151
1 professional?
2 MR. KLAYMAN: Okay. Insult.
3 Certify, improper conduct.
4 MS. SHAPIRO: I expect you to act
5 in a professional manner. I give you that
6 courtesy. I expect the same.
7 MR. KLAYMAN: Certify this.
8 THE WITNESS: Could you please
9 restate your question?
10 BY MR. KLAYMAN:
11 Q Did you discuss the deposition in
12 this deposition in your four hour meeting
13 with Ms. Paxton, correct?
14 MS. SHAPIRO: And I have instructed
15 her not to answer the question, because it is
16 subject to attorney-client privilege. She's
17 not to disclose the substance of her
18 conversation between her and her counsel.
19 MR. KLAYMAN: Certify this.
20 BY MR. KLAYMAN:
21 Q Tell me, just in narrative fashion,
22 whether from the point that you became aware
152
1 of this press release up to today, you're
2 aware of any conversation that Mr. Begala had
3 with anybody concerning Judicial Watch's
4 lawsuit that you're here on today?
5 MS. SHAPIRO: Asked and answered.
6 THE WITNESS: I'm not aware of him
7 having any conversation regarding Judicial
8 Watch's lawsuit.
9 BY MR. KLAYMAN:
10 Q Are you aware of him having any
11 conversation with regard to George
12 Stephanopoulos's statements on ABC "This
13 Week" on February 8, dealing with Ellen
14 Roemech. Are you aware of that?
15 MS. SHAPIRO: Objection. Lack of
16 foundation.
17 BY MR. KLAYMAN:
18 Q You can respond.
19 A I mean, he may have talked about
20 it, but he talks a lot about what George says
21 on Sunday morning.
22 MR. KLAYMAN: I'll show you what
153
1 I'll ask the court reporter to mark as
2 Exhibit 2.
3 (Parker Deposition Exhibit No. 2
4 was marked for identification.)
5 MR. KLAYMAN: This is a transcript
6 of Mr. Stephanopoulos' appearance on
7 February 8, 1998, on This Week with Sam
8 Donaldson and Cokie Roberts.
9 THE WITNESS: Thank you.
10 MR. KLAYMAN: Take an opportunity
11 and review this, particularly pages 1, 2 and
12 3, 2 and 3 in particular.
13 BY MR. KLAYMAN:
14 Q Did you watch ABC's This Week with
15 Sam Donaldson and Cokie Roberts on February
16 8th where George Stephanopoulos made the
17 references contained on pages 2 and 3?
18 A I don't believe I watched it when
19 it first aired.
20 Q Did you watch it after that?
21 A I've seen so many clips of George
22 on TV I don't remember exactly what I've seen
154
1 and what I haven't seen.
2 Q Do you sometimes play back George's
3 appearances in the office?
4 A We usually don't play them back.
5 We get the transcripts, but I've never
6 ordered This Week with ABC to be played back.
7 Q Do you sometimes get video?
8 A On rare occasion, we ask to have
9 news programs played back, or on even rare
10 occasion, we ask for the videotapes.
11 Q I take it for this appearance,
12 someone asked for the videotape of George's
13 appearance?
14 A Not -- I do not know of that.
15 Q Did someone ask for the transcript?
16 A We automatically get the
17 transcripts.
18 Q How does that happen?
19 A There's a person who works -- I
20 don't know exactly in which office he works,
21 but he's kind of in charge of getting -- he's
22 in -- he works on the clips, and he's kind of
155
1 in charge of getting transcripts of news
2 shows. And through him, we get it by E-mail.
3 Q And who is that person?
4 A His full name is Dagoberta Vera,
5 but he goes by Dag. I can't verify the exact
6 spelling of his name.
7 Q Where does he work?
8 A I said I don't know exactly which
9 department he's in.
10 Q He works for Sid Blumenthal?
11 MS. SHAPIRO: Objection. She
12 answered the question. She doesn't know.
13 MR. KLAYMAN: Certify that. That's
14 inappropriate. She said she doesn't know
15 exactly the department, yet you shut the door
16 with her with the way you give her a speaking
17 objection. Certify it. Improper conduct.
18 THE WITNESS: I don't know who he
19 -- I don't know what the line of authority is
20 in his world. I just don't.
21 BY MR. KLAYMAN:
22 Q Where do you think he works?
156
1 A Why?
2 Q Because I get the ask the
3 questions.
4 A Okay. I'm happy to make a guess
5 for you. My guess is that he's perhaps in
6 communications, but I don't know that for
7 sure.
8 Q Do you know where his office is?
9 A Yes.
10 Q Where is that?
11 A He's in the Old Executive Office
12 Building on the first floor.
13 Q And what's the office number?
14 A I don't know.
15 Q And it's in the Communications
16 Department, correct?
17 MS. SHAPIRO: Objection.
18 THE WITNESS: I am not aware.
19 BY MR. KLAYMAN:
20 Q Well, whom is his office located
21 near?
