201
1 Q Where did you hear it?
2 A I said that Paul had said that he
3 had made a joke.
4 Q Did he say he just made a joke, or
5 he made a joke about FBI files. He makes
6 jokes about a lot of things; doesn't he? How
7 did you know it was about FBI files?
8 A I can't answer. I can't answer
9 your question accurately, because I remember
10 the first thing that Paul said about it. I
11 don't remember the chronology of it all. I
12 just know that he said that he had made a
13 joke, and soon, I either read the transcripts
14 of it, or I saw the video. I don't remember
15 what came first.
16 Q You watched the video in Paul's
17 presence; didn't you?
18 A Not necessarily.
19 Q You may have?
20 A I don't remember if Paul was there
21 or not.
22 Q Who else was there?
202
1 A I don't know, sir.
2 Q What was your grade point average
3 in college?
4 MS. SHAPIRO: Objection.
5 Relevancy.
6 BY MR. KLAYMAN:
7 Q You can respond?
8 A Which semester?
9 Q You graduated, right?
10 A I finished school.
11 Q Okay. And where was it you went to
12 college?
13 A George Washington University.
14 Q Right. And what was your grade
15 point average?
16 A It ended with 3.77.
17 Q Out of 4.0?
18 A Uh-huh.
19 Q And is that summa cum laude?
20 A It's the middle, so --
21 Q Magna cum laude?
22 A (Nodding)
203
1 Q Correct?
2 A Correct.
3 Q Graduated with honors, correct?
4 A Correct.
5 Q People have told you frequently
6 that you're a very intelligent woman; have
7 they not?
8 A On occasion.
9 Q And in fact, you have a very good
10 memory, don't you?
11 MS. SHAPIRO: I object to this
12 whole line of questioning. It's nothing more
13 than harassing the witness.
14 BY MR. KLAYMAN:
15 Q You can respond. You can respond.
16 A I don't really don't get too many
17 people telling me I have a good memory.
18 MR. KLAYMAN: Certify it. Do you
19 have a problem, Ms. Paxton?
20 MS. PAXTON: I do.
21 MR. KLAYMAN: I appreciate, since
22 you're not counsel of record, not to make
204
1 noises on the record, please. You laugh; you
2 carry on.
3 MS. PAXTON: But if you ask me a
4 question, I will respond.
5 MR. KLAYMAN: Do you want to go
6 under oath?
7 MS. PAXTON: I'm not under oath
8 here today. You asked me a question. I did
9 the courtesy of responding.
10 MR. KLAYMAN: I asked you not to
11 make noises throughout the deposition.
12 Throughout this, you've laughed, and you've
13 carried out. I think it's inappropriate.
14 MS. PAXTON: That is a completely
15 inaccurate description. Why don't we
16 continue with this deposition.
17 THE WITNESS: I'm sorry, your
18 question?
19 BY MR. KLAYMAN:
20 Q For the last 3 months, have you
21 been on any medication?
22 A No, I have not.
205
1 Q Have you ever been treated for
2 problems with memory?
3 A Not to the best of my memory.
4 MS. SHAPIRO: Objection. This is
5 an improper line of questioning.
6 MR. KLAYMAN: No, it's not improper
7 at all. It's exactly relevant.
8 BY MR. KLAYMAN:
9 Q Now did you have any conversation
10 with anybody else about Paul making a joke,
11 other than Paul himself?
12 A Every time I told someone about my
13 subpoena, all those people I mentioned
14 before, when I would tell them about it, the
15 way I'd say, I'd say Paul made a joke, and
16 therefore, he's been subpoenaed.
17 Q Are you aware that Paul, through
18 his counsel, made an argument to the court
19 that he should not be deposed because he made
20 a joke? Are you aware of that?
21 A I wasn't aware that he made -- that
22 he -- could you repeat that?
206
1 Q Are you aware that that argument
2 was placed before the court in this case, and
3 the court ordered that he be deposed?
4 A I'm not aware of what he -- of his
5 legal actions.
6 Q Are you being critical of the court
7 in having him deposed? Are you critical of
8 the court?
9 MS. SHAPIRO: Objection. You're
10 completely mischaracterizing, and it's
11 irrelevant.
12 BY MR. KLAYMAN:
13 Q You can respond.
14 A It is not my intention to be
15 critical of the court.
16 Q But in your heart, do you think the
17 court made the wrong decision?
18 A I'm not a lawyer. I don't think
19 I'm in a position to make, to make a stab at
20 that.
