Do you 2 know of anybody who has gone out to lunch or 3 dinner with Mr. Jordon? 4 A No, I do not. 5 MS. SHAPIRO: I'm going to object 6 at this point and I'm going to instruct the 7 witness not to answer because this is so 8 wholly irrelevant and there is absolutely no 9 connection between this and anything and I 10 think we should call the judge's chambers are 11 right now. 12 MR. KLAYMAN: In fact. That was my 13 last question for the time being, so I'm just 14 trying to find out whether Mr. Jordan has 15 played any role with regard to individuals 16 who have provided or may provide testimony in 17 this case and there is a demonstrated -- 18 MS. SHAPIRO: She testified to her 19 last conversation with Mr. Jordan. 20 MR. KLAYMAN: There is a 21 demonstrated public record of Mr. Vernon 22 Jordan's involvement with witnesses in legal 114 1 proceedings. 2 MS. SHAPIRO: Well, that's no basis 3 for anything. 4 MR. KLAYMAN: It's an excellent 5 basis. 6 MS. SHAPIRO: And I'm happy to go 7 call the judge right now. 8 MR. KLAYMAN: And I said I was 9 finished with this line of questioning. 10 MS. SHAPIRO: That's fine, but I 11 will note that this whole like of questioning 12 will become before the judge near the very 13 future. 14 MR. KLAYMAN: That's fine. I 15 welcome that. And I welcome your behavior in 16 coming in front of the judge because that 17 will be placed squarely in front of the 18 judge. 19 BY MR. KLAYMAN: 20 Q Now, during the time that you 21 worked for George Stephanopoulos, I take it 22 you left working for him when he left the 115 1 White House to go outside; is that why you 2 left? 3 A No. 4 Q Why did you leave? 5 A I left because I wanted a paying 6 job. 7 Q Was it around the time that he was 8 leaving? 9 A It didn't correspond with the 10 times. 11 Q It did not? 12 A No. 13 Q And what is your current title? 14 What's your official title right now? 15 A Special assistant to the counselor 16 to the President. 17 Q And what are your duties and 18 responsibilities as special assistant? 19 A I manage the flow of paper in and 20 out of the office, I answer the phones, take 21 care of the phone messages. I draft 22 correspondence on occasion, I draft memos on 116 1 occasion, I do small projects, I do what I 2 need to do to keep the office running. 3 Q Does Paul Begala sometimes tell you 4 I want a letter written on such and such a 5 subject, please write it for me? 6 A Yes. 7 Q And what types of subjects does he 8 ask you to write letters on? 9 A Usually it's a thank you for 10 someone's card or notes, or if someone sent 11 something, you know. And if this person 12 deserves more than a cursory thank you note. 13 Q Have you ever done radio or TV 14 appearances? 15 A No, I have not. I mean, define 16 what you mean by that. 17 Q Have you ever been on any 18 television shows? 19 A I've never been booked for a 20 television show, no. 21 Q You ever been on any? 22 A On a few past occasions, I, I have 117 1 been interviewed, and that interview has been 2 on the news. 3 Q And what were those occasions? 4 A I mean, I remember once when I was 5 in high school -- 6 Q I'm talking with regard to the 7 White House? 8 A No. 9 Q Never been on a show called the 10 "Young Bloods"? 11 A I'm not aware of that show. 12 Q Is there a filing system in the 13 office where you keep Mr. Begala's 14 correspondence and your correspondence? Is 15 there a filing system where you keep notes 16 and those kinds of things? 17 A No. 18 Q You do store notes, though; don't 19 you? 20 A What kind of notes? 21 Q Any notes. 22 A I don't systematically store notes. 118 1 I have a couple of old note pads that there 2 are things, sometimes when people call in, 3 I've put those things down so I can put them 4 in the computer, but there's nothing that is 5 -- that I could systematically go back and, 6 say, and look at it. I just happen to keep 7 them because I haven't put those numbers in 8 my computer Rolodex yet. 9 Q Now Paul keeps notes; doesn't he? 10 A He does -- no. 11 Q Sometimes? 