22 A That's not an indicator, sir.
157
1 Q Who is his office located near?
2 A He's by Cabinet Affairs. He's by
3 Communications.
4 Q Near Sid Blumenthal?
5 A No, he's not.
6 Q Who is he near?
7 MS. SHAPIRO: Objection. Asked and
8 answered.
9 THE WITNESS: He is by -- he's by
10 Cabinet Affairs. He's by some communications
11 people. I don't know -- I don't -- I'm not
12 aware of who sits in every office.
13 BY MR. KLAYMAN:
14 Q Okay. Why was this -- I take it
15 this transcript came in the ordinary course
16 of what you guys do?
17 A Uh-huh.
18 Q Did someone sit down and review it
19 at that time?
20 A I am not aware.
21 Q Did you see Mr. Begala reviewing
22 it?
158
1 A I can't be certain.
2 Q Well, do you think you saw him
3 reviewing it?
4 A I've seen him review several
5 transcripts, and when he's reviewing it on
6 the computer, from where I sit, I can't tell
7 what he's reviewing.
8 Q You heard people discuss this
9 transcript, didn't you, since in the last few
10 months at the White House? You heard people
11 discuss George Stephanopoulos's remarks about
12 an Ellen Roemech strategy, correct? I remind
13 you you're under oath.
14 MS. SHAPIRO: Objection.
15 THE WITNESS: I know I'm under
16 oath, sir. And especially because I'm under
17 oath, I don't know specifically if anyone
18 talked about that particular comment. People
19 talk about what George says on TV.
20 BY MR. KLAYMAN:
21 Q Have you had an opportunity to
22 review this comment?
159
1 A Yes, I have, sir.
2 Q Did you review it before today?
3 A Yes, I have.
4 Q Did you review it in the presence
5 of counsel?
6 MS. SHAPIRO: You can answer that.
7 THE WITNESS: I mean, yes.
8 BY MR. KLAYMAN:
9 Q You're aware of what George said
10 was, "I agree with that, and there is a
11 different long-term strategy which I think
12 would be far more explosive. White House
13 allies are already starting to whisper about
14 what I'll call the Ellen Roemech strategy.
15 She was a girlfriend of John F. Kennedy, who
16 also happened to be an East German spy. And
17 Robert Kennedy was charged with getting her
18 out of the country and also getting John
19 Edgar Hoover to go to Congress and say, don't
20 you investigate this, because if you do,
21 we're going to open up everybody's closets.
22 And I think in the long run, they have a
160
1 deterrent strategy on getting a lot of..."
2 You understand that to mean that J.
3 Edgar Hoover looked into Ellen Roemech's
4 affairs with members of Congress and John F.
5 Kennedy; don't you?
6 A I don't understand that to mean
7 that.
8 Q You understand that this is
9 referring to the use of FBI files by J. Edgar
10 Hoover?
11 MS. SHAPIRO: Objection.
12 Relevancy.
13 BY MR. KLAYMAN:
14 Q You can respond?
15 A I don't -- I don't think that --
16 you can necessarily come to that -- that only
17 -- I don't think that's the only conclusion
18 one can come to from reading that statement.
19 Q What a the other conclusion?
20 A I think there's several other
21 conclusions.
22 Q What other conclusions?
161
1 A I think it's odd that you're asking
2 me to comment on what is George's intent.
3 Q But I'm asking you to comment. And
4 what other conclusions have you reached about
5 that statement?
6 A Well, when I first read it -- I
7 mean, if you want to -- if you want to say
8 bad things about person, you don't have to go
9 to -- you can go to other sources other than
10 someone's confidential files to find out bad
11 thing about a person, so it never even
12 occurred of me to think of the FBI files.
13 Q Are there other explanations?
14 A I'm sure there are, but that's the
15 one that I primarily have in my hold.
16 Q What is the secondary explanation
17 of that?
18 A I don't have a secondary
19 explanation. I'd have to come up with one
20 now. I'm not very familiar with the context
21 and the history of his comment. I hadn't
22 really given it too much thought until all of
162
1 this.
2 Q What's all of this? What do you
3 mean all of this?
4 A Until I was subpoenaed and called
5 at deposition.
6 Q But you have heard people around
7 the White House talk about this particular
8 comment that George made; have you not?
9 MS. SHAPIRO: Asked and answered.
10 BY MR. KLAYMAN:
11 Q You can respond?
12 A I don't know.
13 Q You're saying you haven't heard
14 Paul Begala make any reference to this
15 comment by George?
16 A I mean, he may have.
17 Q And what leads you to believe he
18 may have?
19 A The problem is, I don't -- I don't
20 sit and listen to Paul's conversations. I
21 get impressions. I hear the occasional word.