21 Q Have you ever seen the joke that
22 Paul told in writing?
207
1 A I don't believe so, no.
2 Q But you have seen it on a video?
3 A I remember watching the video. I
4 don't know if we saw that excerpt. I
5 remember seeing it, playing it again on
6 C-Span. I watched it on C-Span. I believe
7 I've seen some of the video. But I've heard
8 Paul recount it, so I don't have a clear
9 memory as to whether I've actually seen him
10 on video give the joke, but I've heard Paul
11 recount it.
12 Q Did you ever write a speech for
13 Paul?
14 A I've never written a speech for
15 Paul.
16 Q Have you ever helped him with a
17 speech?
18 A No.
19 Q Have you ever written a joke for
20 him?
21 A No, I have not.
22 Q Do you know anyone who else?
208
1 A No, not for him.
2 Q Does Paul keep a book of jokes or a
3 file where he keeps jokes?
4 A Not that I'm aware of.
5 Q Have you ever seen a joke that he's
6 told written down anywhere?
7 A Uh-uh.
8 Q Have you ever met James Carville?
9 A Yes.
10 Q When did you meet James Carville?
11 A 1993.
12 Q And what were the circumstances of
13 your meeting him?
14 A He was visiting George.
15 Q And did you understand him to be a
16 pretty close professionally with George
17 Stephanopoulos?
18 A I did understand that, yes.
19 Q And in the last 3 months, have you
20 seen Mr. Carville?
21 A No.
22 Q Have you talked with him?
209
1 A Yes.
2 Q About how many times have you
3 talked with him?
4 A At least daily.
5 Q How many times daily?
6 A It ranges.
7 Q Roughly speaking.
8 A One to three times a day maybe.
9 Maybe a little bit more.
10 Q Have you talked to Mr. Carville
11 over this whole issue of the Judicial Watch
12 case?
13 A No.
14 Q Have you been in the office when
15 Paul has been talking to him, and you
16 understood they were talking about Judicial
17 Watch's case, or FBI files, or Filegate?
18 MS. SHAPIRO: Objection. Vague and
19 ambiguous. If you can answer it.
20 THE WITNESS: You need to ask me
21 individually.
22 BY MR. KLAYMAN:
210
1 Q No, I'm asking you the way I going
2 to ask it?
3 A I can't answer it. I mean, come
4 on. There are three different things.
5 Q Well, no, Judicial Watch case
6 involves Filegate, Filegate's Filegate and
7 FBI files are part of Filegate, so I'll just
8 trying to give an example that will give you
9 a feel for what I'm asking.
10 A I've never heard Paul talk about
11 any of the problems with the FBI files. I
12 have heard Paul ask James how his deposition
13 went, and I think -- I've overheard Paul talk
14 to James a little bit about how Paul's
15 deposition went, but that's -- because I must
16 remind you, I do tune him out, and I try to
17 make it a point not to be listening to every
18 word he says. So I mean, that's all I
19 remember.
20 Q Did you discuss this deposition
21 over lunch hour?
22 A Excuse me.
211
1 Q Did you discuss this deposition
2 that you're here on today over lunch hour?
3 A Yes.
4 Q Did you use those words, I tune him
5 out, and I don't listen to every word he
6 says?
7 A No.
8 Q Did anyone else use those words?
9 MS. SHAPIRO: Objection. You have
10 to establish who she was talking to.
11 BY MR. KLAYMAN:
12 Q Anyone.
13 A Could you please ask me that
14 question again? Are you referring to -- I'm
15 sorry.
16 Q Did you hear anyone --
17 MS. SHAPIRO: I will tell you that
18 the only people who had lunch with the
19 witness were two counsel here, so that any
20 conversations that occurred at lunch would be
21 privileged.
22 MR. KLAYMAN: I don't appreciate
212
1 your putting words in the witness's mouth.
2 Certify it.
3 MS. SHAPIRO: I'm not. I'm
4 asserting an objection, and you talked over
5 me again. I just want to make sure my
6 objection is --
7 BY MR. KLAYMAN:
8 Q Did you call the White House during
9 lunch?
10 A No, I did not.
11 Q Did you talk to anybody by phone?
12 A No, I did not.
13 Q Have you talked to anybody since
14 your deposition has begun today by phone?
15 A No, I have not.
16 Q What did you hear Begala say to
17 Carville when Carville called in to find out
18 how Begala's deposition went?
19 A I remember Paul expressing anger
20 and frustration.
21 Q How did he express it?
22 A I remember him saying that he was
213
1 angry, and he was frustrated. That's all I
2 remember.
3 Q Why did he say he was angry?
4 MS. SHAPIRO: Objection.
5 THE WITNESS: He was angry about
6 your -- he was angry about your line of
7 questioning.