12 A Sometimes, I have placed those 13 notes in a file for him. But usually when 14 he's through with his notes, he disposes of 15 them through. 16 Q When did you place notes in the 17 file for him? 18 A I only remember doing it once, 19 because he was working off of several note 20 pads, and I was trying to make it more 21 organized for him. But I only remember doing 22 that once, and I don't remember exactly when 119 1 I did it. 2 Q It was recently; wasn't it? 3 A Uh-uh. 4 Q Has anybody done dictation in the 5 office with dictation equipment? 6 A No. 7 Q Is there any type of video of any 8 conversations, or meetings, or anything like 9 that in your office? 10 A No. 11 Q Have you ever met anyone by the 12 name of Eric Burrman? 13 A I don't know if Mr. Burrman and I 14 have ever met, but I remember taking his 15 calls, and during any duties an intern in 16 George's office and also -- I think he has 17 called occasionally in Paul's office. 18 Q And do you know why he called? 19 A No, I don't recall. 20 Q He does research; doesn't he? 21 A I think at one time he did 22 research. 120 1 Q How do you know that? 2 A I think it's something I figured 3 out over my time as an intern in George's 4 office. 5 Q How did you figure that out? 6 A I don't remember exactly. I may 7 have overheard someone saying it. I called 8 information and lots of strange ways. I 9 don't know. 10 Q Now getting back to this research 11 office. They work sometimes, to the best of 12 your knowledge, with Sydney Blumenthal as 13 well; don't they? 14 A I can't verify that. 15 Q I didn't ask you to verify it. I 16 just asked you to say what you know. 17 A I don't know. 18 Q Inside the White House, is there 19 another office that provides research? 20 A I mean, one can go to the library 21 and ask for things to be retrieved. 22 Q Do they have people inside the 121 1 White House who are in charge with getting 2 information on people who say things that 3 might be harmful to the Administration? 4 A Could you repeat that please? 5 Q Is there somebody in the White 6 House who is in charge with doing research 7 into individuals who may make allegations 8 about the Administration? 9 A I'm not aware of anyone having that 10 job description. 11 Q Is there anybody that does it? 12 Surely there must be. 13 A There may be people who search the 14 public record, and I'm not aware of anyone 15 who, whose job it is to search things, find 16 bad things to say about people who speak 17 badly about the Administration. I just don't 18 know anything about that. 19 Q Well, who are those people you just 20 referred to? 21 A No, I said I don't know of anyone. 22 Q You did make a reference that there 122 1 may be people who do some research on people 2 who are attacking the Administration. Who 3 are the people you were talking about? 4 MS. SHAPIRO: Objection. That's 5 mischaracterization of testimony. 6 THE WITNESS: I know people who 7 work in the research office, and they do 8 research. I don't know what their 9 assignments are. I don't know why they do 10 the research that they do, but I know that 11 they do research. 12 BY MR. KLAYMAN: 13 Q Do you know who they are? 14 A I already said them. 15 Q Do you know whether any such people 16 have ever done research on Judicial Watch? 17 A I'm not aware. 18 Q Larry Klayman? 19 A The only thing I'm aware of is 20 people accessing your web site. 21 Q Who accessed my web site? 22 A I accessed your web site, and I 123 1 believe Glen Wiener accessed your web site. 2 Q Who told Glen Weiner to access 3 Judicial Watch's web sate? 4 A I not aware of anyone telling Glen 5 Weiner to access your web site. 6 Q What did Mr. Weiner tell you was 7 the reason he accessed it? 8 MS. SHAPIRO: Objection. No 9 foundation. 10 BY MR. KLAYMAN: 11 Q You can respond. 