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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