8 BY MR. KLAYMAN:
9 Q What was it about my line of
10 questioning that he said angered him?
11 A Okay. Now I remember him saying
12 that he felt that certain questions that you
13 asked him were irrelevant, or that they were
14 private. See, the problem is, I don't
15 know -- I remember Paul saying that, but I
16 don't remember if he specifically said that
17 to James, so that's the problem I have.
18 I have memories of him saying
19 things, but I don't know exactly who he said
20 it to, but I do know that he was frustrated.
21 Q Tell me what he said. I don't care
22 who he said it to. What did you ever
214
1 overhear?
2 A He was frustrated that you asked
3 him about Justice Breyer. He was frustrated
4 that you asked him about his priest. He was
5 frustrated that you, you know, what wanted to
6 know about his wife's name. That's what I
7 remember.
8 Q That's what he discussed with
9 Carville?
10 MS. SHAPIRO: Objection. That
11 wasn't your question.
12 BY MR. KLAYMAN:
13 Q That's all he discussed with
14 whomever he was talking to?
15 A That's all I remember.
16 Q Did he tell you he was deposed for
17 6 hours, at least he claims 6 hours. We
18 claim less?
19 A He didn't tell me exactly how long,
20 but I was working, and I know how long he was
21 gone.
22 Q Surely you must have asked him what
215
1 went on during the deposition when he came
2 back?
3 A No, surely I did not, because Paul
4 has made it a point of trying not to talk
5 about this, and, you know, no, I did not ask
6 him what happened in the deposition.
7 Q Have you seen Carville in the
8 office in the last 3 months?
9 A No.
10 Q Have you seen him outside of the
11 office?
12 A No.
13 Q Have you talked to Carville
14 yourself at any time in the last 3 months?
15 A Only to field phone calls and
16 exchange pleasantries.
17 Q Did you discuss this case with
18 Carville?
19 A No.
20 Q Not even just to say gee, isn't
21 this terrible that you and Paul are wrapped
22 up in this?
216
1 A No.
2 MS. SHAPIRO: Could we take a quick
3 break, please?
4 MR. KLAYMAN: Sure.
5 THE VIDEO SPECIALIST: Going on off
6 video record at 2:08.
7 (Recess)
8 THE VIDEO SPECIALIST: We're back
9 on video record at 2:14.
10 BY MR. KLAYMAN:
11 Q Have you ever met Mary Madeleine.
12 A No.
13 Q Have you ever talked to her?
14 A I think she's called George's
15 office -- she called George's office on
16 occasion. I only remember talking to her
17 once. It may have been more times, but --
18 Q Anything within the last 3 months?
19 A No.
20 Q Have you talked to Mr. Michael
21 McCurry about Paul Begala's joke?
22 A No.
217
1 Q Have you talked to Mike McCurry
2 about anything related to Judicial Watch or
3 this lawsuit?
4 A No, I have not.
5 Q Same question with regard to Rahm
6 Emanuel?
7 A No.
8 Q Same question with regard to Ann
9 Lewis?
10 A No.
11 Q Same question with regard to Sydney
12 Blumenthal?
13 A I don't remember exactly what he
14 said. He extended some kind of sympathy, and
15 I, I said something that was appreciative of
16 the sympathy, but it was -- that's all I
17 remember.
18 Q Was this recently?
19 A It's within the last week, yes.
20 Q And how did you come in contact
21 with Mr. Blumenthal?
22 A He calls the office.
218
1 Q He called in to ask to talk to you?
2 A Uh-uh, he was calling for Paul.
3 Q And what did he discuss with Paul?
4 A I don't know.
5 Q Were you sitting there at the time?
6 A I mean, you'd have -- first of all,
7 you have to be specific to which time he
8 called in, and -- I mean, do you have a
9 specific conversation --
10 Q I don't know. Only you know. Did
11 he call in more than once in the last week?
12 A Yes.
13 Q How many times has he called in the
14 last week?
15 A He usually calls about once a day.
16 Q Pretty long calls with Mr. Begala?
17 A I don't systematically keep track
18 of how long Paul sits on the phone.
19 Q Seems kind of long winded, isn't
20 he, in your experience?
21 A No, he is not.
22 Q Talking more than 10 minutes or so
219
1 with Paul each time?
2 A Not necessarily.
3 Q But sometimes?
4 A It's in the realm of the possible.
5 Q And within the last week, they
6 called to discuss this case; didn't they?
7 A I can't verify that. Sid didn't
8 say what he's calling about when he called.
9 Q But you heard Mr. Begala talking
10 about the case in the last week, didn't you,
11 on the phone?