12 A We were both accessing your web 13 site because the press release that we had 14 received was barely legible, and we were 15 hoping that you had placed it on your web 16 site. Unfortunately, we could not find it on 17 your web site. 18 Q Who told you to do that? 19 Mr. Begala, correct? 20 A No one told me to do it. It was me 21 trying to find a legible copy of the press 22 release. 124 1 Q Have you ever accessed the web site 2 called Opinion Inc. 3 A No. 4 Q Have you ever accessed other web 5 site of individuals who perceive to say 6 negative things against the Clinton 7 Administration? 8 MS. SHAPIRO: Objection. No 9 foundation. 10 BY MR. KLAYMAN: 11 Q You can respond? 12 A You'd have to define that. I mean, 13 you can say News Week does that. I mean, you 14 would have to define that better. 15 Q Everybody does that, right? 16 MS. SHAPIRO: Objection. 17 Argumentative. 18 MR. KLAYMAN: I'm trying to figure 19 out how she defines it. 20 THE WITNESS: I need you to define 21 it. 22 BY MR. KLAYMAN: 125 1 Q These days it would be everybody, I 2 guess. 3 A So you're asking me whether I ever 4 accessed your web site? 5 Q Yes, to do research on people who 6 perceive to be a threat to the Clinton 7 Administration, you've done that, in addition 8 to Judicial Watch? 9 A I've never set out to find -- I've 10 never set out to -- no. I've never done 11 that. 12 Q You know of others that have, I 13 take it? Mr. Wiener? 14 A I mean, if you're defining Judicial 15 Watch as a group that exists as a threat to 16 the Administration, and that's your sole 17 purpose of being a threat to the 18 Administration, then I guess Glen Wiener has 19 accessed your web site in order to find a 20 threat to the Administration, but I don't 21 think that's what he was thinking. But I 22 can't speak to what he was thinking, so I'm 126 1 just going to stop now. Because I can't -- I 2 don't know what his motivation was, other 3 than to find a legible copy of the press 4 release. 5 Q But you know that the White House 6 is concerned with groups or people that have 7 brought lawsuits against it or say things 8 that are not positive, they are concerned 9 about that, correct? The White House. 10 MS. SHAPIRO: Objection. 11 BY MR. KLAYMAN: 12 Q Correct? 13 A I can't speak to that. 14 Q Well, you just did speak to that. 15 You said that if Judicial Watch is perceived 16 as a threat, then Wiener must have done it? 17 MS. SHAPIRO: Objection. 18 Mischaracterizes her testimony. 19 BY MR. KLAYMAN: 20 Q Now tell me what led you to believe 21 that. 22 A I made the mistake of trying to 127 1 find define it for you, because you weren't 2 being specific as to what you meant by this 3 kind of group. All I said is that I know 4 that Glen Wiener had tried to access the web 5 site. I don't know what his motivation was. 6 I just know that we were trying to find a 7 legible copy of the press release. 8 Q Have you ever heard of someone by 9 the name of Terry Lenzner? 10 A Yes, I have. 11 Q Have you ever taken a call, or do 12 you have any knowledge of him ever having 13 called your office? 14 A I have -- I, to the best of my 15 knowledge, he has never called our office. 16 Q Does that mean yes or no? 17 MS. SHAPIRO: Objection. She 18 answered the question. 19 BY MR. KLAYMAN: 20 Q You can respond. 21 A To the best of my knowledge, he's 22 never called our office. 128 1 Q Has he written to your office? 2 A To the best of my knowledge, he has 3 never written to our office. 4 Q His firm is called IG ����. Has 5 anyone from that firm ever called or written 6 to your office? 7 A To the best of my knowledge, no one 8 has ever called or written to our office. 9 Q Are you aware of him having visited 10 anyone in the White House? 11 A I'm not aware. 12 Q Did you ever meet his daughter? 13 A Yes, I have. 14 Q When did you meet his daughter? 15 A We worked in George's office 16 together. 