22 I don't have coherent narratives, and so it's
163
1 very difficult to answer your question in the
2 narrative fashion that you'd like me to do
3 it.
4 Q I'll take it in any fashion.
5 A Okay. I mean, he may have -- he
6 may have said the name. He may have said
7 George said this, but I don't remember
8 exactly what he said. I don't remember when
9 he said it, and the problem is, I also, not
10 only do I have Paul's voice, I also have the
11 TV, and so often, when I think about the
12 past, I think about what I'm hearing on TV, I
13 think about maybe I heard Paul say. So I
14 can't sit here and say categorically that I
15 heard Paul say XYZ about this, because I
16 don't have that for a solid memory.
17 Q There is a TV in the office.
18 A Yes, there is.
19 Q Is there more than one?
20 A One.
21 Q And is that on all day long?
22 A Usually.
164
1 Q A remote control so you can flip
2 through it?
3 A Uh-huh.
4 Q You're flipping through it to see
5 if there's anything discussed about the White
6 House? Is that your job?
7 A Primarily it's on CNN. If it gets
8 flipped, if I'm flipping it, it's because I
9 don't want to watch CNN, and I want to watch
10 something non-news related, or if he flips
11 it, I don't know what his motivations for
12 flipping it.
13 Q Now you have heard people call in
14 with telephone discussions with Paul about
15 this particular statement by George; haven't
16 you?
17 A Could you repeat that?
18 MS. SHAPIRO: Asked and answered.
19 BY MR. KLAYMAN:
20 Q You are aware that people called
21 Mr. Begala to discuss this statement of
22 Mr. Stephanopoulos?
165
1 A No, I'm not.
2 Q You're aware that Mr. Begala has
3 called others outside of the White House or
4 inside the White House to discuss this
5 statement by George Stephanopoulos?
6 MS. SHAPIRO: Asked and answered.
7 THE WITNESS: I'm not aware.
8 BY MR. KLAYMAN:
9 Q I have never asked and answered
10 that, and that is another way to signal the
11 witness. Certify it.
12 MS. SHAPIRO: The record will speak
13 for itself.
14 MR. KLAYMAN: Improper conduct.
15 It's the way to tell it; she's already
16 answered it.
17 MS. SHAPIRO: The transcript will
18 say that she's already answered it.
19 MR. KLAYMAN: It's wholly
20 inappropriate, Ms. Shapiro.
21 BY MR. KLAYMAN:
22 Q Have you heard George's statement
166
1 about Ellen Roemech, or even just a general
2 statement that White House allies are
3 whispering about a strategy against persons?
4 Have you heard that discussed anywhere?
5 Inside the White House, outside, by anybody,
6 at any time?
7 A Not to it specifically. I have
8 vague memories of people discounting what
9 George says or disagreeing with what George
10 says.
11 Q Who are those people?
12 A Paul.
13 Q And anyone else?
14 A It's pretty surreal, because I
15 can't distinguish necessarily between if I've
16 heard someone in person say something, or if
17 I've seen them on TV in an interview saying
18 something, or if I read of something that
19 they have said. But I have heard Paul have
20 issues with what George has said on
21 television.
22 Q And with regard to this particular
167
1 comment?
2 A I don't know if it's in regard to
3 that particular comment.
4 Q Now if true, this comment would be
5 pretty significant, wouldn't it, based on
6 your understanding of what it meant under any
7 scenario?
8 MS. SHAPIRO: Objection. Lack of
9 foundation.
10 THE WITNESS: Actually, I told you.
11 BY MR. KLAYMAN:
12 Q You can respond.
13 A Well, I'll tell you again what I
14 first thought of when I read that comment.
15 It never occurred to me that anyone would be
16 looking in FBI files.
17 Q When did you first hear this
18 comment?
19 A Around when it was made.
20 Q And who brought it to your
21 attention?
22 A I saw it on television, I believe.
168
1 I either saw it on television, or I read it
2 in the paper.
3 Q Where were you at the time?
4 A I mean, I was in Washington. I
5 don't know if I was in the office or at home.
6 Q You've gone over to Paul Begala's
7 house; haven't you?
8 A No, I have not.
9 Q You've had gone out to lunch with
10 him from time to time?
11 A We've had lunch in the mess once.
12 Q Have you gone out to dinner with
13 Paul or anybody in his family?
14 A I've gone out to dinner with Paul
15 once.
16 Q Recently?
17 A Before I came on as his assistant.
18 Q When was that?
19 A It was either in August or
20 September.
21 Q Was anyone else present?
22 A No.
169
1 MR. KLAYMAN: We can take lunch.
2 MS. SHAPIRO: The witness doesn't
3 want to take lunch.
4 MR. KLAYMAN: I want to take lunch.
5 MS. SHAPIRO: How long do you need?
6 MR. KLAYMAN: Half hour. We'll
7 reconvene at 1:20.