12 A I said I have, but I don't remember
13 exactly what he said to each person. I don't
14 remember him exactly saying anything to Sid.
15 Q How did it come up that you offered
16 his condolences or sympathy, what did he say?
17 A I don't remember exactly what he
18 said because people have been saying about
19 the same -- the same kinds of things to me,
20 so I don't remember who says what.
21 Q Have you ever given a deposition
22 before?
220
1 A No, I have not.
2 Q Have you ever been a witness to a
3 traffic accident or anything to that effect?
4 A No, I have not.
5 Q Why did Mr. Blumenthal say that you
6 had his sympathies just to give a deposition?
7 A I can't speak to his motivation.
8 Q That's what he said?
9 A I don't think he said I sympathize
10 with you, but that was the theme of the call.
11 Q Why would doing your civic duty in
12 testifying in a lawsuit require sympathies in
13 your opinion?
14 MS. SHAPIRO: Objection. This is
15 totally irrelevant.
16 Q You can respond.
17 A I guess I never thought of it like
18 that.
19 Q Did you ask Mr. Blumenthal what he
20 he's talking about?
21 A No, I did not.
22 Q In fact, you got the impression
221
1 that what Sydney Blumenthal was trying to say
2 but that Judicial Watch and Larry Klayman
3 were bad people, correct?
4 A Oh, I definitely can't say that.
5 Q He said we were great people?
6 A I can't say that, either.
7 Q Did you get the impression that
8 what was being said was this whole thing is
9 nonsense?
10 A No.
11 Q Didn't you find the remark then a
12 little peculiar?
13 A I think there are other options
14 that you haven't explored.
15 Q What are the other options? What I
16 am trying to do is to figure out all the
17 options you know on every question?
18 A So could you please ask me again.
19 Q What are the other options?
20 A I think it's reasonable for someone
21 to have empathy or sympathy for a 23-year-old
22 aid when they are called to testify, or
222
1 called to give a deposition in a case that
2 they perhaps only have tangential involvement
3 in.
4 Q So the reason that you're deserving
5 sympathies is because you're actually quite
6 young?
7 A I was just giving you an option of
8 why. I can't speak to his motivation.
9 Q I'm talking about the way you took
10 it. Did you take it that somehow that
11 because your are only 23, that Judicial Watch
12 is persecuting you. Is that what you thought
13 Blumenthal was trying to tell you?
14 MS. SHAPIRO: Objection. I have no
15 idea why this matters and why this is
16 relevant.
17 Q You can respond.
18 A Now you have argued to the
19 contrary,but you know, up until now, I had
20 understood that Paul had made a joke and,
21 that perhaps, you know, he should not have
22 had to gone through this on the basis of a
223
1 joke.
2 Q But now you understand otherwise?
3 A I'm aware of your position.
4 Q You're aware that there may be
5 other issues involved as well?
6 A I'm aware of that.
7 Q Do you know who Charles Rough is?
8 A Yes, I do.
9 Q Have you ever met Charles Rough?
10 A No, I have not.
11 Q Have you ever talked with anyone
12 from his office about this case other than
13 Ms. Paxton?
14 MS. SHAPIRO: You can answer that,
15 but not the substance of conversations.
16 THE WITNESS: Okay. Yes, I have.
17 Q Who did you talk to?
18 A Lanny Brewer.
19 Q When did you talk to Lanny Brewer?
20 A Within the last week.
21 Q Was anyone else present when you
22 talked to him?
224
1 A No.
2 Q Was it in person?
3 A Yes, it was.
4 Q Was it in your office or his or
5 somewhere else?
6 A It was in his office.
7 Q He called you and said he wanted to
8 talk to you?
9 A No, he did not.
10 Q You called him?
11 A He called and said that if I had
12 any questions or concerns that I could --
13 MS. SHAPIRO: Okay. She can't
14 speak to the substance of the conversations
15 between her and counsel's office so I'm going
16 to instruct her not to say anymore. Not to
17 answer those questions.
18 MR. KLAYMAN: I'm not too sure
19 those are attorney-client privilege when the
20 lawyer contacts the individual and actually
21 soliciting legal advice. She's not
22 soliciting advice. This guy apparently
225
1 called her on his own.
2 MS. SHAPIRO: I'm asserting that
3 privilege. I'm not going to argue it with
4 you the law.
5 MR. KLAYMAN: Certify it.
6 BY MR. KLAYMAN:
7 Q How long did you meet with
8 Mr. Brewer.
9 A For 20 minutes.
10 Q Did you review documents with
11 Mr. Brewer?
12 MS. SHAPIRO: I'm instructing her
13 not to answer any questions about what she
14 did with Mr. Brewer and what she said.