17 Q Did Mr. Lenzner visit at that time? 18 A Not that I'm aware of. It was only 19 until very, very recently that I know that 20 Mr. Lenzner was Emily Lenzner's father. 21 Q Did you ever discuss with Emily 22 Lenzner gathering research against opponents 129 1 of the Clinton Administration? 2 A No. 3 Q Have you ever heard anyone say that 4 Paul's talked to Paul Begala, Mr. Lenzner? 5 A No, I've never heard that. 6 Q Do you know whether he has? 7 A No, I do not. 8 Q Have you ever heard the name Jack 9 Paladina? 10 A It's vaguely familiar. 11 Q He's called the office? 12 A No, he has not, to the best of my 13 knowledge. 14 Q You've heard Paul Begala talk about 15 Jack Paladina? 16 A No, I have not. 17 Q How did you find out that Emily was 18 related to Terry Lenzner? 19 A I asked my counsel. 20 Q When did you do that? 21 A This week. 22 Q It concerned you that Emily Lenzner 130 1 might be related to Terry Lenzner? 2 A I don't think concern characterizes 3 it. It was more curiosity on my part. 4 Q Why did you have any curiosity at 5 all? 6 A I'm a curious person. 7 Q And what caused you to be curious? 8 A I care about Emily. 9 Q What does this have to do with 10 Emily? 11 MS. SHAPIRO: Objection. 12 BY MR. KLAYMAN: 13 Q You can respond. 14 MR. KLAYMAN: Let the record 15 reflect that laughter by all three counsel 16 are inappropriate. Certify it. 17 THE WITNESS: I care about Emily, 18 and it hurts me to see her father's name 19 dragged through the mud. 20 BY MR. KLAYMAN: 21 Q Do you know whether or not 22 Mr. Lenzner has done anything illegal? 131 1 A I am not aware. 2 Q So you formed an opinion that his 3 name is being dragged through the mud 4 unnecessarily? 5 A I immediately have empathy for 6 anyone whose name is being released during 7 these times. 8 Q Why is that? 9 MS. SHAPIRO: What's the relevancy 10 of her empathy? 11 MR. KLAYMAN: Her bias and 12 prejudice. 13 MS. SHAPIRO: Her bias and 14 prejudice against whom? 15 BY MR. KLAYMAN: 16 Q You can respond. 17 MS. SHAPIRO: I would like a proper 18 relevancy. 19 MR. KLAYMAN: I just gave it to 20 you, and that's enough. Certify this, 21 please. Please do not mess up and interrupt 22 my deposition any further. 132 1 MS. SHAPIRO: Can we take a moment 2 please? 3 MR. KLAYMAN: It's not a major 4 question. 5 MS. SHAPIRO: It's an improper 6 question. 7 MR. KLAYMAN: It is an improper 8 question. 9 (Discussion off the record) 10 MR. KLAYMAN: Do you want to take 11 lunch right now? 12 THE WITNESS: No, I don't want to 13 take lunch. 14 MR. KLAYMAN: I mean, I have no 15 further question in this area. 16 MS. SHAPIRO: We'll continue. 17 BY MR. KLAYMAN: 18 Q Have you ever heard of a 19 Mr. Pelicano? 20 A No, I have not. 21 Q Have you ever had contact in your 22 office with anyone that is an outside 133 1 investigator in working with George 2 Stephanopoulos or working with Mr. Begala? 3 A Not that I'm aware of. 4 Q But you're not sure, because you 5 don't know who is a private investigator. 6 A Yes, everyone who's called, I don't 7 know exactly what everyone does when they 8 call. 9 Q Have you taken any calls recently 10 in the last 3 months from David Kendall or 11 from Williams and Connolly law firm? 12 A Mr. Kendall may have called once, 13 but I'm not aware. If anyone else called, I 14 don't know who all is in Williams and 15 Connolly, so I don't know where they were 16 calling from. 17 Q How about a Mr. Gattney? Have you 18 heard of that name? 19 A No, I have not. 20 Q When did Mr. Kendall call? 21 A I don't remember. This year, but I 22 don't remember. 134 1 Q Within the last few months? 2 A Correct. 3 Q Within the last 2 weeks, perhaps? 4 A I don't think so. 5 Q But maybe? 6 MS. SHAPIRO: Objection. You're 7 putting words into the witness's mouth. 8 MR. KLAYMAN: She can respond. 9 MS. SHAPIRO: Please let me assert 10 my objection. You're continually speaking 11 over me. I'm entitled to at least state my 12 objection for the record. 