8 THE WITNESS: Okay. That's fine.
9 THE VIDEO SPECIALIST: We're going
10 off video record at 12:49.
11 (Whereupon, at 12:49 p.m., a
12 luncheon recess was taken.)
13
14
15
16
17
18
19
20
21
22
170
1 A F T E R N O O N S E S S I O N
2 (1:25 p.m.)
3 Whereupon,
4 ELEANOR STACY PARKER
5 was recalled as a witness and, having been
6 previously duly sworn, was examined and
7 testified further as follows:
8 EXAMINATION BY COUNSEL FOR PLAINTIFFS
9 CONTINUED
10 THE VIDEO SPECIALIST: We're back
11 on video record at 1:25 p.m.
12 BY MR. KLAYMAN:
13 Q Ms. Parker, have you ever met the
14 President of the United States?
15 A Yes, I have.
16 Q When did you first meet him?
17 A When I attended a radio address in
18 1993.
19 Q Was anybody with you at the time of
20 that radio address besides the President?
21 A There were the other attendees of
22 the radio address.
171
1 Q Who was that?
2 A And some staff people, I think.
3 Q Who was there?
4 A I don't know -- I didn't know
5 anybody else, who was in there, and there may
6 have been staff people in there, but I don't
7 remember who else was in there.
8 Q Was Charlie Chung in there?
9 A To the best of my knowledge, no.
10 Q Did you see anybody who looked Far
11 Eastern?
12 MS. SHAPIRO: Objection.
13 BY MR. KLAYMAN:
14 Q You can respond.
15 A That's an awful question, but no, I
16 don't remember anyone who looked Far Eastern
17 in there.
18 Q Okay. When was the next time you
19 met the President?
20 A I don't remember. There were
21 occasional times that he would stop in, and I
22 may have exchanged a pleasantry or two, but I
172
1 don't remember when was the next time.
2 MR. KLAYMAN: Hold on one second.
3 We'll repeat that. Could you repeat the
4 question?
5 (The reporter read the record as
6 requested.)
7 BY MR. KLAYMAN:
8 Q Has he come by in the last
9 3 months?
10 A Define what you mean by come by.
11 Q Drop by the office.
12 A No, he has not.
13 Q Have you talked to him by phone?
14 A No, I have not.
15 Q Has he called Mr. Begala when
16 you've picked the phone up?
17 A No, he has not.
18 Q Have you attended any White House
19 functions where the President was there as
20 well?
21 A Yes, I have.
22 Q What were those?
173
1 A I remember a birthday party that
2 was thrown for him by the staff. I believe
3 it was in the summer of '93. That I
4 attended. It was on the south lawn.
5 I went to a holiday party last
6 December where I -- where I went through the
7 receiving line and exchanged words. Those
8 are the only functions.
9 Q Have you ever been in the
10 President's presence when issues with regard
11 to files or Ellen Roemech or George
12 Stephanopoulos or Paul Begala were discussed?
13 Any of those issues or names?
14 MS. SHAPIRO: Objection. Compound
15 question.
16 BY MR. KLAYMAN:
17 Q Any of those issues or names?
18 A Are you connecting -- did all those
19 four names have to come up in one
20 conversation?
21 Q No. No.
22 A I remember having a couple of
174
1 conversations where the President will come
2 in and be like, where's George, and I would
3 try to answer. I remember when I first met
4 him, I told him that I did George's
5 correspondence. Those the only times I
6 remember talking about either of those four
7 names or people.
8 Q Have you ever met with the
9 President one on one, you and the President?
10 A When do you mean by that?
11 Q Where nobody else was present?
12 A I mean I've never scheduled a
13 meeting with the President. I mean, there
14 have been times when he's dropped in to --
15 when I worked in George's office, he would
16 occasionally walk through looking for George.
17 But I don't know what he was doing, but I
18 assume he was looking for George, and those
19 are the only times where I've been in that
20 room -- that in that room, he and I were
21 alone.
22 Q Did you ever have a discussion
175
1 about anything related to George
2 Stephanopoulos or Paul Begala or FBI files or
3 anybody like that, Ellen Roemech?
4 MS. SHAPIRO: Asked and answered.
5 BY MR. KLAYMAN:
6 Q You can respond.
7 A I mean, you did ask me that.
8 Q Yes, well, I'll trying to see if
9 that may jog your memory?
10 A I mean, I told you when he'd come
11 through, he'd ask where George was.
12 MR. KLAYMAN: Take a break. I'll
13 be right back.
14 THE VIDEO SPECIALIST: We're going
15 off video record at 1:31.
16 (Recess)
17 THE VIDEO SPECIALIST: We're back
18 on video record at 1:32.