15 MR. KLAYMAN: Generically whether
16 she reviewed documents?
17 MS. SHAPIRO: Yes.
18 MR. KLAYMAN: Certify it.
19 BY MR. KLAYMAN:
20 Q When you met with Ms. Paxton, did
21 you review documents?
22 MS. SHAPIRO: Same instruction.
226
1 You asked her that previously and I gave her
2 the same instruction.
3 Q Did someone direct you to go see
4 Mr. Brewer?
5 A No.
6 Q During that conversation, did you
7 discuss Paul Begala?
8 MS. SHAPIRO: Objection. Same
9 instruction.
10 MR. KLAYMAN: I'm allowed to
11 identify general subject matter. That is
12 normal on any proffer of privilege.
13 MS. SHAPIRO: You've already
14 identified that they talked about the
15 deposition and that's enough to put it under
16 privilege.
17 MR. KLAYMAN: No, I want to know if
18 they talked about Mr. Begala.
19 MS. SHAPIRO: I'm instructing her
20 not to answer so there's no point.
21 MR. KLAYMAN: Certify it.
22 MS. SHAPIRO: It's an
227
1 attorney-client privilege.
2 Q Did you discuss issues of how you
3 searched for records in response to
4 Mr. Begala's notice of deposition?
5 MS. SHAPIRO: Same objection.
6 MR. KLAYMAN: Certify it.
7 BY MR. KLAYMAN:
8 Q Did you discuss with Mr. Brewer how
9 records are kept in your and Paul's office?
10 MS. SHAPIRO: Same objection.
11 BY MR. KLAYMAN:
12 Q I'll ask the same questions with
13 regard to Ms. Paxton?
14 MS. SHAPIRO: Same objection.
15 MR. KLAYMAN: Certify it.
16 BY MR. KLAYMAN:
17 Q Have you ever discussed Joseph
18 diGenova or Victoria Tonsig with anybody?
19 A No.
20 Q Have you heard of those names?
21 A I mean, I have heard of them, yes.
22 Q How did you hear of them?
228
1 A I believe they were in the document
2 request that we received from counsel's
3 office. And then again, in my -- I believe
4 they were also in my -- when you subpoenaed
5 me.
6 Q Have you ever heard of them outside
7 of that?
8 A No.
9 Q Are you aware of any statements by
10 Mr. diGenova made publicly that he and his
11 wife were being investigated by White House
12 investigators?
13 A Oh, wait. I think I have seen him
14 on TV.
15 Q You heard him make that statement?
16 A I don't know if I saw it firsthand.
17 I think I've heard -- it may have been a
18 journalist recounting that but I am vaguely
19 aware of it, they have a complaint.
20 Q You've heard that discussed around
21 the White House?
22 A No, I have not.
229
1 Q During your time at the White
2 House, have you heard anyone identify
3 individuals or groups that they consider to
4 be adverse to the Clinton Administration?
5 A How would you define adverse.
6 Q Doesn't like, take a position
7 against, file a lawsuit against, anything
8 like that?
9 A Any group or individual you're
10 asking me?
11 Q Yes.
12 A Against the Administration?
13 I mean, I've -- yes, I've heard
14 people talk about Ken Starr.
15 Q Other than Ken Starr.
16 A Off the top of my head, I can't
17 think of other groups that have suits against
18 the government other than yours.
19 I mean, if I sat and thought about
20 this for a long time, maybe I can think of
21 something but there's nothing that jumps out.
22 Q Have you ever heard of a Melissa
230
1 Prober?
2 A Yes.
3 Q Who is Melissa Prober?
4 A She's now an assistant in the
5 counsel's office. I don't know exactly her
6 job title. But she was an intern in our
7 office. She -- before I could come in and
8 start my job, there was a -- there was a
9 lag -- there was a lag between when Paul
10 started and when I came in, so she came in to
11 help out Paul, until I was there.
12 Q Have you maintained contact with
13 her?
14 A Occasional.
15 Q Have you talked to her about this
16 case?
17 A No, I have not.
18 Q Has she been in the office
19 recently?
20 A No, she has not.
21 Q Have you ever read the "Drudge
22 Report"?
231
1 A Yes, I have.
2 Q When do you read the "Drudge
3 Report"?
4 A I read it every day.
5 Q Why do you read it every day.
6 A Got to know what's going on.
7 Q You like the "Drudge Report"?
8 A I find that because from the
9 "Drudge Report," you can go to other articles
10 or other papers. I find that convenient. I
11 would say I like the "Drudge Report."