13 MR. KLAYMAN: See what you do is, 14 you make your objection. I then start 15 talking, and then you start talking again. 16 That's the problem, Ms. Shapiro. 17 MS. SHAPIRO: You can describe it 18 however you'd like for the record, but you 19 are talking over me, and we can play the 20 videotape for the judge, and it will reflect 21 it. 22 MR. KLAYMAN: We will be playing 135 1 some videotapes for the judge; I agree. 2 THE WITNESS: Did you have a 3 question? I'm sorry. 4 BY MR. KLAYMAN: 5 Q Yes, was it in the last few weeks? 6 A I don't know. I don't remember it, 7 but I don't know. 8 Q Have you ever received a call from 9 Bob Bennett of Skadden Arps law firm? 10 A I believe Mr. Bennett has called 11 before. 12 Q Called in the last 3 months? 13 A Yes. 14 Q How many times? 15 A Probably less than five. 16 Q Did you talk with Mr. Bennett when 17 he called? 18 A No, I did not. 19 Q Did you talk with Mr. Kendall when 20 we called? 21 A I don't remember. 22 Q Who did you put the call through 136 1 to? 2 A I mean, I don't remember. I don't 3 remember if Paul was there, or if I just took 4 a message. 5 Q Well, these people weren't calling 6 for you, correct? 7 A Correct. 8 Q So since you're the only other one 9 in the office, by definition, they were 10 calling for Paul, correct? 11 A Correct. 12 Q Now you sat there when these calls 13 were given to Paul, correct? 14 A I don't know. On occasion, I do 15 walk out of the room when people call. 16 Q Tell me what you remember about the 17 calls of Mr. Bennett, what was being 18 discussed? 19 A Oh, I don't remember. 20 Q Same question for Mr. Kendall. 21 A I don't remember. 22 Q Have you ever heard of a Victoria 137 1 Radd? 2 A Of Ms. Victoria Radd? 3 Q Yes. 4 A Yes, I know Ms. Radd, yes. 5 Q How do you know Ms. Radd? 6 A Because she's -- she's worked in 7 the White House on and off since I've been -- 8 most since I've been around, and -- most of 9 the time -- and when I did advance on the 10 debate preps, she was kind of -- she was in 11 the leadership position there, and so I 12 worked a little bit, not so much with her, 13 but I was there. I just know her from being 14 in the White House. 15 Q Now I'm going to show you what I'll 16 ask the court reporter to mark as Exhibit 1 17 to your deposition. This is a press release 18 of Judicial Watch of February 13, 1997, 19 headlined, "Stephanopoulos, Begala and 20 Carville Subpoenaed in Filegate." 21 A I see it. 22 (Parker Deposition Exhibit No. 1 138 1 was marked for identification.) 2 BY MR. KLAYMAN: 3 Q You see it? 4 A Uh-huh. 5 Q Have you ever seen this before? 6 A I believe I have. 7 Q When was the first time you saw it? 8 A I don't remember the date. 9 Q Was it on or about February 23, 10 1997? 11 A I don't know. 12 Q How did it come to your attention? 13 A I was called by someone in the 14 research office. 15 Q And who was that? 16 A I don't remember. 17 Q And did that person bring this 18 press release to your attention? 19 A Not necessarily. I mean, someone 20 in that office did, but I don't remember who 21 I talked to, and I don't remember who came 22 into the office. 139 1 Q Was it one of the two men that you 2 identified earlier? 3 A Not necessarily. 4 Q And what did that person say? Man 5 or a woman? 6 A It was a man. 7 Q And what did that person say? 8 A I only -- I mean, I vaguely 9 remember the conversation that, something 10 about Judicial Watch, something about Paul 11 being subpoenaed. Have you heard about this? 12 Have you seen it? Let me get the press 13 release to you. That's what I vaguely 14 remember. 15 Q They had talked to Paul before they 16 called you? 17 A No. 18 Q Did they say how they became aware 19 of this press release? They did; didn't 20 they? 21 MS. SHAPIRO: Objection. Let her 22 answer the question. 140 1 THE WITNESS: See, I think they 2 said -- see -- see, I can't answer it for 3 certain. 