19 BY MR. KLAYMAN:
20 Q Have you ever had contact with
21 anybody from the White House office of
22 security.
176
1 A I don't quite understand your
2 question. I understand there was an office
3 of personnel security I think that existed.
4 And now I know there is an EOP office of
5 security. So I need to know better what
6 you're referring to.
7 Q Well, how do you know that there is
8 a White House office of personnel security?
9 A I understand that there was.
10 Q How did you come to that
11 understanding?
12 A Well, I have been in the White
13 House on around off for the last 3 years, and
14 I have managed to cull some information about
15 the different offices. I mean, be able to
16 understand that they exist. And so somehow
17 along the way, I understood that this office
18 existed.
19 Q Did you have contact with that
20 office?
21 A Yes, I did.
22 Q Under what circumstances?
177
1 A When I first turned in my papers,
2 my -- I forget -- SF-86 for my first
3 background check. I believe I dropped them
4 off there.
5 There was also one time when I was
6 a volunteer. There was a problem in our
7 office that one of the other volunteers had a
8 key to an office in the Old Executive Office
9 Building, and so Craig Livingston wanted to
10 talk to us about it, and so I remember
11 meeting with Mr. Livingston to discuss why
12 people who are not staff should not have
13 keys.
14 Q Okay. Is this a different set of
15 circumstances when you first dropped
16 something off and when you had the meetings
17 with Mr. Livingston?
18 A Yes, they are two different.
19 Q What did you drop off?
20 MS. SHAPIRO: Asked and answer.
21 MR. KLAYMAN: I'm sorry; I may have
22 not heard.
178
1 THE WITNESS: I believe it's called
2 a SF-86, but I believe it's the paperwork I
3 filled out to begin my backup check.
4 BY MR. KLAYMAN:
5 Q When you dropped it off, did you
6 give it to anybody?
7 A I don't remember.
8 Q Did you give it to Craig
9 Livingston?
10 A I really doubt I gave it to him.
11 Q Was it a man?
12 A I mean, I have as vague memory of
13 people being in the office and me dropping it
14 off. I don't remember if I actually manned
15 it to someone, or if I put it in someone's
16 inbox.
17 Q Do you know what Mr. Livingston
18 looks like?
19 A Yes, I do.
20 Q Heavy set fellow?
21 A I'm aware of Mr. Livingston looks
22 like.
179
1 Q Okay. Now when you were in that
2 office, did you see anything, anything laying
3 around? What year was that?
4 A '93.
5 Q Did you see boxes laying around?
6 A I don't remember surveying the
7 office.
8 Q Did you see anything that looked
9 like files laying around?
10 A No, I don't. I don't remember what
11 was in the office, other than desks and
12 people.
13 Q Was the office impeccably neat?
14 Was it kind of disheveled? I mean, what did
15 it look like, generally speaking? A lot of
16 junk laying around? Paper?
17 A I don't remember what it like
18 that. Nothing stood out. It didn't stand
19 out as a poorly kept office or as an
20 impeccably kept office. It was just an
21 office I was dropping my forms off to.
22 Q Was there anyone down that worked
180
1 Mr. Livingston or whoever was running it at
2 the time, like a secretary or assistant whose
3 name you remember?
4 A As I said before, I remember people
5 in the office. I don't remember who I gave
6 it to. I don't know what they did. I don't
7 know who they were. But I remember there
8 being people in the office.
9 Q The second time that you went back,
10 when was that approximately? When you met
11 Mr. Livingston?
12 A This -- both occurrences happened
13 in '93, to the best of my memory.
14 Q And I apologize, but what was the
15 second time you went back? When was that?
16 A The first time was I talked about
17 the keys. The second time was to drop off my
18 paperwork.
19 Q And Mr. Livingston, where did you
20 find him in that office when you dropped it
21 off?
22 A I don't remember -- when I dropped
181
1 off my paperwork, I don't remember seeing him
2 in the office.
3 Q I thought you told me you met with
4 him then?
5 A That was the key issue.
6 Q That was issue one?
7 A That was issue one.
8 Q So you gave the keys to
9 Mr. Livingston?
10 A I don't remember if there was a
11 transfer of keys. I just remember that he
12 talked to us about the situation.
13 Q Okay. The second time that you
14 went, you didn't see Livingston?
15 A I have a memory of seeing him in
16 the office.
17 Q Did you see anyone else in the
18 office?
19 A I said I saw people in the office.
20 MS. SHAPIRO: Asked and answered.
21 BY MR. KLAYMAN:
22 Q Who else did you see?
182
1 MS. SHAPIRO: Asked and answered.
2 MR. KLAYMAN: You can respond.
3 THE WITNESS: I told you I saw
4 people in the office. I don't know who they
5 are. I don't know what they did, but they
6 existed.
7 BY MR. KLAYMAN:
8 Q That's the only two times that you
9 had contact with that office?