12 Q Has there been a White House
13 directive to not read the "Drudge Report"?
14 A I am not aware of it.
15 Q You've been directed to review the
16 "Drudge Report," haven't you?
17 A No, I have not.
18 Q Mr. Begala asked you to review it?
19 A Never.
20 Q He reviews it, doesn't he?
21 A He may have.
22 Q He has discussed it with you from
232
1 time to time, hasn't he?
2 A I don't have any recollection of
3 him discussing the "Drudge Report" with me.
4 Q In fact, it's part of your daily
5 routine to review the "Drudge Report," isn't
6 it?
7 MS. SHAPIRO: Objection.
8 Q You can respond.
9 A It may be, but that's because I do
10 it. Not because someone told me to do it.
11 Q You don't generally use government
12 time to do things that aren't related to your
13 work, do you?
14 A Keeping up with the news is part of
15 my work.
16 Q Why is keeping up with the news is
17 part of your work?
18 A Because I need to know what's going
19 on.
20 Q Why do you need to know what's
21 going on?
22 A In order to help my boss to the
233
1 best of my ability.
2 Q What does your boss do,
3 specifically, as you know it?
4 A He advises the President.
5 Q And it's important for him to know
6 about allegations about the Administration to
7 advise the President?
8 A I would imagine.
9 Q It's important for him to know
10 information about adversaries of the
11 Administration to advise the President,
12 correct?
13 A May I ask how you define
14 adversaries?
15 Q We just defined it. Anybody who
16 says negative things or brings lawsuits or
17 whatever?
18 A I would imagine it would be
19 helpful, yes.
20 Q That's why you had the Internet
21 site, right, so you can look things up like
22 that?
234
1 A No.
2 Q Did you get the Internet site just
3 for entertainment?
4 A Are you talking about -- which
5 Internet site are you referring to.
6 Q On your computer?
7 A Are you asking why we have
8 Netscape?
9 Q Yes, is it for your entertainment?
10 A No, it is not, but there are --
11 Q But you do look up adversaries from
12 time to time, don't you?
13 A I've never been assigned to look up
14 an adversary.
15 Q You are aware that others have been
16 assigned t that, aren't you?
17 A No, I am not.
18 Q You are aware that Mr. Begala has
19 asked others to look up adversaries, are you
20 not?
21 A I'm not aware of that.
22 Q You're aware he himself has,
235
1 correct?
2 A I'm not aware of that.
3 Q You're not aware of anyone in the
4 White House ever doing any research on any
5 adversaries of the Clinton Administration?
6 A I'm not personally aware of that.
7 Q Have you seen recent reports about
8 Kathleen Willey, whatever her name is?
9 A Yes, I have.
10 Q Have you seen that they have
11 released letters about Kathleen Willey,
12 yesterday at the White House?
13 A I'm aware of that.
14 Q They made it known that she was
15 looking for a book deal, "they" meaning the
16 White House?
17 A I'm not aware how much the White
18 House has been involved in pushing the book
19 deal story.
20 Q But that would require research,
21 wouldn't it, to find out whether she was
22 looking for book deals and that may be a
236
1 motivation for speaking out against the
2 President. That's research, isn't it?
3 A I guess reading Army Archer is
4 research.
5 Q Who is Army Archer?
6 A I believe Army Archer writes in
7 daily variety.
8 Q And who did that? Who would do
9 that kind of work, based on your experience
10 in working with Paul and George
11 Stephanopoulos. Who in the White House does
12 that kind of research?
13 A What, reading the paper?
14 Q Whatever?
15 A Most people in the White House read
16 the paper.
17 Q You are aware that the White House
18 has retained Terry Lenzner, a private
19 investigator through Williams & Conolly about
20 Bob Bennett, are you not?
21 MS. SHAPIRO: Objection.
22 Q You're aware of that, aren't you?
237
1 A It's a loaded question.
2 Q It's not a loaded question. Do you
3 know it or not?
4 A No I'm not aware of that.
5 Q You haven't heard that?
6 A I've heard that Williams & Connolly
7 has retained -- but there is a difference
8 between what the White House does and what
9 Williams & Connolly does.
10 Q How about the Clintons, is there a
11 difference between what Williams & Connolly
12 does with regard to the scandals and what the
13 Clintons do, based on your knowledge?
14 A Well, there is a difference
15 between -- I mean, there is -- I do
16 understand that the White House counsel's
17 office deals with certain things and that
18 Williams & Connolly deals with certain things
19 and I don't know exactly where the firewall
20 lies but I do -- so -- but as President, but
21 the President has to deal with things that
22 are both personal and professional, so -- I
238
1 appreciate if you'd ask me that question
2 again.