4 BY MR. KLAYMAN: 5 Q Well, tell me what you think they 6 said. 7 A I think they said it was faxed to 8 them from the Mary Madeleine Show. I don't 9 remember; I'm not sure. 10 Q Did they say who at the Mary 11 Madeleine Show faxed it? 12 A No. 13 Q Was anything else said during that 14 conversation? 15 A Not that I remember. 16 Q What happened after you received 17 the press release? 18 A I don't remember the chronology. I 19 remember having contact with Mr. Carville's 20 office. I believe -- I don't remember if 21 they were going to fax me a better copy, or 22 if I was going to fax them a copy we had. I 141 1 remember going to your web site to see if you 2 had listed it, to see if we could get them on 3 legible copy. I think it was Carville's 4 office that sent us a more legible version, 5 which may be this one. I don't know. And 6 then I remember putting it in Paul's box. 7 Q Did Carville's office contact you, 8 or did you contact Carville's office? 9 A I don't remember how it went. 10 Q Does your office keep phone 11 records? When you make a call, do you log in 12 the call? 13 A I -- when a call comes in for Paul, 14 I keep a phone log. However, as he answers, 15 as he calls each person back or deems that 16 he's not going to call them back, I take that 17 call out of the log. 18 Q What kind of a log do you keep? 19 A I keep it on Word Perfect, and it's 20 in a little graph. 21 Q It's where? 22 A It's in a graph or a table; it's in 142 1 like a table. 2 Q In the computer? 3 A It's something on Word Perfect; 4 yes, I keep it on the computer. 5 Q Do you have any kind of a message 6 pad that you write things down on? 7 A No. I did when we first started, 8 but that was -- I mean, I got rid of that as 9 soon as -- within the first couple of weeks 10 of my starting. 11 Q Have you ever erased any of these 12 telephone messages? 13 A That's what I said. Whenever he 14 calls someone back or deems that he's not 15 going to call someone back, I take them out. 16 I just, I delete them. 17 Q Now do you ever write down what the 18 person is leaving as a message? I guess you 19 do, do you, in the computer? 20 A If I get the message, yes. 21 Sometimes people don't leave messages. 22 Q And you type out the telephone 143 1 messages for him so you can give them to him, 2 correct? 3 A Usually, yes. 4 Q And those little messages are 5 stored somewhere in the office; aren't they? 6 A No, they're on this table. It's 7 all on the table in Word Perfect. It's my 8 little table in Word Perfect, and there's a 9 little section for the time, who called, the 10 number, message, and that's where I put it 11 all. 12 Q But do you type it out when Paul's 13 not there to give him the message? 14 A If Paul's not there to take the 15 call, okay. Well, Paul can be there and not 16 take the call when I put it in his phone log. 17 But for any situation where he's not taking 18 the call, I will put it in the phone log. 19 Q The computer phone log? 20 A Correct. 21 Q But you print it out to give it to 22 him if he's not there, correct? 144 1 A I always print it out to give it to 2 him. 3 Q And those are stored in a file 4 folder? 5 A No, when he's done, I throw it out. 6 Q You don't know if he throws them 7 out; do you? 8 A No, I take care of the phone log, 9 and I throw them out. 10 MR. KLAYMAN: The court reporter 11 needs to change the tape. 12 THE VIDEO SPECIALIST: We're going 13 off video record at 12:26. 14 (Recess) 15 THE VIDEO SPECIALIST: We're back 16 on video record at 12:28. 17 BY MR. KLAYMAN: 18 Q I take it, you recorded the call to 19 Carville on your phone records? 20 A No. 21 Q Is that because he called you? 22 A Okay, this is how it works. If 145 1 someone calls in, Paul's not there to take 2 the call, and it's for Paul, I will put it on 3 the record, okay? 4 Now if I'm calling out or Paul's 5 calling out, it's not recorded. 6 Q So it was most likely a call going 7 out from you to Carville? 