10 A That's the only two times I
11 remember going in that office.
12 Q Did you ever talk to them by phone?
13 A I don't know, because it's
14 conceivably that someone from that office
15 might have called in to talk to someone who
16 worked in George's office or to talk to
17 George. I took a lot of phone calls. I
18 didn't know why exactly why they were
19 calling, so it's conceivable that I talked to
20 somebody from that office, but nothing stands
21 out in my mind.
22 Q Did George Stephanopoulos ever
183
1 receive any documents from Craig Livingston
2 or OPS?
3 A I'm not aware of any documents.
4 Q Did you ever meet Anthony Marsesa?
5 A No, I have not.
6 Q Have you ever met Bernard Nussbaum?
7 A I've never met Mr. Nussbaum, but
8 he's come in and out of the office when I've
9 been in there, but I've never -- I don't
10 think I've exchanged pleasantries with the
11 man.
12 Q Have you ever heard anymore discuss
13 anything with regard to FBI files?
14 A I do not have any kind of
15 recollection of that.
16 Q Was he frequently in the office
17 when you worked for George Stephanopoulos?
18 A He was occasionally in the office.
19 I don't have a memory of him being in there
20 anymore than anybody else was.
21 Q Have you ever met or talked to
22 Richard Ben-Veniste?
184
1 A Ben-Veniste.
2 Q Yes, however you pronounce it.
3 A I spoken with Mr. Ben-Veniste.
4 Q Have you talked to him recently?
5 A I -- I mean, I take the phone calls
6 when he calls in.
7 Q And he's called in the last several
8 week; has he not?
9 A Well, yes, he has.
10 Q And in fact, you were sitting there
11 when he called, and Mr. Begala talked to him?
12 A On occasion, I have been in the
13 office when they've talked.
14 Q Okay. You have overheard a
15 conversation that he had about Mr. Begala's
16 involvement in this Judicial Watch case?
17 A No, I have not. Because those
18 conversations are privileged, I leave the
19 room to protect that privilege.
20 Q Is Mr. Richard Ben-Veniste retained
21 as counsel for Mr. Begala, to the best of
22 your knowledge?
185
1 A I don't know their exact
2 relationship, but I do know that -- I do know
3 that they have a relationship. I don't know
4 what.
5 Q Is it a professional relationship
6 or a personal relationship?
7 A I'm not really -- I can't really
8 speak to that. I don't know what the
9 relationship that they have.
10 Q Has anyone ever told you to leave
11 the room when Richard Ben-Veniste called?
12 A There was one time Paul asked me to
13 leave the room.
14 Q When was that?
15 A I don't remember.
16 Q Recently?
17 A This year.
18 Q Within the last few weeks?
19 A Not necessarily within the last few
20 weeks. I don't remember.
21 Q After February 8, 1998? Around
22 that time?
186
1 A Sir, to answer your question, it
2 was this year. I don't know exactly when.
3 Q Why did Paul ask you to leave the
4 room? Did he tell you?
5 A He doesn't have to tell me
6 everything.
7 Q I didn't ask that. I said did he
8 tell you why?
9 A I didn't ask why. No, he did not.
10 I'm sorry.
11 Q Have you ever met a Thurgood known
12 as Goody Marshal?
13 A We've never actually met.
14 Q Have you talked to him by phone?
15 A Infrequently.
16 Q Who is Thurgood Goody Marshal?
17 A I know he's a senior staff member.
18 I know he works in Cabinet Affairs. I don't
19 know exact -- I don't know what exactly what
20 he does. I'm pretty sure he works in Cabinet
21 Affairs. I may even be wrong on that, but I
22 don't have very many dealings with him.
187
1 Q What dealings, if any, does Paul
2 have with him?
3 A Professional dealings.
4 Q Do you know in what it's regard to?
5 A Trying to do their day jobs.
6 Q You're aware that Paul Begala was
7 recently deposed in this lawsuit, correct?
8 A Yes, I am.
9 Q And did Thurgood Goody Marshall
10 come to the office or did you overhear him
11 say to Paul, gee, I think it's unfair you're
12 being deposed?
13 A No, I did not.
14 Q Have you heard him say anything
15 about this particular lawsuit?
16 A Yes, I have.
17 Q When was that?
18 A I don't know exactly when, but in
19 correspondence to the time that he was made
20 aware that he was being subpoenaed, up until,
21 you know, after he was deposed.
22 Q You're talking about Paul Begala?
188
1 A That's who I am talking about.
2 Q And what did Paul tell you about
3 this lawsuit?
4 MS. SHAPIRO: That's been asked and
5 answered.
6 BY MR. KLAYMAN:
7 Q You can respond. I now have a
8 response.
9 MS. SHAPIRO: If you have a
10 response, why are you asking the question?
11 MR. KLAYMAN: Please don't mess up
12 my question.