3 Q I'll ask you a different question?
4 A Okay.
5 Q How did you find out there is a
6 firewall?
7 A Well, I don't know that as a
8 certain fact, that is something I've called
9 from things from things I've read, and it's
10 an understanding that I have developed.
11 Q Have you ever seen any
12 correspondence from IGI or Terry Lenzner in
13 the office?
14 A No.
15 Q Have you been with Terry Lenzner's
16 daughter recently?
17 MS. SHAPIRO: Asked and answered.
18 THE WITNESS: I have not seen
19 Ms. Lenzner in a few years.
20 Q But you did talk to her, as you
21 testified to?
22 A I'm sorry.
239
1 Q You did talk to her?
2 A No, I haven't talked to her.
3 Q Do you know of anybody at the White
4 House who's testified before Grand Jury or in
5 a civil case or in any other matter that has
6 been scared to testify?
7 MS. SHAPIRO: Objection.
8 Relevancy.
9 BY MR. KLAYMAN:
10 Q You can respond.
11 A No one has ever expressed to me
12 that they were scared to testify for
13 anything.
14 Q Did you sense that they were?
15 A I've never sensed from anybody that
16 they were scared to testify about anything.
17 Q Are you concerned that if you say
18 something that's damaging to the Clintons
19 that you might be retaliated against?
20 A No.
21 Q Are you concerned that you could
22 lose your job?
240
1 A No.
2 Q But you don't want to see this
3 administration fall, do you?
4 A Not particularly.
5 Q Because in fact if it fell, you'd
6 lose your job, right?
7 A There are many, many other reasons
8 why this administration should not fall and
9 the top one would never be my job.
10 Q But it's one of the considerations,
11 correct?
12 A One of thousands.
13 Q Have you ever been assured that you
14 would not lose your job by testifying here
15 today?
16 A It was never a question in my mind.
17 Q Has anyone ever mentioned that to
18 you?
19 A No.
20 Q And what are the many, many reasons
21 why this administration should not fall?
22 MS. SHAPIRO: Is this designed to
241
1 elicit some kind of admissible testimony.
2 MR. KLAYMAN: It's designed to
3 elicit testimony.
4 MS. SHAPIRO: Right, but
5 irrelevant, at this point.
6 MR. KLAYMAN: But at this time, I
7 would be.
8 THE WITNESS: I believe in the
9 President and I believe in the Administration
10 and I think that both the Administration and
11 the President has gotten our country back on
12 the right track and -- and I'm definitely not
13 interested in any of the alternatives.
14 BY MR. KLAYMAN:
15 Q Does it concern you that there have
16 been allegations that this administration has
17 not told the truth to the public and in legal
18 proceedings?
19 A Well, allegations concern me, sure.
20 Q Do these allegations concern you?
21 A Which allegations?
22 Q The ones that have been made that
242
1 this administration has not been truthful to
2 the public and in court proceedings.
3 MS. SHAPIRO: Asked and answer.
4 Q You can respond?
5 A I mean, that allegation is
6 concerning, sure.
7 Q To you?
8 A I mean, one would need to
9 contextualize a little bit more if you want
10 to --
11 Q I'm just asking you, does that
12 concern you?
13 MS. SHAPIRO: And that was asked
14 and answered.
15 Q No, it wasn't. Could you please
16 respond?
17 A It was worthy of concern, sure.
18 Q To you?
19 A Yes, I'm concerned.
20 Q Why?
21 A I mean, it's important -- it's
22 important to be truthful. And I would -- you
243
1 know -- I'll leave it at that.
2 Q Why is it important to be truthful?
3 A It's just, it's just important to
4 be truthful.
5 Q Have you ever heard Mr. Begala say
6 that Ken Starr is corrupt?
7 A Yes, I have.
8 Q When did you hear him say that?
9 A I don't know if I ever watched to
10 Meet the Press, but I heard him repeating
11 what he said that Ken Starr was corrupt and
12 the lord acting sense, or that power corrupts
13 absolutely or something like that, but
14 anyways.
15 Q How long before this deposition
16 today did you read Paul Begala's deposition,
17 his transcript?
18 A I read it the day that he received
19 it.
20 Q You read the whole thing?
21 A I went through the whole thing.
22 Sometimes I glanced other things.
244
1 Q He asked you to review it, didn't
2 he?
3 A No, he did not.
4 Q How did you know that he had
5 received the transcript?
6 A I believe he said that the
7 transcript was coming in and the court
8 reporter had called in to check on a spelling
9 of a name.
10 Q He told you it was important for
11 you to review it, didn't he?