8 A I don't remember how it went. 9 Q Who did you talk to at Carville's? 10 A I don't remember. 11 Q What was said? 12 A All I remember is asking them if 13 they -- I remember talking to them about 14 getting a better copy of the, of the press 15 release. I mean, as you can see, it's hardly 16 legible. 17 Q Who did you talk to there? 18 A I don't remember. 19 Q Now you say you put it in Paul's 20 inbox? 21 A Correct. 22 Q Did you then bring it to Paul's 146 1 attention when he came back? Was he there at 2 the time you put it in the his inbox? 3 MS. SHAPIRO: Objection. Compound 4 question. 5 BY MR. KLAYMAN: 6 Q He was there when you put it into 7 his inbox? 8 A No, he was not. 9 Q He was out of the office? 10 A Yes, he was. 11 Q When did he come back? 12 A I don't remember. Later that day. 13 Q And he became aware that he saw 14 this press release in the end box? 15 A I believe I paged him. 16 Q You paged him before he came back? 17 A Yes, but I page him often. 18 Q Because you viewed this as an 19 urgent matter? 20 A I page him often. 21 Q Because you viewed this as an 22 urgent matter? 147 1 A I page him often, with matters that 2 I would not consider urgent. 3 Q Important? 4 A Yes, I considered it important. 5 Q And he came back to the office, 6 correct? 7 A Eventually he came back to the 8 office. 9 Q And you had a discussion with him 10 about this press release? 11 A No. 12 Q You did discuss the press release 13 with him when he got back? 14 MS. SHAPIRO: Asked and answered. 15 THE WITNESS: No, I did not. 16 BY MR. KLAYMAN: 17 Q You never discussed this press 18 release with Mr. Begala? 19 MS. SHAPIRO: Asked and answered. 20 BY MR. KLAYMAN: 21 Q You can answer. 22 A No, I've never discussed the press 148 1 release with him. 2 Q Did you become aware that he saw 3 this press release when he came back? 4 A I saw him read the press release. 5 Q And what did he say, if anything, 6 when he read it? 7 A I don't remember what he said. I 8 think I may have seen him breathe deeply, but 9 I don't remember what he said, if he said 10 anything at all. 11 Q Did he do anything after that? Did 12 he call anyone? 13 A I'm not aware of him calling anyone 14 regarding this. 15 Q That wasn't my question. 16 MS. SHAPIRO: That was your 17 question. 18 BY MR. KLAYMAN: 19 Q No, it was a much broader response 20 than my question, which obviously causes me 21 to think maybe I need to ask my question 22 differently. 149 1 A Then please do. 2 Q Were you programmed to make that 3 response? 4 MS. SHAPIRO: Objection. 5 BY MR. KLAYMAN: 6 Q You realize I was going to ask that 7 question before you came here today? 8 MS. SHAPIRO: Objection. Is there 9 some reason why you feel like you have to 10 beat up on this witness? 11 MR. KLAYMAN: I don't call this 12 beating up on anybody. The record will speak 13 for itself. 14 BY MR. KLAYMAN: 15 Q Before you came in here, did you 16 think that Larry Klayman was going to ask you 17 this question? 18 A Sir, I have -- I really could -- I 19 would not dare venture to guess what you're 20 going to ask me. 21 Q You wouldn't have an inkling? 22 A I have lots of inklings. 150 1 Q That's why you spent 4 hours with 2 Ms. Paxton? 3 MS. SHAPIRO: Objection. You're 4 arguing with the witness, over nothing 5 relevant to this matter, I might add. 6 BY MR. KLAYMAN: 7 Q Are you saying that when you met 8 with Ms. Paxton, you weren't discussing this 9 deposition? 10 MS. SHAPIRO: Objection. She is 11 not going to answer any question about the 12 substance of our conversations -- 13 BY MR. KLAYMAN: 14 Q Were you discussing this 15 deposition? 16 MS. SHAPIRO: Please let me finish 17 my objection. I was in mid sentence. 18 MR. KLAYMAN: You have a staccato 19 style, Ms. Shapiro. 20 MS. SHAPIRO: But obviously I'm in 21 the middle of talking when you talk over me. 22 I ask you a simple courtesy. Are you a
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of this deposition