13 THE WITNESS: Could you please ask
14 the question.
15 BY MR. KLAYMAN:
16 Q What did you discuss?
17 A I mean, we didn't discuss. I mean,
18 he, he has a -- expressed some opinions about
19 his particular situation, but there was never
20 a following discussion.
21 Q What opinions did he express?
22 A He expressed frustration. He said
189
1 that he was angry, and he expressed that his
2 wife was very angry.
3 Q Did he say why his wife was angry?
4 A He felt that -- she felt that you
5 had defamed him.
6 Q Did he say how?
7 A Your comments on -- I believe it
8 was MSNBC, but your television comments.
9 Q Were you sitting there at the time
10 when MSNBC came on?
11 A Yes, I was.
12 Q Well, tell us about what else he
13 told you?
14 A I mean, that was basically, that
15 was basically it.
16 Q Have you ever discussed this case
17 with Goody Marshal?
18 A No, I have not.
19 Q You say you were sitting there when
20 I came on MSNBC. Do you remember when that
21 was?
22 A I have a memory of it.
190
1 Q Who else was in the office with you
2 at the time?
3 A Paul.
4 Q And you both saw the comments at
5 the same time?
6 A No, because I didn't really pay
7 attention to too much of it, because I had
8 other things that I was doing.
9 Q And did he remark, you know, here's
10 Klayman on TV talking my speech in Miami, or
11 something like that?
12 A I don't remember what he remarked.
13 Q Do you remember him calling MSNBC,
14 though; don't you?
15 A Yes, I do.
16 Q And did he ask you to call, or did
17 he call?
18 A He didn't ask me to call, so --
19 Q He called?
20 A He called.
21 Q And do you know whom he called?
22 A I don't know for sure, no.
191
1 Q A person by the name of Kenan
2 Block; does that ring a bell?
3 A That name rings a bell.
4 Q And what did he say to Kenan Block?
5 A I don't remember exactly what he
6 said.
7 Q He called Larry -- he called
8 Mr. Klayman some names with Kenan block?
9 A I don't remember if he did that.
10 MS. SHAPIRO: I object to the
11 relevancy of this. I don't know if you're
12 defending your own suit or this suit, but I
13 don't know what the relevance is.
14 BY MR. KLAYMAN:
15 Q Did he have a discussion with Kenan
16 Block where he said something to the effect,
17 what I said about FBI files was just a joke?
18 A I can't -- I can't characterize
19 what Paul said, because I don't remember what
20 Paul said, and so I'm not -- I have heard
21 Paul say lots of different things about lots
22 of different things, and I, I, I can't say
192
1 with any kind of accuracy, or I can't repeat
2 with any kind of accuracy what he said.
3 Q Just generally, what do you
4 remember as of today?
5 A No, because you're suggesting
6 things to me and, and I don't remember.
7 Q Well, you have to testify.
8 MS. SHAPIRO: She doesn't have to
9 testify as to things she doesn't remember.
10 If she can't remember, she can't remember.
11 MR. KLAYMAN: Well, I'm not getting
12 the impression that she can't remember.
13 She's basically saying, unless I can say it
14 exactly, I'm not going to give you any
15 testimony.
16 And what I'm telling you is you
17 have to tell me what's in your mind as of
18 today, what you remember as of today.
19 THE WITNESS: And I'm telling you
20 that I don't remember what he said to Kenan
21 Block, or whatever his name is.
22 BY MR. KLAYMAN:
193
1 Q But you did discuss, you heard the
2 word joke; didn't you?
3 A Not necessarily in that exchange.
4 Q You heard it in another exchange?
5 A Correct.
6 Q What exchange was that?
7 A I mean, there have been times when,
8 when he's expressing anger, it's because he
9 had made a joke, and, and later he knew that
10 you understood that, and he was angry that
11 you understood that, but yet were pursuing
12 this.
13 Q When did he tell you that Larry
14 Klayman understood that?
15 A I don't -- I don't exactly remember
16 when.
17 Q Recently?
18 A Well, obviously recently.
19 Q And what did he say, specifically,
20 as best you can remember it today?
21 A That's how I remember it.
22 Q And you remember when he talked to
194
1 MSNBC that he asked them to say on the air
2 that it was a joke?
3 A I don't remember that.
4 Q And you remember that MSNBC asked
5 him if he wanted to come on, come on air at
6 that time? You remember him saying that;
7 don't you?
8 A See, no, because -- see, my -- no,
9 I don't remember that. I don't.
10 Q You don't remember him saying MSNBC
11 wants me to come on, but I'm not going to do
12 it? Something like that?
13 A All I remember is that we were
14 going to Mass. It was Ash Wednesday. Now
15 I'm remembering it, and that's -- and that we
16 wanted someone else to watch the show.