12 A No, he did not.
13 Q Did he use words that you have to
14 review it, so we can keep our stories
15 straight?
16 A He would never suggest a thing.
17 MS. SHAPIRO: Objection.
18 Q But it was your understanding that
19 was the reason to review it, wasn't it?
20 A No, it was not.
21 MS. SHAPIRO: Objection. Asked and
22 answered.
245
1 THE WITNESS: Sorry.
2 Q Have you ever heard Paul Begala say
3 that George Stephanopoulos is a reporter?
4 A I don't know if he ever used that
5 exact word.
6 Q Your answer is no?
7 A I don't know if he ever used that
8 exact word.
9 Q Your answer is no?
10 MS. SHAPIRO: Objection. She just
11 gave you her answer.
12 THE WITNESS: I stand by my answer.
13 BY MR. KLAYMAN:
14 Q Have you heard anyone ever say that
15 George is a reporter?
16 A I've never heard that exact word
17 used.
18 Q Have you ever met Stephanopoulos?
19 A Yes, I have.
20 Q Have you talked with him in the
21 last three months?
22 A Yes.
246
1 Q When did you talk to him?
2 A Probably towards the -- about three
3 months ago.
4 Q What did you talk to him about?
5 A He said he was happy to have me
6 back.
7 Q Did you say anything of substance
8 to him?
9 A No.
10 Q How did that come up?
11 A I had walked into his -- into his
12 outer office to deliver something.
13 Q Have you ever heard Begala say
14 anything negative about George
15 Stephanopoulos?
16 A No, I have not.
17 Q Have you ever heard anybody else
18 say anything negative about George
19 Stephanopoulos?
20 A Yes, I have.
21 Q Who?
22 A First of all, I need a time frame.
247
1 I mean, ask -- when do you want me to --
2 Q Ever.
3 A Over my times as an intern, I don't
4 remember anyone saying to me personally
5 anything bad about George. I remember
6 someone telling me -- calling him a common
7 trader up instead of commentator to me over
8 the last couple of months, but I don't
9 remember who said that.
10 But everyone else would say that
11 most people that worked for him and that if
12 they were going not to like that, they
13 probably wouldn't say it to me.
14 Q But somebody said that he was a
15 common trader to you?
16 A They made that remark.
17 Q And that caught you by surprise,
18 didn't it?
19 A I definitely didn't like it.
20 Q It was pretty shocking, wasn't it?
21 A I've been shocked by more, I guess.
22 Q But it was shocking, wasn't it?
248
1 A I didn't like it.
2 Q It was shocking, wasn't it?
3 MS. SHAPIRO: Objection. Asked and
4 answered.
5 MR. KLAYMAN: It was shocking,
6 wasn't it?
7 A I didn't like it. No, it did not
8 shock me.
9 Q Okay. It was something that stuck
10 in your mind, correct?
11 A Yes.
12 Q And something you didn't expect to
13 hear, correct?
14 A I guess I never expected anyone to
15 contort the word commentator but I can't say
16 I was ever surprised that someone would
17 say -- would allude to him not being loyal.
18 Q You heard that more than once?
19 A Heard what more than once?
20 Q People calling George common
21 traitor?
22 A I only remember it once.
249
1 Q Who said it?
2 A I don't remember it.
3 Q It was a very shocking, it was a
4 very strong statement, surely, you must have
5 remembered?
6 A No, I don't.
7 Q So I guess basically it really was
8 just kind of an insignificant remark.
9 Nothing worth remembering?
10 A I remembered the remark, obviously
11 it wasn't significant to me who said it.
12 Q Do you know what office it was said
13 in?
14 A I have a vague memory of being on
15 the phone and someone, someone telling me on
16 the phone.
17 Q Sid Blumenthal?
18 A I mean, I can't verify it, but I
19 seriously doubt that it was Sid Blumenthal.
20 Q Why?
21 A It doesn't ring -- I don't remember
22 that.
250
1 Q Was it Carville?
2 A I can't verify that, but I
3 seriously doubt that it was James Carville.
4 Q Was it Mike McCurry?
5 A It was not Mike McCurry.
6 Q Was it the President? The
7 President calls sometimes, doesn't he?
8 A No, he does not.
9 Q First Lady?
10 A It was not.
11 Q Vernon Jordan?
12 A It was not.
13 Q Ann Lewis?
14 A It was not.
15 Q Roman Manual?
16 A It was not.
17 Q Do you know generically what kind
18 of person called you, a member of the
19 janitorial staff or somebody in the legal
20 counsel's office?
21 A No.
22 Q Erskine Bowles.