17 Q Who did you get to watch the show?
18 A I -- he called Rahm's office, I
19 think.
20 Q Rahm Emanuel?
21 A Correct.
22 Q And he asked Rahm To watch the
195
1 show?
2 A No, to ask his intern.
3 Q Who is his intern?
4 A He's no longer an intern, but his
5 name is Rajiv, and I don't know his last
6 name.
7 Q How is his first name spelled?
8 A R-a-j-i-v.
9 Q And specifically, what did he say
10 to Rajiv?
11 A I don't remember.
12 Q Watch this and give me back a video
13 copy, or something like that?
14 A No, I don't remember. I don't
15 listen to every word Paul says.
16 Q Did you discuss this MSNBC
17 appearance by me, Larry Klayman when you went
18 with Mass with Paul, on the way to Mass? You
19 must have?
20 A I don't think so.
21 Q Did you discuss it after Mass?
22 A I think I may have said you better
196
1 call Rajiv. And that's the only thing I
2 remembered talked about on the way home, I
3 mean, back to work.
4 Q Why did you tell Paul that he
5 better call Rajiv?
6 A I was just reminding him.
7 Q Did he ask you to remind him?
8 A No, but I remind him of lots of
9 thing each day.
10 Q Well, why would you feel that he
11 had to call Rajiv, if you really didn't know
12 what was going on?
13 A I had a general understanding of
14 what was going on.
15 Q What was the general understanding?
16 A I have a general understanding, now
17 this is my opinion, okay, that I formed by
18 myself, but my opinion was that, that you
19 were on MSNBC, and you were stating that Paul
20 had said things that he hadn't said or -- and
21 I had understood that you went on TV and said
22 that he had read FBI files, which to every --
197
1 to the best of my knowledge, is totally
2 untrue. So that's how I understood this
3 situation, and so I did think, personally, I
4 thought it was important for, you know, for
5 Paul to see what Rajiv had to say.
6 Q What was your basis to believe that
7 it was untrue that Paul had read FBI files
8 Did you ask Paul?
9 A Everything, everything I knew about
10 Paul, everything I understand about Paul, and
11 everything I've ever seen. Every -- my
12 whole, put it like this, I don't have one
13 iota of anything to believe that Paul would
14 be reading the files.
15 Q Did you ever ask him whether he
16 reviewed FBI files?
17 A No, I have not.
18 Q Never was curious? Short of asking
19 him, have you been curious?
20 A I've never been curious about that.
21 Q And why would it be wrong to review
22 FBI files?
198
1 A Because they're confidential. I
2 mean, I can go on. I can tell you what else
3 I think is wrong.
4 Q Sure, go on. Tell me.
5 A Well, let's keep it at this. It's
6 raw data, and it's just -- you know, many
7 things that wouldn't be admissible in court.
8 It's just -- it's raw personal data about
9 people, and if you don't have a -- if you
10 don't have a authorized, legitimate reason to
11 look at them, then not only are you not
12 allowed to, but it's -- immoral to do it.
13 Q Looking at FBI files is a very
14 serious matter, correct?
15 A Both legally and ethically, yes.
16 Q It's not a funny thing to look at
17 FBI files; is it?
18 A No, I don't think anyone thinks
19 it's a funny thing.
20 Q It's not something that you would
21 make a joke about; would you?
22 A Obviously, Paul was making a joke.
199
1 Q No, I'm asking you. It's not
2 something you'd make a joke about?
3 A Obviously Paul was not --
4 Q Would you make a joke about that?
5 Would you make a joke about that?
6 MS. SHAPIRO: Objection.
7 Hypothetical.
8 BY MR. KLAYMAN:
9 Q Would you make a joke about FBI
10 files, looking at them?
11 A I have repeated Paul's joke,
12 only -- I've repeated Paul's joke.
13 Q When have you repeated Paul's joke?
14 A When I was explaining to my parents
15 the situation.
16 Q How did you know Paul even made a
17 joke?
18 A I didn't know about the joke until
19 Paul was subpoenaed. I didn't watch all the
20 C-Span tape.
21 Q How did you find out about the
22 joke?
200
1 A When he was subpoenaed.
2 Q Well, what happened when he was
3 subpoenaed that caused you to learn about the
4 joke?
5 A I don't remember, sir.
6 Q I think you do remember. Would you
7 please tell me?
8 MS. SHAPIRO: Objection.
9 Argumentative.
10 THE WITNESS: I mean, I've heard
11 Paul say several times that he made a joke.
12 I've read it in his -- I don't remember the
13 first time I heard it. But it became very
14 clear as soon as all this came up that that
15 was, that was the reason that you had
16 subpoenaed him.
17 BY MR. KLAYMAN:
18 Q And how did you reach that
19 conclusion?
20 A I didn't personally reach the
21 conclusion. I was -- it was something that I
22 heard.